Object

Representation ID: 10341

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.

EMP5 LAND AT PEAR TREE FARM, ELSTOW

EMP5 Policy Wording

Types of Employment
Throughout the Local Plan document Bedford Borough Council have draft allocated employment sites with the wording ‘a modern research campus-style development, primarily for research and development with elements of manufacturing, warehousing and distribution’. This is a very generic statement for a number of significant areas of land within the borough. By having made such a sweeping statement of uses (ranging from Use Classes B2 and B8 to Use Class E) enables a site to potentially come forward with any one of those or all of those outlined. Such a large site being used for research and development, differs hugely from such a large site being used for warehousing and distribution, including physical and technical requirements and space together with associated demands and consequences.

Planning policy words that are so broad are subjective, in that if it is not concise and clear on what the purpose of the site is, that it becomes unmanageable at masterplanning and outline planning application stages. What may be intended by Planning Policy Officers in reality is then broadly something quite different, and it is the local residents who have to live with that adverse changes and impact for generations to come.

The evidence within the subsidiary planning policy document (Employment Land Study 1 and 2) of there being a need for such a large site not only at EMP5 but also other sites to take ‘modern research style development’ is weak and imprecise, failing to meet the golden rule, which is that policies should be clear, concise, positive, relevant and capable of being delivered.

Site History
As local authority Officers know, the site known as Medbury Farm within the parish, was allocated in the Allocations and Designations Local Plan 2013 as a 31ha B1 business park. Elstow Parish Council were throughout the Plan consultation phase strongly in objection to this.

It is understood that despite discussions since allocation, no site-wide masterplan was forth- coming, no planning application was ever made and therefore, thankfully no planning permission was issued for this enormous site. Unsurprisingly, yet still very disappointingly, the site was submitted through the ‘Call for Sites’ 2020 process as a potential housing site with capacity up to 1400 dwellings. This has always been a great worry that this site would receive an employment allocation, that was clearly never going to be delivered, to then reappear as a site for housing.

Elstow Parish Council wish to make it abundantly clear that this site which has not in the last twenty years been so much even attempted to be progressed must not be considered for any type of allocation, employment or housing. Not just to the over-riding factors listed previously, also contained within this response, but in addition to the fact this site is clearly undeliverable. The Parish Council were concerned as well that the loss of such a large employment site previously allocated would put pressure on the local authority to meet the required deliver of such land in the immediate and near future.

As a result Officers have found themselves needing to allocate an exceptionally high number of employment sites to meet the lack of the former allocation at Medbury Farm coming forward. It is weak, that the site remains in situ again in the draft Local Plan given the poor history of the site. The effectively ‘lost’ employment allocation from Medbury Farm not being delivered appears to have now resulted in very high numbers of employment sites all being given a generic designation for research use. Surely if the need for such research was rampant in Bedford borough then the Medbury Farm allocation would have been snapped up.

Environment
The sites are best and most versatile (BMV) agricultural land as defined in the NPPF and should be protected from significant, inappropriate or unsustainable development proposals.

Building height
Any structures and associated infrastructure constructed on the proposed sites, particularly large distribution and warehouse units, would have an unacceptable height and scale, be imposing on nearby residential units and prominent within its rural landscape context, particularly given the elevated topography and openness of the land. The proposals would be visually intrusive on the local landscape, harmful to its character and qualities.

There is only some small linear housing settlement on Wilstead Road which would look totally out of keeping with a range of employment buildings, regardless of use.

Transport/Highways
A full study was commissioned by the Borough Council for the current Local Plan 2030 on the effect of proposed additional traffic on the A6 approaching from the North into Bedford. This was the main reason that large developments north of the town have been ruled out. The research carried out by AECOM on the effect of the increase in traffic approaching from the South if these developments were to go ahead is inadequate and does not show the effect of so much more traffic being generated by the proposed developments in Elstow, by the cut-through traffic from

and to the A600 and the large developments proposed close to the A6 by Central Bedfordshire Borough Council. The build up of traffic approaching the A421 or the new Wixams station would be extreme and no proposals are evident of mitigating road changes.

The biggest cumulative impact that will be seen within the parish will naturally be around high- ways and further increases in traffic on the already overwhelmed existing busy rural roads which have become very congested at school opening and closing times throughout the rush hour period as the village is used as a ‘rat run’. The Parish Council have extensive data from local surveys, Police and local authority survey with the problems experienced particularly along Cot- ton End Road. Traffic originates from outside the village and is an indication of how development outside of the Parish Council’s area has in turn adversely affected the resources within the village.

Technology advances and changes to industry/Pandemic
There have been a number of changes to how the population now work from home, with fundamental changes to the workplace environment. Is additional formal workspace really required when there are already so many vacant office and employment sites in the borough? There also over time been, as there will be also going forwards, the evolution of technology.

Need/demand
Direct competition with the other nearby allocations including the proposed new settlement and related employment provision at Kempston Hardwick.
In November 2020, there were 68,916 sqm of office units and 90,760 sqm of industrial units available in the Borough. Instead of allocating more ‘strategic road network’ employment sites, the Council should focus on managing and encouraging the development of the 3 already allocated sites, land at Medbury Farm (AD11, land west of B530 (AD17) and Bedford River Valley Park (AD23), totalling 72 ha, where development has not yet started. This would assist in meeting part of the identified additional B-class employment land between 118 and 142 ha.

Whilst the draft allocated site may be in proximity to a junction with the A421, they currently have no direct access to it, nor do they meet the Council’s requirement of being in a location with good access to existing or planned rail stations (para 10.22 of the Employment Land Study May 2022).

Para 10.23 of this study clearly identifies two sites:

“Sites at Broadmead and Kempston Hardwick offer an opportunity to provide a location with particular potential for an innovation hub and business / science campus primarily focussed on innovation, research, development and education in conjunction with significant residential growth centred on a proposed new station as part of East-West Rail in the Stewartby / Kempston Hardwick area.”

No other new sites are recommended in this study.

The EHH (England’s Economic Heartlands, where Bedford is located within) strategy sets out to focus on decarbonisation of the transport system by harnessing innovation and supporting solutions which create green economic opportunities; and promote investment in digital infrastructure as a means of improving connectivity, in order to reduce the need to travel. These proposals contradict this strategy and fail to:

• Support the delivery of low carbon transport by working towards reduced congestion, digital connectivity, and a net zero carbon system by 204027
• Promote connectivity and accessibility in new development, and link new and existing communities
• Support opportunities for active travel and green infrastructure
• Promote and support infrastructure development which reflects the ambitions of the three preceding principles.

Sustainability
Anything from electric charging points, solar panels or enhancement of the cycle and pedestrian routes could be included. Brownfield sites should be considered first before proposing development on greenfield sites. Previously developed land in or immediately adjoining the urban area of Bedford should be utilised in the first instance, with the opportunity to adapt against climate change, rather than encroaching into the open countryside.

Light pollution
The site will be lit and therefore dramatically change the local landscape for the residents in this part of Elstow community which currently have no street lighting and welcome the ‘dark skies’ policy in this rural setting.

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.

S ECTION 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 EMP5 LAND AT PEAR TREE FARM, 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 Figure 10 to safeguard the settlements in closest proximity to the development.
3. Policy amendment to include clear identification of protection for the site and growth coming of EMP5 from HOU16 located in close proximity to the south of the site.
4. 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.
5. Environmental considerations include tree/hedgerow planting; creation of wildlife opportunities.
6. Sensitive lighting that recognises the dark sky policy within the southern part of the village.
7. Sensitive operational hours of work recognising the needs of the local community.

8. Community assets created and enhancements to recreational facilities, local amenities, cycle paths, safe footpaths, safe access to the site.
9. Noise control recognising the needs of local residents.
10. 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 (beyond the minimum requirement of 10%).