Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4693

Received: 01/09/2021

Respondent: Mr Darren Edwards

Agent: Fuller Long Planning Consultants

Representation Summary:

We consider Option 2a is preferable for sustainability reasons. Benefits stem from reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and access to community services, reducing the need to travel and promoting sustainable modes of travel.

A settlement at Wyboston would not be consistent with the NPPF due to the following:

Greenfield Site
Grade 2 Agricultural Classification
Harm to the character of the countryside
Loss of identity of Honeydon and Begwary.
Insufficient open space between the settlement and St Neots.
Little or no benefit to sustaining Bedford Town Centre.
Flood Risk
Damage to ecology

Full text:

Representation on behalf of Darren Edwards

Option • 2a – We consider in accordance with Government Guidance set out in the NPPF that growth from the existing urban area is preferable for sustainability reasons. This is supported by the Council’s sustainability appraisals. Benefits stem from reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and access to community services, and reducing the need to travel and promoting sustainable modes of travel. New stations south of Bedford are planned and the A421 has capacity for additional traffic.

Regarding the remaining options, having reviewed the draft local plan and site assessment pro formas our client shares the concerns detailed by Staploe Parish Council. We have set out the pertinent points below.

Whilst paragraph 73 of the National Planning Policy Framework (NPPF) recognises that new homes can often be best achieved through planning for larger scale development such as new settlements or significant extensions to existing villages and towns this is provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes). Furthermore, Paragraph 174 under the heading ‘Conserving and enhancing the natural environment’ confirms planning policies and decisions should contribute to and enhance the natural and local environment by:

“…….recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land”

and that;

“Where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality”

We do not consider the proposed settlement at Wyboston (site id 977) is consistence with the guidance given in the NPPF for the following reasons:

1. The site is entirely greenfield.
2. The land has a Grade 2 Agricultural Classification (higher than other sites)
3. The substantial development of 10,000 houses (as set out in the vision document) would decimate the character of the open
countryside whilst resulting in the loss of the identity of existing hamlets namely Honeydon and Begwary.
4. Insufficient open space is retained between the new settlement and St Neots leading to “urban sprawl”, again harmful to the
Countryside.
5. There would be little or no benefit to sustaining Bedford Town Centre given the proximity of the site to St Neots.
6. Flood Risk - There are 5 watercourses which feed into the Ouse just upstream of St Neots from the area which are known to flood.
7. Ecology – As the Council are aware the site provides habitat for several protected species (these have been listed by the Parish
Council). Furthermore, there are significant roadside nature reserves in Honeydon.
8. Impact on Heritage – There are several Listed Buildings both within the site or within its setting including St Denys Church,
Colmworth, Chestnuts, and Dairy Farm Cottage, Honeydown and Tythe Farm.
9. Impact on existing residents’ quality of life though the loss of their peaceful and quiet enjoyment of the surrounding countryside.

Indeed, many of these concerns have been identified by the Council in their site assessment for Wyboston (Site 977). The following are confirmed as negatives to its development.

1a) The site is not within or adjoining the urban area or a defined policy area, or within the built form of a small settlement.
2a) The site is within or adjoining a site of nature conservation importance
2b) Protected Species recorded on the site (identified by the Council as a major negative)
4a) The proposal has the potential to cause harm to heritage assets.
9a) The site is not on previously developed land
9b) All or a majority of the stie is best and most versatile agricultural land as defined in the NPPG
15f) Serious capacity constraints in terms of highways and absence of footpaths/cycleways.

Considering the above, we believe the development of a new settlement at Wyboston in the manner proposed would be entirely contrary to the sustainability objectives set out in the NPPF and that there are preferable sites with reduced negative impacts available that would still enable the Council to meet their housing requirements.