Object

Plan for submission evidence base

Representation ID: 10228

Received: 29/07/2022

Respondent: Mr Ben Pile

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3.0 A Proposed Allocation at Church End Biddenham
Potential for development within the Urban Area
3.1 Biddenham comprises part of the Urban Area of Bedford Town, and it is approximately 2.5km from Bedford Town Centre.
3.2 Given that Biddenham is within the Urban Area of Bedford Town, it is not assessed within the Settlement Hierarchy (2030) and Addendum (2022), however, Bedford comprises the primary settlement in the borough and is therefore the most sustainable settlement. It provides an array of services with unrivalled access to surrounding road networks and public transport services. Development sites on or within its boundaries, therefore, comprises the most logical and sustainable option for the delivery of new growth in the Borough.
3.3 Open land to the west of Biddenham has, however, been allocated as Urban Open Space, despite its clear potential to provide some of the most sustainable residential development in the borough. The imposition of this designation in this location is counterproductive to the principles of housing delivery. Residential schemes should be focused within or adjacent to the most sustainable areas within Local Planning Authority areas and the use of designations to limit development in these locations does not conform with the general approach applied to housing delivery nationally.
3.4 The concept of Urban Open Spaces and Gaps was outlined in Policy AD43 of the Allocations and Designations Plan (2013). This states that “Development will not be permitted on land designated as urban open space and gaps unless it can be demonstrated that the reasons for designation are not compromised or that other material considerations outweigh the need to retain the urban open space and gaps undeveloped”. In the context of the 27,100 units required to be delivered throughout the plan period, as outlined by the Standard Method for assessing housing need, the overall need to deliver significant levels of housing in sustainable locations is considered to outweigh the protection of this land. Freeing up this land for the delivery of housing would avoid the use of substantial areas of open countryside poorly related to existing settlements for the use of residential development when suitable, sustainable and connected sites are available elsewhere. The value of keeping isolated open countryside underdeveloped outweighs the importance of limiting the use of valuable sites on the edge of urban areas. This does not mean to say development in these locations cannot be sensitively developed in the context of urban open space but the option for the delivery of residential development alongside this should not be neutralised.
3.5 Whilst a number of sites are located adjacent to Bedford within the Local Plan 2030, including some on the edge of Biddenham, the emerging Local Plan 2040 fails to acknowledge further sites of this nature and instead focuses on housing delivering in large areas of open countryside through the development of strategic greenfield sites and new settlements. The single exception to this is Draft Policy HOU5, which allocates Abbey Field, West of Elstow. Similarly, to land on the edge of Biddenham, this land had been designated as Urban Open Space, nonetheless, its development for residential development alongside this has not been precluded. This approach should be more actively applied in relation to available sites within the Bedford Urban Area.
3.6 Land to west of the settlement, north of the site that is the subject of this report, is allocated for development under the Local Plan 2030 Policy 18 (Land at Gold Lane, Biddenham). This allocation seeks to deliver 160 dwellings as well as strategic open space alongside additional public transport, pedestrian and cycle connections further contributing to the sustainability of the area, reflecting the approach applied in Draft Policy HOU5. The location of this allocation in the context of the site is provided in figure 2 for clarity. This provides clear acknowledgement that this location is considered capable of supporting further residential development.
[See attached for plan]
Site Details
3.7 The site proposed for allocation is approximately 3.42ha, is located to the rear of development on Church End in the western area of Biddenham. The location of the site is shown in figure 4 overleaf and a Site Identification Plan is provided in Appendix 1.
3.8 The site comprises an agricultural field bounded by established trees and hedgerows on all boundaries aside from the southwestern corner of the site which sits adjacent to a cemetery gifted by the landowner to the church. The existing settlement of Biddenham and associated built form abuts the site on its southern boundary and the Gold Lane development being built by Dandara dominates the land to the north. Two smaller parcels of land to the north and east of our site (blue and green stars above), owned by the same landowner are also available for development and also comprise agricultural land. These two parcels are likely to be presented under separate representations, but we can advise that our landowner and the adjoining landowner of these two parcels are in direct discussions about a joint approach to the delivery of a combined site.
[See attached for plan]
3.9 The wider residential area and associated facilities are located to the east of the site. The site is therefore set amongst existing and upcoming development and can be considered well contained. Biddenham St James Church is located to the southwest of the site and comprises a Grade l listed building. Public rights of way are located on the northern, eastern and western boundaries.
Site Assessment
3.10 Optimis propose that this site is allocated for residential development in conjunction with land allocated to the north and east of the site. Representations for the site have previously been submitted to the Council for their consideration under the Bedford Borough Council consultation on the Regulation 19 Local Plan: Plan for Submission in 2018 and remains a logical site for development in the context of the emerging Local Plan.
3.11 The site is capable of delivering up to 80 dwellings alongside publicly accessible Urban Open Space at a density of 23d/ha. Given the location of the site in the context of the settlement it has the potential to form a well-connected and logical extension to the settlement that will build on allocations previously made in a proportionate and sensitive manner.
3.12 An extract of the emerging Local Plans draft policy map is shown below in figure 5 with the site highlighted for context.
[See attached for plan]
3.13 It is acknowledged that the development site is located on land identified as Urban Open Space, however, for the reasons discussed previously, this should not preclude its use for the delivery of residential development. A low-density residential scheme sensitive to this allocation can still be delivering in line with the approach applied in relation to Policy 18 and Draft Policy HOU5 of the adopted and emerging Local Plans.
3.14 In addition to this, the presence of listed buildings to the south of the site is noted. The Parish Church of St James, a grade l listed building is the only one considered to have a relationship with the site. Nonetheless, through provision of landscaping and separation between the church and new residential development, it is considered impacts can be managed and mitigated in line with the protection that is afforded to this heritage asset. It is recognised a detailed Heritage Impact Assessment will need to be completed for the site and future proposals to assess the extent of harm.
[See attached for plan]
3.16 The provision of housing on a site well related to an existing highly sustainable settlement in response to housing need alongside the delivery biodiversity net gain and localised green infrastructure, associated contributions and further public benefits identified throughout the design process could reasonably overcome any harm to the heritage assets in the area.
3.17 Access is achievable from several alternative positions, and this can be explored with Dandara and adjacent landowners as required. An indicative scheme to deliver an extension to the Dandara scheme to the north has been discussed and is considered below as one alternative.
3.18 The site has the potential to supply a range of residential development in response to identified need and the client is willing to cooperate with Bedford Borough Council and the Parish Council to provide the type of housing scheme that is required in this area of Biddenham alongside the provision of enhanced Urban Open Space in response to the existing designation.
3.19 The suggested Policy wording is as follows:
Policy x – Land to the rear of Church End, Biddenham
Land to the rear of Church End, Biddenham will be developed for the provision of residential development alongside strategic open space. Key principle for development:
i. Provision of a range of housing types and sizes.
ii. Provision of pedestrian and cycle routes at appropriate locations throughout the development.
iii. Provision of a Transport Assessment detailing the impact on surrounding highways and mitigation measures;
iv. Assessment of impact on landscape and submission of a comprehensive landscape scheme;
v. Development should protect, preserve and where opportunities arise enhance heritage assets and their setting, including:
- Biddenham Conservation Area and listed buildings within, particularly Grade I listed St. James Church, and other local heritage assets;
vi. Pre-determination archaeological evaluation;
vii. Contribution to the preservation/enhancement of Biddenham Village Pond and the habitats it provides;
viii. Assessment of the nature and extent of ground contamination and preparation of a remediation strategy for the site including methods of disposing of contaminated material, measures to prevent the pollution of surface and ground water, and provisions for future monitoring, to be approved by the Council.
ix. Provision of a strategically designed and phased Sustainable Urban Drainage Scheme
x. Submission of a biodiversity report with appropriate mitigation and enhancements.
Figure 7. Proposed Allocation Wording (Authors Own)
Conclusion
3.20 As discussed in this report, the Emerging Local Plan pays no regard to the importance of sites that are well related to existing sustainable settlements in delivering housing in line with identified need. Rather, the plan places emphasis on the use of substantial strategic sites and new settlements in large areas of open countryside to deliver housing need, overlooking existing settlements for expansion as is clear from the Spatial Strategy outlined in section 2. It is considered the draft Local Plan should afford more consideration to the potential allocation of sites adjacent to or within the existing the Urban Area.
3.21 This site is located within the identified Urban Area of Bedford Town and therefore comprises one of the most sustainable areas for development in the district. It has the potential to provide an uplift on previous allocations in the area but has been overlooked in favour of Urban Open Space and this should not preclude the site from development. The Standard Method for assessing housing need has identified significant demand for housing in the area. On this basis, the overall need to deliver significant levels of housing in sustainable locations is considered to outweigh the protection of this land, freeing it up for the delivery of housing that would avoid the use of substantial areas of open countryside poorly related to existing settlements.
3.22 Whilst is acknowledge that the site is located in close proximity to designated heritage assets, it is concluded that impacts in this respect can be identified and overcome through detailed assessment and sensitive design. Furthermore, discussions regarding vehicular access are ongoing with the landowner and a workable solution is in place to facilitate this.
3.23 The site outlined above presents a sound option for delivering development of this nature and should be considered by the Council as a preference to the proposed allocations in the plan.

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