Object

Representation ID: 7431

Received: 03/09/2021

Respondent: Trakbak Racing Limited

Agent: WSP

When the Council previously withdrew the garden village settlement at Colworth (nearby to SPD), which was put forward as an allocation in the previously emerging Bedford Local Plan 2030, they recognised that the development of housing in close proximity to Santa Pod is inappropriate. Despite this, there is nothing in the ‘Growth Strategy Options’, on pages 19-23 of the emerging Local Plan 2040, to reflect that or to protect Santa Pod from the effects of alternative development proposals on its business.
Trakbak Racing Limited has concerns about this and, in particular, if the Council fall into a position of failing to demonstrate a five-year supply of housing land during the emerging plan period which could result in speculative housing applications being submitted nearby to SPR. At paragraph 3.9 of the document ‘Trakbak Racing LTD Regulation 19 Representations to the Bedford Borough Local Plan (October 2018)’ it is explained that there is a known noise issue in connection with Santa Pod. In consequence, there is a risk of unreasonable restrictions being placed on SPR because of new development.
In relation to this, paragraph 187 of the NPPF that “existing businesses should not have unreasonable restrictions placed on them as a result of development permitted after they were established” needs to be complied with to ensure that the emerging local plan is in accordance with policies of the NPPF (as required by paragraph 35 of the NPPF). The agent of change (the housing development) should be required to provide suitable mitigation where the operation of an existing business could have a significant adverse effect on new development.
Attached at Appendix 23 is a letter from MAS Environmental dated 25th October 2018. This makes it clear that any development within the previously proposed Colworth garden village development area (Site reference: 1002) would carry significant risks regarding noise impact. Development in the area indicated as the inner buffer zone (highlighted in red) would be subject to noise from the raceway for the majority of events and there is no evidence to suggest that mitigation could adequately resolve the issue. Trakbak Racing has been advised that such mitigation could not be satisfactorily provided within the inner buffer zone without its cooperation. The cooperation of Trakbak Racing has not been secured and it would not be appropriate for housing to be allocated in the inner buffer zone.
In the outer buffer zone it would be essential for the Council to be satisfied, before supporting the allocation of a site, that it would be possible for mitigation within the proposed development to provide an acceptable noise environment. This would need to be supported by robust evidence and the Council should provide guidance in the Local Plan as to what standard should be required.
Adoption of the MAS recommended exclusion buffer zone for residential development around Santa Pod would represent a positive response to the issue of housing around SPR and would ensure that paragraph 187 (‘agent of change’) of the NPPF is complied with. The restriction would need to be in a strategic policy to ensure that it guides the Neighbourhood planning process adequately.
It is significant that in the case of the SPR there is no restriction on noise levels. The distance selected for the buffer zone has been identified based on the measured noise levels experienced in the relevant areas and so is based on a sound evidence base.
The introduction of housing into the inner buffer zone would represent a serious threat to the continuation of the business at Santa Pod, which makes a valuable cultural and economic contribution to the wider area. It would not accord with paragraph 187 of the NPPF and so would render the Plan unsound. Any housing within the outer buffer zone would need to be subject to robust mitigation measures to provide a specified satisfactory indoor and outdoor noise environment and sites should not be allocated unless that can clearly be demonstrated. In this case the plan does not, in the absence of clear policy guidance in relation to the location of housing to avoid noise issues from Santa Pod, provide a clear and adequate strategic framework and that omission goes to the soundness of the plan.
Summary
These representations are made on behalf of Trakbak Racing LTD to object to the allocation of four sites (references: 1002, 529, 531 and 532) submitted as part of the local plan consultation. The allocation of these sites would be contrary to paragraph 35 of the National Planning Policy Framework (NPPF) (2021) which explains that in order for local plans to be found sound, they must be in accordance with policies of the NPPF.
These representations also explain that the ‘Growth Strategy Options’ of the emerging local plan should be amended to protect Santa Pod from the effects of inappropriate housing development proposals on its business. These representations explain that an exclusion buffer zone for residential development around Santa Pod should be outlined in strategic policy, as this would represent a positive response to the issue of housing around SPR and would ensure that paragraph 187 (‘agent of change’) of the NPPF is complied with, and therefore ensure the soundness of the emerging Bedford Local Plan 2040.
We would be grateful if you could confirm safe receipt of this representation and we look forward to them being considered in the consultation process of the emerging plan. In the meantime, please contact me if you have any queries in respect of the matters raised in this letter.