Object

Representation ID: 10340

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

SECTION 8: POLICY HOU5 ABBEY FIELD WEST OF ELSTOW, AND POLICY EMP5 LAND
AT PEAR TREE FARM, ELSTOW

General Issues applicable to both HOU5 and EMP5
The village is an established 'rat run' which is well documented, as traffic comes into the village travelling in huge volumes during peak times. The most popular route is from the A6 travelling in both directions, along Wilstead Road, onto the High Street, then West End, through to the Cow- bridge junction which even after numerous redesigns still suffers from monumental levels of congestion. There is also the Progress Way traffic flows which are significant as a popular route on the local network. The cumulative impact of both these makes highways a real issue in the local area throughout the week.

The popularity of Elstow Primary School attracts pupils from a wide area. It is located in Abbey- fields many travel to the school by car and on regular occasions cars are parked and there is total grid lock at the end of the school day. There has been a number of incidents in recent years involving pedestrians being knocked down. The school has been extended by two additional forms to create a primary school which has resulted in further pressure for parking. Elstow is rightly proud of its local environment, wildlife and heritage assets found throughout the village.

The abundant wildlife along Elstow Brook, in the meadows along Abbeyfields through to its in- famous connection to John Bunyan. The Parish Council have a range of resources evidencing this which all act as further proof that Elstow is a unique parish. To change the setting of these world renowned connections that really are at the centre of Elstow would be devastating.

As mentioned earlier within this response, Elstow sits in a very rich local landscape, any development would impact negatively, in particularly in regards of visual impact. For example any cur- rent open spaces or green areas in the parish, if development were to be sought then it would have a visual intrusion on either the John Bunyan Trail, Cardington Air Sheds or Elstow Abbey. In addition to this, there is the heritage asset of the Medbury medieval village earthworks.

Much work, effort and volunteer time has gone into improving and strengthening the visual appearance of the village. The manicured grass at the Playing Field, the award winning Abbey- fields Roundabout Group with their colourful floral displays, through to the popular tourist attraction destination of Moot Hall. Growth within a community evolves over many years, it is a concern of the Parish Council that if both these sites were allocated then they would not sit naturally in the village setting.

In recent years, Elstow has seen a significant change in the local landscape in terms of flooding and drainage. Reports of issues with watercourses within Elstow have not only become more noticeably frequent but also more wide spread, these have been reported to and followed up by the Internal Drainage Board as well as the Environment Agency. Also there needs to be consideration the different, but exceptionally characterful parts of Elstow which differ greatly. For ex- ample, the area off Wilstead Road, around South Avenue has no street lights, there is a strong sense within that community that if this were to change it would totally alter the setting.

HOU5 ABBEY FIELD WEST OF ELSTOW
SEE ATTACHMENT
Precedent
A huge concern for the Parish Council, shared by the residents are regarding the issue of precedent if there were to be any allocation of housing on this site. Once a site has been included in an accepted strategic growth document it allows a principle of development being acceptable. At this point it then relies on the local planning process as a site goes forward with a planning application. Having left the inspection process it then falls to BBC as the local planning authority to implement the planning policy set out in the Local Plan 2040, and in reality the site bound­ary for HOU5 is extensive and could clearly take a much larger development.

The landowner and their agent have been working together for multiple decades regularly presenting housing proposals in various different parts of the village. The Parish Council will continue to challenge these alongside the HOU5 allocation in order to safeguard the historic and uniqueness of Elstow.

Subsidiary planning policy Document 52 titled 'Changes to the Policies Map' Page 18 shows the HOU5 within the whole parish setting, as illustrated below with the red hatchings. The area within the marked red arrows below is the part of Elstow known as Abbey Fields, this diagram is to highlight the size of Abbeyfields and the size of the HOU5 in that the site could take a significantly higher number of dwellings which has been set out in the Call for Sites supporting docu­mentation supplied by the land owner and their agent. Again, a real concern for the Parish Council and Elstow residents.

SEE ATTACHMENT
Viability
As already mentioned above there is a worry about this site allocation not being restricted to growth of up to 200 dwellings. The Parish Council have seen on multiple occasions in recent years and over time the strategies used within the local planning system in regards to planning gain to enable more houses and therefore more profit from a site. If the precedent is lost with the allocation then there would be further concerns about whether the site is viable with up to 200 houses on. The proposed location of development being restricted to the south west corner of HOU5 means all site infrastructure will be required at the furthest point of the site, therefore costing the most to implement. For example, building a highways access, connecting utilities etc which because of the increased distance to service the south west corner will cost significant more as it is the furthest location from any existing such local infrastructure.

This then enables through the local planning process for viability to be sited as a reason as why the site can not be delivered. More houses therefore being proposed with a the threat to the local authority that they may fall behind with their strategic housing need supply being delivered. This again leaves the site vulnerable over time.

Infill
Once the site infrastructure has been put in place, it leads to opportunities for this site within the Urban Area Boundary even with the special classification of Elstow being a historic rural village, it is highly likely that the site would in the life time of the Plan grow and the density of housing within the site if it were to grow would again bring a swathe of urbanisation and the risk of El- stow being submerged into Bedford Town.

Isolation
Communities take time to grow, this is a process that evolves over time. Elstow has had first hand experience of how when development comes it can not immediately be integrated into the local village. The proximity of the pocket of houses within the site is a great concern for the Parish Council and again Elstow community as it is effectively distinctly located well away from any exiting housing settlement and the village centre. In order to do anything it will require the in- habitants to have to get in their vehicle(s) to access services or facilities, this therefore does not feel like sustainable growth which is now the understandably favoured direction for growth.

Wildlife and habitat
Loss of wildlife, habitat, the wider ecological network, and valuable landscaping (trees and hedgerows), failing to conserve and enhance the natural environment, as required by the NPPF 2021. It is important to understand that there are protected species on this site such as red kites nesting.

SECTION NINE: MITIGATION MEASURES

The purpose of this section is to outline the Parish Council’s comments, having engaged with parishioners, to understand what mitigation measures would in their opinion be needed. The Parish Council would like to reiterate that these comments are being made without prejudice in terms of Policy EMP5 and HOU5 and should not be taken that the Parish Council support the proposed employment allocation but are following feedback from residents:

POLICY HOU5 ABBEY FIELD WEST OF ELSTOW

1. Ensure that Elstow Parish Council takes an active role and is fully engaged and identified as a key stakeholder in the preparation of the Masterplan.
2. Policy amendments to include clear, robust wording within HOU5 that states ‘the number of dwellings up to’, so the size of growth within this site is restricted.
3. Traffic management must be robust and measured given the ongoing issues Elstow has with speeding, volume of traffic and the use of the village highways network as a ‘rat run’ with large volumes of congestion stationary for long periods at peak flow times. Along with particular attention to the Elstow Primary entrance located on Abbeyfields Road which has a number of regular highways safety issues well documented.
4. Strong protection, with extensive mitigation measures for the numerous heritage assets as identified within the Elstow Conservation Area Management Plan.
5. Environmental considerations include tree/hedgerow planting; creation of wildlife opportunities.
6. Sensitive lighting that recognises the position of the site being some distance from any other settlement area.
7. Community assets created and enhancements to recreational facilities, local amenities, cycle paths, safe footpaths, safe access to the site.
8. Enhancement of PROW and bridleway networks.

Given that the sites’ developments are meant to be in a landscaped setting/environment, a significant proportion of the sites should therefore be identified for meaningful landscaping and enhanced opportunities for biodiversity net gain noticeably beyond the minimum requirements