Object

Representation ID: 8085

Received: 25/09/2021

Respondent: Mr and Mrs John and Di Hey

Dear Sir/Madam
Consultation Response: Dennybrook – Local Plan 2040
I am responding to the above consultation in which you outline four proposals for housing development.
Whilst it is important to provide affordable housing in local areas, it’s also important to make sure 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.

We have set out the key reasons for the objection to planning permission being granted for the Dennybrook proposal and we propose and alternative that is clearly a better, more suitable and sustainable alternative,.

1. Process and Disclosure: Concerns and Challenges.
The Borough’s options paper in August 2020 shows the brown option as urban development on ‘brownfield’ sites with a large brown development over the whole of 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 could render the formal consultation invalid.
It’s also questionable why the local plan appears to refer to 2,500 homes at Dennybrook up to 2040 when the developers’ vision for the site is for nearly 11,000 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.
Finally, it’s 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.
2. Concentration and impact on Inadequate Infrastructure
The Borough is building houses at more than 3 times the national rate. Whilst it is admirable that our borough is providing affordable housing for those in need, it’s totally inappropriate to provide concentration risks of housing developments without totally inadequate 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 x miles away 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 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 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 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.
Option 2a: Proven More Suitable Alternative
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.
Importantly, development within urban areas performed best particularly in reducing carbon emissions, promoting town centres (which incidentally are in decline), encouraging physical activity, delivering residents’ needs, access to community services (which are so important to mental wellness) and reducing the need to travel and promoting sustainable types of travel. New stations South of Bedford are planned and the A421 has capacity for additional traffic.
3. Government Planning Policy – Application and Relevance to These Proposals.
Government planning policy requires that brownfield sites be selected as a much greater priority than greenfield sites for very robust reasons. One of these reasons they quote is that developments must recognise “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 higher quality”.
In further support of this, a relevant definition within the National Planning Policy Framework is:
“Best and most versatile agricultural land: Land in grades 1,2 and 3a of the Agricultural Land Classification”.
The land proposed for Dennybrook at Honeydon and Wyboston is mostly Grade 2.
There are alternative, much more suitable sites, which are brownfield land, at Twinwoods, and much of the East West Rail route (Bedford to Cambridge).
On these grounds alone, as a further alternative to Dennybrook or even an urban development, the brownfield site on Twinwoods is much more suitable, particularly as:
• It does not flood
• It has no major watercourses and is distinct from other settlements – so no loss of identity for existing settlements
• Government planning policy seeks to develop brownfield land ahead if greenfield land (open countryside)
4. 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 of gas, a telephone exchange that is some distance away and there is already pressure on the mains water pipe that leaks frequently in Bushmead Raod.
• 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 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 if roadside nature reserves in the Borough – which would be destroyed.
• A wide range of wildlife biodiversity will be destroyed through this proposed development which includes protected species of Bath Asparagus, Small Eggar Moths, Sulphur Clover, Crested Cow Wheat, Red Kites, Corn Buntings as well as Badgers, Bee Orchids, Owls, Egrets, Skylarks and Dragonflies.
• 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.

5. Alternative and Better Suited Sites
As it is a brownfield site, Tempsford Airfield would be ideally suited for development and far better, along with Twinwoods, rather than obliterating the Hamlets of Duloe, Staploe, Honeydon and Wyboston.

Our challenge is also whether any thought has been given to how GP Surgeries, hospitals and schools are expected to cope with such a massive influx of people. We are chronically short of all medical staff as it is and this also applies to teachers. Even if new hospitals and schools are built where are the qualified staff to man then?
Finally we should aim to be more self-sufficient in food production. Importing food massively increases C02 emissions, building on grade 2 farming land is totally irresponsible given the need to drastically reduce emissions.

Summary.

We have set out the very clear reasons for and the specific objections to the proposed development which creates a new area known as Dennybrook.
Having considered all the choices put forward by the Planning Department we believe that Tempsford Airfield would be ideally suited for development and far better, along with Twinwoods, because:
• Urban area is widely preferred, even expressed through government policy, to rural areas particularly ‘open countryside
• 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.
We hope that this is helpful.

Yours Faithfully

John and Do Hey