1.21

Object

Representation ID: 4420

Received: 31/08/2021

Respondent: Miss Andrea Witham

You have bombarded residents with a vast quantity of documents, many of which are technical and lengthy. And, given the limited amount of time allowed until the consultation period ends, it is unreasonable to expect the layman to assimilate and form any sort of opinion whilst continuing the functions of normal day to day life. I haven't had time to read them all. We have effectively been drowned in documents and many local residents have simply given up in despair.

Object

Representation ID: 4740

Received: 01/09/2021

Respondent: Mr David Rawlins

It is wholly unreasonable to provide so many documents which are technical and lengthy, allow a limited amount of time allowed until the consultation period ends, and then expect local residents to assimilate and form any sort of opinion whilst continuing the function of normal day to day life.

Object

Representation ID: 5613

Received: 07/09/2021

Respondent: Brian Currie Ltd

Agent: Aragon Land and Planning

The current plan policy in the BBLP 2030 which was adopted in January 2020 plans provides polices and allocations until 2030. However, employment and the nature of the local economy has seen significant changes with regard to the needs for employment in the region and Bedford Borough. Some of these changes have also been influenced by the Pandemic which has resulted in a number of employment changes, including a significant growth in home working. The trend locally has also seen both a significant increase in large warehouse development on the edge of Bedford/A421 and second, very little or new employment in the older and historic employment areas whilst some re use has occurred very little inward investment in new build has taken place. There have been notable changes of use away from employment uses to retail and leisure opportunities within these historic employment areas as the market readjusts to try and re use some of these sites. Bedford with its connections to the M1 and A1 and central location is also well positioned to provide for logistics. The Pandemic has highlighted the importance and value of logistics and with retail changes this continues to be change in the type of employment being delivered.

Support

Representation ID: 8232

Received: 26/09/2021

Respondent: Amanda Quince

The consultation references a significant number of accompany policy document that are being
reviewed as part of the Local Plan process. Again, this is a huge challenge to fully understand
the terminology, digest the technical nature of the documents, and to fully appreciate and
understand the context of which these policies will be used by the local authority.
These policies will effectively underpin the strategic development through to 2040, so they are
hugely important. The Parish Council understand the need for robust and effective planning
policy documents to support positive experiences for all stakeholders involved within the
planning process. Whilst the Parish Council are sympathetic to the difficulty in balancing all the
different needs and consideration, it is absolutely critical that these policy documents enable the
local authority decision making process to be secure.
Frustratingly, the Parish Council have seen first-hand on numerous occasions applications and
subsequent developments which have been totally harmful to the rural setting. The local
authority must ensure planning policy documents of the highest standard are developed,
reviewed and updated through this Local Plan 2040 process to make sure that they not only
satisfy the Secretary of State inspection process, but equally crucially that they are strong
enough to be referenced and applied within the local planning process and potentially taken to
the Planning Inspectorate.
Given Renhold’s locality, the Parish Council will set out in 4. Urban Area Boundary Safeguarding
Renhold further specific feedback to the part of the consultation regarding the urban area
boundary.
Housing growth allocation numbers calculated by BBC that have been identified are of concern
to the Parish Council, and this has been shared as well by residents. Whilst the Council are not
familiar with the calculations of such data, it was interesting to read Bedfordshire Campaign to
Protect Rural England’s submission to this consultation which raised some alarmingly and most
worrying discrepancies with BBC’s growth when compared to nearby local authorities.
Therefore, the Parish Council wish to seek clarity on the questions raised given the presented
evidence within the CPRE response that clearly show Bedford Borough having a
disproportionate amount of growth.

Object

Representation ID: 9016

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

In summary, our review of the Local Plan consultation finds that there are a number of areas of the 2040 Local Plan and its evidence base that need further consideration, in some instances due to the changes to the NPPF which were published after the consultation had launched. The three key issues are summarised below:
1 Duty to cooperate - It is not clear that BBC is currently cooperating effectively with HDC in assessing the cross-boundary impacts of the proposed new settlements at Little Barford and Wyboston, which is not in compliance with the NPPF and the duty to cooperate at paragraph 24. The Council needs to show that it is engaging with HDC to determine that the new settlements are deliverable and that they are based on effective joint working across the local authority boundaries. This evidence is also needed to provide communities and other stakeholders with a transparent picture of how they have collaborated.
2 Highways modelling and unlocking the north of Bedford - development of any strategic site north of Bedford appears to have effectively been ruled out on highway capacity grounds. Vectos considers the approach BBC has taken to its 2040 Local Plan site selection using the Predict & Provide approach to traffic capacity that ignores mobility as a whole in line with leading transport guidance is incorrect. It is not policy compliant in the context of the Climate Emergency declared by BBC, the Department for Transport paper – Decarbonising Transport published in July 2021 nor the NPPF, paragraph 7, 11a and 73). This ‘business as usual’ approach is unlikely to be compatible with a 30-year vision (outlined in 3. below) which properly embraces all the changes to sustainable transport that are a realistic prospect over that extended timeframe.
3 Visioning and future housing needs – the introduction of paragraph 22 of the NPPF 2021 provides the Council with the chance to look ahead and plan for the longer term. Although the Council is still without specific housing growth figures to plan for over that period, there is already evidence to suggest needs in excess of the Standard Method to c.45% and the Oxfordshire Plan is already seeking to deliver more than the Standard Method in it’s part of the Arc. A visioning exercise needs to be undertaken to 2050 which as well as increasing housing needs, also considers the very recent changes and expectations of sustainable transportation and active travel in the future across the Arc. The assessment of TwinWoods should be revisited in light of its potential to form part of this vision.
TwinWoods
5.2 In transport modelling terms, TwinWoods has not been considered as a new self-sustaining town, but instead as only additional housing whose residents are attracted to Bedford and beyond. This is an outdated view of development, not reflective of what is proposed at TwinWoods which has embraced the provision of everything communities need in 20-minute neighbourhoods, reducing the need for individual travel. For this reason, the BBC modelling results are not an appropriate basis on which to make determinative planning decisions which would fix directions of growth and represent an effective moratorium on any growth north of Bedford.
5.3 In the context of the 30-year visioning exercise required, combined with the emergence of the OxCam Spatial Framework, which itself is looking c.30 years ahead, Bedford Borough cannot afford to disregard any development to the north of Bedford for future decades on the basis of transport evidence which utilises out of date methods which do not adhere to national planning policy or the decarbonisation agenda, including BBC’s own declaration of a Climate Emergency.
TwinWoods represents a strong opportunity to create a new sustainable settlement capable of providing a significant number of homes to meet Bedford’s long-term housing needs beyond the plan period. It is deliverable, with all of the land in control of the two promoters, and it would involve the re-development of a partial brownfield site. TwinWoods also has the potential to link growth with the East-West rail route as part of a self-contained sustainable settlement, providing its own jobs, services, shops and local connections to Bedford. The previous consultation responses and supporting evidence documents that we have provided, including a detailed Feasibility Report, demonstrates that TwinWoods is a viable scheme that would support the aspirations of the NPPF.

Object

Representation ID: 9068

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

10. Heritage
10.1. The Council’s evidence base in relation to Heritage is unsound and severely lacking particularly in relation to the fact that BBC has not prepared Heritage Impact Assessments on its options to comply with the NPPF and Historic England’s Advice Notes.

10.2. Chapter 16 of the NPPF places an emphasis on the need to conserve and enhance the historic environment. In the context of Bedford Borough, this sentiment is mirrored in the Bedford Borough Landscape Character Assessment (2020), which states that “it is important that the many opportunities for the enhancement of the borough’s historic environment, including its historic landscape character, are realised. Any adverse impacts on the historic environment arising from development should be minimised to avoid degradation. The historic environment provides character and identity to places, and a positive template for new development. It can play a key role in creating a ‘sense of place’ and identities as new communities are created and existing ones enhanced”. Despite this, the Draft Local Plan and its evidence base provide very little information relating to the historic environment. CPC is therefore concerned that the absence of historic information could result in the degradation of heritage assets.
10.3. The Bedford Borough Landscape Character Assessment refers to the Church of St Denys, Colmworth, as is states that “the spires of stone-built churches (such as St Denys at Colmworth) are landmarks in this fairly level, open plateaux landscape”. It is worth noting that the Church of St Denys is a Grade I listed church dating back to 1430.
10.4. The Figures below highlight the view from Honeydon Road to the Church of St Denys in relation to the site plan of the proposed Dennybrook scheme. As shown below, the western boundary of the proposed development would sit within the historic setting of the Church of St Denys. With this in mind, it is clear that the Regulation 18 Local Plan does not align with paragraph 195 of the NPPF, as the local planning authority has failed to assess the significance of the Church of St Deny that how it (and its surroundings) would be affected by a proposal.

INCLUDES FIGURE 10.1: VIEW CONE OF PHOTO AND PHOTO OF VIEW ON HONEYDON ROAD WITH THE DENNYBROOK SITE HIGHLIGHTED

10.5. In relation to the Dennybrook site and the impact on the Church of St Deny’s, the Wyboston Garden Village Heritage Impact Assessment (2021) states that “there are views to the Grade I listed Parish Church of St Denys at Colmworth from the western area of the Site (Plate 2), and distant views to the tower from parts of the central area of the Site. The use of open space in the western area of the Site as indicated in the Concept Masterplan would put built form over 1.5km east of the church. It would also avoid built form within the church’s historic parish (Colmworth). While there might be some loss of views to the spire from the wider area, it is not anticipated that this in itself would be sufficient to adversely impact the significance of the listed building.” This argument cannot be justified, as, in acknowledgement that key views to and from the Church of St Denys would be lost, the Wyboston Garden Village is in conflict with paragraph 130c) and d) of the NPPF, as it is clear that the Wyboston Garden Village proposal is not sympathetic to the surrounding built environment and will in fact erode the local area’s sense of place.
10.6. It is also worth noting that a recent appeal regarding 49 dwellings in a Suffolk village was partly dismissed on the grounds that the inspector deemed there to be a high impact on a manor house and two barns and a medium impact on a grade II* church. The Inspector felt that the public benefits of the development did not outweigh the harm to heritage assets and therefore this provided a clear reason for refusal in accordance with paragraph 11d) of the NPPF. Similar to the above, the Wyboston Garden Village Heritage Impact Assessment (2021) notes that the following Grade II listed buildings are within or immediately adjacent to the proposed site: “Dairy Farmhouse (1114114), at the northern edge of the Site, west of Honeydon; Chestnuts Farmhouse(4321615), at the northern edge of the Site on the southern side of Honeydon; Sudbury Farmhouse (1146461), within the central area of the Site; Eaton Tithe Farmhouse (1157864), within the eastern area of the Site; Moat Cottage (1146457)”. By applying clause b ii) of paragraph 11 of the NPPF, it is clear that the adverse impacts of the Wyboston Garden Village proposal would significantly and demonstrably outweigh the benefits of the proposal, and on that basis this site should not be considered for development.
10.7. Historic England has prepared a number of Advice Notes with its guidance on how authorities should approach heritage in the Local Plan and in their selection of potential sites including the potential impacts on heritage that might result from the proposals. There are two of these Advice Notes we would like to bring to the attention of BBC:
• The Historic Environment and Site Allocations in Local Plans (Historic England Advice Note 3) October 201543.
• Statements of Heritage Significance: Analysing Significance in Heritage Assets (Historic England Advice Note 12) October 2019
10.8. There is no evidence available in the Local Plan or its supporting documents that sets out how the Local Plan process has complied with the NPPF (and the Historic England guidance) in respect of heritage (including archaeological, architectural, artistic or historic, or a combination of these) in terms of considering which development options to select and then the need to assess the heritage impact from these proposals. At a minimum the Council should have undertaken the following staged approach as set out in Advice Note 12 (see paragraph 6):
1. Understand the form, materials and history of the affected heritage asset(s), and / or the nature and extent of the archaeological deposits
2. Understand the significance of the assets
3. Understand the impact of the proposal on that significance
4. Avoid, minimise, and mitigate negative impact, in a way that meets the objectives of the NPPF
5. Look for opportunities to better reveal or enhance significance

SEE OBJECTION TO SITE 977 DENNYBROOK FOR CONTEXT AND MORE INFORMATION