Housing & Employment land Availability Assessment and Site Assessment

Comment

Representation ID: 9237

Received: 30/06/2022

Respondent: Clerk to Hail Weston Parish Council

Hail Weston Parish Council (HWPC) resolved at their general parish meeting held on 21 June 2022 ‘objection’ in relation to the proposed development known as ‘Eaton Bank’ land north of Bushmead Road, submitted in response to Bedford Borough Council’s (BBC) ‘Call for Sites’.
Hail Weston Parish Council has previously objected twice to the BBC ‘Call for Sites’ and copied Huntingdon District Council (HDC) in relation to proposed developments at Cottage Farm, Upper Staploe, Flints Field and Top Homes.
The Hail Weston Parish Council supports and agrees with the assessment that “the site has been excluded from further assessment at Stage 1 because its location is not in accordance with the development strategy” This statement is in keeping with the objections originally raised by HWPC urging both Bedford Borough Council and Huntingdonshire District Council to discount this area of development due to it being a non-suitable location.
Objection: Our Community Plan for 2016-2021, which had a 71% household response rate, shows that:
A large majority (92%) of respondents disagree with the statement that Hail Weston should grow considerably, including 68% who disagree strongly stating the value of living in a rural location. Residents would least like to see the village being developed eastwards towards St Neots or towards any other nearby settlements.
At recent parish meetings, which have been well attended, members of the public have spoken up against the proposal to develop this site, concerns were raised about: High-quality agricultural land being developed for more housing, lack of community influence over the density, and the number of houses that could be built if the land in question was sold for housing development, lack of public engagement, lack of services and infrastructure in the surrounding area, increased motor vehicles on B645 and that whilst developments to upgrade the Black Cat roundabout, A428 upgrade and East-West railway. Hail Weston Parish Council believes these will not directly benefit this development furthermore Hail Weston Parish Council believes the biggest impact will be seen on local infrastructure and highways and services.

Object

Representation ID: 9523

Received: 27/07/2022

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Reference Site 590 Willington.
This representation has been prepared on behalf of Clarendon Land & Development in respect of
their land interests at Barford Road, Willington as illustrated on Figure 1 below. This site is an
omission site in the emerging Bedford Local Plan 2040. The site is suitable for allocation in the
scenario that further housing sites are required to enable the Local Plan to be found sound (as we
consider to be the case and as set out within these representations). (Map included in original)
Figure 1: Site Location and Illustrative Masterplan
1.2 The Barford Road site is located to the southern edge of Willington. The adopted Bedford Local
Plan identifies Willington as one of Bedford’s 8 ‘Rural Service Centres’ which are acknowledged to
be sustainable settlements and have previously been identified through the Council’s own
evidence as being able to accommodate up to 150 new dwellings.
1.3 Willington is located just 4km east of Bedford. The site is located off Barford Road. The existing
facilities and services in Willington are within walking distance of the site. The site also benefits from nearby bus stops on Sandy Road, Bedford Road, and Station Road which afford regular
access to Bedford and Biggleswade, with half hourly services running throughout the day,
providing quick and convenient access to larger centres for commuting, education and social
purposes.
1.4 This representation follows policies in the order that they appear in the consultation document.
The Housing and Employment Land Availability Assessment and Site Assessment Topic Paper (May 2022) includes the Council’s assessments of the sites submitted for consideration throughout this Local Plan process.
3.2 A copy of the assessment for Barford Road, Willington is provided below, with our suggested amended assessment where relevant which is based on site specific technical assessments that have been carried out.
3.3 With the above in mind, it is clear that Land at Barford Road, Willington is better suited to come forward for residential development than actually assessed by the Council. Copies of the available technical information have been provided with previous representations demonstrating the site’s deliverability.

Object

Representation ID: 9588

Received: 29/07/2022

Respondent: Arrow Planning Limited

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

4.1 The land at West Park Farm sits immediately south of Wilstead, as shown on the Site Location Plan enclosed at Appendix 1. The land measures c.21ha and was submitted to BBC through the Call for Sites process in 2020. Enclosed at Appendix 3 is the Council’s
assessment of the site contained in the Site Assessment Pro Formas.
4.2 The land has previously been put forward for a residential development, with the Council’s assessment suggesting 525 homes. Curiously, whilst considering the site for residential development, the appraisal concludes stating that the site is not a preferred location for employment. This is a concern and suggests the site has not been correctly assessed compared to what it has been proposed for.
4.3 Furthermore, the assessment concludes that the site was excluded from further assessment as its location is not in accordance with the Development Strategy. Again,
this is a fundamental flaw as the site location does accord with the development strategy, namely growth south of Bedford including in the parish of Wilstead.
4.4 Our previous representations (August 2020) set out a thorough consideration of the site against the assessment criteria, repeated below for the Inspector’s benefit. Having reviewed against the updated proforma, the Council’s assessment has not failed to consider these proposals. Of particular note is the response to question 3a, concerning renewable energy. As those representations evidenced (and seen below), the site is
proposing a net zero carbon scheme with wind and solar. This is further evidence that the site has not been correctly assessed by the Council.
4.5 A full and thorough assessment of the site, carried out in accordance with the full evidence base and the proposals as put forward on behalf of the landowner, would find that the site should be allocated. The Local Plan is, therefore, unsound as it is not justified. The Local Plan should be modified to allocate the land at West Park Farm for housing and renewable energy development. This is necessary to both respond to the evidence base, and to make up the shortfall of housing that will result from the correct assessment and planning of the other south of Bedford sites, as set out in Section 3 of
these representations.
4.6 As set out in our previous submission, a more detailed land use assessment of the site and the enclosed illustrative masterplan (Appendix 2) demonstrates how the site could provide the following net zero carbon development1:
• 13.6 hectares of residential (511 dwellings at around 37.5 dph - 1.9 hectares is shown as 'multi-generational housing)
• 5.5 hectares of solar, a large scale (potentially 6MW) wind turbine and ground sourced heating infrastructure to supply homes with hot water 1 Definition of Next Zero Carbon for operational energy: “When the amount of carbon emissions associated with the building’s
operational energy on an annual basis is zero or negative. A net zero carbon building is highly energy efficient and powered from on-site and/or off-site renewable energy sources, with any remaining carbon balance offset”. Source: Government Property
Agency, Net Zero and Sustainability Design Guide – Net Zero Annex, August 2020
9 Pre-Submission Local Plan Consultation Response ● APL–046
• 1 hectare school site (single form entry)
• 2 hectares playing fields
• 3.3 hectares of woodland in addition to woodland buffer planting
• Allotments
• Community Hub
• Retail/café with EV charging
• A new roundabout on the A6 at the Chapel End Road junction
• A new cycle/footpath connection into Wilstead along the ‘old’ route of the A6
4.7 The proposals are a comprehensive approach to delivery of a net zero carbon, highly
sustainable development within the southern parish of Wilstead. The proposed development would meet the requirements of national policy, particularly in relation to
climate change, and would be an exemplar development that would assist the Council as a flagship scheme to lead the way for other developments to follow, so assisting the Borough in moving towards becoming a net zero carbon Borough.
4.8 The Site is in a single ownership, is available and is deliverable, being actively promoted by the landowner. It is not reliant upon any third parties and would be
capable of “consuming its own smoke” in terms of infrastructure. The Site could, therefore, be delivered early within the plan period.
4.9 The proposed development has several key benefits that meet the aims and vision of both the Local Plan, and national policy. In addition to being a net zero carbon
development with renewable energy and heat alongside development, it would deliver multi-generational housing and a new school, as well as major highway improvements. The ability to connect to the settlement of Wilstead with a new cycle/footpath connection enhances the sustainability of the Site, and enhanced by the
topography, it is in an excellent location to connect to the new Wixams station, the proposed East-West rail station north of Stewartby, and the nearby proposed Bedford
Business Park. The homes would therefore be in an excellent location by providing opportunities for people to live and work locally and reduce reliance upon the private
car.
4.10 The Site Proforma confirms that the land is adjoining a defined settlement area, and that there are no major issues that would preclude the allocation of the Site. Turning to more detailed aspects of the Council’s assessment and, in turn, the evidence base for this Local Plan, there are a number of positive matters which further point towards the case for allocating this Site.
Highways and Access
10 Pre-Submission Local Plan Consultation Response ● APL–046
4.11 The Bedford Borough Local Plan Transport Access Assessments document2 (site ref 686)
finds that the proposed highway mitigation is possible and scores the Site with an amber rating. It does not highlight any technical issues with the Site and, those matters that score less well (namely bus stop and cycle connectivity) would be addressed as part of the development. The subsequent proforma assessment (Appendix 3) does not identify any highway or access constraints that cannot be mitigated against and does
not raise any objections to the mitigation proposed in the submission.
4.12 The highway summary of the Site correctly notes that a development of this scale would have the ability to either provide its own bus stop or deliver a flexible public transport service. Thus, the scoring of the Site regarding public transport would improve and, given the proximity to both the Wixams rail station and new East-West rail station near Stewartby and the proposed Bedford Business Park, it would be realistic for a shuttle
bus service (or similar) to connect this development, local villages, and those locations.
4.13 Turning to cycle, the layout at Appendix 2 shows how the Site would connect to Wilstead, with a new cycle connection along the former route of the A6. The
topography in this area is relatively flat, and thus conducive to cycling, and therefore the Site is one that would be a realistic cycling option for residents to choose to cycle.
4.14 Finally, the delivery of a new roundabout at the Chapel End Road/A6 junction (as shown in Appendix 4) would deliver wider highway benefits. Presently this junction is one which has experienced several accidents over recent years, a risk that may be increased given future development pressures in the locality. The delivery of a new roundabout would have considerable benefits in terms of highway safety, whilst not resulting in congestion issues on the A6 given the distance to other junctions.
Heritage
4.15 The summary Site Proforma refers to potential harm to heritage assets. However, upon examination of the Historic Environment Assessments that forms part of the evidence base, the assessment finds that there are no known heritage assets, and only that a
“pre-determination evaluation will be required”.
4.16 The document also confirms that there is unlikely to be an impact on Listed Buildings.
The concluding comments in the assessment, that, in effect, find that there ‘may or may not be’ a harmful impact on heritage assets or their setting is misleading, if not completely incorrect.
4.17 There is, therefore, no reason to find that the Site should be excluded on heritage grounds. This is in direct contrast to other allocated sites, in particular HOU13 with
several heritage assets (not just buildings but features such as ridge and furrow) identified as requiring mitigation within the Policy wording.
Landscape
2 Link in paragraph 5 of the Site Assessment Pro Formas June 2021
3 Link in paragraph 5 of the Site Assessment Pro Formas June 2021
11 Pre-Submission Local Plan Consultation Response ● APL–046
4.18 The Site sits within the East Marston Clay Vale (5E) as identified in the Landscape Character Assessment (2014, updated 2020) (‘the LCA’). The LCA finds that this area has a number of urban and built form influences, namely:
• Large scale industrial features such as distribution warehouses
• Roads, such as the A6, with a strong visual and audible presence
• The urban edge of Bedford and development along the A6 associated with Wilstead brining urban fringe characteristics.
4.19 The vale is low lying, and the Site itself sits within this low topography. The Site benefits from the change in levels to the east and south, and the Ancient Woodland to the east of the Site. This change in topography, along with the woodland, provides a sense of enclosure for the Site, separating it from the changing character further south and preventing the feeling of encroachment into the wider countryside.
4.20 The LCA in particular identifies that the settlement edge expansion of Wilstead is a potential future change to the landscape4, thus acknowledging that growth in this area is something the landscape is likely to accommodate. Moreover, the LCA identifies (para
SE.1.42 p.120) that this future growth must prevent linear expansion and the merger of villages, with specific reference to the potential for the merger of Wixams with
Wilstead.
4.21 This means that, based on the LCA, the only possible location for growth of Wilstead is to the south. Any growth to the north or west would lead to a potential merger with Wixams, whilst to the east there is the risk of coalescence with Littleworth.
4.22 Plainly, therefore, allocating the Site for development would be a logical approach considering the landscape evidence base for the Local Plan.
Summary
4.23 The land at West Park Farm, south of Wilstead, is being actively promoted for a net zero carbon development of some 515 homes, with a school, multi-generational housing, transport infrastructure and large-scale renewable energy and heat.
4.24 The Local Plan evidence base finds that this location is a logical and appropriate location for development; indeed the LCA actively points to this location (by process of elimination) for future growth. The Site would accord with the emerging development
strategy for BBC and would deliver housing in a sustainable location, together with renewable energy, as advocated in the NPPF.
4.25 The land at West Park Farm should therefore be allocated for development (housing and renewable energy) within the Local Plan.
4 Page 119, Landscape Character Assessment (2014, updated 2020)

Object

Representation ID: 9596

Received: 27/07/2022

Respondent: Andrew and Robert Tusting

Agent: Fisher German LLP

Legally compliant? No

Sound? Not specified

Duty to co-operate? Not specified

Site 42
This representation has been prepared on behalf of XXX in respect of their land interests to the west of Odell Road, Harrold as illustrated on Figure 1 below – the site is edged red. This site is an omission site in the emerging Bedford Local Plan 2040. The site is considered
suitable for allocation in the scenario that further housing sites are required to enable the Local
Plan to be found sound (as we consider to be the case as set out within these representations). Harrold is a sustainable settlement designated in the adopted Local Plan as a Rural Service Centre.
Harrold is the highest scoring Rural Service Centre in the Borough (59 points), scoring only a few
points less than settlements designated as Key Service Centres (Settlement Hierarchy Paper
2018), such as Great Barford which score 62 points. The adopted Local Plan seeks to deliver 25 -
50 dwellings in Harrold through the emerging Neighbourhood Plans (this is in contrast to the 500
dwellings in the Key Service Centres, which Harrold falls just outside of). In historic iterations of the Bedford Local Plan (2015 consultation paper) the Council produced evidence which
demonstrated that the Rural Service Centres such as Harrold could each accommodate up to 150
dwellings. The Council recognised the benefits of delivering larger developments in the Rural
Service Villages advising that:
“Some villages have experienced the loss of vital services such as shops and pubs in recent
years. Changing the current strategy of restraint in the rural policy area could increase the
population and change the age profile of rural villages. An increase in activity and spending
power would support existing vulnerable village services and facilities, and possibly lead to
new provision. Furthermore, larger developments would be likely to bring with them a range
of types and sizes of housing, which would provide more choice for existing residents
wanting to stay within a village but down-size.” (Development Strategy and Site Selection
Methodology Background Paper, September 2015)
1.3 The draft policies at that time supported such an allocation. Despite this latent capacity, the
Council ultimately sought to reduce the quantum of housing to be delivered within the Rural
Service Centres in favour of a new settlement, however, when the viability and deliverability of this
was challenged the Plan period was reduced with an early review mechanism. A number of
interested parties objected to this approach of the new settlement and the thereafter the reduced
Plan period allowing the Plan to be found sound with the new settlement removed.
1.4 Harrold Neighbourhood Plan has since progressed to referendum on 18 November 2021. The
result demonstrated support for the Neighbourhood Plan, with 86% of votes in favour, with a 28%
turnout. The Neighbourhood Plan was ‘Made’ on 5 January 2022.
1.5 The Neighbourhood Plan identifies land to deliver 25 dwellings across two allocations, the
minimum level of growth identified in the Local Plan. This includes land fronting onto Odell Road
(17 dwellings), immediately adjacent to the wider land now being promoted. Notwithstanding this,
as has already been evidenced by the Council, settlements such as Harrold remain well positioned
to provide additional sites to ensure the Council can meet its future housing needs. Sites in the
Rural Service Centres can deliver quickly and ensure that the step change in delivery is met in the
initial years of the Plan period whilst maintaining the vitality and viability of the services and
facilities these settlements offer.
1.6 The land west of Odell Road, Harrold can deliver circa 60 dwellings, subject to detailed
masterplanning based on the site’s opportunities and constraints. It is considered this is
commensurate with the size and sustainability of the settlement and combined with the 25
dwellings to be delivered through the Neighbourhood Plan would still be significantly below of the
150 dwellings the Council has previously evidenced the settlement can deliver within the Local
Plan period. Indeed, having regard to the sustainability of the settlement, and its place within the
settlement hierarchy, just below those settlements which are expected to deliver 500 dwellings, it
is considered that the capacity of Harrold to accommodate new homes could be greater than 150
dwellings.
1.7 This representation follows policies in the order that they appear in the consultation document.

3 Land to the west of Odell Road, Harrold – Site Assessment
3.1 The Housing and Employment Land Availability Assessment and Site Assessment Topic Paper (May 2022) includes the Council’s assessments of the sites submitted for consideration throughout this Local Plan process.
3.2 A copy of the assessment for Land to the west of Odell Road, Harrold is provided below, with our suggested amended assessment where relevant which is based on technical assessment that have been carried out.
(extract table from site assessment included in original)
3.3 With the above in mind, it is clear that Land west of Odell Road, Harrold is better suited to come forward for residential development than actually assessed by the Council. Copies of the available technical information have been submitted in support of planning application 19/00842/MAO and demonstrate the sites acceptability. In particular it is further noted that part of the site previously promoted is now allocated for development within the Harrold Neighbourhood Plan, further demonstrating the acceptability of development in this location.

Object

Representation ID: 9651

Received: 29/07/2022

Respondent: Thakeham

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Re Eaton Bank (Land west of Eaton Socon between Kimbolton Road and Bushmead Road) Call for sites ref 8835
Thakeham responded to the Regulation 18 consultation in September 2021 as we are promoting land to the west of Eaton Socon, between Kimbolton Road to the north and Bushmead Road to the south (known as Eaton Bank). As part of this promotion, we supported strategic growth options that included a new settlement at Wyboston as it benefits from existing sustainable transport links, is not reliant on new transport infrastructure before delivery and will provide additional services in the north of the district, which will benefit the wider population of the Borough beyond merely Bedford town centre.
Thakeham is an infrastructure-led sustainable placemaker and is committed to creating new, extraordinary places, where the highest attention to detail makes a positive difference.
Thakeham build for the future, for communities and for individuals. Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham Homes will be carbon neutral in construction and zero carbon in lifetime use.
We will engage local primary schools with our ‘Eddie & Ellie’s Wild Adventures’ initiative to promote the importance of ecology and biodiversity, delivering National Curriculum linked activities and early career-based learning.
Thakeham design all homes to be beautiful and reflect the character of the area. The materials used across all developments are of the highest quality. Thakeham builds all developments tenure blind to ensure no drop off in quality.
As one of 12 members of the NHS Healthy New Towns network, Thakeham is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over
time, we have realised that these principles are just the starting blocks, and at Thakeham we are committed to delivering sustainable, zero carbon communities.
Our level of commitment to sustainability means that we are streets ahead of our competitors and aiming for a far higher level of impact. Thakeham has become the first housebuilder in the UK, and one of only five in the construction sector globally to have made commitments on the SME Climate Hub, and be part of the United Nations’ Race To Zero campaign. As part of this, we have committed to the SME Climate Commitment. Recognising that climate change poses
a threat to the economy, nature and society-at-large, our company has pledged to take action immediately in order to halve our greenhouse gas emissions before 2030, achieve net zero emissions before 2050, and to disclose our progress on a yearly basis. Our sites will include the following sustainability improvements:
• All Thakeham homes will be carbon neutral in production and zero carbon in lifetime operation by 2025. This puts us well ahead of the pledges we have made as referred to above.
• On all Thakeham developments we follow industry best-practice by taking a ‘fabric first approach’, which looks at how design and materials can contribute to the energy performance of the completed building.
• We will also consider the potential for incorporating sustainable energy features, such as air-source or ground-source heat pumps, communal rainwater recycling, solar panels, battery storage, renewable energy tariffs, and highly efficient heating and hot water systems.
• Thakeham uses a UK-based factory which manufactures panels using timber from sustainable sources. The off-site panelised system improves efficiency, speed of construction, quality, and reduces carbon emissions.
• Our Sustainable Procurement Policy encourages the use of recycled materials, such as otherwise nonrecyclable waste plastics (One tonne of MacRebur mix contains the equivalent of 80,000 plastic bottles), as well as utilise products part of a circular economy.
• We ensure that our whole supply chain is a local as possible. We have gold membership with the Supply Chain Sustainability School.
• On site, we monitor and aim to minimise construction travel emissions, construction waste and energy consumption and are registered with the Considerate Constructors Scheme.
Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards.

Object

Representation ID: 9758

Received: 27/07/2022

Respondent: De Merke Estates

Agent: Neame Sutton Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Site 1326
Site Specific Representations – Land East of Green Lane, Clapham
5.1 This section addresses the promotion of the site at land east of Green Lane, Clapham. The accompanying
Vision Document, which summarises the technical assessment of the site, indicative masterplan and
access plans are included in Appendix A for reference.
5.2 The site was considered as part of a wider parcel of land (500 houses), as a reasonable alternative in the
Clapham Neighbourhood Plan Strategic Environmental Assessment (December 2020). The site has been
reduced to accommodate 100 dwellings on account of the progression of the East to West Railway (EWR)
route, which is indicated in the Key Diagram (Fig.12) of the Pre-Submission Plan.
The masterplan has been informed by De Merke Estates’ technical team, and future access to land northeast of Clapham (west of The Baulk) can be maintained across land in De Merke Estates’ landownership.
5.4 The proposed density is reflective of the local area and would provide approximately 100 homes, including affordable housing, making a valuable contribution to the housing requirement, in a sustainable location, further enhanced by the EWR, which is making significant progress.
5.5 There are no environmental constraints on the site and its development would ensure future access to land northeast of Clapham, as well as generate economic benefits:
• Construction jobs.
• Ongoing site maintenance jobs, including landscape and SUDS management.
• Increased spending in the local area.
• CIL contributions.

Comment

Representation ID: 9777

Received: 29/07/2022

Respondent: Prologis

Agent: Lichfields

Land west of A1, Wyboston
Same site area as 951 but now proposed by Prologis (agent Lichfields)
See attachments for two technical reports submitted in support of revised proposal for employment use.
1. Technical representations concerning Employment land
2. Site specific representations

Object

Representation ID: 9778

Received: 22/07/2022

Respondent: Mr Rupert Gates

Agent: Taylor & Co Land & Property Consultants

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

The broad approach to the development strategy in Local Plan 2040 retains the initial focus for growth in the urban area, including suitable, previously developed ‘brownfield’ sites. The strategy then focuses on growth based around the rail network, taking advantage of the opportunity to enable people to live and travel sustainably. This includes two new settlements at Kempston Hardwick, and at Little Barford. Other development sites are allocated south of Bedford, where new sustainable connections to existing or planned rail stations at Kempston Hardwick and Wixams, and to nearby Bedford, can be achieved.
In relation to the rural areas, the Local Plan 2040 Spatial Strategy (at Policy DS2(S)) relies upon the completion of the strategic Key Service Centre and more limited Rural Service Centre residential development that was identified in Local Plan 2030 on sites which are allocated in neighbourhood plans (together with the completion of Local Plan 2030 Policy 27 Land north of School Lane, Roxton).
Policy DS3(S) outlines the amount and timing of housing growth, with over 62% of growth profiled in the period from 2030. There is a small error in the calculations and, as such, the total dwellings for the period 2025/2026 to 2029/2030 should read 5,250 instead of 4,850. Correction of the error does not, however, alter the concern at the late profiling of growth due to dependency on the delivery of infrastructure. Whilst this dependency must be recognised, it is also relevant that other sites (that are not proposed for allocation) have much more immediate development potential (improving the five-year land supply position).
Policy DS5(S) outlines the distribution of growth by location, and takes into account existing commitments. This factors in the growth envisaged by adopted neighbourhood plans in rural areas, and it recognises that some Parish Councils may choose to allocate further sites for development in their neighbourhood plans to meet particular local needs.

Comment

Representation ID: 9796

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Site 1334
write to provide a response to the above consultation on behalf of our client, BDW Trading Limited. This
group includes Barratt Developments and hence I shall refer to this name going forward.
Background
We provided a response in September 2021 to the Local Plan 2040 Draft Plan consultation. This comprised
a letter from Savills dated 3 September 2021 which we have enclosed.
In December 2021, we provided an updated response to the call for sites which comprised the sites form and
a vision document. We have also enclosed a copy of these documents.
Overview
The proposals for land at Box End, West of Bedford seek to deliver an exemplar sustainable urban extension
of some 1,150 homes that meet or even exceed policy requirements in relation to issues such as bio-diversity
net gain, renewable energy etc. Critically, the homes will contribute towards much needed market and
affordable housing requirements in the core of the Oxford-Cambridge Arc, whilst at the same time delivering
critical social infrastructure such as a new primary school, local centre and extensive informal and formal
green infrastructure. Detail on the proposals is provided in the enclosed vision document which includes
detailed master planning proposals. This should leave no doubt about the intent to deliver an outstanding
living and recreational environment.
Land at Box End, West of Bedford is an accessible and sustainable location for residential-led, mixed-use
development and should be identified as such in the emerging Local Plan for Bedford Borough. This site is
located within the Kempston Rural Ward and the Kempston Rural Parish and is identified within the Call for
Sites under Site ID 1334.
Land West of Box End Road, Kempston (as it is named) is identified under reference: 1334, in the Call for
Sites. The housing quantum identified at that point in time is shown as 2,082 dwellings.
The call for sites assessment identified positive, neutral and negative potential aspects of development at this
site. The potential negative points were not all site specific but nonetheless our responses to the potential
negative points are listed below:
• Site is not within or adjoining the urban area or a defined settlement policy area, or within the built
form of a small settlement. There is insufficient capacity within the urban area to provide for the
minimum requirements under local housing need and hence greenfield land will be required. This
site is well related to the urban area of Bedford and Kempston.
Protected species on the site. There are no national, regional or local ecology designations and
further ecology work can be undertaken to ensure species are fully surveyed and protected.
• Potential harm to heritage assets. The Historic Environment Desk-Based Assessment, prepared by
Orion Heritage Limited demonstrates this is not the case.
• Site is separated from a defined settlement policy area or the built form of a small settlement. The
same response is relevant here to the first bullet point above.
• Site is not previously developed land. There is insufficient previously developed land in Bedford
Borough and hence to provide for the minimum requirements under local housing need and hence
greenfield land will be required.
• The site includes best and most versatile agricultural land i.e. grades, 1, 2 or 3a. This is relevant for
the wider area of the Borough and is not specific to this site which is considered to only include small
parts of 2 and 3a and is not all arable land.
We consider these few potential negative aspects and this location performs well in sustainability terms.
The assessment shows there are no showstoppers to development at Box End and Barratt Developments
have an enviable track-record of delivering new sustainable development in Bedfordshire including at the
Wixams.
There are positive aspects of the assessment including that there are no access constraints, no highway or
junction capacity issues and no concerns over environmental matters such as flood risk, air quality, etc.
The Phase 1 ecological walkover of the Site confirmed that the habitats within and around the Site do not
pose an ‘in principle’ constraint to residential development. Any development of the Site has the potential to
increase not only the grassland diversity, but the habitat diversity overall.
As well as biodiversity improvements, the Site presents the opportunity to reinforce and enhance the green
infrastructure network and corridors to provide east – west connectivity and movement. The Site is more than
capable of delivering a 10% net gain in biodiversity and meeting the requirements of 30% new woodland
planting to accord with the Forest of Marston Vale policies and SPD. A major piece of structural landscape
along the B560 would include significant woodland planting to secure appropriate separation between
existing communities and the new residential areas.
An appraisal of the existing baseline transport conditions demonstrates the Site has good connections to the
local and strategic highway network. Box End has the opportunity to directly connect into, and enhance, the
existing levels of walking, cycling and public transport infrastructure provision. The creation of a sustainable,
mixed-use community at Box End will maximise internalised based trips, whilst active travel will be promoted
through several ‘corridors’ running alongside key transport routes.
For the purpose of consideration under the National Planning Policy Framework, this site is within the
definition of ‘developable’ being a site in a suitable location for housing development with a reasonable
prospect that the site will be available and could be viably developed at the point envisaged for example
2025 onwards.
We can confirm that the site is a suitable location for housing development and that the landowners working
in partnership with Barratt Developments intend to make the land available for housing development, subject
to progress through planning and the site can be viably developed, commencing within the proceeding 5
years. Overall, the site is capable of being fully delivered within the proposed plan period.
BDW Trading Limited are in a unique position to have sales outlets from both Barratt and David Wilson
brands. This allows for accelerated delivery rates. BDW Trading Limited have an unrivalled track record in
delivering accelerated rates of home building in the housing market area as demonstrated in the table
overleaf.
SEE ATTACHMENT
Conclusion
Land at Box End, West of Bedford is an accessible and sustainable location for residential-led, mixed-use
development and should be identified as such in the emerging Local Plan for Bedford Borough. We
acknowledge this would require a modification to the current consultation version of the Local Plan.

Comment

Representation ID: 9904

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

6. Land west of Hall End Road, Wootton (Site ID 371)
6.1 We set out below an overview of the site HSL are promoting for residential development in Wootton for up to 81 homes, however a reduced scale of development could be considered if necessary.

Site Location and Description
6.2 The site is generally rectangular shape, on the edge of the western built-up area of Wootton, which lies south west of Bedford. The site, as identified by the red line boundary, covers approximately 6.5 hectares (ha) or 16 acres.
SEE ATTACHMENT FOR SITE PLAN

6.3 The northern edge of the site is defined by Hall End Road (also National Cycle Route 51) and the John Bunyan Trail. There is a field access gate to the northeast corner of the site. From this direction, the settlement of Wootton has recently been expanded towards the site with the construction of 58 dwellings (Ref: 14/02939/MAF) (Allocation AD2) and is a prominent feature. An allocation for a school extension is also located north east of the site on the opposite side of Hall End Road and is yet to be implemented and extends the settlement edge outwards towards the site.
6.4 The eastern boundary runs alongside an unnamed road that provides access to Wootton Upper School and commercial/ farm premises. The southern boundary is contiguous with Wootton Wood, an area of ancient and semi-natural woodland. The western boundary is shared with an adjacent field, laid to pasture. These boundaries are all formed from native hedgerow with a combination of post and rail or post and wire fencing within.

Sustainable and Suitable Location

6.5 The village centre of Wootton is located approximately 900 metres to the east of the site. The village benefits from many amenities including local convenience stores, pubs and restaurants, several churches, a petrol station, pharmacy, public library and football club. The wider parts of the village contain community services such as the village hall, memorial hall, play areas, skate park and tennis courts.
6.6 In terms of transport links, bus services serve Wootton and can be accessed within a short walk of the site. These services provide regular daily services to destinations such as Bedford, Milton Keynes and other local villages, providing residents with the opportunity to access a wide range of employment, shopping, leisure and cultural opportunities without having to rely upon the private car. The site location therefore would accord with NPPF §110.
6.7 The Environment Agency Flood Maps show the site lies entirely within Flood Zone 1 indicating it has a low probability of flooding and is suitable for residential uses.
6.8 Wootton has a historic character, with buildings and monuments dating from as early as the 14th Century. Wootton Church End Conservation Area is located approximately 250 metres to the east of the appraisal site and encompasses the Grade I listed Church of St. Mary and several other listed buildings. These heritage assets are separated from the site by Wootton Upper School and so development of the site would not have a negative impact upon their setting. The westernmost part of the site is within an Archaeological Interest Site. The LPA also agreed in the committee report that there is no heritage issue.

The Proposed Development
6.9 This proposal submitted to the LPA sought outline planning permission for the construction of up to 81 dwellings with access. The final layout, scale, landscaping and appearance would be the subject of a reserved matters application. The proposed illustrative site layout and Design and Access Statement submitted with the application shows how the dwellings could be comfortably accommodated on the site along with open space and the conserved and managed meadow.
These are enclosed as Appendix EP1.
6.10 All of the proposed dwellings within the site would be served by a single access road which would be taken from Hall End Road. The main internal access road is shown and the precise details would form part of the reserved matters application. Pedestrian and cycle connectivity can be explored at the reserved matters stage.
6.11 The TA states that the proposed site is situated approximately 950m west of Wootton village centre, and coupled with the site’s proximity to frequently serviced bus stops, cycle routes and viability to access the nearest rail station, accessibility from the site is considered to be of a good standard with opportunities to promote sustainable travel from the site. A Travel Plan was also submitted with the application to help promote more sustainable choices of travel.
6.12 We note the highways comments in the HELAA which state:
“The site is a Greenfield site and located in the village of Wootton approximately 6 miles south-west of Bedford town centre. The sites proposed access is along Hall End Road and is reportedly considered acceptable by BBC highways through application 19/00894/MAO. There is moderate traffic congestion along Hall End Road and the development could worsen this. The nearest bus stop is located 550m away on Cause End Road. Acceptable footway is located on the opposite side of Hall End Road and it is also considered a bicycle friendly route. Provide crossing to the footway on the opposite side of Hall End Road. A Transport Assessment would be required to assess the impact of this scale of development on the local highway network”.
6.13 As we examine in the next section, whilst highways was a reason for refusal at the application stage, contrary to the advice of the highway authority, the Inspector found no highway issue.
6.14 With regard to the Site assessment conclusions, the HELAA states:
“The site has been excluded from further assessment at Stage 1 because its location is not in accordance with the development strategy.”
6.15 We have addressed this matter under Policy DS5(S).
6.16 I note that some local residents questioned the need for more housing in the village and suggested that Wootton has ‘reached the limit’. However, the housing figure is based on the Housing Needs Survey (2017) and NPPF section 5 confirms that it is the Government’s objective to significantly boost the supply of homes. Paragraph 11 of the NPPF confirms that a sustainable pattern of development should be promoted. I consider that the wide range of community facilities and services that are available in Wootton contribute significantly to its credentials as a sustainable location for development.

The Application and Appeal
6.17 Following their consideration of the proposal, the professional officers of the Council concluded that planning permission should be granted and recommended this to the planning committee on 28th October 2019. The application was deferred for a site visit and it was considered again on the 25th November. The members of the Planning Committee voted to refuse the application solely on highway grounds contrary to the advice of the planning and highway officers.
6.18 The committee report sets out the detailed 22 planning considerations that were examined and the planning officer was informed by statutory and non-statutory consultees and other consultation letters during the determination period with the conclusion that permission should be granted.
6.19 An appeal was submitted and determined. However, following a High Court challenge the Inspector’s decision on the appeal dated 15 September 2020 was quashed. The proposal has the following benefits:
• the delivery of open market housing to assist in boosting the supply of housing in Bedford and can meet the a locally-arising need identified in the evidence base for the WNP as well as borough housing needs;
• delivery of a medium sized site by HSL who have a proven track record of delivery which would accord with the clear objective of the Government in paragraph 69 of
the Framework.
• the development accords with the spatial strategy as expressed in Policy 3S of the Local Plan which identifies Wootton as a Key Service Centre which can accommodate strategic residential development in a sustainable location.
• the proposed development helps to meet the objectives set out in the Bedford Green Infrastructure Plan (2009) and the provision of open space to meet the needs of existing and proposed residents and maintain a Green Corridor as required by saved policy AD24.
• residential development at the site through the proposed scheme will result in an improvement to the biodiversity value of the site and the net gain benefits to be achieved and secured by the scheme outweigh the estimated loss of c. 3.1 hectares of the neutral grassland at the CWS to achieve compliance with the paragraph 180(c) of the Framework.
• the delivery of 30% affordable housing accords with Policy CP8 and would assist in addressing the very significant and persistent shortfall in affordable housing delivery. There is a significant shortfall of affordable homes since 2003 and there is a significant need going forward. There is also an identified need for 24 affordable homes in Wootton as set out in the Housing Needs Survey.
• highway works that will improve highway safety; and;
• a range of social and economic benefits and increase spending for local services and facilities.
6.20 In the Site Assessment Pro-Formas June 2021 the subject site is Site ID 371. However, the assessment does not take account of the Officers Report to committee for the application and HSL sent an email to the LPA on 2nd August 2021 setting out our comments which were noted in an email dated 11th August 2021.
6.21 Our position is that the site can be delivered in full in the first five years of the plan period. This is because the land is controlled by HSL, an experienced land promotion company complete with its own housebuilding division. The site is controlled by a willing landowner, and there are no legal or ownership issues that would prevent development. The Council can proceed in the confidence that the site is deliverable, is sustainable overall as confirmed by the application officer’s report and should be allocated on that basis.

Comment

Representation ID: 9905

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

7. Land south of Bromham Road, Biddenham (Site ID 7432)
7.1 The site comprises a field located south of Bromham Road and north of the A6. It is a well contained triangular site with roads and development to the north and an extant consent for development to the south. The western boundary adjoins an existing field.
7.2 Enclosed as Appendix EP2 is a Vision and Delivery Statement. This shows that:
• It is an infill site lying with the urban area boundary to the north and south;
• The site extends to 1.81 hectares. The site is currently undeveloped and is considered suitable for the delivery of around 40 dwellings.
• HSL have undertaken initial survey work and due diligence and have fully considering any constraints and opportunities presented by the site as a whole. An overview of the key technical considerations to-date is also provided, which helps to demonstrate that the site is Available, Suitable, Achievable and can therefore be considered Deliverable;
• Given the site’s context, the site’s attributes and sustainable location make it an ideal logical location for some housing growth on an SME site which the NPPF considers is important. There is an opportunity to provide a sustainable development that meets borough-wide and local housing needs and supports the local economy
7.3 As set out under Policy DS5(S) sites such as this should have been allocated. We now assess how the site was assessed and discounted.
7.4 Page 105 of the SA states:
“The Council has decided that sites adjoining the edge of the urban area in most instances should not be part of the local plan strategy because, in many locations, the gap between the edge of the town and villages surrounding it is very narrow and the strategic expansion of the urban area in recent years has already reduced that separation. The Council’s strategy is not to infill those gaps but to support only two sites adjacent to the urban area, where there are clear benefits associated with delivering the Council’s strategic green infrastructure priorities (Bedford and Milton Keynes Waterway Park and Bedford River Valley Park, including the watersports lake)”
7.5 The omission site is reference 7432. The SA states:
“The location is not consistent with the Council’s preferred strategy. In addition the site is already subject to a development plan allocation (H6) which intended the land to be kept free from development”
7.6 The Site Assessment conclusion on page 878 states:
“The site is outside of the urban area. The location is not consistent with the Council’s preferred strategy. In addition, this site falls within the development area of Policy H6 of the 2002 Local Plan policy for Biddenham Loop which intended the land to be kept free from development.”
7.7 Given how the site has been assessed it is necessary to set out the planning history since the site was identified for development in 1994. This demonstrates that given the consents to the north and south that this site is now suitable as the reasons why it was not shown for development in the revised 2002 Biddenham Loop designation is no longer applicable. Therefore, the constraint to development no longer applies and importantly with regard to page 105 of the SA there would be no reduction in the gap between Biddenham, and Bromham. The extract from the Vision and Delivery Statement encapsulates this in one image.
SEE ATTACHMENT FOR PLAN
7.8 We now assess why we come to that conclusion.

Planning History and Context
7.9 On the Interactive Policies Map for the current local plan, the site is shown under Policy H6 of the 2002 Local Plan and states “Site Name: Biddenham Loop Development Brief - Policy Number: H6”. The inclusion of the site in H6 is used as a reason to discount the site but given that H6 is to be deleted (Page 123 of the Plan), then the site needs to be assessed on the current position.
SEE ATTACHMENT FOR PLAN

7.10 In the extract below, which is from the Biddenham Loop Development Brief in 1994, which we have taken from the 2002 Local Plan, the subject site is shown hatched as residential.
SEE ATTACHMENT FOR PLAN

7.11 The fact that it was identified for residential development demonstrates it suitability as far back as 1994. However, in the Revised Biddenham Loop Development Brief dated 2002 the subject site was shown as part of a wider River Protection Area.
SEE ATTACHMENT FOR PLAN

7.12 Paragraphs 4.12 to 4.14 of the Development Brief then explains the purpose of that designation as follows:
SEE ATTACHMENT FOR ECOLOGY AND LANDSCAPE PARAGRAPH

7.13 In the intervening period, the site no longer has any such ecology or landscape designation on the policies map. In addition, as can be seen from the extract of the Policies Map, with the allocations to the north and south in the 2030 Local Plan and the Upper Great Ouse Rover Valley, then there has been a material change and the site is white land and has no constraint to development.
SEE ATTACHMENT FOR PLAN

7.14 The omission site also lies between Biddenham and Bromham, however the arrows on the policies map for AD42 do not include this site is within the gap. With the development and allocations to the north and south that can only be correct.
7.15 The developer for Policy 18 applied for 249 dwellings which extended the development area shown in the Plan significantly westwards and was won at appeal where a key issue was the gap between Bromham (AD42) and the development of urban open space (AD43).
7.16 Following the refusal of the 249 dwellings scheme the developer submitted an application for 160 dwellings (18/03100/MAO). The committee report states:
“2.17 It was on this basis that the previous application was partly refused: that the proposal for up to 249 dwellings did not adequately respond to ADLP Policies AD42 and AD43. The current application however constrains the extent to which the proposed development would extend westwards and northwards such that the important open visual attributes of the Biddenham – Bromham Gap would not be significantly compromised. The current proposal which is set further off the northern boundary with the A4280 than the previous application proposal and allows a much greater area of existing farmland to be retained west of the site, along with the proposed mitigation planting, would not significantly alter the sense of ‘visual relief’ and openness experienced, and thus the perception of the ‘Gap’, beyond the Deep Spinney roundabout upon leaving Biddenham / Bedford. By constraining the proposed development area to an area comparable to that shown in Figure 6 accompanying Policy 19 in the ELP (accepting that limited weight should be given to the ELP at this current time), the proposal as it stands would not inappropriately intrude into the ‘Gap’ and alter the perception and sense of arrival when approaching Biddenham and Bedford from the west and / or alter the perception of where the urban edge starts. Both physically and visually the existing ‘Gap’ between Biddenham and Bromham would not be unreasonably compressed, a criticism of the previous scheme.”
7.17 The refused 249 scheme referred to in the above quote was then allowed on appeal (Ref 3227767) in October 2019. Policies AD42 and AD43 were assessed in that decision. The Inspector concluded that “given the presence of the Western Bypass and open space between the Local Gap and the appeal site, along with the additional open space to be retained within the appeal site, this is not a case where the proposed development would adjoin the local gap. Consequently, there is no conflict with policy AD42”. He then states:
“22. Therefore, even taking account of the 160 dwelling scheme as a baseline (to which I have given significant weight) the appeal proposal would compromise the purpose of the Gap contrary to the aims of policy AD43 of the ADLP. Taking account of all my reasoning above, I consider that the level of resulting harm would be moderate.”
7.18 The Inspector states that “whilst the benefits of the scheme are considerable, they would not, under a normally weighted balance, outweigh the need to retain the urban open space and gaps as undeveloped”. However, as paragraph 11(d) was engaged the appeal was allowed (see below).
SEE ATTACHMENT FOR PLAN

7.19 For the outline consent (19/01394/MAO) for Policy 23 to the north of the subject site, the officer report states:
“2.19 The local gap identified between Bromham and the
Bedford urban boundary at Biddenham varies between 200 metres at its closest and 1 km. At the position where the site is located the gap between the two settlements is approximately 570 metres wide. Whilst the intervening open land contains some frontage development on Bromham Road, there is no development at depth, except for a single dwelling which is set back and mainly screened from outside of the site. The application site is an undeveloped grassed area, containing no buildings (except 112 Bromham Road), which contributes to the openness of the area and its importance as a visual break between the settlements of Bromham and Biddenham.”
2.20 The previous planning application on this site was refused in principle (reason 1) and due to the character of the development to the rear (reason 2 and 3) and the impact the development would have on the Local Gap. Since that decision the allocation of the land within the emerging local plan 2030 under Policy 23 for housing has been a significant material change in circumstance. This allocation accepts the principle of development at depth on the site and the impact this may have on the landscape and character of the area.
2.21 Given that the emerging policy 23 accepts the principle of housing on the site the general impact of the development on the gap will be a matter for the details of the reserved matters application. At this stage only the access is being considered with all other details being the subject of the further reserved matters applications.”
7.20 The site was approved. Therefore, the planning history demonstrates the fact that the western boundary of the site is in line with the proposed developable area for Phase 2 of the Gold Lane site for the pending application 21/03302, and with the existing and consented (Policy 23) development to the north.
7.21 With respect to the gap between Bromham and Biddenham these consents are a material consideration for the omission site (south of Bromham Road) as it would be a logical infill with no harm. The approved developable area for Policy 18 is in line with its western boundary of the omission site. Therefore, the evidence base has wrongly concluded that the site should be kept free from development. To the contrary it is a most logical site for allocation and early delivery. Conformity with SA and Policy DS5(S) 7.22 In the assessment in the HELAA the site is scored very highly and should have been given further serious consideration in the choice of allocations, particularly as the SA found growth adjoining the urban area performed almost as well as growth within the urban area, was better than new settlement growth, and was better in relation to economic growth. It was also noted that the Council recognises development in the urban area will be more challenging compared with adjacent to the urban area.
7.23 In terms of the Council’s preference for only two sites adjacent to the urban area (based on their benefits associated with the strategic green infrastructure priorities) there is no clear reason why Omission Site 7432 would not deliver any green infrastructure benefits. Indeed, the HELAA assessment recognises that “the site is within or adjoining the green infrastructure opportunity network and is able to enhance the network”.
Conclusion
7.24 To conclude, the site is a logical well contained site that was identified for development as far back as 1994. The gap between Bromham and Biddenham would not be reduced by the allocation of this site. The land south of the A6 (Policy 18) now has consent for 249 dwellings and with the site to the north (Policy 23) also consented, then the development of the subject site will not bring Biddenham any closer to Bromham. With the emerging housing requirement, this site should be allocated.
7.25 This concludes our representations.

Comment

Representation ID: 9934

Received: 29/07/2022

Respondent: Rainier Developments Limited

Agent: Marrons Planning

760 Land South of Keeley Lane, Wootton

1. This is a deliverable site in a sustainable and accessible location, with potential for a further 20-30 homes which complements the existing Wootton Neighbourhood Plan (WNP) (made March 2022) allocation on part of the site – W6 – Land on the south side of Keeley Lane, allocated for 20 dwellings (a planning application for this allocation was submitted in May 2022 and awaits determination – ref. 22/01035/MAO). This area is already recognised as a sustainable location for development given its allocation in the made WNP, with the extension proposed simply helping to meet future needs at Wootton over the new local plan period to 2040.
2. The site’s sustainability and accessibility credentials are identified in the Council’s SA of the site, summarised at Appendix Ei of these representations. The site is in close proximity to a food store, primary school and major employment – all of which scores positively in the Council’s assessment.
3. The site is close to existing bus services at Keeley Corner, providing frequent services to the centre of Bedford and Bedford train station – just 20 minutes journey time via Services 53 and 41 (Stagecoach East).
4. The SA demonstrates that access can be achieved without constraints. With respect to the ‘uncertain’ impacts on highway capacity identified in the SA, this is clearly a scale of development where impacts will be limited and no capacity issues are identified at nearby junctions (refer to the Transport Technical Note enclosed at Appendix Eii). Even if issues were encountered the modest scale of development on this non-strategic site would be capable of localised mitigation through the S106/S278 process as required.
5. In terms of highway capacity, the Council’s SA shows that strategic-scale developments including HOU16 (Land East of Wixhams), HOU14 (Kempston Hardwick New Settlement) and HOU19 (Little Barford New Settlement) will have a negative impact on highway and junction capacity in any event with highway access also identified as constraints by the Highway Authority. Site 760 performs better in access and highway terms than strategic growth allocations preferred by the Council, and is not dependant on SRN improvements or EWR.
In terms of ecology, the Ecology Topic Paper at Appendix Eiii (EDP, July 2022) demonstrates the potential presence of breeding birds, bats, badgers and reptiles, with an off-site population of GCN following surveys undertaken between 2019 and 2022. However, the assessment concludes that “none of these species would provide an in-principle constraint to development. Any potential impacts upon these species can be mitigated for within the generous amount of open space being provided within the proposals for the Site.” In any event, the enclosed Biodiversity Net Gain calculation demonstrates how a net gain of 12.3% could be achieved. This resolves the SA’s
‘uncertain’ impacts under objectives 2b (protected species) and 2c (achieving a net gain). In the Council’s SA the site clearly performs better than the preferred strategic site allocations where negative impacts are identified in the SA – for sites HOU11, HOU13, HOU15 and HOU16 for example (refer Appendix Ei).
7. With respect to heritage it is important to note that the SA shows that all of the Council’s favoured strategic allocations (HOU11, HOU13, HOU14, HOU15, HOU16 & HOU19) score negative against this SA objective (4a) as demonstrated in Appendix Ei. Nevertheless, the conclusions of the Council’s heritage assessment for site 760 have been considered and are addressed in the topic paper enclosed at Appendix Eiv (EDP, July 2022). The assessment demonstrates that there would be harm to the significance of 35 Keeley Lane (a Grade II Listed Building c.50m to the west) and that the level of harm to 18 and 20 Keeley Lane and Pear Tree Cottage (Grade II) is minimal and did not prevent allocation of the northern part of the site in the WNP in any event. No other designated assets will be affected by development on the site.
8. With respect for the potential impacts on and loss of a small proportion of moderately preserved ridge and furrow (where the Council’s assessment identifies a level of
‘substantial harm’) the enclosed assessment explains that this represents “no more than the eroded corner of a much larger 15ha block of better-preserved ridge and furrow, in a parish that has been identified more generally as having a “high level survival of ‘good’ condition ridge and furrow” (Albion Archaeology, 2016). Therefore, the level of potential harm is low - affecting just 3.5% of the block of ridge and furrow mapped in the HER -and the earthworks within the Site are assessed as being of low or local significance.”
9. A draft masterplan is enclosed at Appendix Ev to illustrate how a well-planned community can be realised, informed by the above technical work. Rainier Developments is keen to work with the Council, Members, local community and key stakeholders to realise the opportunities and benefits associated with this deliverable site.

Comment

Representation ID: 9938

Received: 28/07/2022

Respondent: Trakbak Racing Limited

Agent: WSP

Please see supporting covering letter which sets out amendments required in order for the plan to be made sound.

This cover letter sets out that Trakbak Racing LTD agree with the council’s assessment that the following six sites, 1002, 529, 531, 527, 519 and 532, are not suitable for a housing allocation. Trakbak Racing LTD object to the allocation of these six sites because their allocation would be contrary to paragraph 35 of the NPPF which explains that in order for local plans to be found sound, they must be in accordance with policies of the NPPF.

These representations also explain that the ‘Spatial strategy and Site allocations’ chapter of the emerging local plan be amended, with Santa Pod Raceway (SPR) allocated under a specific policy allocation which reflects the primacy of the venue and looks to support its future growth. Further to this, to protect SPR from the effects of inappropriate housing development proposals on its business, it is explained that an exclusion buffer zone for residential development around SPR should be outlined in policy. This would represent a positive response to the issue of housing around SPR and would ensure that paragraph 187 (‘agent of change’) of the NPPF is complied with, and therefore ensure the soundness of the emerging Bedford Local Plan 2040.

Comment

Representation ID: 9956

Received: 25/07/2022

Respondent: Barton Willmore

In summary, whilst support is provided for the overall strategy of directing growth to accessible locations, we consider that in order to be considered ‘sound’, the housing trajectory for a greater proportion of housing should be directed to urban areas other than Bedford, such as our Site at Rushden Road. The North Northamptonshire Joint Core Strategy 2011-31 (adopted July 2016) recognises Rushden as a Growth Town (the highest tier of settlements) and defines its ‘spatial role’ as “to provide the focus for major co-ordinated regeneration and growth in employment, housing, retail and higher order facilities serving one or more districts”. Furthermore, the East Northamptonshire Local Plan Part 2 identifies Rushden as a growth town, which will provide the majority of new housing and employment development during the plan period, through a new sustainable urban extension. This is considered to demonstrate the suitability of Rushden as a location for new development.
Several additional changes are proposed to the BBLP2040, based on the Local Plan tests of soundness (NPPF, Paragraph 35) and we respectfully request that these are considered going forwards.

Object

Representation ID: 9981

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Details of Site Submissions
In pursuing a stepped trajectory, it is clear that delivery of housing will be stifled in the short term. This approach is not considered to be appropriate as has been discussed earlier.
Instead, it is essential to allocate further housing sites to improve housing delivery in the short-term negating the need to use a stepped trajectory. The following section provides an overview of the sites promoted by Gladman in the Borough that have not been identified for residential allocation.
An ArcGIS StoryMap link can be found in Appendix 1, giving further details of sites listed below. This is an interactive software that the Council can use to explore the information provided and use analysis tools. These sites include:
• Land east of Hookhams Lane, Salph End, Renhold (602)
• Land on the north west of Hall End Road, Wootton (603)
• Land off Bedford Road, Willington (566)
All of the above sites are sustainable and deliverable in their own right. Significant technical work has been undertaken on all sites to demonstrate that they can deliver new homes effectively across the plan period. Moreover, several of the sites can be brought forward for development immediately, such that they can make a significant contribution to the Council’s five-year housing land supply.
Site Submission Conclusions
We encourage the Council to identify additional sites to ensure the Council’s housing requirements are met and we respectfully request that these sites are assessed fully in the Local Plan process which will identify that they are all appropriate for allocation.
Appendix 1 – Gladman Site Submission
Gladman sites can be found using the following ArcGIS StoryMap link: https://storymaps.arcgis.com/stories/dea77c18dae546528591bce47896c10f

Comment

Representation ID: 10072

Received: 28/07/2022

Respondent: Richborough Estates

Agent: Fisher German LLP

The Housing and Employment Land Availability Assessment and Site Assessment Topic Paper (May 2022) includes the Council’s assessments of the sites submitted for consideration throughout this Local Plan process.
3.2 A copy of the assessment for Land at to the east of Newton Lane, Turvey is provided below, with our suggested amended assessment where relevant which is based on technical assessment that have been carried out.
(see table in attachment)
With the above in mind, it is clear that Land east of Newton Lane, Turvey is better suited to come forward for residential development than assessed by the Council. Copies of the available technical information have been provided to the Council, however we can provide a full suite of documents should they aid the understanding of the site for the Inspector.

Comment

Representation ID: 10084

Received: 28/07/2022

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Reflecting on the inability of the council’s current proposed trajectory to deliver sufficient new homes to meet its LHN prior to 2030 (our Enclosure 2) and considering the clear difficulties faced in the delivery of five of its key town centre sites beyond this point (our Enclosure 1) it appears critical that the submission version of the Local Plan 2040 seeks to include our client’s land between Hookhams Lane and Ravensden Road, Salph End for a residential development of up to 400 dwellings, land for a new primary school along with public open space and green infrastructure.

The location and extent of the site is shown below: (map)

Our client’s land has been promoted consistently towards both the adopted Local Plan 2030 and now towards the Local Plan 2040. This included two separate submissions towards the council’s Call for Sites comprising our client’s initial response in August 2020 and an addendum submission following the outcome of an appeal at the site in January 2021. Combined, these submissions have informed the council’s Call for Sites Assessment which concludes that our client’s land is devoid of any legal, environmental, or technical constraint. Specifically, the assessment included as part of the evidence base of the plan includes the following key conclusions:

• It is within acceptable walking distance of a full range of shops, services, facilities and amenities (most within 0-10 minutes’ walk);
• It adjoins the urban area and/or an existing settlement policy area so is not detached from existing built form;
• Its development would not have a harmful effect on the landscape (a conclusion of neutral);
• It is not at risk of flooding, nor are there any on-site environmental or physical constraints which would preclude its delivery; and
• There are no local highways or junction capacity issues that would require the delivery of significant off-site infrastructure.

Indeed, it is clarified by the site assessment that the previous concern that precluded it from allocation in the Local Plan 2030 – that is coalescence – has now been resolved to the satisfaction of the council. Indeed, it confirms that it has now only been omitted from the current Regulation 19 draft of the plan due to its conflict with the preferred development strategy. As is made clear by our Enclosures 1 and 2 the current development strategy is deeply flawed.

Once again, we are therefore pleased to confirm that the site is:

• Available: The site is being actively promoted by our clients, Manor Oak Homes, who wish to use this submission as an opportunity to once again state the availability of the land for allocation in the emerging Local Plan and indeed for immediate delivery;
• Suitable: The site is in an entirely suitable location for a residential-led development being immediately adjacent to the Bedford urban area and the Settlement Policy Area of Renhold/Salph End, this being evidenced by the Council’s decision to identify it as a possible allocation in an early iteration of the now adopted Local Plan 2030 and then as clarified by the conclusions of the appeal Inspector in December 2020; and
• Deliverable: The site is devoid of any constraints and capable of contributing towards the housing and infrastructure needs of Bedford Borough in the first 5-years of the plan period. In addition, the land is promoted by Manor Oak Homes, a company with a strong track record of securing implementable residential and mixed-use planning permissions that have in turn led to the delivery of a substantial number of large scale developments across the South East and Midlands.
In light of the above it is worth reminding the council of the remarkably candid remarks of the appeal Inspector who, despite dismissing the case on the grounds of prematurity, identified the land as an obvious and compelling development site that it is clear should come forward at the earliest opportunity. He stated at paragraph 12 of his decision:

“Nevertheless, the appeal site is not without its intrinsic merits in terms of the spatial strategy; it is adjacent to the defined Settlement Policy Area of Salph End; within walking distance of a local grocery store and post office, a public transport route and some other local facilities; and it would provide that settlement with education provision and open space facilities. Most of the site was included as an allocation in a consultation version of the Local Plan before its adoption. The eventual decision to exclude the site from the plan was judged by the Inspectors who examined the plan to be a reasonable one, although they note that the matter was clearly finely balanced. It is again included in options being considered in the current review of the Local Plan and so, it is not unreasonable for the appellant’s advocate to imply, as he does in his closing remarks, that it is a matter of when, not if, the site is to be developed.

It should be noted that our client’s land was considered as an almost identical form of development as the site subject of draft Policy HOU13 ‘Land at Gibraltar Corner’ during the preparation of the Local Plan 2030, that is as a sustainable extension to the urban area. It was subject of a draft allocation on the same basis as our client’s land and was similarly removed for the previous reason of harm to character (a matter now resolved in respect of our client’s land following the Section 78 appeal). Whilst the allocation of the land at Gibraltar Corner is once again justified based on its contribution to green infrastructure it is vital to note that our client’s own land would achieve the same, partially falling as it does in the ‘Bedford Northern Fringes Green Infrastructure Opportunity Zone’. In addition, our client’s site would secure the significant benefit of land for a new primary school, playing pitch provision and unlike the land at Gibraltar Corner would be first deliverable within the immediate 5-year period following the adoption of the Local Plan.

In respect of delivery and assuming a 2023 adoption we have modelled the development of our client’s land against the oft-cited Lichfields report ‘Start to Finish ’ which identifies that following the grant of planning permission the average annual build-out rate is 60 to 70 dwellings per year for sites of 100 to 1,000 dwellings. Based on the submission of a full planning application in 2023 we would expect work to start on site within 6 months of the plan’s adoption, so early to mid-2024. Using the upper end of the Lichfields range, and anticipating two developers on site, it is assumed that completions would take place at a rate of 70 per year. On this basis the development is capable of being delivered in full by 2029. These rates of delivery would ensure that the site is completed within the first 10 years of the plan period prior to 2030 when there is a critical demand for additional homes.

The expected annual delivery from the application scheme, factoring in the time until the grant of planning permission (PP), is set out in Table 3 below:

Table 3: Delivery Timescales of Site ID 822

20/21 21/22 22/23 23/24 24/25 25/26 26/27 27/28 28/29 30/31
- - - PP 50 70 70 70 70 70

Based on the lack of any legal, technical or environmental constraints to our client’s land allied with both the critical need for additional homes across the Borough and its ability to be delivered swiftly there is no logical or rational reason to omit the land as an allocation in the plan.

Failure to allocate our client’s land would contribute towards a strategy which fails to be positively prepared, justified or indeed effective whilst conflicting with the national policy requirement to significantly boost the delivery of new homes.

Comment

Representation ID: 10087

Received: 28/07/2022

Respondent: Trakbak Racing Limited

Agent: WSP

OBJECTIONS TO THE SIX SITES SUBMITTED IN THE CALL FOR SITES PROCESS
Trakbak Racing LTD, the operator of Santa Pod Raceway (SPR), objects to the allocation of the following six sites submitted as part of the local plan consultation:
• Up to 600 homes at Glebe Farm Solar Park, Podington (Site ID:529)
• 800+ dwellings at Land to the north west of Forty Foot Lane, Podington (Site ID: 532)
• Up to 700 dwellings at Odell Solar Park, Odell (Site ID: 531)
• 4,500 dwellings at Land adjacent to Colworth Science Park (Site ID: 1002)
• Land to the West of Vicarage Lane, Podington (Site ID: 527)
• Land to the south east of Wymington Road, Podington (Site ID: 519)
Trakbak Racing LTD agree with the councils assessment that the sites listed above are not suitable for a housing allocation. Their allocation would be contrary to paragraph 35 of the National Planning Policy Framework (NPPF) (2021) which explains that in order for local plans to be found sound, they must be in accordance with policies of the NPPF. The allocation of these six sites would render the local plan unsound because they are not in accordance with the following paragraphs of the NPPF:
• Paragraph 81: which explain that “Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development”.

Paragraph 174: which explains that: “Planning policies and decisions should contribute to and enhance the natural and local environment by… preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability” (underline added).
• Paragraph 185: which explains that “Planning policies and decisions should also ensure that new development is appropriate for its location…. In doing so they should: a) mitigate and reduce to a minimum potential adverse impacts resulting from noise from new development – and avoid noise giving rise to significant adverse impacts on health and the quality of life” (underlines added).
• Paragraph 187: which explains that “Planning policies and decisions should ensure that new development can be integrated effectively with existing businesses and community facilities (such as places of worship, pubs, music venues and sports clubs). Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed”.
Further to the above, paragraph 2 of the NPPF explains that planning permissions should be determined in accordance with the development plan. Owing to this, these six sites are not deliverable (and should not be allocated) because they conflict with the following extant policies in the Bedford Plan 2030. These policies are:
• Policy 28S (Place making): which explains that development will be expected to “have a positive relationship with the surrounding area, integrating well with and complementing the character of the area in which the development is located”.
• Policy 32 (The impact of development- disturbance and pollutions impacts): which explains that “development proposals should ensure that they minimise and take account of the effects of pollution and disturbance. Planning applications should give particular attention to….the suitability of the existing environment in relation to nuisance or pollution in the vicinity of the site”.
• Policy 47S (Pollution, disturbance and contaminated land): which explains that development proposals should: "Avoid noise giving rise to significant adverse impacts on health and quality of life or, where appropriate, mitigate and reduce its impact" and that development proposals should "be appropriate for their location, having regard to the existing noise”.
Explanation as to why these six site submissions conflict with the NPPF and adopted development plan is outlined below in this letter. This letter follows on (and should be read alongside) Trakbak Racing LTD previous representations to the Bedford Local Plan 2030 and the Bedford Local Plan 2040, these are listed below:
• Letter by WSP on behalf Trakbak Racing Ltd – Representations to the Bedford Local Plan 2040 (dated 02-09-2022)

Trakbak Racing LTD – Regulation 19 Representations to the Bedford Borough Local Plan 2030 (dated 28-3-18); and the following appendices in relation to this representation
o Appendix 1: Local Noise Profile Assessment undertaken by Santa Pod
o Appendix 2: Review of Noise Impact in relation to Santa Pod Raceway (27th March 2018)
• Trakbak Racing LTD Regulation 19 Representations to the Bedford Borough Local Plan 2030 (October 2018); and the following appendices in relation to this representation
o Appendix 1 of the above representations entitled “Report in the Examination into the Torbay Local Plan”
o Appendix 2 of the above representations which outlines a composite list of noise assessments undertaken by MAS Environmental
Many of these documents were previously submitted on behalf of Trakbak Racing LTD to the consultation period of the then emerging (now adopted) Bedford Local Plan 2030 in which a previous proposal for a new 'garden village' settlement at Colworth (nearby to SPD) was put forward as an emerging allocation. This emerging garden village allocation was subsequently removed prior to the adoption of the plan over issues around SPR noise. This garden village proposal has again been submitted (Site ID 1002) in the call for sites submission for this emerging local plan, with a further representation of support submitted at the last round of consultation (Regulation 18) in the form of a letter by the site promoters (Wrenbridge Land Ltd / Fiera in association with Unilever, herein referred to as ‘Wrenbridge / Fiera’) planning consultants Rapleys.
This letter outlines the unacceptably of this garden village proposal and of the other five housing proposals submitted in the call for sites process nearby to SPR. The three key reasons why these six housing proposals should not be allocated in the emerging local plan are because they would cause/create issues with:
• Noise issues;
• Unaccepted living environment; and
• Effect on the SPR business and the local economy.
These three key issues are explained further under the subheadings below.
Noise issues
As outlined in our previous representations to the Bedford Local Plan 2040 (dated 02-09-2022) submitted on behalf of Trakbak Racing Ltd, SPR is synonymous with high speed and noise; these two elements are at the very heart of what they do. SPR has consent to operate on 365 days of the year from 9.00am to 9.00pm. It holds in the order of 29 competitive meets a year and this level of mainstream drag racing activity is necessary for the business to remain financially viable and to provide a level of activity to support and maintain the interest of the fan base.
The potential development of a housing proposal in such close proximity to the racetrack would be a serious threat to SPR and its business operations. The power available to members of the public with modern legislation is formidable; this means that the opportunity for a single complainant or a group of complainants to curtail the business activities of a company like SPR is very real. Fortunately, due to SPR being present and active in running drag racing for over 50 years, the sites 1002, 529, 531, 527, 519 and 532 would not be in compliance with paragraph 187 of the NPPF because it relies on placing unreasonable restrictions on SPR and its operations in order to deliver any housing.
It is welcomed that Bedford Borough Council have recognised these noise issues in their assessment of this proposed new settlement as part of their evidence base for the emerging local plan (in the document entitled ‘New Settlements Assessment, April 2022’), and have explained that these issues remain unresolved. It is noted that Wrenbridge / Fiera most recent representation (dated 24/08/2021 and submitted by Rapleys), promoting the site at regulation 18 stage of the emerging local plan 2040, provides no further supporting technical information as to how these noise issues could be mitigated/resolved despite alternative noise mitigation solutions being sought from them by the council.
As MAS Environmental explain (at bullet point 4 of page 3 of their ‘Review of Noise Impact in relation to Santa Pod Raceway’, dated 27th March 2018) any mitigation required would be substantial and relate to significant limitations on the form of residential development as well as major infrastructure changes at SPR. Furthermore, there is no evidence or reasoned logic that such measures would be, even remotely, sufficient. Evidence indicates some of the more important elements of the noise impact cannot be readily mitigated, in relation to its impact upon much of the proposed development site.

It can therefore be satisfactorily concluded that no suitable noise solution/mitigation can be found and therefore this garden village proposal should not be brought forward for a housing allocation in the emerging plan (as recognised by the council).
Paragraph 35 of the NPPF requires that in order for local plans to be found sound they must be in accordance with policies of the NPPF. The local plan would therefore be unsound if these sites were to be brought forward for allocation in this local plan review, as it would not comply with paragraph 187 of the NPPF.
Unacceptable living environment
The proposed development locates residential dwellings (i.e. noise sensitive land use) within close proximity of a noisy site. This goes against basic principles for avoiding adverse noise impact.
In their assessment of the noise issues around site 1002, MAS Environmental explained (at paragraph 1.11 of their ‘Review of Noise Impact in relation to Santa Pod Raceway’, dated 27th March 2018) that the objective is to stop short periods of high noise which is precisely what happens at SPR. MAS Environmental then assess that (in paragraph 1.12 of the same report) conservative estimated noise levels at site reference 1002, based on levels previously measured in nearby community locations, exceed noise limits used at other raceways including within the Bedford district (42-47dB LAeq,T) by a significant margin, from around 10-30dB(A) depending on source type and meteorological conditions etc. The MAS report provides clear evidence that this is simply too large to be addressable by mitigation such as screening. As sites 529, 531, 519, 527 and 532 are also adjacent to SPR, similar noise survey results can be anticipated.
If site references 1002, 529, 531, 527, 519 and 532 were to be allocated for development in the local plan review, the nearest residential houses would be around 500m from the SPR start line. The sound generated by SPR this close to a family home would be intrusive and impossible to ignore. As MAS Environmental explain (at paragraph 1.26 of their ‘Review of Noise Impact in relation to Santa Pod Raceway’, dated 27th March 2018) this would fail to meet the aims of the NPSE 2, as described within the Planning Practice Guidance on noise, to mitigate and reduce adverse noise impacts to a minimum and to improve the health and quality of life through effective management of noise. It also fails to protect SPR or any future development of the site.
Government guidance places emphasis on improving health and quality of life but also not placing unreasonable restrictions on industry or commerce. Substantially higher noise levels occurring much more often are predicted at the proposed sites than currently exist in nearby communities. Thus, health and quality of life for those at newer housing in the area cannot be improved compared to existing communities.
Housing on this site would therefore be in conflict with policy 47S of the adopted local plan (Bedford 2030) which explains that development proposals should "Avoid noise giving rise to significant adverse impacts on health and quality of life or, where appropriate, mitigate and reduce its impact" and that development proposals should "be appropriate for their location, having regard to the existing noise". For the same reasons, it would also be in conflict with policies 28S and 32 of the adopted local plan and paragraphs 174 and 184 of the NPPF, owing to noise issues creating an unacceptable living environment.
Paragraph 35 of the NPPF requires that in order for local plans to be found sound they must be in accordance with policies of the NPPF. The local plan would therefore be unsound if this site were to be brought forward in this local plan review, as it would not comply with paragraphs 174 and 187 of the NPPF.
Effect on the SPR business and the local economy
Trakbak Racing Ltd (the freehold owner of the raceway and a 50% shareholder in SPR) has a new 30 year lease over the racetrack which started this year and a 25 year lease over additional land which is used mainly for car parking and camping. Since it took over the track, in 1996, it has invested £7M on the venture.
As explained under the subheading above, entitled ‘Noise issues’, if site references 1002, 529, 531, 527, 519 and 532 were to be allocated in the emerging Bedford Local Plan 2040 the future of SPR and its business operations would be under serious threat. In considering this, it is important to take into account the importance of SPR to the economy and culture of the district and (being the only drag racing track in the UK) to the culture of the UK as a whole.
SPR makes a significant financial contribution to the local economy by providing employment in a rural area. Excluding director’s salaries, the SPR wage bill for 2016 was £1,315,459. The vast majority of SPR employees live within 15 miles of the venue. As a business SPR spends £1,633,215.76 on goods and services in the locality. The company also pays an annual rates bill of £50,000. Santa Pod is able to operate at this level because of the type of events that are run at the venue.
In reference to the above, any housing on the sites 1002, 529, 531, 527, 519 and 532 would be contrary to paragraph 81 of the NPPF which explains that “planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity”.
Paragraph 35 of the NPPF requires that in order for local plans to be found sound they must be in accordance with policies of the NPPF. The local plan would therefore be unsound if these sites were to be brought forward in this local plan review, as it would not comply with paragraph 81 of the NPPF.

Object

Representation ID: 10161

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Introduction
On behalf of J.C Gill Development Ltd, I am pleased to formally submit representations to the Bedford Borough Local Plan 2040 Regulation 19 (Pre-submission) consultation together with the Response Form accompanying this letter.
We object to the spatial strategy set out in the draft Local Plan as matter of principle because it does not propose to allocate the most suitable site’s in the most suitable locations. The approach taken by the Council is flawed, not only because it fails to recognise the more sustainable locations for growth, but also because it overly relies upon the delivery of site’s that are in less sustainable locations and rely on the delivery of substantial infrastructure projects that are uncertain and likely to cause delay. The full details of the objections are presented in this representation.
In order to assist the Council in preparing a sound and credible plan we advocate those additional site’s are allocated in locations that are sustainable, meet the vision and objectives set out in the plan and present a significantly more deliverable and robust housing allocation.
The Proposed Allocation
Site Details
The site is located between no.34 and no.36 High Street, Riseley. It has not previously been promoted for inclusion in the Local Plan, however, following assessment of the draft document it is considered it could prove valuable in quickly delivering short term housing need. The site, approximately 0.65ha, is located in the southern area of Riseley, a Group 3 village. Access is available directly from High Street on the northern corner of the site. The satellite location plan of the site is shown in figure 1 below and the site identification plan is available in appendix 1.
[See attachment for Figure.]
The site comprises of an open field, lined by trees and hedgerows on three boundaries and post and rail fencing on the south eastern boundary. It adjoins existing residential development on its north eastern and south western edges and a Police Station and further residential development to the north west beyond High Street. Land to the south east, beyond post and rail fencing, comprises open countryside. This site slopes from the highest point on the south east down to the High Street.
The site is located within Flood Zone 1, with areas of Flood Zone 2 abutting the north western edge as a result of Riseley Brook. It is located outside of the settlement policy area, has been identified as a key view and forms part of the Riseley Conservation Area as outlined in the Local Plan 2030 Policy Map shown in figure 2.
[See attachment for Figure.]
Site Assessment
Optimis propose that the land between no.34 and no.36 High Street, Riseley be allocated for residential development. The site has not previously been considered as part of the Bedford Borough Local Plan but presents a logical development opportunity within an established, sustainable settlement.
Whilst the site is currently located outside the Settlement Policy Area, it presents a logical infill to the village well located to existing built form on three sides. Through the creation of a strong boundary on the south eastern edge the site could be contained, and any future development could easily be incorporated in to the existing pattern of development.
It is acknowledged that the site is currently allocated as an important view. Upon review of the site from High Street, the north western boundary comprises established trees and hedgerows providing comprehensive screening. This thereby limits views into the countryside significantly and potential impacts on the visibility of the landscape are not considered to be adverse. Nonetheless, further assessment of landscape impacts and consideration of these throughout the design of the scheme could be facilitated through the site’s allocation. It should also be noted that rural settlements such as Riseley have many sections where views extent into the countryside. This site is not of any great importance and its designation is not sufficient to prevent the much needed delivery of homes in sustainable locations such as this. Form this site, public footpaths extend into the wider landscape where long distance views are afforded.
It is also acknowledged that the site is located within the Riseley Conservation Area. The heavily landscaped north western boundary has the potential to provide significant screening, aiding in the mitigation of visual impacts on the Conservation Area. It is recognised that the site would still be likely to give rise to less than substantial harm on a designated heritage asset and sufficient public benefits should accompany any future scheme to outweigh this. The provision of housing on a site well related to an existing sustainable settlement in response to housing need alongside the delivery biodiversity net gain, associated contributions and further public benefits identified throughout the design process could reasonably overcome this.
Constraints identified in relation to this site are therefore not detrimental to its development and could be overcome throughout the design process to ensure the scheme is deliverable without resulting in adverse harm.
The suggested Policy wording is as follows:
[See attachment for Figure.]
The below indicative parameter plan has been prepared to demonstrate how the site could be developed, identifying landscaping and green space on the site’s northern and southern boundary and residential development enclosed in the centre of the site’s in line with existing residential development on High Street.
[See attachment for Figure.]
Conclusion
To conclude, it is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic site’s and new settlements. The potential of smaller sustainable settlements throughout the borough in meeting housing need has been overlooked in favour of this, having extensive implications on the timescales for housing delivery throughout the plan period.
Riseley presents a logical location for development, comprising one of the most sustainable settlements in the northern area of the borough that would benefit from policy support. Additional but proportionate development in this location could be delivered quickly and provide valuable economic, social and environmental benefits to an existing community. The site outlined above presents a logical option for delivering development of this nature and should be considered by the Council for allocation alongside other extensions to existing sustainable settlement in the borough to alleviate reliance on substantial strategic site’s throughout the plan period.
Although designated in the Local Plan as an open view from the village, we consider that the scheme can be developed to retain views from the wider countryside from the southern edge of the site through the positioning of a sensitive viewpoint.

Comment

Representation ID: 10180

Received: 29/07/2022

Respondent: Jeremy Clayson

Relating to HELLA site 1226
I am born bred and educated in North Bedfordshire before 3 years at college. After school I returned to carry out my chosen path in land agency and surveying. I worked in north Beds for 40 years before retiring in 2016 and becoming a consultant to pave the way for improved locality. I have lodged a number of representations previously, in connection with the new Borough plan progress. I have missed some previous deadlines for the borough Plan and some of the subsequent neighbourhood Plans and would ask to be kept informed of Borough Planning progress albeit now residing near Huntingdon. Bedford still my “home” for the usual requirements of dentist, opticians, garages.
Willington is a composite village and borders a matrix of road roadways/lanes to the south. It was formerly designated a Rural Service Centre in the early Call for sites programme.
The principal built up areas in the village are either side of Station Road which grows into Church Road and Chapel Lane Branches. It does have a school, garden Centre and Nursey and playing field. What is does not have and needs is a formal post office and MORE RESIDENTS to make use of its position and services. There was a site under consideration for some 35 units but this is totally insufficient for the needs of the village. The Parish is now considering sites in Sandy Road (542 up to 5 dwellings), in Bedford Road adj to 55 (up to 6 dwellings) adj to 77 Bedford Road (up to 7 units). This is totally unrealistic with the demand locally and the best solution would be to develop the area hatched and edged red on the attached plan. Areas would be from Gostwick Place existing and on Barford Road and would be divided as required periodically.

Comment

Representation ID: 10186

Received: 29/07/2022

Respondent: Jeremy Clayson

Relates to HELAA site 42
HARROLD NEIGHBOURHOOD PLAN

I am born bred and educated at Sharnbrook and Bedford before 3 years at college. I worked in north Beds for 40 years before retiring in 2016 and becoming a consultant to pave the way for improved planning in Sharnbrook and neighbouring villages. I have lodged a number of reps previously, particularly on the borough plan progress. I have missed previous deadlines for the borough Plan and some of the subsequent neighbourhood Plans and I would ask to be kept informed on my former homeland and my retired home is near Huntingdon but I am in Bedford a lot because it is still my “home” with dentist, opticians, garages, Waitrose and many other facilities.
Harrold is a composite village with good amenities and facilities. Due to the great demand for housing in these larger villages like Sharnbrook and Harrold there are several sites suitable for housing but one in particular is at little Odell, edged yellow on the plan herewith.

Object

Representation ID: 10209

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Site 530 Land south of Parkside, Milton Ernest
4.0 The Proposed Allocation
Settlement Assessment
4.1 Milton Ernest is a settlement and civil parish in Bedfordshire. It is approximately 8km north of Bedford town centre. The village is located on the east bank of the River Great Ouse and is well serviced with easy access to Bedford and Luton to the south and Rushden to the north. The A6 comprises a major road link for the area and runs directly through the settlement. Milton Ernest is therefore located on a key access route to and from Bedford and is well placed in this context.
4.2 There are a range of local facilities available in Milton Ernest. The village received a score of 58 within the Settlement Hierarchy Addendum (2022) provided in support of the emerging Local Plan. The Settlement Hierarchy classifies Milton Ernest as a Group 2 settlement, rural service centre. Bedford Borough Local Plan 2030 identifies rural service centres as centres that “provide a more localised convenience and service role to meet the day to day needs of residents and businesses in the rural areas”. Rural service centres have good or reasonably good road and public transport links to Bedford. Growth in these settlements is not opposed where it helps to support local services.
4.3 The Milton Ernest Neighbourhood Plan (2021) has identified a site at Rushden Road for the allocation of a maximum of 25 units. The Local Plan 2030 has provided evidence to support the allocation of up to 50 dwellings within the plan period to 2030. On this basis, it is reasonable to assume that Milton Ernest can accommodate at least a further 25 residential units throughout the next 10 years, based on the old methodology for calculating objectively assessed need. Further development beyond 2030, the expiry of the Neighbourhood Plan, is also needed to accommodate the needs of the emerging Local Plan 2040.
4.4 To conclude, Milton Ernest is well located in the context of surrounding rural and major settlements and comprises a sustainable location for additional residential development. This conclusion has previously been reached by the Council, leading to its promotion for additional development in the adopted Local Plan 2030, however, it is not considered that its potential has been fulfilled and no further development has been considered or proposed as part of the emerging plans beyond the period of 2030 or to account for the under provision in the Neighbourhood Plan.
4.5 The settlement can accommodate further growth and it is reasonable to consider that based on the need objectively assessed need for the borough that the settlement of Milton Ernest might accommodate at least a further 50-75 new dwellings, over and above the Neighbourhood Plan allocation. This is made up of the shortfall 25 dwellings in the Neighbourhood plan to 2030 and 50 for the period 2030 -2040. This doesn’t take account for the increase in need across the Borough, which could arguably double this number.
Site Details
4.6 The site is located south of Parkside in Milton Ernest, a Group 2 settlement within the Bedford Borough administrative area, and is approximately 4.2 ha in size. Vehicular access to the site is available from Parkside, a cul-de-sac to the north of the site. The location of the site is shown in figure 3 below and a Site Identification Plan is provided in Appendix 1.
[See attachment for plan]
4.7 The site is on an open field comprising scattered tree cover and bounded by trees on its southern and western boundaries. The existing settlement of Milton Ernest bounds the site with residential development on its northern and western boundary. To the south, the site is defined by the River Ouse. Milton Ernest Hall Care Home and Stable Block are situated to the south east of the site and comprise Grade I and Grade II buildings. An open field lies to the east. The site is therefore well contained. In terms of the topography of the site, it declines 5 metres from north to south and there is a clear drop from the edge of the site down to the floodplain several metres below.
4.8 The site sits outside the settlement policy area but has no policy designations that restrict its potential for development in the context of the Local Plan.
Site Assessment
4.9 Optimis proposes that this site is allocated for residential development. The site was submitted for Representations by Optimis responding to Bedford Borough Councils consultation on the Regulation 19 Local Plan: Plan for Submission in 2018 and remains a logical site for development in the context of the emerging Local Plan.
4.10 The site is capable of delivering between around 50 dwellings alongside accessible open space. Given the site’s location in the context of the settlement it has the potential to form a well-connected, logical extension to the settlement, with good access to existing services and facilities. Its location in the context of the surrounding settlement is shown below in figure 4.
[See attachment for plan]
4.11 The site abuts the Settlement Policy Area to the north and west. The main access point to the site is located within the Settlement Policy Area at Parkside and, therefore, provides a logical expansion in geographical terms. A revised settlement boundary would also be robust in physical terms due to the contained nature of the site.
4.12 The site was assessed as part of the Milton Ernest Neighbourhood Plan Site Assessment Report (Updated 2019). The site’s availability, capacity, access to surrounding services and facilities, limited impact on the countryside and the site’s well connected relationship with the existing settlement were all confirmed acceptable throughout its assessment. The Neighbourhood Plan Site Assessment Report concluded:
“The site is a good extension to the existing settlement as in keeping with the existing settlement pattern, however the presence of the Grade I Listed Building to the south of the site and associated Grade II Listed Buildings, as well as the Flood Zones means development to the south of the site is limited”.
4.13 The presence of Flood Zone and Listed buildings to the south of the site is acknowledged and a reduced level of residential development is suggested on this basis. Isolating development in the northern area of the site, adjacent to the settlement, and providing open space to the south provides a strong settlement edge and a green buffer zone to protect future development from Flood Zone and the setting of existing listed buildings to the south east. Therefore, whilst the site is subject to some constraints, it is considered that these can be overcome through sensitive design and management and this has been assessed by qualified experts in ecology, heritage, highways and drainage.
Proposed Development of up to 50 dwellings
4.14 The site has the potential to supply a range of residential development in response to the identified need and the client is willing to cooperate with Bedford Borough Council and the Parish Council to provide the type of housing scheme that is required in Milton Ernest.
4.15 The proposed development (in a sketch format at Figure 5 below) at the land south of Parkside of around 50 dwellings would be able to deliver a range of benefits for the local community, including:
• Upgrading cycle facilities in the area,
• Provision of cycle routes,
• Publicly accessible open space,
• Contribution and provision of community facilities,
• Provision of, or contribution towards, existing play facilities,
• Affordable housing,
• Provision of bungalows
• Biodiversity Enhancements
[See attachment for plan]
4.16 The site is contained by strong defensible boundaries and connects well to Milton Ernest on its northern edge, therefore, any future development could be easily absorbed within the existing development pattern. In addition to the primary access route on Parkside, there is the potential for further cyclist and pedestrian routes into the site.
4.17 In order to maintain a buffer between residential units, flood risk and listed buildings, the scheme would be designed sympathetically and pay due regard to these features throughout the planning process. All significant existing trees are to be retained and reinforced where necessary as part of an enhanced public open space to provide an attractive river side setting for the community to enjoy.
4.18 The suggested Policy wording is as follows:
[See attachment]
Conclusion
4.19 As discussed in this report, the Emerging Local Plan pays little regard to the importance of sites that are well related to existing sustainable settlements in delivering housing in line with identified need. Rather, the plan places emphasis on the use of substantial strategic sites and new settlements in large areas of open countryside to deliver housing need, overlooking existing settlements for expansion. The draft Local Plan should afford more consideration to the potential allocation of sites adjacent to existing key and rural service centres acknowledging their importance in meeting housing need.
4.20 Milton Ernest presents a logical location for development, comprising a sustainable settlement within the borough that would benefit from policy support. Additional but proportionate development in this location could be delivered quickly and provide valuable economic, social, and environmental benefits to an existing community.
4.21 The site is well connected to the settlement boundary and therefore, if allocated, would create a logical extension to the settlement. Given its close proximity to a range of facilities, the site would be well-serviced for future occupiers. There are no constraints identified that cannot reasonably overcome through assessment and sensitive design and the site provides an opportunity to deliver a sustainable and proportionate scheme to the settlement alongside valuable enhancements and fit for purpose open space.
4.22 The site outlined above presents a sound option for delivering development of this nature and should be considered by the Council for allocation alongside other extensions to existing sustainable settlements in the borough to alleviate reliance on substantial strategic sites throughout the plan period. The site has the capacity to deliver around 50 residential units, and this complies with the growing housing requirement set in this review. Furthermore, if the Council is concerned that the allocation of the site might undermine the recently made Neighbourhood Plan, the Council could allocate the site post 2030, when the Neighbourhood Plan will cease to have any effect.

Object

Representation ID: 10214

Received: 29/07/2022

Respondent: Mr Ben Pile

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Land off Bromham Road, Biddenham
Introduction
On behalf of the landowner (xxxxxx), I am pleased to formally submit representations to the Bedford Borough Local Plan 2040 Regulation 19 (Pre-submission) consultation, together with the Response Form accompanying this letter.
We object to the spatial strategy set out in the draft Local Plan as matter of principle because it does not propose to allocate the most suitable sites in the most suitable locations. The approach taken by the Council is flawed, not only because it fails to recognise the more sustainable locations for growth, but also because it overly relies upon the delivery of sites that are in less sustainable locations and rely on the delivery of infrastructure that are uncertain and likely to cause delay. The full details of the objections are presented in this representation.
In order to assist the Council in preparing a sound and credible plan we advocate that additional sites are allocated in locations that are sustainable, meet the vision and objectives set out in the plan and present a significantly more deliverable and robust housing allocation.
Proposed site for Housing Allocation
This representation contends that land at Bromham Road, Biddenham should be identified as a residential development site and may be considered in conjunction with land to the east that is available for development. The sites may either be developed in isolation or together as access is achievable off the Bromham Road, where the two sites cojoin.
The land is approximately 2.18 hectares and comprises a small agricultural field that slopes from east down towards the river in the west. Access is gained off Bromham Road to the north. Residential development presently abuts the site to the north and will soon dominate the land to the south as the site off Gold Lane is developed by Dandara Properties. Land to the East has recently been marketed and it is understood that it is being promoted by a developer for residential purposes.
The site is identified on the attached plan (REF P911g 001) and is shown overleaf:
[See attachment for plan]
The adjacent river, the Great Ouse, has a flood plain that extends onto or near the site and technical assessments in the local area suggest that most of the site is outside of the flood plain in flood zone 1, leaving a parcel of land that is capable of delivering 25 or more residential dwellings.
Planning Policy – Adopted Local plan 2030
The site is presently lies on the edge of the Urban Area, but unusually this is bounded on two sides as shown below. Recent allocations (annotated 18 and 23) are in the early stage of construction or planning and once built will provide a clear built-up area surrounding the site, which will allow this site to operate as an infill site, contiguous with the edge of the urban area and provide a natural rounding off of this edge of the urban area.
The site is not affected by any other designations as indicated by the Policy plan below and therefore its proposal as an allocation in this review does not have the effect of undermining the broad strategy of the existing adopted Local Plan or the emerging one.
There is an existing access from the site directly onto the Bromham Road, which is a wide road, recently reduced to 20 MPH speed limit. Bromham Road has a footpath and bus route that provides a service to Bromham in the west and Bedford to the east. It is well located to local facilities, in walking distance to various community facilities such as recreation areas, play areas and retail facilities in both Bromham and Great Denham. A public footpath also extends along the eastern edge of the site that provides a direct route to Church End Biddenham.
The site will therefore be one of the most sustainable green field locations, be it that it can provide homes within easy reach of local village and town facilities and is immediately adjacent to the most sustainable settlement in the Borough. Access to public transport, cycle and pedestrian routes all capable of linking to the villages of Biddenham and Bromham and to the town railway station enable the site to reduce the use of the private car and allows an opportunity to encourage a modal shift:
[See attachment for plan]
The below indicative parameter plan has been prepared to demonstrate how the site could be developed, identifying landscaping and green space on the sites western and southern boundary and residential development extending from the south to meet existing residential development on Bromham Road.
[See attachment for plan]
Conclusion
To conclude, it is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic sites and new settlements. The Council should consider sites that are located on the edge of the Urban Area, such as this one, ahead of less sustainable alternatives. We encourage the Council to create flexibility in the plan to accommodate this site to make a contribution to the delivery of homes.

Comment

Representation ID: 10219

Received: 29/07/2022

Respondent: Anwyl Land

Agent: Fisher German LLP

1. Introduction
1.1 This representation has been prepared on behalf of Anwyl Land in respect of their land interests at Kennel Hill, Sharnbrook as illustrated on Figure 1 below – the site is edged red. This site is an omission site in the emerging Bedford Local Plan 2040. The site is considered suitable for
allocation in the scenario that further housing sites are required to enable the Local Plan to be found sound (as we consider to be the case as set out within these representations).
SEE ATTACHMENT

1.2 The site has been previously promoted through the various stages of the adopted Local Plan, Neighbourhood Plan and was included as a preferred site as part of the Council’s 2017 consultation paper. Technical documents to support the allocation of the site were submitted, including highways and landscape, demonstrating the sites acceptability and deliverability.
Despite this however, the adopted Plan opted to defer allocations to subsequent Neighbourhood Plans, which would deliver the housing targets set out in the Local Plan. For Sharnbrook, the Local Plan allocated 500 dwellings to be delivered through the Neighbourhood Plan.
1.3 Sharnbrook is designated in the Local Plan as a Key Service Centre, which are described as settlements “which contain a good range of services and are well connected to larger town centres by regular public transport. They provide a strong service role for the local community and surrounding area”.
1.4 The Sharnbrook Neighbourhood Plan Examiner’s Report was published on the 19th July 2021. This concluded that the Plan could proceed to referendum subject to modifications, despite significant concerns relating to the deliverability of the Plan’s key allocation (Hill Farm) and limited evidence to support that the housing requirement could be met having regard for the Plan’s short period up to 2030. The allocation at Hill Farm is predicated on delivery of significant improvements to the junction at the A6, with no confirmation from County Highways that the proposed Neighbourhood Plan allocation is deliverable.
1.5 A referendum on the Neighbourhood Plan was held in October 2021. The Plan passed the referendum with 457 votes in favour and 80 against, with a 30% turnout. Following this result, the Plan was formally made by Bedford Borough Council in November 2021.
1.6 A planning application has been submitted on the Plan’s primary allocation, a strategic scale development isolated from Sharnbrook to the east, for up to 500 dwellings and other community infrastructure (ref: 22/01037/MAO). Key consultation responses are yet to be received for this application at time of writing, including highways.
1.7 This representation follows policies in the order that they appear in the consultation document.

Object

Representation ID: 10226

Received: 29/07/2022

Respondent: Anwyl Land

Agent: Fisher German LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

3 Land at Kennel Hill, Sharnbrook – Site Assessment
3.1 The Housing and Employment Land Availability Assessment and Site Assessment Topic Paper (May 2022) includes the Council’s assessments of the sites submitted for consideration throughout this Local Plan process.
3.2 A copy of the assessment for Land at Kennel Hill, Sharnbrook is provided below, with our suggested amended assessment where relevant which is based on technical assessment that have been carried out. As set out previously the site has historically been accepted by the Council as suitable for allocation, and would likely have been allocated had the Neighbourhood Plan approach correctly been rejected through its examination.
SEE ATTACHMENT FOR TABLE

3.3 With the above in mind, it is clear that Land at Kennel Hill, Sharnbrook is better suited to come forward for residential development than actually assessed by the Council, despite the historic draft allocation. The site can come forward early and can be used to replace lost supply in Sharnbrook in the initial years of the Plan period (when a sensible trajectory for the delivery of the new settlement is adopted), enabling a sensible lead in time for the new settlement, which will then in turn provide local growth later in the Plan period, closer to 2040 (albeit concerns relating to freestanding nature of the settlement remain).

4 Conclusions
4.1 This representation has been prepared on behalf of Anwyl Land in respect of their land interests at Land at Kennel Hill, Sharnbrook.
4.2 To conclude:
- The LP2040 is not consistent with national policy because it does not plan for sufficient housing to meet future needs and does not proactively plan for any uplift as a result of the Arc Framework.
- The distribution of growth within the LP2040 is not effective or justified as the level of growth expected on the strategic sites, particularly the new settlements are not reflective of historic delivery within Bedford or nationally when compared to other similar sites. The Council has assumed delivery rates of up 600 dwellings per annum on the Kempston Hardwick and Little Barford allocations (1,200 per annum in total), equating to an average annual deliver of 380 dwellings per annum on strategic allocations (760 dwellings per annum in total), wherein evidence suggests average delivery closer to 160 per annum per site is likely to be deliverable (320 per annum in total), having a significant impact on the deliverability of the proposed stepped trajectory.
- The Spatial Strategy is not justified because it has not fully taken account of all the reasonable alternatives. There is also no justification for not including a requirement for neighbourhood plans to make allocations beyond those already committed to 2030. Role of Sharnbrook underutilised given all local development directed to independent new settlement meaning non of the 500 dwellings will be delivered within Sharnbrook itself. Opportunity for Sharnbrook to actually receive housing allocations as part of updated strategy.
It is considered unlikely that the Council can demonstrate a robust five-year housing land supply at adoption, nor throughout much of the Plan period, even if the hyper ambitious assumptions made by the Council are realised. Opportunity for growth at Sharnbrook to mitigate early shortfalls (particularly when sensible and deliverable build rates are adopted in respect of the Sharnbrook NDP allocation).
- Land at Kennel Hill, Sharnbrook is a suitable site for development and should be included in an uplift of housing growth beyond that already proposed in the LP2040 and to realise the spatial role of Sharnbrook itself within the adopted and emerging hierarchy. This uplift should comprise of sustainable growth to allow housing to be delivered earlier in the plan period, balancing growth throughout the Plan instead of the back loaded approach advocated by the Council.
4.3 We politely request that we are kept informed of the progress on the LP2040 including the need to attend any relevant Hearing sessions for the Examination of the Plan.

Object

Representation ID: 10228

Received: 29/07/2022

Respondent: Mr Ben Pile

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

3.0 A Proposed Allocation at Church End Biddenham
Potential for development within the Urban Area
3.1 Biddenham comprises part of the Urban Area of Bedford Town, and it is approximately 2.5km from Bedford Town Centre.
3.2 Given that Biddenham is within the Urban Area of Bedford Town, it is not assessed within the Settlement Hierarchy (2030) and Addendum (2022), however, Bedford comprises the primary settlement in the borough and is therefore the most sustainable settlement. It provides an array of services with unrivalled access to surrounding road networks and public transport services. Development sites on or within its boundaries, therefore, comprises the most logical and sustainable option for the delivery of new growth in the Borough.
3.3 Open land to the west of Biddenham has, however, been allocated as Urban Open Space, despite its clear potential to provide some of the most sustainable residential development in the borough. The imposition of this designation in this location is counterproductive to the principles of housing delivery. Residential schemes should be focused within or adjacent to the most sustainable areas within Local Planning Authority areas and the use of designations to limit development in these locations does not conform with the general approach applied to housing delivery nationally.
3.4 The concept of Urban Open Spaces and Gaps was outlined in Policy AD43 of the Allocations and Designations Plan (2013). This states that “Development will not be permitted on land designated as urban open space and gaps unless it can be demonstrated that the reasons for designation are not compromised or that other material considerations outweigh the need to retain the urban open space and gaps undeveloped”. In the context of the 27,100 units required to be delivered throughout the plan period, as outlined by the Standard Method for assessing housing need, the overall need to deliver significant levels of housing in sustainable locations is considered to outweigh the protection of this land. Freeing up this land for the delivery of housing would avoid the use of substantial areas of open countryside poorly related to existing settlements for the use of residential development when suitable, sustainable and connected sites are available elsewhere. The value of keeping isolated open countryside underdeveloped outweighs the importance of limiting the use of valuable sites on the edge of urban areas. This does not mean to say development in these locations cannot be sensitively developed in the context of urban open space but the option for the delivery of residential development alongside this should not be neutralised.
3.5 Whilst a number of sites are located adjacent to Bedford within the Local Plan 2030, including some on the edge of Biddenham, the emerging Local Plan 2040 fails to acknowledge further sites of this nature and instead focuses on housing delivering in large areas of open countryside through the development of strategic greenfield sites and new settlements. The single exception to this is Draft Policy HOU5, which allocates Abbey Field, West of Elstow. Similarly, to land on the edge of Biddenham, this land had been designated as Urban Open Space, nonetheless, its development for residential development alongside this has not been precluded. This approach should be more actively applied in relation to available sites within the Bedford Urban Area.
3.6 Land to west of the settlement, north of the site that is the subject of this report, is allocated for development under the Local Plan 2030 Policy 18 (Land at Gold Lane, Biddenham). This allocation seeks to deliver 160 dwellings as well as strategic open space alongside additional public transport, pedestrian and cycle connections further contributing to the sustainability of the area, reflecting the approach applied in Draft Policy HOU5. The location of this allocation in the context of the site is provided in figure 2 for clarity. This provides clear acknowledgement that this location is considered capable of supporting further residential development.
[See attached for plan]
Site Details
3.7 The site proposed for allocation is approximately 3.42ha, is located to the rear of development on Church End in the western area of Biddenham. The location of the site is shown in figure 4 overleaf and a Site Identification Plan is provided in Appendix 1.
3.8 The site comprises an agricultural field bounded by established trees and hedgerows on all boundaries aside from the southwestern corner of the site which sits adjacent to a cemetery gifted by the landowner to the church. The existing settlement of Biddenham and associated built form abuts the site on its southern boundary and the Gold Lane development being built by Dandara dominates the land to the north. Two smaller parcels of land to the north and east of our site (blue and green stars above), owned by the same landowner are also available for development and also comprise agricultural land. These two parcels are likely to be presented under separate representations, but we can advise that our landowner and the adjoining landowner of these two parcels are in direct discussions about a joint approach to the delivery of a combined site.
[See attached for plan]
3.9 The wider residential area and associated facilities are located to the east of the site. The site is therefore set amongst existing and upcoming development and can be considered well contained. Biddenham St James Church is located to the southwest of the site and comprises a Grade l listed building. Public rights of way are located on the northern, eastern and western boundaries.
Site Assessment
3.10 Optimis propose that this site is allocated for residential development in conjunction with land allocated to the north and east of the site. Representations for the site have previously been submitted to the Council for their consideration under the Bedford Borough Council consultation on the Regulation 19 Local Plan: Plan for Submission in 2018 and remains a logical site for development in the context of the emerging Local Plan.
3.11 The site is capable of delivering up to 80 dwellings alongside publicly accessible Urban Open Space at a density of 23d/ha. Given the location of the site in the context of the settlement it has the potential to form a well-connected and logical extension to the settlement that will build on allocations previously made in a proportionate and sensitive manner.
3.12 An extract of the emerging Local Plans draft policy map is shown below in figure 5 with the site highlighted for context.
[See attached for plan]
3.13 It is acknowledged that the development site is located on land identified as Urban Open Space, however, for the reasons discussed previously, this should not preclude its use for the delivery of residential development. A low-density residential scheme sensitive to this allocation can still be delivering in line with the approach applied in relation to Policy 18 and Draft Policy HOU5 of the adopted and emerging Local Plans.
3.14 In addition to this, the presence of listed buildings to the south of the site is noted. The Parish Church of St James, a grade l listed building is the only one considered to have a relationship with the site. Nonetheless, through provision of landscaping and separation between the church and new residential development, it is considered impacts can be managed and mitigated in line with the protection that is afforded to this heritage asset. It is recognised a detailed Heritage Impact Assessment will need to be completed for the site and future proposals to assess the extent of harm.
[See attached for plan]
3.16 The provision of housing on a site well related to an existing highly sustainable settlement in response to housing need alongside the delivery biodiversity net gain and localised green infrastructure, associated contributions and further public benefits identified throughout the design process could reasonably overcome any harm to the heritage assets in the area.
3.17 Access is achievable from several alternative positions, and this can be explored with Dandara and adjacent landowners as required. An indicative scheme to deliver an extension to the Dandara scheme to the north has been discussed and is considered below as one alternative.
3.18 The site has the potential to supply a range of residential development in response to identified need and the client is willing to cooperate with Bedford Borough Council and the Parish Council to provide the type of housing scheme that is required in this area of Biddenham alongside the provision of enhanced Urban Open Space in response to the existing designation.
3.19 The suggested Policy wording is as follows:
Policy x – Land to the rear of Church End, Biddenham
Land to the rear of Church End, Biddenham will be developed for the provision of residential development alongside strategic open space. Key principle for development:
i. Provision of a range of housing types and sizes.
ii. Provision of pedestrian and cycle routes at appropriate locations throughout the development.
iii. Provision of a Transport Assessment detailing the impact on surrounding highways and mitigation measures;
iv. Assessment of impact on landscape and submission of a comprehensive landscape scheme;
v. Development should protect, preserve and where opportunities arise enhance heritage assets and their setting, including:
- Biddenham Conservation Area and listed buildings within, particularly Grade I listed St. James Church, and other local heritage assets;
vi. Pre-determination archaeological evaluation;
vii. Contribution to the preservation/enhancement of Biddenham Village Pond and the habitats it provides;
viii. Assessment of the nature and extent of ground contamination and preparation of a remediation strategy for the site including methods of disposing of contaminated material, measures to prevent the pollution of surface and ground water, and provisions for future monitoring, to be approved by the Council.
ix. Provision of a strategically designed and phased Sustainable Urban Drainage Scheme
x. Submission of a biodiversity report with appropriate mitigation and enhancements.
Figure 7. Proposed Allocation Wording (Authors Own)
Conclusion
3.20 As discussed in this report, the Emerging Local Plan pays no regard to the importance of sites that are well related to existing sustainable settlements in delivering housing in line with identified need. Rather, the plan places emphasis on the use of substantial strategic sites and new settlements in large areas of open countryside to deliver housing need, overlooking existing settlements for expansion as is clear from the Spatial Strategy outlined in section 2. It is considered the draft Local Plan should afford more consideration to the potential allocation of sites adjacent to or within the existing the Urban Area.
3.21 This site is located within the identified Urban Area of Bedford Town and therefore comprises one of the most sustainable areas for development in the district. It has the potential to provide an uplift on previous allocations in the area but has been overlooked in favour of Urban Open Space and this should not preclude the site from development. The Standard Method for assessing housing need has identified significant demand for housing in the area. On this basis, the overall need to deliver significant levels of housing in sustainable locations is considered to outweigh the protection of this land, freeing it up for the delivery of housing that would avoid the use of substantial areas of open countryside poorly related to existing settlements.
3.22 Whilst is acknowledge that the site is located in close proximity to designated heritage assets, it is concluded that impacts in this respect can be identified and overcome through detailed assessment and sensitive design. Furthermore, discussions regarding vehicular access are ongoing with the landowner and a workable solution is in place to facilitate this.
3.23 The site outlined above presents a sound option for delivering development of this nature and should be considered by the Council as a preference to the proposed allocations in the plan.

Object

Representation ID: 10238

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Site 726 The Walled Garden Willington
Settlement Assessment - Willington
Willington is located in the eastern portion of the administrative area and is an established rural settlement. There are a number of advantages in allocating residential development in Willington such as good public transport links to Bedford, a post office, public house, church, coffee shop, primary school, memorial hall, and recreational space. Appendix 4 of the Settlement Hierarchy (2030) with Addendum (2022) categorises the settlement as a Group 2 Rural Service Centre. The Council states that Group 2 villages have “good or reasonably good road and public transport links to Bedford and have better levels of service provision than settlements lower in the rankings”. On this basis, the settlement is considered sustainable, presenting a logical location for proportionate residential development. Willington as 5th highest ranking settlement under the Group 2 bracket, scoring 54.
The Bedford Local Plan 2030 describes Rural Service Centres as settlements that provide a “more localised convenience and service role to meet the day to day needs of residents and businesses in the rural area”. Policy 4S of the Local Plan 2030 addressed the amount and distribution of housing development in the Borough allocating Willington 25-50 homes throughout the plan period. This allocation suggests that Willington therefore presents a logical location for delivering housing in the eastern area of the borough which has been significantly overlooked for the provision of new homes throughout the adopted and emerging plans.
The Proposed Allocation
Site Details
The site is located to the southwest of Church End in Willington. It has not previously been promoted for inclusion in the Local Plan, however, following assessment of the draft document it is considered it could prove valuable in quickly delivering short term housing need.
The site, approximately 0.46ha, is located in the western area of Willington, a Group 2 village. The potential for site access is available from a private road to the north of the site. The site is relatively flat and has not previously been developed. The satellite location plan of the site is shown in figure 1 below and the site identification plan is available in appendix 1
[See attached for plan]
The site currently comprises open land, lined by walls and landscaping on all boundaries. Landscaping containing established trees and hedgerows is denser on the southern boundary of the site. St Lawrences Church and associated grounds abut the site’s eastern boundary, Willington Stables sits to the north of the site and Manor Farmhouse is situated to the south west. Existing residential development is located to the west of the site and either side of Church Road extending east away from the site.
Willington Stables comprises a Grade l listed building and St Lawrences Church and Manor Farmhouse comprise Grade ll listed buildings and wall structure. The site is located within Flood Zone 1 and it sits outside the Settlement Policy Area. The Local Plan 2030 Policy Map is shown in figure 2.
[See attached for plan]
Site Assessment
Optimis propose that The Walled Garden at Church End, Willington be allocated for residential development. The site has not previously been considered as part of the Bedford Borough Local Plan but presents a logical development opportunity within the built area of an established, sustainable settlement.
Despite the site sitting outside the Settlement Policy Area, it presents a logical extension to the village as it is well located with residential development situated to the west of the site and east of the site on either side of Church Road.
Whilst Willington has a made Neighbourhood Plan, it covers the period to 2030. This Local Plan covers the period 2040 and therefore there is an opportunity to identify this site for development in the latter stages of the plan post 2030.
The site is not within a conservation area and is not subject to any policy designations. The site is bounded by a soft edge to the south comprising of established trees and hedgerows extending west, providing screening. Views into the countryside are therefore not substantial and development in this location would have limited impact on the surrounding landscape. Despite this, further assessment of landscape impacts and consideration of these throughout the design of the scheme could be carried out through its allocation. There are a number of listed buildings within Willington, some in close proximity to the site, any scheme for the site will require sympathetic design and assessment and justification of these features, the potential impacts of the development and mitigation and public benefits that could be employed to outweigh harm.
The constraints identified will not be detrimental to its development and can therefore be overcome provided careful consideration is adhered to throughout the design process. This will ensure the scheme is deliverable without causing adverse harm.
Policy x – The Walled Garden, Church End, Willington
The Walled Garden, Church End, Willington will be developed for residential use. Key principle for development:
i. Provision of a range of housing types and sizes.
ii. Provision of a landscaping and tree planting scheme within the site and along site boundaries to reduce the impact of the development on wider views and in particular minimise impacts on heritage assets.
iii. The preparation and submission of a Desktop Archaeological Assessment and the preparation of further information recommended thereafter.
iv. Provision of a strategically designed and phased Sustainable Urban Drainage Scheme
v. Submission of a biodiversity report with appropriate mitigation and enhancements.
vi. Development should protect, preserve and where opportunities arise enhance heritage assets and their settings, including:
- Grade I listed St Lawrence’s Church
- Grade II listed Manor Farmhouse
- Grade II listed Wall at Manor Farm
Figure 3. Proposed Allocation Wording (Authors Own)
Conclusion
To conclude, it is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic site’s and new settlements. The potential of smaller sustainable settlements throughout the borough in meeting housing need has been overlooked in favour of this, having extensive implications on the timescales for housing delivery throughout the plan period.
Willington presents a logical location for development; it can deliver short term housing quickly and would benefit from policy to support this objective. Development that is sensitive and proportionate in this location will provide the existing settlement with economic, social, and environmental benefits. The site outlined above presents an option for delivering development of this nature and should be considered by the Council for allocation either immediately or post 2030 to align with the Neighbourhood Plan period.

Object

Representation ID: 10246

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Settlement Assessment - Wootton
Located in the southern portion of the administrative area, Wootton is a rural settlement. The Settlement Hierarchy (2030) with Addendum (2022) designates Wootton as a Key Service Centre within the Marston Vale growth area, classified as a Group 1 village. Wootton benefits from a number of services including a post office, public house, coffee shop, a number of schools, recreational and sports facilities, a convenience store and GP surgery. It benefits from good main road and public transport links to Bedford and has generally improved levels of service provision when compared to settlements that score lower in the rankings. The nature in which Group 1 settlements are distributed across the administrative area means that they can serve their surrounding rural area independently.
The Settlement Hierarchy (2030) with Addendum (2022) places Wootton as the 3rd highest in the ranks against all settlements in the Group 1 bracket, scoring 72 within Appendix 4. As one of the highest scoring settlements in Group 1 key service centres, Wootton is considered well-established and has good connections within Bedford Borough. Its strategic location and range of facilities make it a logical location for housing, capable of supporting a growing community. Its proportionate expansion would not only provide economic and social support for the settlement in isolation but also facilitate further improvements to these facilities through financial contributions and investment to the benefit of surrounding rural settlements that rely on the services it provides.
Paragraph 2.23 of the Local Plan 2030 addresses recent growth and change within the Borough. Wootton is described as a ‘growth area’ despite being allocated only 105 dwellings in the Neighbourhood Plan within the plan period. The settlement is able deliver significantly more development than this in the context of its sustainability. Only 105 dwellings over 20 years amounts to 5.25 dwellings per annum and is significantly disproportionate to the size and importance of the settlement.
The Proposed Allocation
Site Details
The site is located off Cranfield Road, south of Wootton. Despite not being promoted previously for inclusion in the Local Plan, it could prove valuable in quickly delivering short term housing need following assessment of the draft document. The site is approximately 5.3ha and is situated south of Wootton, a Group 1 settlement. The site is accessed directly off Cranfield Road, on its southern corner and its location is shown below in Figure 1. The site identification plan is available in appendix 1.
[See attached for plan]
The site comprises of an open field with a cluster of structures in the south-western corner. On three of its boundaries, the site is lined by trees and hedgerows. The site abuts existing residential development and Maple Tree Cottage self-catering accommodation on its southern edge creating a defensible boundary to the south. Residential development adjacent to the eastern boundary of the site beyond Cranfield Road was permitted in 2018 (LPA Ref. 15/02060/MAF) for the Erection of 600 dwellings, including vehicular access, pedestrian and cycle links, public open space, car parking, landscaping, drainage and associated infrastructure works. This demonstrates that substantial strategic development has been considered and approved on the boundary of Wootton, confirming its suitability as a settlement for expansion. Further south on Cranfield Road is additional residential development.
The site and its surroundings are located in Flood Zone 1. As shown in figure 2 below, the site is not within the Settlement Policy Area however is closely related to existing residential development on the southern boundary of Wootton. The site is not located in a conservation area and is not covered by any further policy designations. There are no listed buildings within the vicinity of the site.
[See attached for plan]
Site Assessment
Optimis propose that Land at Cranfield Road, Wootton be allocated for residential development. The site has not previously been considered as part of the Bedford Borough Local Plan however it has been assessed as part of the Wootton Neighbourhood Plan. Wootton has been recognised as a strategic area for development that has the potential to bolster the sustainability and growth objectives as set out in the previous and emerging Local Plan. The site presents a logical development opportunity adjacent to the built area of an established, sustainable settlement.
Although the site sits outside the Settlement Policy Area, it would create a proportionate extension to the existing development located off Cranfield Road acting as a gateway into the settlement of Wootton, particularly if delivered alongside land to the north which is Council owned. Land to the north of the site was assessed within the Wotton Neighbourhood Plan also. The allocation of this site would create a more sustainable gateway development into Wootton as opposed to the existing ribbon development that creates a scattered appearance with dwellings that have no succinct relationship and pattern. The site would create an extension that is logical for a settlement of its nature and scale.
The site is not located within any conservation areas and has not been allocated any policy designation and the site would therefore not pose any major policy constraints to residential development. The landscaping on three boundaries of the site provides valuable screening limiting the potential impacts of future development on the surrounding landscape and open countryside.
The provision of housing on a site in a high scoring settlement is a logical response to the housing need. The delivery of biodiversity net gain, associated contributions and additional public benefits identified throughout the design process would deliver further benefits to this settlement, enhancing its sustainability
The site presents no technical or legal constraint for the delivery of residential development and it is a logical option for allocation within the plan.
The suggested Policy wording is as follows:
Policy x – Land at Cranfield Road, Wootton
Land at Cranfield Road, Wootton will be developed for residential use. Key principle for development:
i. Provision of a range of housing types and sizes.
ii. Provision of a strategically designed and phased Sustainable Urban Drainage Scheme
iii. Submission of a biodiversity report with appropriate mitigation and enhancements.
iv. Cohesion with the adjacent residential development to the eastern boundary of the site on Cranfield Road for the promotion of a sustainable gateway for Wootton
v. Provision of a landscape buffer to the west and south of the site to protect views from long distance and the amenity of adjacent residents.
Figure 3. Proposed Allocation Wording (Authors Own)
The below indicative parameter plan has been prepared to demonstrate how the site could be developed, identifying landscaping and green space on the site’s western and southern boundary and residential development to the north eastern corner of the site to meet existing residential development on Cranfield Road.
[See attached for plan]
Conclusion
It is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic site’s and new settlements. The potential of sustainable settlements such as Wootton to meet the housing need has been overlooked which will have extensive implications on the timescales for housing delivery throughout the plan period.
Wootton demonstrates a logical location for development, comprising one of the highest scoring Group 1 settlements in the south-western area of the borough that would benefit from policy support for further housing. The site outlined above presents a logical option for delivering development of this nature and should be considered by the Council for allocation to alleviate reliance on substantial strategic site’s throughout the plan period.

Object

Representation ID: 10259

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Settlement Assessment – Brick Kiln Field, off Butler Road, Ravensden
Situated in the northern section of the administrative area, Ravensden comprises an established rural settlement. Despite its size, the settlement benefits from good public transport links to Bedford and surrounding settlements, a village hall, public house, corner shop, church, primary school and recreational space. Appendix 4 of the Settlement Hierarchy (2030) with Addendum (2022), that support the emerging Local Plan, categorises the settlement as a Group 3 village with a score of 28. It therefore benefits from a higher score than some of the settlements identified for draft allocations in the plan such as Gibraltar Corner, which scores only 8 in the Settlement Hierarchy.
The current level of housing provision allocated in Ravensden does not support the range of services presently available. In order to maintain these services, additional rural residential development would be beneficial in providing additional investment and economic support. On this basis, It is also important to note the value of development in this location in supporting the rural economy in line with the National Planning Policy Framework. Paragraph 84 notes that planning policies and decisions should enable “sustainable growth and expansion of all types of business in rural areas” and “the retention and development of accessible local services and community facilities, such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship”. As such, there is clear benefits to the provision of proportionate residential development in Ravensden which will aid in bolstering the existing economy, making full use of the sustainable services available in the settlement.
Whilst the settlement of Ravensden is small and covers several clusters of development, it is in a strategic location regarding its connections to Bedford. The village is situated less than 1km away from the urban boundary of Bedford and, therefore, benefits from good access to the wide range of services, facilities and transport links available in this area. The presence of services within the village and its proximity to Bedford Town, make it a unique locations for the delivery of sustainable rural development.
The Proposed Allocation
Site Details
The site is located off Butler Road at the crossroads onto Bedford Road, Ravensden. The surrounding area comprises of built form on three sides, two of which are residential. Beyond the built form on its northern boundary, the site abuts a green field site. Access to the site is currently gained off Butler Road. The site has not previously been promoted for inclusion in the Local Plan. The satellite location plan of the site is shown in figure 1 below and the site identification plan is available in appendix 1.
[See attached for plan]
Bedford Road (B660) sits less than 50m from the site’s entrance and runs south in to Bedford Town, reaching its boundary in 4 minutes. The site is located next to a bus stop that services routes to Bedford, Kimbolton and Pertenhall.
The site comprises of an open field lined by trees and hedgerows on three of its boundaries and a fence on either side of its entrance off Butler Road. The site is located in Flood Zone 1 and a Grade II listed building sits to the east of the site comprising the Old White Lion. The site sits outside the Settlement Policy Area for Ravensden and is not included the adopted policy map for the settlement.
Site Assessment
Optimis propose that Brick Kiln Field, off Butler Road, Ravensden be allocated for residential development. The site has not previously been considered as part of the Bedford Borough Local Plan but presents a logical development opportunity for rural housing located within a residential cluster associated with the settlement of Ravensden.
Whilst the site is currently located outside the Settlement Policy Area, it presents a logical expansion to the built form of Ravensden, well located to existing development on three sides. Through the creation of a strong boundary on the north western edge the site could be contained, and any future development could easily be incorporated in to the existing pattern of development.
As discussed above Ravensden comprises a sustainable rural settlement with unique access to surrounding Group 1 and primary service centres. It is therefore concluded that development in this location provides an opportunity to not only support the existing services within the settlement, thereby enhancing the rural economy, but also delivering increased economic support to existing services further afield.
It is acknowledged that a Grade ll Listed building is located to the east of the site on the corner of Bedford Road and Oldways Road. However, the site’s position to the rear of development on Butler Road and Bedford Road mean there is no clear sight lines or relationship between it and the listed building. As such, the development of this site is not considered to give rise to any impacts on the setting or appearance of this building.
The site does not present any technical constraint and is therefore a logical and sustainable site for the allocation of rural homes within the emerging Local Plan.
The suggested Policy wording is as follows:
Policy x – Brick Kiln Field, off Butler Road, Ravensden
Brick Kiln Field, off Butler Road, Ravensden will be developed for residential use to deliver housing. Key principle for development:
i. Provision of a range of housing types and sizes.
ii. Provision of a Sustainable Urban Drainage Scheme
iii. Submission of a biodiversity report with appropriate mitigation and enhancements.
iv. Provision of a landscaping and tree planting scheme within the site and along site boundaries to reduce the impact of the development on the wider open countryside
Figure 3. Proposed Allocation Wording (Authors Own)
Conclusion
It is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic site’s and new settlements. The potential of smaller sustainable settlements throughout the borough in meeting housing need has been overlooked in favour of this, having extensive implications on the timescales for housing delivery throughout the plan period.
Ravensden demonstrates a logical location for development, comprising a range of services and facilities that would benefit from additional economic support. The settlement is also sustainably located amongst other key sustainable settlements. The site outlined above presents a logical option for delivering sustainable rural development and presents negligible constraints preventing its use for this purpose. Development in this location would benefit from policy support and should be considered by the Council for allocation alongside other extensions to existing sustainable settlement in the borough to alleviate reliance on substantial strategic site’s throughout the plan period.

Object

Representation ID: 10352

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Reference sites 839 / 832

This representation relates to Land East of Station Road, Oakley. This representation should be read alongside previous Regulation 18 consultations (Representation ID: 7450 / Site IDs: 839 / 832) (Appendix 1) and Indicative Masterplan Proposals (Appendix 2). This Statement should also be read alongside the overarching Spatial Strategy and Legal Compliance Representation Report covering our clients’ wider interests and accompanying representations forms.
1.3 Consideration is given to the development potential of our clients’ land at Oakley, and these representations provide a response in respect of the draft policies relating to the spatial strategy and scale and distribution of housing of housing provision.
1.4 We object to a number of the draft Policies contained within the publication version of the Bedford Local Plan 2040 and consider that in their current form, they would not be found sound at Examination. Further, as outlined within these representations, we do not consider that the Sustainability Appraisal has been prepared in line with the requirements of the SEA regulations and thus do not consider the Plan as drafted is legally compliant.
In-keeping with the approach of our clients at previous consultation stages these representations should be read in parallel with those prepared on behalf of the Meridian Academies Trust (MAT) which seek recognition within the plan-making process of the significant increase in the pupil roll be accommodated through the expansion of Lincroft Academy. These representations support the proposed reclassification of Oakley as a Key Service Centre and endorse the further assessment of potential benefits that would result from the reconfiguration of the current land uses East of Station Road.
1.6 Further to representations to the last consultation stage, heads of terms are agreed between the two parties, as landowners, to deliver a ‘land swap’ and enable provision of the ‘one-site’ solution and additional improvements outlined here. The final detail of this agreement is capable of completion within a short timeframe.
1.7 MAT has continued to progress the proposed 'land swap' due to the uncertainties generated by the failure of the Local Plan process to recognise the requirements for expansion of Lincroft Academy and the significant funding gap that needs to be addressed to secure the minimum increase in capacity that is necessary.
1.8 Furthermore, even where there is an acceptance of the need for expansion of Lincroft Academy from Bedford Borough Council there is no guarantee of funding from alternative sources such as the ESFA in relation to replacing existing out-dated facilities.
1.9 Were the funding gap for these minimum requirements to be filled this would not in any case ‘complete the picture’ in terms of making best use of MAT’s interests. This is specifically in terms of delivering additional benefits from relocation of the existing playing pitches for both Lincroft Academy and Oakley Primary Academy as well as the wider community.
1.10 Negotiations have therefore been continued to provide a potential alternative source of funding to address the funding gap and to confirm the feasibility of securing additional benefits beyond the minimum requirements identified. We reiterate the availability of land East of Station Road and as per the representations submitted previously, we believe that this is a matter where Bedford Borough Council would ordinarily welcome further engagement and assessment of the site option in light of known educational and infrastructure requirements.