Comment

Representation ID: 9650

Received: 29/07/2022

Respondent: Thakeham

Sustainability Appraisal Appendix 11 – Site Assessment for Eaton Bank site (8835)
Thakeham submitted representations to the Reg 18 Draft Plan consultation in September 2021, with regard to promoting a site at Land west of A1, north of Bushmead Road and south of Kimbolton Road (Eaton Bank). As part of this submission we submitted a Vision Document that sets out our vision for the site as well as the proposed facilities and spaces within the site.
We have reviewed the site assessment work that the Council has undertaken for Eaton Bank, which appears to be inconsistent with the information we submitted as follows:

1. Accessibility on foot to a food store is ranked as a major negative
Our proposed vison document and Call for Sites forms include a shop and a local centre within the site. Therefore the entire site would be within 15 minute walk for all residents and should be classed as a positive for objectives 1b, 3c and 15b of the assessment.
2. Accessibility on foot to a primary school is ranked as major negative
Our proposed Vision document and Call for Sites forms include a primary school within the site. Therefore, the entire site would be within 15 minute walk for all residents and should be classed as a major positive for objective 1c, 3d and 15c of the assessment.
3. The site does not adjoin an urban area or defined settlement boundary
Whilst Eaton Socon does not lie within Bedford Borough Council, it is still an identified settlement. The site abuts this settlement and so objectives 3b and 15a of the assessment should be amended from a negative effect to a positive one.
4. The proposal is not within 400m walking distance of a publicly accessible open space
The Vision Document specifically identifies a green spine running through the whole site that is accessible to all. Furthermore, proposals include a central village green, a rural park, orchards and sports pitches. Therefore, the proposal is within 400m of publicly accessible open space and should be re-assessed as a major positive effect.
5. The site is unlikely to provide a mix of housing and/or is unlikely to include affordable housing and has a negative effect
This is false and contrary to all the forms submitted. Thakeham have always provided policy compliant affordable housing across every scheme, and we never run a viability case to try and reduce this amount. Furthermore, all of our affordable housing is pepper-potted throughout our schemes and is constructed to the same high level as our market housing.
Thakeham also provide an appropriate mix of housing.
Therefore, objective 12a should be amended to having a major positive effect.
6. The Site is not within 800m of a facility where cultural or social activities can be accessed
Community allotments and sports pitches are proposed within the site. A new village centre is also proposed with a community hub and café. The provision of a rural park and green spine through the site will also provide opportunities for social activities within the site.
Therefore, objective 13a should be amended to having a positive effect.
In light of the above, we suggest the assessment for Eaton Bank should be redone as this site can help deliver sustainable net zero homes in line with the spatial strategy for Bedford.

Sustainability Appraisal Appendix 11 – New Settlements Assessment
We believe there are a number of inconsistencies within the new settlement assessment, that could affect the legal compliance and soundness of the Plan. These errors should be rectified, and the growth strategy options amended, to reflect the changes prior to submission of the Plan. Therefore, the New Settlement Assessment (as included at Appendix 11 of the SA) should be amended to reflect the changes to the conclusions for Little Barford as set out below.
We support the criteria used to assess the appropriateness of the four new settlement options. We also accept that Little Barford and Wyboston settlements fair better across all considerations than either Colworth or Twinwoods, with the only difference in grading being on Objective 9 regarding loss of high quality agricultural land.
However, we do not agree with the Council’s conclusions that Little Barford is the more sustainable settlement option, as we believe there are three specific objectives with erroneous conclusions:
1. Objective 9: Wyboston is Grade 2 agricultural land whereas Little Barford is Grade 3 land;
2. Objective 13: Both Little Barford and Wyboston are assessed positively for community, education and shopping facilities; and
3. Objective 15: Both Little Barford and Wyboston have a negative effect on sustainable modes of travel.
We believe the Council’s conclusions to these points is erroneous and should be amended.
Objective 9: Maximise development on previously developed land and avoid the loss of high quality agricultural land
Whilst we do not disagree with the conclusions for Wyboston, the Council acknowledge that the Little Barford settlement has an element of Grade 2 land, and also may be Grade 3a, which would put it in a similarly high quality position.
This should be amended to possible major negative until confirmation of the quality of the Grade 3 land can be confirmed.
Objective 13: Provide for residents’ needs and improve access to community services and facilities
The assessment concludes that Little Barford would positively support community, education and shopping facilities. The assessment states that “The development would be supported by small scale convenience shops and cafes. Some existing vacant buildings could be repurposed to provide community facilities”
However, there is no Vision Document setting out the quantum or location of community and shopping facilities, nor is there any commitment to repurpose those buildings. Indeed, the reference to small convenience shops and cafes does not appear to be sufficient to support a new settlement of 4,000 homes.
In light of the lack of information submitted on this point, the conclusion for Objective 13 at Little Barford should be downgraded from Positive to Uncertain.
Objective15: Reduce the need to travel and promote sustainable modes of transport
There is an inconsistency in the assessment of sustainable transport solution within the document.
The Council find the Colworth settlement to have major negative transport options, due primarily to the lack of certainty over the ability to provide a new railway station, citing “Considerable additional work is required to finalise the full business case, funding and delivery of the station. As a result there remain considerable risks to the delivery of the station.”
However, when considering the Little Barford settlement, the Council simply accept the supposition of a new railway station south of the site as part of the new East West rail route. This is despite:
• there being significant opposition to the route from Bedford to Cambridge;
• no confirmation of the preferred route beyond Milton Keynes;
• no consultation on the proposed new station near Little Barford; or
• no confirmation of location of the new station near Little Barford.
Indeed, Grant Shapps, then Secretary of State for Transport, stated his opposition to the construction of Phase 2 and 3 of East West and that the decision on the construction and funding of Bedford to Cambridge section was one for the next Prime Minister. This is only going to cause further delay.
Therefore, it appears there is still risk to the delivery of this station, and the Little Barford settlement should be assessed accordingly to certainty.
Despite stating that “Walking and cycling provision, together with improved bus links to St
Neots and proximity to a planned East West Rail station mean that car use is likely to be
minimised.” the Council still assess the Little Barford site as having a negative effect on sustainable modes of travel, due to car trip generation.
Therefore, if the East West Rail line does not come forward quickly, or within the Local Plan period, it is reasonable to suggest that car use will increase, resulting in the Little Barford site having a major negative effect on sustainable modes of travel.
In addition to this, the Little Barford site is reliant on the national highways upgrade works to the A428 for access, and specifically a new junction being built. Within the DCO now in place, there is no provision for such a junction and therefore a new junction couldn’t be constructed until after the A428 upgrade works are complete in 2026.
In light of this, it appears that the sustainable transport options for the Little Barford settlement should also be considered as a major negative.
When considering the updated findings across each objective as set out above, the findings should be amended for the Little Barford assessment to ensure consistency across all four settlement assessments. These amendments should be:
Objective 9: Amend from Negative to Possible Major Negative;
Objective 13: Amend from Positive to Uncertain; and

Objective 15: Amend from Negative to Major Negative.
Once the conclusions have been amended for Little Barford, the assessment would suggest that the Wyboston area is a more sustainable location for new settlement option.