Object

Site Assessment Pro Formas

Representation ID: 6634

Received: 14/09/2021

Respondent: Mr Mark Potts

Representation Summary:

Duloe Field – site 3420
The land at Duloe Field is not considered a suitable site by Staploe Parish Council and should be discounted as a sustainable location for development by Bedford Borough Council.
The proposed site falls within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for a development at Duloe Field.
It is clear that the proposed development at Duloe Field would be a car reliant settlement because it would not be within walking distance of sustainable transport. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be no employment associated with Duloe Field with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Duloe Field site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 25 homes would require infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance in what is a tranquil and idyllic countryside setting. This site has very poor access. The proposed access is onto a narrow, steep, single track lane with very poor visibility.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 300 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The hamlet of Duloe currently only has around 40 homes and is currently a ribbon development with houses usually only on one side of the road. This gives each home a rural outlook on both sides. A development of 25 homes would fundamentally change the character of the hamlet.
The Duloe Field area includes hedgerows which are havens for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving. These could be significantly impacted by development.
There are also several Grade II Listed Buildings located within the hamlet of Duloe which are directly within site of the proposed development. The Thatched Cottage is particularly iconic in Duloe and gives the hamlet its identity. This development would block the view of this beautiful traditional cottage as you approach from Staploe. It would also affect the view of the Dovecote. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. We would strongly suggest that this site would cause serious harm to heritage assets.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies 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 of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
Valued local views would be lost across open farmland to the Thatched Cottage.
Residents of Staploe, Duloe and Eaton Socon would be affected by an increase in traffic through the hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic and the approach to St Neots is past a primary school.
The bottom of the field floods and there is constant runoff down the road from the site in wet weather.
Overall, the land at Duloe Field does not offer a truly sustainable form of development, and is thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new development should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.
100 Word Summary Duloe Field Site 3420
Duloe Field is unsuitable because: the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the adjacent roads are very narrow with steep sides and sharp bends, it is too far from the new E-W rail station to offer sustainable transport, there are listed buildings (Thatched Cottage and the Dovecote) very close to the site and the development would block views of these buildings which are important “placemakers” in the hamlet. The bottom part of the site floods.