Housing & Employment land Availability Assessment and Site Assessment

Showing comments and forms 31 to 35 of 35

Object

Plan for submission evidence base

Representation ID: 10367

Received: 29/07/2022

Respondent: Renhold Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

This subsidiary planning policy document includes a simple question and answer assessment for each of the sites under consideration to indicate their compatibility with Bedford Borough Council policies. In regards to Policy EM6 which are references as Sites 761 and 764 detailed on Pages 462, 463, 466 and 467 the Parish Council would like to draw attention to some of the responses.

Question 1. a) relating to Site 761 has a question mark over the reply that the site ‘Within or adjoining UAB SPA or built form of a small settlement’. The Parish Council have identified clear evidence that that it is not within the boundaries of any Settlement Policy Area and abutting a very small SPA for a few metres is not a reasonable justification for ‘approximately 30 hectares’ of employment use’.

Question 8. a) relating to both Site 761 and 764 also has a question mark over the reply that the site(s) ‘Likely to have a significant adverse impact on the surrounding landscape?’. The site assessments for both Site 761 and 764 state ‘ ? It is uncertain what effect the proposal is likely to have on the landscape / more information is required.’. The Parish Council have identified clear evidence that the impact on the surrounding landscape will be detrimental.

Attachments:

Object

Plan for submission evidence base

Representation ID: 10406

Received: 29/07/2022

Respondent: Orchestra Land

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Our client’s position is that the approach taken to allocating sites and, in particular, the quantum of development allocated on certain sites is not justified nor consistent with national policy, for the following reasons.
3.2 Firstly, the Local Plan does not put dwelling numbers against allocations HOU13, HOU15, HOU16 and HOU17. The Policy must be amended to do so that there is a clear understanding and expectation as to the quantum of development that the Plan is proposing in these locations.
3.3 Upon review of the Stepped Trajectory Topic Paper (April 2022), numbers have been proposed against these sites as follows:
HOU13: 500
HOU15: 300
HOU16: 1800
HOU17: 1000
3.4 What is not evident from the evidence base or the Local Plan, is the approximate developable areas and thus whether these are realistic densities. Upon examination of the Policies for each site, and the Figures in the Local Plan which accompany each, the only way to achieve all the Policy requirements, in particular the amount of open space and green infrastructure, it would necessitate very high densities on the majority of these sites (c. 50/60+ dph).
3.5 There is no evidence accompanying the Local Plan which justifies this approach; the HEDNA does not identify such a high requirement for small (1-2 bedroom homes) which a high density would lead to, nor is there market evidence supporting housing demand for such a high quantum of small units in these locations.
3.6 This is likely to lead to future applications which either decrease the number of homes, resulting in unmet need (in terms of overall quantum and/or mix) and possibly non-delivery of key infrastructure. Alternatively, it may lead to non-delivery of green infrastructure due to pressures to deliver housing numbers.
3.7 The quantum for each allocation is not based on a proportionate or robust evidence base and are therefore not sound.
3.8 In order to make the Local Plan sound, additional allocations are therefore necessary to make up this shortfall in numbers. Doing so would have the further benefit of addressing the stepped trajectory shortcomings as set out in Section 2 of these representations.
3.9 The next section of these representations puts forward a case as to one such location for growth within the southern parishes, which would deliver growth in a sustainable location, close to East-West Rail and on a site which has erroneously been discounted from the site selection process.

4.0 Land to the north of Top End, Renhold
4.1 The land north of Top End, Renhold sits close to the centre of the settlement, some 14 minute walk from the Primary School. It is enclosed by woodland to the east, with housing to the south and west. It is identified on the drawings enclosed at Appendix 1. The land measures c.4ha and was submitted to BBC through the Call for Sites process in 2020. Enclosed at Appendix 2 is the Council’s most recent 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 25 homes. The site is in sole ownership and can be brought forward in different phases to reflect local housing needs. The enclosed Plans at Appendix 1 show the different approaches which can be taken to delivery of the site.
4.3 The Council’s assessment of the site confirms it is in a sustainable location, being only 200m from the nearest bus stop and a short walk to the primary school (scoring
positively in both regards).
4.4 Indeed, the proforma assessment does not identify any constraints to the development of the site, other than those which can be adequately mitigated against as part of any proposals.
4.5 The site is being promoted for residential development, which could include self-build homes. There is an identified need within the Borough for self-build homes, and a lack of specific allocations within the Plan for this. The site could provide an important contribution to meeting this identified need in accordance with national policy.
4.6 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 to the north of Top End, Renhold, for housing including self-build homes. This is necessary to both respond to the evidence base, and to help contribute to 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. Moreover, as a non-strategic site the land is not reliant upon larger infrastructure. It can, therefore, come forward early in the plan period and help to deliver homes within the first 5 years. This would further boost the trajectory position and the Council’s housing land supply, an important benefit.
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 location both within Renhold, but a reasonable distance from Bedford, enhances the sustainability of the Site, which could deliver a widened footpath on the frontage as noted by the Council in the proforma. 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.

Highways and Access
4.10 The Site proforma (site ref 431) finds that the site would likely not cause significant issues in highway terms.
4.11 It also highlights the proximity (200m) to the nearest bus stops, and does not raise any concerns regarding access. The site benefits from a direct frontage to Top End Road and sufficient land to create a satisfactory access, with appropriate visibility splays.

Heritage
4.12 Whilst there are three Grade II listed buildings near to the site, these would not be unduly harmed by development here and could be screened through an appropriately designed and landscaped scheme.
4.13 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.

Summary
4.14 The land to the north of Top End, Renhold, is being actively promoted for residential development, including self-build homes to meet identified local needs.
4.15 The Local Plan evidence base finds that this location is a logical and appropriate location for development; The Site would accord with the emerging development strategy for BBC and would deliver housing in a sustainable location, as advocated in the NPPF.
4.16 The land north of Top End, Renhold should therefore be allocated for residential development within the Local Plan.

Attachments:

Object

Plan for submission evidence base

Representation ID: 10415

Received: 27/07/2022

Respondent: Lone Star Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Introduction

Pegasus Group are instructed by Lone Star Land Ltd ("Lone Star") to submit representations to the Regulation 19 consultation on the Bedford Local Plan 2040.

Lone Star control 1.8 hectares of land south of Roxton Road in Great Barford (the" Site", or the" Lone Star Site" - see land control plan at Appendix A). The Lone Star Site has been assessed as part of the Council's Call for Sites, under site reference 1D915.

Lone Star have been actively engaged with the local community and Great Barford Parish Council since acquiring an interest in the Site. In addition to maintaining a dialogue with Great Barford Parish Council's Neighbourhood Plan Sub - Committee, Lone Star have presented proposals for the Site to the local community via a website, the distribution of leaflets, an individual consultation event in October 2020 and participation at the "Meet the Developers" consultation event in November 20 20. The Site is not allocated for development in the Made Neighbourhood Plan but did score well in the Parish Council's own assessment for deliverability.

Lone Star welcome the opportunity to engage further in the Local Plan process through these represent at ions, having previously made representations to the now adopted Core Strategy and also having made submissions through the Council's Call for Sites and the Bedford Local Plan 2040 Regulation 18 consultation.

• Positively prepared - providing a strategy which, as a minimum, seeks to meet objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and s consistent with achieving sustainable development;
• Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective - deliverable over the Plan period, and based on effective joint working on cross­ boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in the Framework.

These tests of soundness, along with other legal and procedural requirements associated with the Plan-making process provide a contextual framework for these representations.

Representations

The Council's consultation page identifies a number of documents which sit behind the Local Plan. Key amongst these are the 'Site Assessments' and the Sustainability Appraisal.

Lone Star highlighted at Regulation 18 stage that the Council's assessment had not accurately reflected the Site's merits. In particular, the Site was identified by the Council as having possible highway capacity issues. That query, however, was not supported by the Highway Department comments identified in the Site Assessment pro-forma, which acknowledged that the Site could deliver betterment to local connectivity (i.e. widen pre-existing footpaths), and noted that there are no access constraints.

The Site was also assessed as being Best and Most Versatile ("BMV") agricultural land, whilst Lone Star's submission documents to the Call for Sites made clear that whilst it is in class 3, it is unclear if the land is Class 3a (BMV), or 3b (not BMV). In any event, the size of the Site and location of the Site do not make it critical to the viability of an agricultural unit. Finally, the Site Assessments Report queried the Site's ecological value. Detailed survey work has been undertaken on site (and was attached to the Regulation 18 submissions) and identified that whilst the habitat may be suitable for reptiles, the nature of the Site is such that it has low potential of supporting any viable population, and that standard working practice surveys can avoid any harm. The submitted ecological report also identified how a net gain in biodiversity could also be delivered at a nearby off-site location to mitigate any loss on sit e, a point which was also incorrectly referenced in the Council's assessment as being 'uncertain'.

The Council's HELAA which sits behind the Regulation 19 version of the Local Plan, however, has made no attempt to re-evaluate the Site correctly, but rather dismiss en masse, all those sites deemed not to be in accord with the selected preferred strategy. Of 307 sites excluded from consideration in the Stage One initial sift, 293 sites were dismissed for this reason alone. How a preferred strategy is identified when there are significant factual errors in the evidence base (as highlighted by my client's example site), calls into question the veracity of both the preferred spatial distribution strategy, and the site selection process.

Attachments:

Comment

Plan for submission evidence base

Representation ID: 10450

Received: 29/07/2022

Respondent: Biddenham Society

Representation Summary:

We have already provided a comment on Policy DS1(S) Resources and Climate Change through the
formal commentary route but it was unclear where we might provide a comment on the Site
Assessment Pro Formas that impact our historical village.
There are three village sites allocated for potential development in this Local Plan:
- 218 – Land to the rear of 21a to 39 Church End, Biddenham (5+ houses)
- 578 – Land east of Vicars Close, Biddenham (12 houses)
- 808 – Land south of Vicars Close, Biddenham (12 houses)
The proposed infill development of the remaining green spaces in and around Biddenham continues
to reduce the tranquil and rural characteristics of the village, turning it more into a Great Denhamtype
community rather than the historical and rural village that it is. Not only does this detract from
the pleasant visual and community nature of the village but it also reduces the habitat for wildlife
that has always been an inherent part of the village. Such development has far more negative impact
than, for example, adding the same 30-or-so houses to one of the more significant developments
that is planned across the region. Why destroy what we already have through infill and reduce water
run-offs, CO2 absorption and wildlife habitat when alternative plans could easily be implemented?
The Biddenham Society recommends that the inclusion of these sites is reconsidered and not
included within the plan.

Comment

Plan for submission evidence base

Representation ID: 10536

Received: 26/07/2022

Respondent: Barton Willmore

Representation Summary:

Site 896 Rushden Road
The Site is located on the southern edge of Rushden, 12 miles east of Northampton and 17 miles north of Milton Keynes. Rushden offers a range of shops and services, including convenience stores, supermarkets, pubs, primary schools a post office and medical facilities. Additionally, there is also a primary school and pubs in Wymington to the south. The Site is therefore considered to represent a sustainable location for residential development.
The Site is comprised of a number of agricultural fields and an area of existing allotments, and currently extends up to 30.8 hectares. Immediately to the north of the Site are existing properties in Rushden with a public right of way running along the Site’s northern boundary. To the east, the Site is bounded by residential development on Rushden Road as well as Rushden Road itself. Green Lane bounds the Site to the south, beyond which is agricultural fields. To the west are agricultural fields with an existing tree belt along some of the Site boundary.
The Concept Plan (shown within the Vision Document) provides an indicative vision and masterplan for the Site. Following dialogue with the Local Authority, information is provided within the Vision Document which illustrates how the Site could be successfully phased, with the first phase delivering approximately 5.7ha of residential development, alongside landscaping, drainage, infrastructure and community benefits such as public open space in line with the wider proposals.
The overall Concept Masterplan for the Site will retain and enhance existing hedgerows and planting across the Site including extensive new screening planting along the development edge. An integrated sustainable drainage system will be utilised with informal and formal open space accommodated within the development. The existing PRoW will be retained and enhanced to link into the wider network, and the existing allotments within the Site will be retained, with the potential for these to be expanded. The vision for the Site will assist Bedford in sustainably meeting the housing needs of existing and future residents.