Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10335

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

P roposed Allocations Objections
Substantial development has been included in the Local Plan document with EMP5 and HOU5 both within Elstow parish. On review of Document 52 Changes to the Policies Map it further highlights the encroachment from Policy HOU16 Land at East Wixams in particular. In light of this very sizeable allocation, the Parish Council is also mindful of the large allocation for Policy HOU17 Land at College Farm, Shortstown which will be addressed as well in this response as it virtually adjoins HOU16.

If HOU16 and HOU17 allocations were taken forwards as strategic growth options by the local authority, they would most likely consist of estate-type development which would be out of character with the rural, multi-age and mixed style of the current range of dwellings and rather worryingly create a broad swathe of dense development in the immediate area.

In addition for site HOU5 if it were to be developed it would be mean it would be totally neces- sary for people to have to travel by car into other communities, as these resources are not nearby in light of the isolated location of the pocket of housing.

 Schooling (insufficient places available locally)
 Shopping (local store cannot supply the range of goods required)
 Health facilities (limited locally)
 Onward bus or train travel (limited services, considerable travel time due to insufficient highways network capacity)

P olicy HOU16 Land at East of Wixams
In addition to the Parish Council objecting to HOU5 and EMP5 proposed allocation for the plan- ning policy reasons set out above, the Parish Council wish to highlight in particular that for HOU15 for this site, the detrimental impact in terms of coalescence with Elstow village, in partic- ular the South Avenue part of the village.

The location of this site is a real concern as it sets total precent for high density estate development east of the A6 within Elstow parish. For many years land that side of the A6 and the village road into Elstow has been put forward for planning, and refused, rightly so. Such an allocation with Policy HOU16 is going to have a significant knock on effect.
The proposed Settlement Policy Area for HOU16 also extends a long way eastwards, again a concern given the large land masses nearby in Elstow which have received planning applications for housing development. Whilst they have been refused previously, it does bring concern that this allocation could bring precent.

The policy wording makes a brief reference to a long term buffer between Wixams and Elstow, however, this is not reflected in Figure 8 of the consultation document within the site boundary. This is concerning as in many other site maps illustrating proposed allocations there has been distinct reference already included of important areas identified as key open spaces even at this strategic level. Such safeguarding of areas can be included at this stage of the Local Plan, again this omission is concerning for the Parish Council.

Equally for this Policy HOU16 site the Council feel in light of the landowner/site agent represent- ations within the ‘Call for Sites’ process it is clear the site can hold significantly more than the 1800 proposed allocation. Given recent experiences of sites that have come forward, the Parish Council are mindful it is often the wish of the developer when bringing a site forwards to place as many houses on as possible to maximise revenue output. It is therefore reasonable that if this site remains included that it must have written into the strategic policy robustly a definite number of houses, along side the key earmarked open space areas to act as a strategic buffer. Without this change and inclusion within the policy there is no safeguard or protection for the site to not be fully developed and given the site has capacity to hold enough for a new town this is really a concern for the Parish Council.

Again the Parish Council feel that Policy HOU16 wording is not clear enough on a number of important factors that must be stated within the overarching policy if this site goes forward. There are again too many ‘lose’ words which during the development of Wixams resulted in so many expectations not being met, alongside with the limited local authority powers, it caused a lot of distress that facilities were not being progressed in a timely manner and many ultimately never were delivered.

Paragraph 4.87 makes no reference of the site within Elstow parish or its proximity to Elstow, these omissions are not acceptable.

The Metrological Research Unit at Cardington is referenced, having tried to better understand the impact this has on the site, in terms of planning policy, this is not clear. It would be reason- able for such an item considered to be so significantly important to be mentioned in the planning policy that somewhere there is clarity on what such a reference actually means along with the types of mitigation that will need to be factored in. The reference is made in both paragraph
4.87 as well as Policy number i. so it must be an important item.

Item iii. references transport improvements are required, in fact the development is dependant on it. Again the policy wording is insufficient and unclear, this needs to be defined.

The Parish Council feel that there needs to be more included with the Transport Assessment point number iv. it seems illogical that a site for 1800 houses has less requirements stipulated in the associated policy that Policy HOU15 which is to have 300 houses. Surely as a bare minimum the four bullet points contained within HOU15 should be referenced in HOU16. Along with, as mentioned previously, the local authority needing to have higher expectations and aspirations for further enhancements to the local network to maximise more sustainable methods of transport.

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.
SEE ATTACHMENT

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.
SEE ATTACHMENT

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.