Object

Representation ID: 7748

Received: 22/09/2021

Respondent: Colmworth Parish Council

I do not support the proposal for a new “garden village” settlement at Dennybrook (site ID 977) included in three of the four options within the draft Local Plan 2040
(LP40).
I believe the Dennybrook proposal should be rejected for a number of reasons:
- Dennybrook delivers very few houses in the all important 0-5 year period, it is
the worst choice among the major sites.
- Dennybrook’s claims of housing delivery beyond year 5 at a rate of 500 per annum (10 sales per week, every week, for 20 years) seem highly optimistic,
way beyond the expectations of the other major developments. This creates a far higher risk of under-delivery than with other proposals. Even though BBC
is not relying on this delivery rate it highlights an unacceptable concentration of power in the hands of a single developer.
- The submission shows that the developer expects construction traffic on the site for over 25 years, that is an unacceptable burden on neighbouring communities.
- Dennybrook has comparatively poor access to Bedford, many people will favour St Neots which adds further economic damage to Bedford town centre which is in serious decline.
- Apart from the far end of the Dennybrook site near St Neots, the only exits from the site are unclassified roads incapable of handling the traffic volume.
The central road is a single-track road. Wilden Road is one of several local roads classified as “Unsuitable for HGVs” presenting a clear risk of unsuitable
traffic using local access privileges elevating accident risk. Neither the Dennybrook submission nor the Transport Model include any proposals for road widening or enhancement of the local minor roads that will be
overwhelmed.
- There is no shortage of high quality development opportunities for inclusion in the plan. The call-for-sites returned over 430 responses totalling in excess of
70,000 plots against a need of around 12,500 plots for completion of the plan.
There is no need to consider something as large and destructive as the Dennybrook proposal.
I recognise that the principal advantage of including a garden village settlement is that it creates the potential for a community of a size that can be largely self sufficient
and thus less reliant on neighbouring communities for services and facilities over time.
When the (originally much smaller) Wyboston site was assessed as part of LP35 BBC concluded that “the site is on the edge of the Bedford housing market area and
therefore the Council consider that if the garden village were to be allocated, it would contribute to meeting Bedford’s economy and housing need. However, the site lies very close to St Neots and it is likely that pressure would be placed on services and facilities in St Neots. This impact has not been assessed by the site promoter.” I believe this under-estimates the relative convenience and attractiveness of St Neots and thus overstates the likely contribution to Bedford’s economy and housing needs.
The site lies in the northeast corner of Bedford Borough and is significantly closer to the town of St Neots. It is likely that most new residents, in common with existing
residents in the area, will focus on that community for shopping and entertainment needs and to some degree employment. This presents a problem for BBC as the
site will be relatively unattractive to residents whose lives currently focus on Bedford, many purchasers are likely to be drawn from the St Neots area and thus the site may
not adequately address anticipated growth in housing demand from Bedford.
Moreover, Bedford will receive comparatively little economic benefit from the site’s residents and it is even possible that Bedford may see a negative impact from some of its wealthier residents who currently commute to London from the Midland station who choose to relocate to this site to benefit from the proposed Little Barford rail
station. Thus the site will likely fail to support Bedford housing needs and fail to provide economic growth to Bedford in proportion to the scale of the development.
In terms of delivery of the site the program is heavily dependent on road access arising from the planned improvement works around the Black Cat roundabout A421/A1 junction, the timetable for which remains unassured and the necessary capacity improvements are not guaranteed. The DCO has not yet been granted and a delay to the completion of the Highways England’s scheme could have a significant impact
on both the delivery of housing and local traffic flow generally. No work has been done within the Dennybrook proposal to evaluate the mitigation that would be
required to the Black Cat Roundabout should the Highways England scheme not progress or be delayed.
The Dennybrook site lies in a very rural situation where there are exceptionally few existing facilities in the immediate vicinity. There is minimal employment, little public transport, no retail outlets and no educational resources locally at present. The proposal allocates some land towards the provision of such facilities but the
scheduled build-out rate for the site is unlikely to provide self-sufficiency in these facilities for more than a decade leading to significant reliance on neighbouring
communities, particularly in the St Neots area, placing a substantial burden on those communities. Once the development is complete there will be inadequate gaps
remaining between the development and the communities of Colmworth, Wyboston and others to prevent coalescence with the existing settlements, effectively erasing the identity of historic settlements dating back to medieval and earlier periods.
The location of the site means that, for employment purposes in particular, many residents will be commuting above-average distances and will be almost wholly
reliant on private cars. The distances for most would not encourage walking and cycling and while there is a new railway station planned for the area, possibly around
Little Barford, this will best suit London commuters for the most part. Residents working in and around Bedford Borough are unlikely to find it either efficient or
economic to travel away from Bedford to the new station in order to take a train back to Bedford Midland station for a connecting train, bus or taxi onto their employment
destination.
In the LP35 assessment of the site BBC concluded that “the existing walking and cycling provision near the site is generally good, however some of the surrounding
infrastructure requires improvement (e.g. subway under Northfield road, footbridge over the A1).” However, the proposed is site is three miles in length and two miles
from the midpoint to Eaton Socon. Accordingly it seems unlikely that walking will be feasible outside the site boundaries. BBC noted “The site is located in a relatively
convenient location for vehicle journeys on the strategic road network, which may be a deterrent to non-motorised travel.“
There is no doubt that residents would be almost wholly dependent upon the private car, that is simply an established characteristic of rural life and nothing in this
proposal contributes to an effective solution to this issue. As a result, the proposal cannot be considered to be the most environmentally sound or sustainable solution
to Bedford’s housing needs. While the site will be inconvenient and unattractive to many in Bedford, there is likely to be increasing demand from residents working in the Cambridge area, looking to benefit from the new East West Rail service when available. However, these housing needs could in all likelihood be accommodated within a much smaller development such as site ID 907 at Little Barford, very close to the proposed East West Rail
station. It is difficult to see how the Dennybrook development in its current form could deliver the most appropriate strategy for expanding Bedford.
Within the analysis for LP35 the Council’s view was that the timing was not right to take forward a garden village in Wyboston. The Council wanted to have more
certainty on the timing of delivery of the Black Cat scheme, the A428/Caxton Gibbet scheme and the possibility of the A1 realignment. In particular, the Black Cat and A428 projects were considered crucial pre-requisites to a major Wyboston development and while plans and surveying for these road schemes have moved
forward, there is still no certainty as to the timing of completion. On present scheduling, construction traffic for Dennybrook would be heaviest at a time when the
Black Cat, the A1, the A421 and the A428 are all subject to partial and temporary closures adding to the current congestion.
There are multiple points of access to the Dennybrook site but currently there is no direct access to classified roads. The primary access point will be at the eastern end of the site via the A4280 onto the A1 and A421 at the Black Cat junction. There are no other A or B class roads near the site. The main access point on the western side
is Mill Road, a single-track road that runs through the site. Thus road access, particularly in the direction of Bedford, can only be described as inadequate for such
a large development.
When the site was assessed as part of the LP35 analysis, the Council stated that “the existing road widths, visibility and constraints are inappropriate to accommodate the proposed levels of development” “Access to the A1 via rural roads is currently
considered to be inadequate and unacceptable, with no proposals for improvement identified.” That conclusion related to a site of only 4,000 homes compared to the
current proposal for 10,150 homes. Despite being aware of the problem for several years now the promoters have not been able to incorporate any suggested solution
within the proposal.
The commercial value of the Dennybrook project would exceed £3 billion. Despite this, the site promoters have provided extremely little information about, or
commitment to, infrastructure improvements that would need to be delivered. There is no material information showing new roads, road widening schemes, road junction redesign, footpaths and cycle paths, public transport support, public services, leisure
facilities etc. The promoters are seeking permission to build a new town the size of
Biggleswade but are focused almost solely on the sale of houses and have given no commitment to providing the key components that comprise a successful and
desirable town environment. While there is a long way to go before the site has formal planning permission, the inclusion of the site within the LP40 would give
effective commitment to the project, essentially a commercial decision would have been made without most of the crucial facts, specification and evidence that a project of this magnitude would ordinarily provide as a prerequisite. That process introduces an unacceptable degree of project risk that is so easily avoidable. This proposal places too much control in the hands of the site promoter at the expense of BBC.
A key concern is that this single site would be selected to address almost half of all housing need in Bedford Borough for an entire generation. It seems extremely
unlikely that this scale of development in what is probably the most rural part of the Borough, largely detached from Bedford by distance and transport accessibility, can
be achieved at the rate suggested by the promoter of 500 units annually for two decades. There is a material risk that development will be moderated to support
prices meaning the site will not deliver housing at the rate promised affecting this and future Local Plans. That would also lead to a connected concern about
extension of the development schedule from the current 25 years to much longer meaning that local communities may be affected by construction traffic for 30 years
or more. That seems wholly unreasonable when there are so many other site alternatives that will not have such a destructive effect on existing residents’ lives.
Although not directly relevant to a decision on housing allocation it is worth noting that BBC made a very strong presentation to attract the East West Rail link into
Bedford town centre because of a marginal economic gain. It makes no strategic sense therefore to promote a housing scheme that is the most economically
disadvantageous to the Borough of all the proposals arising from the call-for-sites.