Object

Representation ID: 10334

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Elstow has seen change of a massive scale in recent years. There is the development of Progress Way/Hillesden and Abbeyfields estates [which quadrupled the number of residents living in Elstow], the huge Interchange Retail Park, which is expanding further with the B&Q and M&S additions, whilst the access road is nowhere near suitable. The development of the A421 bypass split the village and the construction of the BP station and hotel simply added to the police crime list. There have been a number of infill developments within the village with more in the “pipeline”, including the old school site. There is also the park and ride, the massive Health Care Logistics/Audi complex, in addition to the large retirement complex.

Apart from the re-location of the school to its current site, and increased size, in Abbeyfields, there has been no increase at all in the facilities in the parish as a result of these changes, in fact there's been a decrease following closure of the Swan pub, a middle school, and shop at Peartree View.

There has continued to be significant increases in through traffic and their speed in the village, to the disadvantage of local residents, and clearly this would increase if further development were to come to Elstow or the surrounding area.

Elstow is a rural community, which is vitally important to retain, through securing its rural feel by maintaining a large number of green spaces, such as through strategic gaps between settlements and important views into the surrounding open countryside.

Site EMP5 earmarked for ‘a modern research campus-style development, primarily for research and development with elements of manufacturing, warehousing and distribution’ in terms of local context does not sit naturally alongside a linear rural settlement.

Site HOU5 earmarked for residential use sits a substantial distance from any existing rural settlement, in fact being quite detached from the Elstow community.

Both EMP5 and HOU5 are not sensitive to the local landscape and setting which will be detailed greater below.

Current Local Planning Policy applicable to Elstow

Elstow has always been recognised as being unique in all previous framework and development strategy documents. This is even documented in the Borough Council's planning framework document, Allocation and Designation Local Plan 2013 which in Section 15 deals with the urban area boundary and local gaps. Policy AD42 specifically deals with coalescence between settlements and the importance of local gaps, aiming to prevent ‘coalescence between the urban area and nearby villages'. This 2013 Plan document has not been superseded by the adoption of the more recent Local Plan 2030 strategy framework document, so it is important to be aware of the policy as it is still relevant.

Furthermore, Policy AD42 (Local Gaps) with its supporting text clearly sets out that:
'In this respect local gaps will be protected, not only from development that would lead to a physical joining of settlements, including that which might normally be considered to be

acceptable development in the countryside, but where possible also from an increase in levels of activity which would reduce the distinction between leaving one settlement and arriving in another. This policy takes account of the principle that the essential feature of the gaps can be purely the absence of development and activity rather than necessarily its landscape quality.'

Paragraph 15.9 goes on to also explain that the policy “also takes into account that local gaps are generally narrow and limited in extent such that any development could seriously affect their openness and could be seen as contributing to visual or physical coalescence. The appropriate width of a local gap is likely to be no more than 1 mile (1600 m) in extent and may be much less.”

This is further reinforced by the reference that recognises Elstow

2.37 The settlement of Elstow can be considered in two parts (apart from the area south of the A421 which has been considered earlier in this project as a potential addition to the urban area). The northern part comprises an historic core along the High Street and around Elstow Abbey, together with later areas of housing along West End and at Bunyans Mead on the east side of the High Street. Most of the development in this area is currently within a defined settlement policy area. Open land separates this northern part from other areas of development to the west and east, however to the north it immediately abuts development within the main part of the urban area.

2.38 The southern part, between Elstow Brook and the A421 comprises development which primarily fronts Wilstead Road. This area does not currently have a defined Settlement Policy Area. Open land separates it from other areas of development to the west and east.

2.40 From this analysis, in terms of visual attachment it can be seen that the selected areas within the northern part of Elstow are distinct from the selected area south of Elstow Brook. The northern part is itself varied, with the Bunyans Mead area very similar in density, built form and type of building to the nearby built-up area, with both having a suburban feel. Conversely, the West End and High Street areas are quite different from nearby built-up areas to the north and east. The historic core of north Elstow, around Church End and the High Street retains a village- like character consisting largely of closely spaced individual dwellings in the High Street and a distinctive open character around Church End and Abbey Close. Nevertheless, this is only a small part of the current settlement and overall the northern part of Elstow can be considered to be primarily suburban in character.

2.41 The southern part of Elstow is completely different from the built-up areas to the east in terms of density, built form and type of building. It has a distinctly rural-like feel.

The extracts above show that Elstow manages in its current form to retain its rural nature. Paragraph 2.44 goes on to highlight: Looking at the land use and character of the open land in the northern part of Elstow, to the west the open land is used for agriculture between the Abbeyfields road and the A6. Between Abbeyfields road and the settlement the open land is variously rough grassland, woodland and mown grass. The character therefore changes from being distinctly rural in the west to becoming more managed and enclosed closer to the s ettlement.

Focusing on the policy wording, it would therefore be totally contradictory to place HOU5 in this pocket which is described as being a distinctly rural part of the village.


The AD41 Policy document goes on in Paragraph 2.47 to detail that the southern part of Elstow can be considered to be rural-like in terms of visual attachment. It would therefore be totally contradictory to place EMP5 in this area which is described as being rural and also contains ribbon like development along Wilstead Road which runs alongside the EMP5 site boundary.

During the preparation of the document previously known as Local Plan 2035, which went on to be adopted as the Local Plan 2030, at no point did it include any intended changes to the Urban Area Boundary policy AD41.

Located on Bedford Borough Council's Development Plan documents webpage is a link to the Bedford Borough Local Plan 2030 document that was adopted on 15th January 2020. On Page 189 of the document, it clearly shows that AD41 are current.
SEE ATTACHMENT

development of 34 houses at Village Farm, which is along Wilstead Road. The application was recommended for refusal by Borough Officers. This again re-enforces the supporting planning policy reasons as to why these areas are so important in terms of Elstow's character and history. Below is the extract from the 2015 report prepared by Planning Officers:

The Urban Gap was identified in the Urban Area Boundary Review as a means of preventing coalescence and to contribute to the separate character and identity of the settlement. The quality of the landscape is not considered in the designation of an Urban Gap. Whilst the Urban Area Boundary Review states that the green spaces cannot be considered countryside due to being surrounded by development, it does identify this particular area of Elstow as having a rural-like character, which is contributed to by the historic farm buildings that front onto Wilstead Road. It notes generally that the Urban Gaps in this area provide a separation between the historic core of Elstow village and the more suburban character of more recent surrounding development.
The proposal does not allow for the retention of any green corridor to the northern Urban Open Space, occupying as it does the entire space between the rear of the buildings on Wilstead Road to the west and Elstow School to the east. The proposal includes an area of open space between the southern and northern parcels, but this does not address the reasons for the Urban Open Space and Gap designations. The site assessment that was completed as part of the Allocations and Designations Local Plan acknowledged that the site would represent

development into an open space that provides a buffer against coalescence, a point backed up by the reason for the Urban Open Gap designation. In its present form the proposed development would conflict with the rural “feel” of the area. It would effectively remove the green corridor linking in to urban open space in the north as well as the gap between the suburban development of Abbeyfields and the more rural feel of Wilstead Road and it is considered that this compromises the purpose of the Urban Open Space and Urban Gap. - 83 - Heritage Issues.
Section 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 imposes a statutory duty on LPAs to have special regard to the desirability of preserving listed buildings, their settings and any features of special architectural or historic interest they may possess; and preserving or enhancing the character or appearance of a Conservation Area. Saved Local Plan Policies BE11 (setting of Conservation Areas), BE21 (setting of listed buildings) and Policy CP23 of the Core Strategy reflect those duties. Chapter 12 of the NPPF sets out the Government's national policies on the conservation of the historic environment. The site lies to the southeast of the designated Elstow Conservation Area and the Grade I listed Hillersdon Manor, also a Scheduled Monument. There are numerous listed buildings along Wilstead Road, including Acacia Cottage, Village Farm and curtilage listed barns, 193 Wilstead Road, Merrick Cottage and Lynn Farmhouse, all listed Grade II.
Part of the significance of these listed buildings is their historic interest. The character of the road, including both the settings and contexts of the above heritage assets, is the semi-rural nature of this ribbon development. This road distinguishes the change in character on entering and leaving Elstow Conservation Area. Therefore, the retention of the semi-rural character of this area is important both to the context of the Elstow Conservation Area and the setting of the identified listed buildings.
A development of 34 dwellings on the site would undermine the semi- rural character of this area and would thus create a much more urban setting to the identified listed buildings. The semi-rural setting of Village Farmhouse and associated traditional agricultural buildings is important to the historical development of the original farm complex and further erosion of the setting would be considered harmful to this identified significance. Two access points into the development have been proposed, in particular that adjacent to Village Farm barns has the potential to over formalise this area through the hard landscaping required. This could further undermine the semi-rural character of the settings of the identified barns and Village Farmhouse. The historical significance of the ribbon development pattern along Wilstead Road would also be further undermined by the infill of land to the rear of the properties to the east of Wilstead Road.
The Conservation Officer therefore advises that that the application would fail to preserve or enhance the setting of the identified listed buildings.

The proposed development site is located in an area of cropmarks comprising a number of ring ditches and linear features some of which have been previously investigated both as part of the bypass investigations and also the school to the east. The investigations identified remains of Late Neolithic/Early Bronze Age ring ditches, an Iron Age settlement, and settlement from the Saxon through Medieval period also. In addition to this the HER records the presence of a possible small Quaker burial ground within the site, traces of gravestones are recorded as being visible possibly as late as the 1950s in local newspaper articles.
In conclusion, the proposed built development would result in a significant incursion into the urban open space and gap which would be harmful to the character and appearance of the area. The development would also undermine the semi- rural character of the area and would thus create a much more urban setting which would be detrimental to the setting of the Grade II Listed Buildings at Acacia Cottage, Village Farmhouse and barns, 193 Wilstead Road, Merrick

Cottage and Lynn Farmhouse. It would thus fail to meet the statutory duty under s66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to preserving the setting of listed buildings.

RECOMMENDATION: Refuse Permission for the following reasons:-
1. The proposed built development would result in a significant incursion into the urban open space and gap which would erode the visual break between the historic core of Elstow village and the more suburban character of more recent surrounding development and result in the loss of the green corridor linking in with the urban open space to the north. The development would therefore compromise the purpose of the urban open space and urban gap and be harmful to the character and appearance of the area, contrary to saved Policy BE30 (i) of the Bedford Borough Local Plan 2002; Policy CP21 (iii, vii) of the Core Strategy and Rural Issues Plan 2008; and Policy AD43 (viii, ix) of the Allocations and Designations Plan 2013
2. The proposed development, by virtue of its scale, siting and layout would undermine the semi- rural character of the area and would thus create a much more urban setting which would be detrimental to the setting of the Grade II Listed Buildings at Acacia Cottage, Village Farmhouse and barns, 193 Wilstead Road, Merrick Cottage and Lynn Farmhouse. The development would therefore be contrary to saved policy BE21 of the Bedford Borough Local Plan 2002 and policy CP23 of the Core Strategy and Rural issues Plan 2008.

Summary

This clearly shows that the allocation of HOU5 and EMP5 are in breach of the Borough Council own planning policy, that aspects of Elstow and its immediately surrounding open countryside must be protected in order to retain its character, setting and separate identity.

Whilst the Parish Council have made their desire very clear on multiple occasions to Planning Policy Officers, to see greater protection for all local green and open space areas within Elstow that lay between the various ribbon areas of the village. It is understood that there is no intention for the Urban Area Boundary to be changed that affects Elstow parish, however, policy AD41 makes it clear what a rural community Elstow is.

Also referenced on the above diagram is Policy AD42 which also remains relevant regarding Local Gaps.

The above planning policies remain in situ, valid reasons as why development in Elstow would contravene the existing policies.

SECTION 5: COALESCENCE

The Parish Council can not reiterate how this aspect of the Local Plan as proposed allocations on multiple sides within and adjacent to Elstow are closing in, which bring increased worry over the rural village being totally engulfed. It is fundamental to safeguard the rural historic nature of Elstow that it is does not become lost into Bedford and end up as an urban suburb.

There really needs to be a distinct difference between Elstow village and Bedford (to prevent "coalescence") with the urban town, as well as between the very distinct communities of Elstow, Wilstead, Wixams, Cotton End and also Shortstown so that their historically separate identities are preserved. The potential size of major development would threaten the very heritage of a vil­lage that is described in the Domesday Book.

The existing very stretched parish of Elstow would not tolerate further development on its edges without these developing into separate, isolated, communities in themselves, or necessitating car journeys to the centre. This is a concern to the Parish Council, as well as Elstow residents who have first hand experience of some of the challenges that developing like this already have. It has taken a number of years to integrate Abbeyfields, a new area of the community in with the older part of Elstow village. Growth in the wrong parts of a rural community will be damaging for not just the short term, but also for future generations to come.
SEE ATTACHMENT

Figure 12 Key Diagram, Page 83 in the consultation sets out an overview of proposed develop­ meant for housing and employment sites. It shows a clear distribution of allocations heavily around the area south of the A421 now being defined as the South of Bedford Policy Area. However, the marking of the map again is misleading in how it represents the sites as it places Wixams and Elstow on the section of the map on the same side of the A6.
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This is factually incorrect and is inaccurate.

Showing vague, poorly located blobs of roughly where allocations are is not helpful. Having spent more time looking at local policy maps relating to Elstow parish it has shown the clear is­ sue with the allocations EMP5, HOU5, HOU15, HOU16 and HOU17 in terms of coalescence. It has already been raised there is noticeable development closing in on Elstow and looking at the local maps it is really evident, please see below.

The Parish Council feel that there needs to be more done to protect the parishes otherwise it will be one large swathe of development.

Map 8 in Policy 52 Changes to the Policies Map shows the level of coalescence.
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This will lead to the areas highlighted by the red arrows which are vulnerable, and them being lost along with the rural village identity of Elstow.