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Site Assessment Pro Formas

Representation ID: 8741

Received: 29/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Representation Summary:

3.1 Our client’s interests at Land off Marsh Lane have previously been promoted at each consultation stage of the adopted Bedford Local Plan 2030 and throughout the preparation of the Milton Ernest Neighbourhood Plan.

3.2 As part of the Bedford Borough Councils previous ‘Call for Sites’ our client’s land was assigned site reference 518 (‘Land off Rushden Road’). This site forms the current proposed MENP housing allocation (Policy ME H1). The adjacent site, also in our client’s ownership (ref: 162), adjoining the southern eastern boundary, was assigned to ‘Land at Marsh Lane’. The site is now collectively referred to as Site Ref 910 in the Local Plan 2040 supporting Site Assessment Proforma June 2021.

3.3 The site forms an opportunity for comprehensive, sustainable development in the longer term. The larger part of the site previously referred to as Site 518 has been comprehensively analysed within the Borough Council’s ‘Site Assessments and Potential Options for Allocation’ Report (April 2017) where it was identified as a potential allocation option for Milton Ernest considered to be able to make a “significant contribution both alone and in conjunction with adjoining site 162 towards the strategy target of up to 50 dwellings for this village”. As illustrated at Table 2.1.1 of the AECOM Masterplanning Report (prepared as evidence to support the Neighbourhood Plan) sites 518 and 162 were both listed for consideration.

3.4 As part of the MENP evidence base a Site Assessment, was undertaken by Troy Planning and Design (TPD) which included Site 518 in the list of four site options flagged as having scope for further consideration. The TPD Assessment again also included Site 162 as a potentially suitable option. Within the TPD Assessment, Site 162 achieves a favourable Green/Amber assessment reflecting the potential opportunities associated with enhancements to Green Infrastructure and links to the countryside. The TPD Assessment also acknowledges that these benefits would likely be achieved through development in conjunction with the adjoining land under Site Ref 518, in terms of facilitating access and links to the A6.

3.5 In terms of TPD’s view on site capacities, utilising their density calculation method, TPD


recorded a potential site capacity of 75 dwellings for site 518, if 50% of the site is developable at a density of 30dph. Adjacent site 162 is recorded in the TPD’s Assessment as having a potential site capacity of 11 dwellings, at 30dph assuming a developable area of 70%.

3.6 Whilst several suggested amendments were taken forward by the Parish Council in the production of the submission version of the MENP, our client continued to highlight the potential benefits of incorporating a wider site boundary (including further green infrastructure
/ SUDS opportunities, improved links to the countryside and ecological / biodiversity enhancements), which could be further realised by joining site 162 to the allocation area.

3.7 The MENP Examiner’s report published 28 July 2021, which recommended the Plan proceed to referendum subject to modifications, included removing the reference to a maximum of 25 dwellings (amending to minimum) reflecting policy and supporting acknowledgement that this site could support the delivery of further dwellings to address housing need.

Land off Marsh Lane

3.8 The site is located to the north of the village of Milton Ernest and covers an area of approximately 4.99 hectares, currently in agricultural use. The site is located outside of the current Settlement Policy Area (SPA). However, Policy ME C1, seeks to amend this boundary to include that part of the proposed housing allocation at Land off Marsh Lane (Policy ME H1) identified as the ‘Development Area’.

3.9 For the avoidance of doubt our client intends to bring the scheme forward for residential development within the amended SPA as set out in the MENP policy ME H1. However, this should not preclude the potential to provide additional capacity for suitable residential development as part of preparation of the Local Plan 2040.

3.10 The site is positioned to the north of Bedford. The A6, one of the main routes into Bedford, runs through the settlement. As set out in the highways comments supporting TPD’s Assessments, a safe and suitable access should be deliverable from Rushden Road (A6), at multiple points along the site frontage. This is also confirmed within the Borough Councils Site Assessment Proformas (June 2021) where it is stated “A new access would have to be created onto the A6 however the proposed access location is fine. No significant traffic congestion in the area, and the development is unlikely to have more than a moderate impact”.


3.11 The site is bound by Rushden Road to the south-west, private residential properties to the north-west and south-east, and countryside to the north-east. A tall hedgerow screens the south-western edge from Rushden Road and the back of private properties south of the road, and the northern edge runs along an open field boundary. The gradient of the land rises north eastward through the site and as is shown on the supporting Constraints and Opportunities map at Appendix 2. There is little subdivision within the site.

3.12 The surrounding built environment consists of mainly lower density detached and semi- detached one and two-storey residential buildings, in various architectural styles. There are no flats, commercial or industrial buildings in the immediate vicinity of the site. The two Listed Buildings near the south-east are screened by walls and vegetation, but partly visible from the site. Mitigation for these assets in terms of any impact on their significance (including the contribution made by their setting) has been considered as part of the preparation and Examination of the MENP. The MENP Policy H1 criteria includes a requirement to maintain an appropriate buffer with between the development area and heritage assets, which our emerging proposals will accord with. Our client is also in the process of commissioning a detailed heritage assessment to inform future design proposals and requirements in terms of mitigation.

3.13 The site has good access to a range of local facilities. As confirmed through TPD’s and Bedford’s Local Plan Assessments, it is recorded as Green (less than 400m) in terms of access to village centre services including access to a primary school and access to public transport. The site is within close proximity to the village centre and a short walking distance (2 minutes) to nearest bus stop on Rushden Road with public transport connections to Bedford.

3.14 The site is defined by the Environment Agency as Flood Zone 1, which indicates that flooding from nearby rivers is unlikely. A small section of the south-eastern edge of the site can be prone to surface water flooding but this area of land would also form a suitable landscaped area that can incorporate flood attenuation and sustainable drainage features. A mature hedgerow runs along the western boundary of the site parallel to Rushden Road which largely defines the existing view from Rushden Road.

3.15 The site is not located within any statutory area, AONB, Local Nature Reserve, SSSI or Green Belt.


3.16 The land has no outstanding planning permissions and no planning history of note.

Potential Development Scheme

3.17 These representations have been prepared in the context of the submission version MENP and the proposed ‘development area’ indicated under Policies ME C1 and ME H1 of the MENP. While appropriate modifications were suggested (including those acknowledged by the Examiner in terms of capacity and links with the adjacent site), there were no overriding objections to the approach proposed in the MENP.

3.18 Equally, however, the evidence for the site itself reflects that there is no in-principle constraint to extending the area proposed for built development beyond the MENP’s suggested extension to the SPA boundary. Achieving further built and non-built uses beyond the proposed SPA boundary could be achieved together with potential benefits towards the requirements for sustainable development within the wider boundary of site refs 518 and 162.

3.19 As stated, the site as allocated is considered suitable, available, and achievable to meet the dwelling requirement set out in the MENP and policy 4S of the Local Plan. The site is capable of delivering a carefully considered residential development, which can help achieve the objectives of the proposed development strategy, in a sustainable location. The location of the site provides a natural extension to Milton Ernest and is well-related to and capable of enhancing the existing pattern of development along Rushden Road.

3.20 The site would allow for the development of a mix of dwelling types and sizes to complement and enhance the existing housing stock and to meet and address the specific local needs of the area. The site could be developed to respect and complement the established pattern, form, and character of the village, be sympathetic to the settings of the adjacent Listed Buildings and provide a congruous extension to the existing settlement form.

3.21 This site additionally provides opportunities to unify the western and eastern portions of the village along Rushden Road, together with providing a new active frontage facing the A6. The allocation of this site would reduce the linear spread of development to the south-west of Rushden Road, away from the existing village centre, instead facilitating the centralisation of development closer to the heart of Milton Ernest.


3.22 Whilst the allocation of this site has some potential to affect the local landscape character, this can be limited through comprehensive master planning and a careful consideration of green infrastructure. As highlighted in the AECOM Masterplanning document this can be achieved through the integration of landscaping buffering which delineates the new edge of the built-up area from the countryside to the north and “ensures a sympathetic village edge transition”.

3.23 To support these representations a Constraints and Opportunities Plan has been prepared (see Appendix 2).

3.24 The proposed approach in the MENP is broadly consistent with this Plan, in terms of initially focusing built residential development within the ‘development area’ proposed together with opportunities to deliver open space, recreation and ecological enhancement outside of the proposed amendment to the SPA boundary.

3.25 The Constraints and Opportunities Plan illustrates the ability to test further layout options considering the wider area, identifying scope for flexibility in terms of the extent of residential development and future opportunities for extension of the built area. This demonstrates scope for the delivery of increased dwelling numbers both within and beyond the proposed amendments to the SPA boundary as set out in the emerging MENP.

3.26 To support the progression of development in this location in accordance with Policy ME H1 our client is in the process of commissioning a series of technical assessments covering highways, heritage and archelogy and drainage options. Layout considerations and Masterplanning work has also been undertaken.

3.27 Emerging proposals for the site as proposed for allocation within the emerging MENP Policy ME H1 indicate that the site can sustainably facilitate options for site capacity that would sit comfortably across the range of 25-50 dwellings indicated in Policy 4S of the Bedford Local Plan 2030. These representations demonstrate the scope to assess the potential to support higher levels of growth based on the potential benefits to be provided such as the delivery of additional open space.

3.28 As part of preparation of the Local Plan 2040 it is important to safeguard acceptable parameters for future proposals in this location whilst avoiding the unnecessary prescription and limitations on opportunities to secure the achievement of sustainable development. This


would facilitate the Council identifying Milton Ernest to make a modest further contribution towards the additional needs for development in the period to 2030 and beyond, consistent with the Plan’s overall requirements and objectives.

APPENDIX 1 OF ATTACHMENT IS SITE LOCATION PLAN
APPENDIX 2 OF ATTACHMENT IS CONSTRAINTS AND OPPORTUNITIES PLAN

Attachments: