Object

Representation ID: 7557

Received: 21/09/2021

Respondent: C Smith

I am responding to the above consultation in which you outline four proposals for housing development.
Whilst it’s important to provide affordable housing in local areas, it’s also important to make sure that any plans follow consistent national and local planning principles, environmental policies and guidelines for appropriate supporting infrastructure – so that proposals are appropriate, climate and environmentally friendly and sustainable.
I have set out the key reasons for the objection to planning permission being granted for the Dennybrook (site 977) proposal and I propose that Twinwoods (site 883) or Colworth (site 1002) is clearly a better, more suitable and sustainable alternative.

1. Process and Disclosure: Concerns and Challenges
There are a number of concerns about the misleading disclosure of information – and the lack of time in which some residents have been given to consider quite material changes.
The Borough’s options paper in August 2020 showed the brown option as urban development on ‘brownfield’ sites with a large brown development over the whole of the local Staploe parish.
It’s unclear why the inaccurate and misleading local planning designation was included and presented and whether its due to a lack of understanding of the actual local planning designation but what is very clear is that there is ‘no’ brownfield land in our parish – as it is all clearly classed as ‘open countryside’.
This also calls into question whether the misrepresentation of the current planning designation for the proposed development renders the formal consultation invalid.
It’s also highly questionable why the local plan appears to be further misleading as it refers to 2,500 homes at Dennybrook up to 2040 when the developers’ vision for the site is for nearly 10,800 homes in the longer term.
Clarity on the reconciliation and timing of these two important levels of housing concentration as well as the likely impact on the local infrastructure and environment is material in properly considering and consulting upon the planning proposals.
In the Council’s draft Sustainability Appraisal (DSA) dated June 2021 it states that ‘all spatial options have been assessed’. This is incorrect and, again, misleading as options 2b, 2c and 2d clearly identify two new settlements – whose impact needs to be fully assessed and the findings included in the DSA. The options testing in the draft Sustainability Appraisal (DSA) are, as a consequence, inaccurate and incomplete and is contrary to the Environmental Assessment of Plans and Programmes Regulations 2004.
It is also noted that, residents of Honeydon were only informed about the expansion of the site, which is proposed to engulf 40% of Honeydon, some eight months after the deadline close for the call for sites – giving them just one month to consider this before the draft consultation.
Finally, it is important that throughout the whole process, conflicts of interest are identified and properly managed – and minuted as an accurate record of how they were approached.

2. Concentration and Impact on Inadequate Infrastructure:
The Borough is building houses at more than 3 times the national rate. Whilst its admirable that our borough is providing affordable housing to those in need, its totally inappropriate to provide concentration risks of housing developments without totally adequate infrastructure to support it on a sustainable basis.
Residents of the proposed Dennybrook development would be required to use personal transport to access shops, services and key transport links as they would be at least a number of miles from their nearest railway station.
Furthermore, due to the location of the proposed development, St Neots would naturally be the town centre relied upon by this new community, not Bedford as assumed, where St Neots is already unable to fully and properly support its local residents.
With a decline in the high street in both St Neots and Bedford, but particularly in St Neots, will there be sufficient jobs to meet the needs of new local residents? Has the employment plan been considered alongside the development plan?
At a time when the global and national community is pursuing a strategy of climate change transformation to target net zero emissions by no later than 2050, these proposals fly in the face of that global effort particularly since the proposal is to use ‘open countryside’ for development rather than urban development on brownfield sites in the Borough’s options paper in August 2020.
The proposal for Dennybrook will not just oppose national policy by using ‘open countryside’ and all the environmental disadvantages that clearly presents, it is also likely to ‘increase’ net emissions in this local area – providing a much less healthy environment and contributing to not mitigating global warming.
5. Key Objections to the Development of Dennybrook
The proposed development for Dennybrook is the least appropriate and has been inappropriately considered as a ‘brownfield site’ when in fact it is designated ‘open countryside’.
The key reasons why alternative sites are significantly and indisputably more appropriate than Dennybrook are:
• Destruction of greenfield: It is a purely greenfield site on grade 2 (good quality) agricultural land – therefore contrary to government policy
• In the future, greenfield sites will be incredibly important for sustainable environmental, food production and climate change reasons
• Town Centre Dependence and Concentration: The proposed development at Dennybrook will depend on St Neots and not Bedford – with a high number of unintended negative consequences
• Urban Sprawl: There will be insufficient segregation between St Neots and the new development – creating a material risk of ‘urban sprawl’ and consequences from ineffective planning policy
• Pollution: The proposed development at Dennybrook, for the reasons explained, will increase pollution of air, water, soil, noise and light.
• Climate Change Increased Risk: The choice of the use of ‘open countryside’ rather than an urban development or other preferences of Government Policy, will naturally increase net emissions and be contrary to the global aim of being net zero by 2050
• Flooding Risk: There are 5 water courses which feed into the River Ouse just upstream of St Neots from the Dennybrook area. There is a recognised track record of flooding which makes this an inappropriate place for high density housing which could lead to high insurance premiums to local residents or, as climate change evolves, a risk of residents bearing an uninsured risk – where the consequences on financial and mental unwellness of residents has been clear to see in other parts of the UK
• Over Concentration on Local Infrastructure: Many of the roads in the Dennybrook area are single track with high banks and sharp bends which are unsuitable for large volumes of traffic or for HGVs
• There are no mains sewers or gas, a telephone exchange that is some distance away and there is already pressure on the mains water pipe that leaks frequently in Bushmead Road
• Public Transport: The traffic in and out of St Neots is already heavy at key times of the day and there are no seats on trains from St Neots to London before any increase in the local population, a lack of additional parking. No buses at present and no safe routes to reach the station on foot or bicycle
• Public Services: An increased local population would naturally increase pressure on doctors and dentists
• Devastation of nature reserves: Over decades, nature reserves have developed naturally. Many roadside and highly valued wildlife habitats along these roads would be destroyed if these single track roads were to be widened
• Honeydon has, by far, the largest area of roadside nature reserves in the Borough – which would be destroyed
• A wide range of wildlife and biodiversity will be destroyed through this proposed development which includes protected species of Bath Aspargus, Small Eggar Moths, Sulphur Clover, Crested Cow Wheat, Red Kites, Corn Buntings as well as badgers, bee orchids, owls, egrets, skylarks and dragon flies.
• The setting of Listed Buildings and Areas of Importance: These include St Deny’s Church, Colmworth; Chestnuts and Dairy Farm Cottage in Honeydon; Tythe Farm; Manor Farm which has strong connections to the Church of Jesus Christ, Latter Day Saints and the Old Chapel in Chapel Close.
Summary
This letter sets out very clear and specific objections to the proposal to create a new area of development that would be known as Dennybrook (site 977).
Of the options that have been presented in the consultation, Bedford Borough Council’s own sustainability appraisals demonstrated and concluded that the alternative Option 2a is the preferred and most suitable option because urban development is more sustainable than rural.
Little Barford (site 907 – option 2b)y, ‘excluding’ Wyboston / Dennybrook, is the next most appropriate, which would provide additional 3,085 dwellings in the rail corridor and would create:
• A development in and around the urban area plus A421 transport corridor with rail based growth parishes
• Access to a large number of services and facilities including existing employment which would reduce the need to travel by car
Twinwoods at Thurleigh (site 977) is the next best alternative and more appropriate because:
• Urban Area is widely preferred, even expressed through government policy, to rural areas particularly ‘open countryside’ – and a significant part of Twinwoods is brownfield land
• Government planning policy requires brownfield sites to be prioritised over greenfield sites
• This choice is better aligned to the infrastructure, environmental and structural challenges that need to be properly addressed as part of a robust planning process
A further alternative would be Colworth (site 1002) for the reasons set out above.