Comment

Representation ID: 9737

Received: 29/07/2022

Respondent: Daren Maskell

Agent: Robinson & Hall LLP

1.0 Policy HOU16 Land at East Wixams

1.1 Policy HOU16 criterion (i) requires preparation of a masterplan and design code to be completed prior to and submitted with any planning application and to accord with the South of Bedford strategic framework. This framework will be detailed further in an SPD and as there is no indication as to when this SPD will be adopted there is a real risk that development in the South of Bedford area will be delayed.

1.2 Site-specific design codes could take several months to develop and if there is a delay in the South of Bedford SPD this could push back submission of applications and housing delivery substantially. We therefore suggest that the policy is more flexible and allows design codes to come forward either as part of an outline application or prior to the submission of the first reserved matters application, as is experienced in other local authority areas.

1.3 With respect to HOU16(i), we acknowledge the merits of consultation with the Meteorological Office to ensure the proposals minimise or mitigate any adverse effects on relevant sensitive receptors. The Met Office in this case is a non-statutory consultee. It should be noted that the Met Office’s Cardington facility is not a formally safeguarded site as defined by the following Directions that make provisions for such sensitive sites:
• Town and Country Planning (Safeguarded Meteorological Sites) (England) Direction 2014; and
• Town and Country Planning (Safeguarded aerodromes, technical sites, meteorological technical sites and military explosives storage areas) (Scotland) Direction 2016.

1.4 The facility does not appear on the corresponding Safeguarded Zones Map on the Met Office website (https://www.metoffice.gov.uk/services/business-industry/energy/safeguarding) and therefore it is understood not to benefit from any additional planning protection.

1.5 It is therefore important that the consultation process undertaken is proportionate to the status of the Met Office facility and that the delivery of land East of Wixams is not unduly delayed.

1.6 Paragraph 4.87 of Policy HOU16 states that “The proposals will complement the existing development at Wixams and provide additional facilities and infrastructure including schools and an employment hub to cater for a range of flexible employment uses.”

1.7 However, we note that Policy HOU16 itself does not contain references to an employment hub or any local centre that is likely to be required given the scale of the development proposed. We consider that this should be addressed in the policy.

1.8 In addition, given the significant role that the site will play in terms of delivering additional services, education and employment provision – in combination with enhanced vehicular and pedestrian linkages to the new railway station at Wixams – we are of the view that every effort should be made to deliver this site as early in the Plan period as is feasible.

1.9 Criterion (iii) of Policy HOU16 states that the development is dependent on the delivery of transport improvements which will need to be secured before development can take place in accordance with an agreed Infrastructure Delivery Plan.

1.10 The Council has identified that development of the land at East Wixams would relate to a number of improvements to the pedestrian, public transport and vehicular road network. Although it is recognised that some peak hour delay and congestion may be forecast in 2040 on the wider south of Bedford road network, we are of the opinion that a ‘Monitor and Manage’ approach should be adopted, in conjunction with the wider and more extensive improvements to widen A421 between A421/A6 and A421/A603 Cambridge Road.

1.11 The implementation of the proposed transport infrastructure and in particular the suggested widening of A421, should not prejudice either the commencement or the full occupation of dwellings on the Site. The adoption of a ‘Monitor and Manage’ approach would therefore be consistent with the current views of both National Highways and BBC, and any future highway scheme to improve various junctions along A421 should also be assessed as part of the more extensive proposal by National Highways.

1.12 For the above reason, there is opportunity for East Wixams to come forward earlier than anticipated in the Council’s stepped trajectory under Policy DS3(S) and this would go some way to addressing the shortfall in housing supply earlier in the Plan period.

1.13 Currently, the trajectory shows the first homes on East Wixams occurring in 2029/30 due to the timing and need for upfront transport interventions. We can advise that new homes could be delivered as early as 2025/6 without the need for major strategic interventions and therefore the trajectory should be amended to reflect these considerations.

1.14 Criterion (xv) requires “delivery of a low carbon and environmentally resilient development that is adaptive to and resilient to climate change.” There are no specific targets suggested as part of this objective and therefore we would question its relevance to the policy and whether it is required in light of other similar policies in the draft Plan, such as Policy DS1(S) Resources and Climate Change.