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Representation ID: 8653

Received: 28/09/2021

Respondent: Mr Chris Bearman

Agent: Fisher German LLP

These representations have been prepared on behalf of and in respect of their land interests to the north of the A4280, south of Bromham Road, Biddenham, as illustrated on Figure 1 below.
Figure 1: Site Location Plan
1.2 The site has been submitted to the Local Planning Authority as part of the May 2021 Call for Sites.
1.3 Biddenham is demonstrably a sustainable settlement and the site is located between significant approved development south of the A4280 (policy 18- Land at Gold Lane, Biddenham) and proposed allocation north of existing residential development north of Bromham Road (Policy 23 – Land to the rear of Bromham Road, Biddenham). As such the land forms an infill location between proposed
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development. The land is well contained by existing mature vegetation which would be largely retained, save for that which would be removed to facilitate an appropriate access onto Bromham Road, which will be replaced as part of any eventual developments landscaping strategy.
1.4 The site can deliver circa 33-45 dwellings, depending on eventual matters such as density, housing mix and layout.
1.5 In terms of impacts on the historic environment, the nearest designated asset is Bromham Bridge, which is a scheduled ancient monument located 150m west of the site. The site will not bring development closer to Bromham Bridge, with existing development north of Bromham Road being located far closer to this historic asset. A distance in excess of 150m will exist between the proposed housing and this Scheduled Ancient Monument. The existing mature planting to the north of the site, will be complemented by new boundary planting, meaning views towards the bridge will be largely unaffected. As such, it is not considered that the proposed development will have a tangible impact on this historic asset. There is a Grade II Listed building (66, Bromham Road) located 400m to the east. Existing mature vegetation however acts as a visual screen between this asset and the appraisal site and it is considered that the development of the site would have a negligible impact on this asset.
1.6 The site does not contain or adjoin any designated environmental asset. The site is located within Flood Zone 1, low probability of flooding.
1.7 Whilst detailed access proposals are currently being explored, it is assumed that a suitable access will be possible on the site having regard for the allocation to the north. The site is adjacent to existing bus stops which are served regularly by the 41 service which runs between Bedford and Northampton. Services begin at 7am and run hourly until 9pm in the evening. This would reasonably enable those traveling for commuting, education, retail, leisure and health, sustainably and easily from the site. Improvements to the existing bus stops could be provided as part of development proposals in accordance with neighbouring sites, to encourage their use.
1.8 The site is also considered to be logical when looking at the close proximity of Bedford Railway Station. This is located circa 2.5km to the east, with easy access for pedestrians, cyclists and public transport. Significant weight should be afforded to this connection, not least with planned improvements to the station through the development of East West Rail, providing ready access to other key Arc destinations on this new rail infrastructure, not least better connectivity to Cambridge and Oxford. This connection will help elevate Bedford’s role within the Arc, with significant economic and social benefits to the town
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and wider area, in particular Biddenham.
1.9 With regards to pedestrian access, there is existing footpaths north of Bromham Road which provides access east of the site towards Biddenham and Bedford via an existing underpass under the Great Ouse Way to the east.
1.10 The site can deliver a mix of house sizes, types and tenures, as well as a policy compliant level of affordable housing. As referenced, the site sits between two extant housing allocations (one with planning permission), demonstrating the site’s sustainability. The site is within walking distance of the range of services and facilities contained within Biddenham, with Bedford within easy reach by bus or cycle. The development of the site would therefore clearly constitute sustainable development and would have a strong synergy with existing commitments.
1.11 The site therefore is considered to be entirely logical having regard for existing residential site allocations to the south-east and north, which demonstrates the area is clearly considered to be sustainable and suitable for residential development. The site lacks constraints that would reasonably preclude development and as such is considered to be entirely appropriate. In this context it is considered this site is a logical allocation for future development in the area commensurate with existing levels of planned growth.
1.12 For ease of reference these representations follow the order of the policies in the Consultation Document.

Growth Strategy Options
2.10 Having regard to the concerns raised in respect of the housing requirement and the need to ensure that the Plan is sufficiently flexible to meet the Borough’s own needs and those arising through the Arc, it is considered the distribution of housing should be displayed as a percentage. This would ensure that the Plan is able to respond quickly to changes in housing requirement, whilst maintaining the spatial distribution of housing.
2.11 In respect of the proposed options, it is considered that the spatially optimal solution is a hybrid of a number of the options presented. Our favoured approach would be an approach which seeks to continue delivery in the urban areas, delivers higher growth on key transport corridors, particularly the A421, but also retains an apportionment of growth across to the rural area.
2.12 The issue with the other options proposed is that they place significant emphasis on delivery in limited areas. Such an approach reduces the ability of the market to function most efficiently, as the variety and competition will be reduced. This reduces the ability for small and medium housebuilders to enter the market and reduces the options for home purchasers. This will become particularly apparent if a higher housing requirement is deemed to be appropriate, placing further pressure on a limited pool of settlements. As well as assisting delivery, dispersed growth, across the borough, will encourage a wider
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range of housebuilders into the market delivering concurrently; it also has the benefit of ensuring rural communities remain vibrant and maintain a healthy demographic composition, preventing issues such as ageing village populations and falling rolls at village schools for example.
2.13 Dispersed growth (or Village related as it is referred in the consultation material) should form part of every spatial option proposed, albeit the level to be delivered could of course differ option to option. Any attempt to constrain dispersed growth is not supported.
2.14 Whilst it is recognised that the Adopted Plan makes some provision for dispersed growth, and growth in the sustainable rural settlements to the period 2030, if this pattern of development is not continued, it could result in 10-year + period where no growth occurs in such settlements. This could have a negative impact on the vitality and viability of these settlements.
2.15 A dispersed pattern of growth is better enabled through the availability of modern technology including recent modal shifts to online shopping, improvements to high-speed broadband provision, the increasing prevalence of home working and the greening of private vehicles through developments in electric vehicles (by the end of the proposed Plan Period petrol and diesel car sales will have ceased). In addition, following the recent periods of lockdown there is likely to be a continued demand for semi-rural opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
2.16 Whilst we do not object to the principal of identification of a new settlement as a mechanism of future delivery, caution should be applied to overreliance on the delivery from new settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered. The preferred approach in this scenario is to positively allocate new settlement sites above and beyond the sites needed to meet the Borough’s identified housing needs, with new settlements delivering towards the latter part of the Plan i.e. 2040 onwards. Smaller sites should be identified and allocated for delivery in the early years of the Plan to ensure that delivery of the Borough’s housing needs is not constrained.
Site Allocations and Call for Sites
2.17 Biddenham forms part of the continuous urban area of Bedford and as such should be considered as part of the Urban Area when satisfying the level of allocations required to meet the eventual scale of development as distributed through the chosen spatial strategy. Whilst the Local Plan allocates a
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number of sites within the Biddenham, these allocations are only to cover a period up to 2030. It is therefore necessary to ensure sufficient land is allocated to the period up to 2040.
2.18 Having regard for the clear benefits of the residential development of land north of the A4280 (Figure 1), its inherent sustainability located between existing allocations (which were both found to be sustainable and sound as part of the adopted Local Plan examination) and lack of constraints which would preclude development of the site, we consider this site should be positively allocated as part of the emerging Local Plan.
2.19 This site can deliver circa 35-45 dwellings, including policy compliant levels of affordable housing and a suitable housing mix.