New Settlements Assessment

Object

Representation ID: 9318

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investment LLP

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

The Local Plan is not legally complaint owing to its failure to comply with the duty to co-operate and fails to meet the tests of soundness. Our review of the New Settlements Assessment finds that the chosen spatial strategy is not positively prepared or justified. The Assessment contains factual errors, is inconsistent in its approach and does not represent a suitable, fair and objective assessment of the new settlement options. Further, the SA objective scorings within the Assessment are contrived to bolster the planning and sustainability case for Little Barford, impacting the chosen spatial strategy as a whole.

Comment

Representation ID: 9939

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: 10088

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 community in which they sit is largely accepting of what they do. Existing communities have expectation of intrusion from SPR as they have evolved along with the raceway. This same form and level of expectation cannot exist for any new community who naturally expect development is permitted with their quality of life already protected as part of the assessment process.
Trakbak Racing Ltd previously commissioned a ‘Review of Noise Impact in relation to Santa Pod Raceway’ (dated 27th March 2018), from MAS Environmental. This report outlines the unacceptability of a housing proposal nearby to SPR and forms an important part of this representation. Paragraph 1.25 (on page 7) of this report explains that it will not be possible to achieve a satisfactory noise environment for a nearby housing development as it would fail to meet numerous objectives of planning guidance and seeks to introduce a large number of noise sensitive receptors at a distance of 500m - 1km from the SPR site. The same paragraph of this report goes further to state that “Noise at dwellings would be dominant, at times highly intrusive and significantly above background sound levels. Widespread complaints are expected and control by way of statutory nuisance (whether privately or by the Council), use of Community Protection Notices or common law action should be expected”.
SPR would certainly expect to be the subject of legal injunctions and be in conflict with new residents if houses were to be built this close to its venue. MAS Environmental have previously assessed that, without substantial changes at the Santa Pod site, this potential conflict would likely lead to the demise of the Santa Pod business as a direct result of noise complaints and potential noise nuisance claims1. In this context it is important to state that paragraph 187 of the NPPF explains that "Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established". Any housing on 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.
1 Reference to this can be found on page 1 and 63 of the Appendix 2 (Review of Noise Impact in relation to Santa Pod Raceway) which outlines a composite list of noise assessments undertaken by MAS Environmental

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
2 Great Britain. Department for Environment and Rural Affairs (DEFRA) (2010) Noise Policy Statement for England

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.

Comment

Representation ID: 10148

Received: 29/07/2022

Respondent: Roebuck Land and Planning

New Settlements Assessment
The document highlights the lack of information for Little Barford New Settlement and the many references to needing to undertake further work to complete the assessment. The reliance upon documents provided by the promoters is unhelpful given that most were submitted on a confidential basis and have not been made available for public to view in order to understand the issues under consideration. All documents being relied upon must be placed within the public domain and a further period of consultation undertaken to allow consideration and comment as necessary.

Object

Representation ID: 10235

Received: 29/07/2022

Respondent: Taylor Wimpey

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? No

TW object to the New Settlement Assessment Paper, specific in relation to the sustainability
scoring of Wyboston and Little Barford.
Please see attached representations…specifically section 3, paragraphs 3.1-3.28, section 4
paragraphs 4.1- 4.3, section 5 paragraphs 5.2 bullet 3, 5.6, section 6, Appendices A,B,C.

Comment

Representation ID: 10407

Received: 29/07/2022

Respondent: The Executors of the late Nigel Alington

Agent: Code Development Planners Ltd

This section provides an assessment of the methodology used by BBC in carrying out the sustainability
appraisal exercise.
2.2 Appendix 1 of this representation shows CODEs interpretation of the SA process followed by BBC and
is used to provide a structure for these representations.
2.3 In considering the options, the SA first considered the amount of growth and then the options for
distribution. In considering the options for the distribution of growth, five broad components for growth
were identified and tested against the SA objectives. Subsequently various combinations of these broad components for growth were devised to form a ‘long list’ of potential growth strategies before assessing
detailed site alternatives.
3 Assessment of the Sustainability Appraisal Framework and reasonable alternatives
Sustainability appraisal objectives
3.1 The sustainability objectives have been developed following a review of relevant international and
national polices, plans and programmes, together with baseline information, taking account of
international and EC objectives. For the prevalent themes and topics identified the subsequent review
of evidence has led to the identification of key sustainability issues for which one or more objective
encapsulates the key issues that have been identified.
3.2 Having established the key issues a Sustainability Appraisal Framework has been produced. This is
the recognised way for testing social, economic and environmental effects of the local plan and
alternatives. The Sustainability Appraisal Framework is found in Appendix 1, Pg.1 of the Sustainability
Appraisal Report Appendices, (April 2022) (Appendix 2 of the representations)
3.3 CODE is broadly supportive of the approach used in identifying the sustainability appraisal objectives
and the framework applied in assessing local plan polices, proposals and objectives. However, we have
a noted amount of duplication across the assessment of Little Barford as a site in the New Settlement
Assessment Document and as a part of the local plan policy assessment for Policy HOU19.
Developing and refining options and reasonable alternatives
3.4 The following section provides a more detailed comment on the process the Council has followed in
developing a series of reasonable alternatives for growth and the assessment of those options.
Particular focus is given to the growth strategy options and the consideration of the Little Barford site
within the various options.
Options for the amount of growth
3.5 The Council has used the NPPF requirements for local planning authorities to assess local housing
needs, informed by a local housing needs assessment that is conducted using the standard method in
National Planning Practice Guidance as a starting point for considering the amount of growth the plan
will deliver.
3.6 The local housing needs assessment shows that the local plan must provide a minimum 1,355 dwellings
per year. Over the 20-year plan period the Council will therefore need to allocate land to enable a
minimum of 27,100 dwellings to be delivered. However, with existing commitments of 14,824 dwellings
there is a need to allocate sufficient land to deliver a further 12,276. The Council appointed Opinion Research Services to undertake Bedford’s local housing need assessment (May 2021) and was
prepared following the Standard Method revised as of December 2020.
3.7 In considering reasonable alternative amounts of growth to be provided by the local plan the Council
considers a figure lower than the 12,276 is not realistic due to NPPF requirement for plans to meet
assessed needs in accordance with the standard method. This is the minimum amount of growth to be
planned for and as such the Council has also assessed a higher growth figure where the local plan
would need to allocate 14,986 new dwellings. This figure has been based on a 10% uplift to the local
housing needs assessment. In assessing the options for the amount of growth, the higher growth option
shows that there were likely to be more negative effects when assessed against the sustainability
objectives. The Council concluded that the higher level of growth would exceed the identified needs
and result in a number of negative effects on the sustainability appraisal objectives which would exceed
any identified benefits and as such is not considered a reasonable option for growth. The Council
concludes that the only reasonable option for the level of growth to be planned for is the growth option
which meets the assessed housing needs for growth. We consider that the Council has sufficiently
considered the reasonable alternatives for the amount of growth.
Sustainability appraisal testing - Options for the distribution of growth – Broad spatial
components
3.8 Following the Issues and Options consultation in 2020 the Council worked to devise a strategy and
define specific strategy options for consultation in relation to the location of development. Having
consulted on six potential development locations in 2020, the Council drew these options together into
five broad components of growth:
• Within the urban area (sites within the urban area boundary).
• Adjoining the urban area (all or part of the site is within 0.5 miles of the urban area boundary).
• Village related (Key Service Centres and Rural Service Centres).
• New settlements (Wyboston, Little Barford, Twinwoods, Colworth).
• A421 transport corridor with rail based growth (stations at Kempston Hardwick, Stewartby, Wixams
and at a location between St Neots and Tempsford).
- Transport corridor –growth focused on Kempston Hardwick, Stewartby and Wixams (railbased
growth)
- Transport corridor – south (the parishes of Wootton, Kempston Rural, Elstow, Wilstead,
Shortstown, Cotton Endo
- Transport corridor – east (the parishes of Cardington, Cople, Willington, Great Barford,
Roxton, Wyboston and Little Barford)
- Transport corridor – growth focused on new settlements in the A421 corridor (Wyboston and/or
Little Barford).
3.9 The broad components have been derived following the 2020 Issues and Options consultation paper
which considered six potential development locations. These were:
• Urban based
• A421 based growth
Rail growth
• East West Rail northern station growth
• Dispersed growth
• New settlement-based growth
3.10 The consultation document made clear that these locations would then form the building blocks for
potential development options for further consultation in the draft plan and made clear that the final
strategy would likely combine a number of the development locations listed above.
3.11 All of the potential spatial development options will be made up from one or several of the component
locations for growth. As an initial exercise, and before the reasonable alternatives are considered, the
Council assessed how each broad component of growth compared in principle when assessed against
the sustainability appraisal objectives.
3.12 In reviewing the broad spatial components CODE notes that the site at Little Barford has been
considered as part of two of the options, that of new settlements and as part of the A421 transport
corridor with rail-based growth. CODE contends that the proposal at Little Barford could in fact be
considered as part of a further broad spatial options component; adjacent to the urban area and benefit
from the associated sustainability benefits. The following section goes on to discuss the implications of
including the new settlement at Little Barford within this additional component.
Broad spatial component - Adjacent to the urban area
3.13 This section provides comment on the orange box within the CODE SA flow chart.
3.14 CODE would contend that the Council and the Sustainability Appraisal has failed to take into account
the relationship between the site at Little Barford and the adjoining urban area of St Neots, instead only
focusing on the areas adjoining Bedford.
3.15 The site at Little Barford shares its northern boundary with the RWE gas power plant and Alington Road Industrial Estate, which although located within Bedford Borough, is adjacent to the urban area of St
Neots, Huntingdonshire. St Neots has been identified within the Huntingdonshire Local Plan to 2036 as
one of four spatial planning areas. This designation is the highest order settlement and reflects St Neots’
status as a traditional market town and as one of the most sustainable centres for development1. As
such, the site at Little Barford should be considered within the 0.5 miles of the urban area boundary
and considered as part of the broad spatial option for adjacent to urban area growth locations.
3.16 The relative positions of St Neots and Little Barford within the settlement hierarchy, with St Neots
categorised as the equivalent of a strategic or district centre and Little Barford as a local centre: key service centre (policy TC1(S)) recognises that whist the day to day needs of the residents of the new
settlement of Little Barford will be provided on site, residents would travel beyond the new settlement
for access to higher order facilities. The proximity of the two settlements to one another enables such
journeys to be made by sustainable and active modes of travel.
3.17 Recognising that the new settlement at Little Barford should also be assessed as ‘adjacent to the urban
area’ further demonstrated the site as being part of a sustainable strategy for growth when considered
against the 15 sustainability objectives and should be considered as equally, if not more sustainable
when assessed as part of the new settlement and A421 transport corridor with rail-based growth spatial
options for development. The table below ‘Summary of broad components of growth testing’ (Pg. 45,
Sustainability Appraisal Report Appendices, April 2022) shows that the option for growth adjacent to
urban areas scores much more positively when considering sustainability objectives 3 - Reduce
emissions of carbon dioxide and improve energy efficiency, 6 - Promote vital and viable town centres
and 15 - Reduce the need to travel and promote sustainable modes of transport. [see table in original submission]
The sustainability appraisal testing shows that development adjacent to the urban area should be
assessed as a major positive when considered against the sustainability objective to reduce emissions
of carbon dioxide and improve energy efficiency. Concentrating development around existing urban
areas is likely to reduce the need to travel and the length of trips undertaken by private cars and
commercial vehicles which are a major source of emissions. In locating development close to major
destinations, in this case St Neots and the services and facilities available within, the likelihood of travel
by walking and cycling for residents and employees is increased. Concentrated development also
increases the viability of public transport which can further reduce emission levels as an alternative to
private vehicles.
3.19 Similarly locating development adjacent to the urban area also provides major positives in reducing the
need to travel and the promotion of sustainable modes of transport. Once again, the need to travel
should be reduced due to the proximity of services and facilities and the location would benefit from an
enhanced public transport service providing real alternatives to the private vehicle.
3.20 The Council’s own evidence base in relation to transport have modelled the provision of a high
frequency bus route between St Neots and Sandy, stopping at the new settlement at Little Barford,
further demonstrating the benefits associated with the new settlement proximity to an urban area
location with regards to sustainability objectives 3 and 15.
3.21 Further to the high frequency bus service the new settlement will also provide a range of alternative
sustainable transport links both within the settlement and to the neighbouring urban area of St Neots
which includes an existing station on the East Coast Main Line. [Paragraph 6.1.2, pg. 24, Transport
Technical Note, WSP, July 2022]
3.22 In light of the above, CODE contends that the Little Barford new settlement does indeed fit within the
parameters of adjacent to urban area spatial growth option and can demonstrate significant positives
associated with the sustainability objectives 3 and 15. When compared with those assessments for new
settlements and A421 transport corridor growth there is clear differences demonstrating ++
assessments against these two sustainability objectives. The rightful inclusion of Little Barford within
this board spatial growth option further demonstrates the site’s sustainability and supports the allocation
for a new settlement.
3.23 The further benefit associated with adjacent to urban area development is associated with the locations
ability to promote vital and viable town centres. In identifying the issues around employment, business,
retail and tourism which have shaped the sustainability objective 3 the Council has identified the key
issue of promoting the vitality of Bedford and Kempston town centres (Paragraph 3.71, pg. 44,
Sustainability Appraisal Report, April 2022). Whilst CODE acknowledges the Little Barford site location
is unlikely to benefit those town centres in Bedford and Kempston the site’s location on the edge of
St Neots cannot be overlooked.
St Neots will provide future residents of the new settlement with access to high order facilities such as
cinemas, and other entertainment and leisure, and a wider range of employment that will not be
provided by the new settlement. Policy HOU19 details how the new settlement will provide ‘all the key
services and facilities to address its own needs, including health, education, retail, culture and
community components.’ The need to establish and sustain these key services and facilities to address
the day to day needs of residents of the new community at Little Barford is supported by the landowners.
The Transport Technical Note (July 2022) submitted in support of these representations explains the
proposals commitment to self-sufficiency through inter alia the delivery of on-site social infrastructure
including education, health, retail, sport and leisure and other community facilities supported by digital
communications infrastructure assisting in minimising the need to travel externally from the site.
However, the sites proximity to the urban area of St Neots is a positive factor, the principle of which is
recognised in the other sections of the SA. High frequency bus service and new active travel would
connect with existing routes and the National Cycle Network will ensure there are a greater percentage
of journeys beyond the site can be undertaken by sustainable modes of transport than a site that is not
adjacent to an urban area. This should be reflected in the SA in the assessment of Little Barford. It
demonstrates that although the proximity to EWR is a significant advantage over other locations in the
choice for Little Barford as the location for a new settlement. However, even in the absence of EWR,
Little Barford’s location in the borough and its relationship to other urban areas makes is a sustainable
choice.
3.25 It would assist the BBLP2040 objective for Little Barford to cater to the day to day needs of its residents
if Policy HOU19 and TC1(S) identified the new settlement as a local centre: Key service centre.
Currently the Council has failed to designate the new settlement within the hierarchy of town centres
as set out in Policy TC1(S). CODE therefore contends that in order to deliver the required town centre
facilities as set out in Policy HOU19 the new settlement at Little Barford should be included within the
town centre hierarchy as a ‘Key Service Centre’. This would follow a similar approach to Wixams new
settlement which ‘is identified as a potential key service centre, as over the course of the plan period,
the planned town centre will be constructed and, once complete, will serve the settlement’ (Paragraph
5.7, pg. 85, Local Plan for Submission, BBC, April 2022)
3.26 Doing so would allow for the provision of town centre uses within the new settlement and, whilst not
promoting the vitality or viability of Bedford or Kempston town centres will allow for the creation of new
suitably sized key service centre, within Bedford Borough as an integral part of the new settlement at
Little Barford. The table produced under paragraph 2.5 of the Town Centre and Shopping Polices Topic
Paper (April 2022) indicates that key service centres will serve a primarily local catchment but also the
surrounding rural area through the provision of a range of shops of a local nature that could include a
small supermarket, newsagent and pharmacy type facilities. In making provision within allocation Policy
HOU19 for a defined ‘town centre’ area, BBC will remove the need to apply a sequential test for main town centre uses within the defined area. This would be one element to encourage take up and assist
in establishing, in early phases of the development, services and facilities for the community to use and
the associated sustainable travel patterns.
3.27 This demonstrates an overlap between the objectives set out within the SA where although the new
settlement at Lille Barford may not support vitality and viability within Bedford and Kempston but
benefits from enhanced the proximity to an out of district town centre with regards to objectives 3 and
15 and the desire to reduce emissions of carbon dioxide and promote sustainable modes of transport.
Development strategy options
3.28 Having established the broad components for growth BBC further refined its options for growth. Using
the broad components for growth in different combinations produced 16 alternative strategies for
development. In developing these strategies BBC considered that all but two had the potential to meet
the housing and employment figures of the plan and have therefore been considered reasonable
alternatives.
3.29 These options are set out in the Development Strategy Topic Paper (Paragraph 3.13 – 3.14, pg. 8 –
21, May 2022)
3.30 Each of the 14 options have then been assessed against the 15 sustainability objectives. It is highlighted
by the Council that in some instances no difference can be distinguished between the options, as the
assessment at this stage is being undertaken at a strategic level and a number of the SA objectives
require more detail associated with specific site circumstances. This means that a meaningful
assessment of objectives relating to biodiversity, historic environment and promoting social cohesion /
preventing crime is not possible. BBC explains that ‘as a result, certain sustainability objectives have
been assessed as more significant in assessing the strategy alternatives’ (Paragraph 8.8, pg. 93,
Sustainability Appraisal Report, April 2022).
3.31 Having assessed the reasonable alternatives for the distribution of growth the Council has identified
Option 2bi as its preferred option for growth distribution. This shares housing growth between Stewartby
/ Kempston Hardwick and Wixams which has benefits for delivery, whilst maintaining a sufficient level
of growth to enable housing needs to be met and to support major strategic green infrastructure projects
(Paragraph 9.7, pg. 102, Sustainability Appraisal Report, BBC, April 2022). Additional to the growth at
Stewartby / Kempston Hardwick and Wixams this option also includes the provision of one new
settlement at either Wyboston or Little Barford.
4 Distribution of growth – detailed site alternatives
4.1 Having established a preferred strategy for the location of development the SA then moves on to
provide detailed site assessments of all the proposed sites to fit within the preferred strategy. This helps inform the process of selecting sites for inclusion within the local plan by identifying whether a
site is likely to produce positive, negative or uncertain effects in relation to the SA objectives with the
exception of new settlements which are assessed separately within the New Settlements Assessment
Topic Paper (April 2022)
New settlements assessments
4.2 This section provides comment on the yellow box within the CODE SA flow chart.
4.3 Proposals for four new settlements have been put forward in the new local plan. The Council has made
the decision that the new settlements should be assessed for allocation using a bespoke criteria
specifically designed for large, standalone developments. Details of this are set out in section 3 of the
New Settlement Assessment Document (Paragraph 3.1, pg. 4, April 2022). This includes a range of
Council identified criteria along with an assessment of each new settlement against the 15 sustainability
objectives.
4.4 In assessing the site at Little Barford the Council has failed to consider the points raised earlier in the
representations that not only does the proposal fit within the broad spatial components of ‘new
settlements’ and ‘A421 travel corridor growth’, but also as ‘development adjacent to an urban area’.
Failing to recognise the location on the edge of an urban area has resulted in what CODE considers an
inaccurate assessment of the site against some of the sustainability appraisal objectives where most
positive scores would be wholly justified. Once again these relate to issues around the reduction of
emissions of carbon dioxide and the promotion of sustainable transport methods.
4.5 The testing goes on to show that the negative effects of the assessment against the SA objectives are
less severe for Little Barford and Wyboston in relation to air quality, carbon dioxide and travel objectives
than for Colworth and Twinwoods. Paragraph 8.26 of the Sustainability Appraisal Report (April 2022)
indicates that these benefits are derivative of both Little Barford and Wyboston’s location in relation to
new stations proposed as part of the East West Rail infrastructure project. Once again CODE contends
that were proper consideration given to the site’s location adjacent to an urban area (one which includes
a railway station on the East Coast Mainline), these negative effects should in fact be considered
positive effects. The development of Little Barford not only creates a new settlement but is in a location
that facilitates journeys by sustainable and active modes of travel to higher order facilities whilst also
reducing the distance to be travelled. Locating development close to the major destinations or highlevel
facilities within the neighbouring St Neots also increases the likelihood of travelling by walking and
cycling for residents and employees.
4.6 In explaining their preference for the land at Little Barford paragraph 9.10 of the Sustainability Appraisal
Report states ‘The Council prefers Little Barford because it is more conveniently located to the planned
East West Rail interchange and avoids the loss of high quality agricultural land.’ CODE believes that the justification for the selection of Little Barford should also recognise its unique
geographical location positioned close to and well connected by sustainable and active modes of
transport to another settlement further up the settlement hierarchy in St Neots which includes a railway
station on the East Coast Mainline. The settlement hierarchy with St Neots in a higher tier of settlement
than Little Barford, protects St Neots from competition from Little Barford whilst recognising that there
will be a relationship between the two. The above representations further strengthen the allocation of
the land and Little Barford by demonstrating that enhanced levels of sustainability should be considered
when assessing the site as part of the broad spatial options considered by the Council. Had the Council
assessed the site as an edge of urban area site positive effects would have been identified when
assessed against sustainability objectives 3 and 15. In assessing the site in such a way it has become
clear that, although the Council has stated Little Barford is the preferred option as a result of its location
in relation to East West Rails proposals, the delivery of East West Rail is not fundamental to the delivery
of a self-sustaining settlement at Little Barford. Internal links within the settlement to proposed town
centre uses and external links to higher order services and facilities within St Neots, which supplement
and complement the range of facilities to be provided within the development, serve to demonstrate the
sustainability of the location and support the sites allocation.
4.8 In addition to changes in the assessment of the Little Barford new settlements sustainability scores for
objectives 3 and 15, CODE also considers there to be additional SA objectives where the proposals
have not been properly considered.
Biodiversity and green infrastructure – Protect, maintain and enhance biodiversity and habitats
4.9 As part of the New Settlements assessment the site at Little Barford has been assessed as having an
‘uncertain’ impact with regards to SA objective 2 (Pg. 32, New Settlements Assessment Topic Paper,
April 2022). As part of the Regulation 18 consultation representations and a suite of evidence was
submitted in support of the site at Little Barford, evidence which CODE feels demonstrates clear
positives when considered against the assessment criteria.
4.10 A County Wildlife Site (CWS) is located on land within the Alington Estate. The CWS designation covers
the field between Lower Farm Barns and St Deny’s Church, the adjacent grazed field to the south of
the access track to the Church and an area of wetlands/wet woodlands adjacent to the River Great
Ouse. Although no development is proposed on the CWS, it is included within the land proposed for a
new settlement allocation so that an appropriate programme of management can be implemented which
may over time enhance the grassland habitats (refer to Botany Assessment of Grassland Component
of Little Barford CWS, September 2021). Extended phase one habitat surveys have been undertaken in respect of land within the Alington Estate,
west and east of the ECM (refer to Preliminary Ecological Appraisals, September 2021 and July 2022
(PEAs)).
4.11 The PEAs establish that the site supports a range of protected species the likely impacts, mitigations
and enhancement measures have been considered. The PEA concludes that with suitable measures
there will be no negative residual effects associated with the development. Further details can be seen
in table 8 of the PEA.
4.12 PEAs have been undertaken for the site and established that, “Through incorporation of further surveys,
mitigation, and precautionary methods, it is considered that the site could deliver a significant
biodiversity net gain in terms of measures to support high value habitats and protected species and to
carry this out in line with current wildlife legislation, chapter 15 of the NPPF (MHCLG, 2021); and local
planning policies relevant to ecology.” (Paragraph 5.2, pg.26, PEA, SES, September 2021). The
proposed development provides an opportunity to deliver landscape scale biodiversity benefits that
enhance habitats within and adjacent to the River Great Ouse floodplain and strengthen the ecological
connectivity for priority habitats and protected and notable species. Furthermore, the relevant
documents (as set out in paragraph 1.5) are submitted in support of these representations so they can
continue to be considered as part of the local plan preparation process.
4.13 The most western area of the site is within the Lower Great Ouse River Valley green infrastructure
opportunity zone under Policy AD24 of the Bedford Borough Allocations and Designations Local Plan,
July 2013. Paragraph 6.3 of the Transport Technical Note (July 2022) explains of the feasibility and
deliverability of a multi-user route along the River Great Ouse will be considered as an option to
accommodate pedestrians and cyclists travelling through the site. This again supports the SA objective
and evidence has been prepared to demonstrate positive effects of the proposal in relation to its
delivery.
4.14 Having regard to the above CODE therefore contends that the proposal site at Little Barford should be
assessed as at least having minor positive impacts in the delivery of SA objective 2.
Appraisal findings – the preferred approach
4.15 Having assessed the reasonable alternatives for the distribution of growth the Council has identified
Option 2bi as its preferred option for growth distribution and includes a new settlement at either
Wyboston of Little Barford. The Council has chosen this despite option 2a being the best performing
option for the distribution of growth when considered against the sustainability objectives. Paragraph
9.5 of the Sustainability Appraisal Report (April 2022) explains that the decision has been made
‘because of its [Option a’s] extremely high concentration of growth on one location at Stewartby / Kempston Hardwick, which presents challenges of delivery and increased risks to the plan’s delivery
as a whole.’
4.16 Paragraph 10.1 of the Sustainability Appraisal Report (April 2022) explains the main focuses of the
preferred option and includes reference to ‘a new settlement and related employment provision at Little
Barford well connected to the new East West Rail interchange with the East Coast Main Line.’
4.17 In assessing the new settlement proposals against the sustainability objectives (part of the New
Settlements Assessment criteria) both Little Barford and Wyboston perform better the Twinwoods and
Colworth. The Council considers both Little Barford and Wyboston to be consistent with the Councils’
preferred broad spatial option for growth which concentrates growth within the A421 transport corridor
with rail-based growth.
4.18 The sustainability appraisal testing has shown that each site can deliver positive effects, particularly in
relation to the following sustainability appraisal objectives:
• Promote strong, sustained and balanced economic growth, stimulating job creation across a range
of sectors.
• Encourage and support physical activity.
• Protect the quantity and quality of water resources.
• Promote good quality housing, ensuring an appropriate mix of house types and sizes.
• Provide for residents’ needs and improve access to community services and facilities.
• Promote social cohesion, the prevention of crime and reduce the fear of crime.
4.19 The Council explains that in choosing between Little Barford and Wyboston the preferred option is Little
Barford because it is more conveniently located to the planned East West Rail interchange and avoids
the loss of high-quality agricultural land.
4.20 This fits in with the Council’s preferred strategy for growth locations within the A421 transport corridor
and with potential rail-based growth. However, these representations have demonstrated that the site
at Little Barford should not be considered solely as a location for rail-based growth in respect of reliance
upon EWR. The location on the edge of St Neots has considerable sustainability benefits which have
not been fully assessed by the Council but are raised within this representation. Assessing the site in
this manner clearly shows additional positives when assessed against the SA objectives and would
further strengthen the allocation.
4.21 Having established the preferred option, this is then tested against the sustainability appraisal
objectives with the results shown in paragraph 10.3 of the Sustainability Appraisal Report (April 2022)
This is a broad assessment of the preferred option as a whole and is then followed by an assessment
against the SA objectives of the draft local plan for submission to the Planning Inspectorate for
examination on a policy-by-policy basis.
Sustainability appraisal testing – Local Plan Polices - Policy Hou19 Little Barford new settlement
4.22 This section provides comment on the green box within the CODE SA flow chart
4.23 The SA appraises each of the polices that are included in the draft plan for submission. The policies
are evaluated against the Sustainability Appraisal Framework (Appendix 1, Pg.1 of the Sustainability
Appraisal Report Appendices, April 2022). Each policy is assessed to determine whether it supports
or conflicts with each sustainability objective, the size of impact and how this may change over time.
The assessment of the sites that are development allocations in the local plan is based on the detailed
site assessment questions of the Sustainability Appraisal Framework. The assessment in full is set out
in Appendix 11 of the Sustainability Appraisal Report, where new settlements are assessed in the
separate New Settlement Assessment Topic Paper.
4.24 There appears to be some conflict or confusion around the exact methodology of assessment for the
new settlements and the criteria they have been assessed against. Accounting for the above the
Council has previously explained that the assessment of the four new settlement proposals is
undertaken using bespoke criteria specifically designed for large, standalone developments as
explained and set out in the New Settlements Assessment Topic Paper (April 2022).
4.25 We agree with the overall conclusions and outcomes, but CODE has identified inconsistencies across
the assessment of SA objectives 3, 6, 7, 13 and 15 where some of the objectives seem to recognise
the benefits associated with the site’s location on the edge of St Neots whilst the assessment of other
objectives fails to do so. Objectives 3 and 15 have, as above been highlighted, as objectives improperly
assessed. Corrections to the inconsistencies we raise in the assessment would only reinforce the result
that Little Barford is a sustainable location for new settlement growth.
SA objective 3. Reduce emissions of carbon dioxide and improve energy efficiency
4.26 The Council has commented that as a ‘self-contained’ new settlement it is expected that the settlement
be largely self-supporting in terms of amenities and services and therefore reduces the needs for
residents to travel outside of the settlement. Where travel, out from the settlement is required walking
and cycling provision, together with the high frequency bus service between St Neots and Sandy means
there is the potential to minimise car use. As explained in the table on page 36 of the Sustainability
Appraisal Appendix ‘Ensuring that major destinations are close together means that there is a greater
likelihood of travel by walking and cycling for residents and employees. Concentrated development also
increases the viability of public transport, which is a lower producer of carbon dioxide per head than
private car travel.’ And should be considered a major positive when assessed against the SA objective.
This is before considering the additional sustainability benefits and public transport options that could
be further provided by the East West Rail line. SA objective 15. Reduce the need to travel and promote sustainable modes of transport.
4.27 The assessment of policy HOU19 against SA objective 15 has resulted in the scoring of minor negative
effects across the short, medium and long term. The comments provided by the Council explains that
a self-contained new settlement would be expected to be largely self-supporting in terms of amenities
and services thus reducing the need for residents to travel outside of the settlement. Walking and
cycling provision, together with improved bus links to St Neots and proximity to a planned East West
Rail station mean that car use is likely to be minimised. However, there are still likely to be trips by car
for employment and services that cannot be met within the settlement and are not easily accessible by
public transport.
4.28 CODE would refute the final sentence of the Council’s assessment and highlight the assessment SA
objective 15 when considered against the edge of urban area growth spatial option. Scoring a major
positive it is recognised that ‘Concentrating development is likely to reduce the need to travel and length
of travel by private car and commercial vehicles. Ensuring that major destinations are close together
means that there is a greater likelihood of travel by walking and cycling by residents and employees.
Concentrated development also increases the viability of public transport.’ (Sustainability appraisal
testing, broad components of growth, Adjacent to urban area table, pg. 35 - 38, Sustainability Appraisal
Report Appendices, April 2022)
4.29 The location of Little Barford adjacent to St Neots will provide future residents of the new settlement
with access to high order services and facilities that may not be provided by the new settlement itself.
Access to these facilities will be promoted through a range of sustainable modes including walking and
cycling [Transport report, WSP, July 2022] or public transport facilities (high frequency bus service
between St Neots and Sandy) [Transport report, WSP, July 2022].
4.30 East West Rail would provide an additional benefit by providing a sustainable alternative to the car for
those long-distance journeys. However, given the proximity of St Neots and the high order facilities that
are on offer there it is considered that a majority of the needs of future residents of the new settlement
at Little Barford could be met whether by the settlement itself or St Neots train station.
5 Conclusions
5.1 CODE Development Planners considers that the BBLP 2040 is broadly in accordance with the legal
requirements and meets the tests of soundness have been met.
5.2 Despite this CODE has some concerns over the assessment of the site at Little Barford and the
application of assessments of broad spatial components in assessing the sustainability of the site. In
recognising the site’s location on the edge of St Neots the Council would identify additional positive
effects against sustainability objectives 3 and 15 of both the site assessment and assessment of Policy HOU19. Assessing the site with proper consideration of the location on the edge of St Neots provides
further justification for the allocation, additional to the Councils reasoning for allocating. The Council
have stated that Little Barford is the preferred option for a new settlement because of its convenient
location in relation to the planned East West Rail interchange and because the site avoids the loss of
high-quality agricultural land. The above representations have demonstrated that whilst the site does
benefit from the East West Rail the selection of Little Barford new settlement is justified even in the
absence of East West Rail. Where there is a need to leave the new settlement the location adjacent to
St Neots and planned pedestrian, cycle and public transport enhancements provide highly sustainable
means of access. [See appendices in attachment.]