4.1

Object

Representation ID: 3452

Received: 12/07/2021

Respondent: Mr Gordon Message

Plan is calling for new sites when there are some previously approved ones that have not been developed.

Object

Representation ID: 3817

Received: 26/08/2021

Respondent: Roxton Parish Council

Until sites are allocated in a sensible consistent manner no comment can be made.

Object

Representation ID: 4010

Received: 29/08/2021

Respondent: Mr Keith Turner

The dennybrook site is way too large and should not be considered

Object

Representation ID: 4721

Received: 01/09/2021

Respondent: Barton Willmore

St Modwen Logistics support Thurleigh Airfield’s continued allocation for employment use, classified as Protect and Enhance, and respectfully request that it is prioritised as a location for employment growth in the Local Plan 2040 (please see separate comments on the Draft Plan Sections 3 & 6, and the Bedford Employment Land Study).

Object

Representation ID: 5611

Received: 07/09/2021

Respondent: Land Allocation Ltd

Agent: AAH Planning Consultants

The current draft Local Plan 2040 out for consultation does not include any housing allocations for the borough, however it is noted that these will come forward in the next draft version, following the Call for Sites exercise which has previously taken place. We consider it essential for the Council to over-allocate housing land to ensure flexibility, choice and competition in the housing market, reflecting the government guidance including the requirement to significantly boost the supply of housing as per the NPPF.
Whilst the spatial strategy is still being formulated and which has been considered above, it is considered that due to the higher housing need figure of the Local Plan 2040, compared to the Local Plan 2030, then we consider it is likely that more rural areas such as Oakley are to be subject to either housing allocations or reviews of neighbourhood plans to reflect the significantly higher housing need figure. Development in these sustainable but more rural areas would help to meet the identified need and help support the rural economy.
Our client’s site at Land West of Pavenham Road, Oakley was submitted as part of the Call for Site’s exercise and is identified as Site 702. There is a willing landowner who has previously submitted an outline planning application under reference 20/00433/MAO and an appeal with an indicative plan showing how the site could accommodate dwellings. Although the previous outline planning application was subsequently refused and also dismissed at appeal, taking the comments of the Inspector into account, the site can still be considered suitable for a small-scale residential development, which could be focused to deliverable housing for a specific group, for example affordable or over 55’s housing, and can also respond to the existing character of the village.
None of the technical reports completed for the outline planning application and appeal indicate that there are on site issues that would prevent the sites allocation for residential development. There are no significant abnormal or major infrastructure requirements. The Full Policy Requirements for Planning Obligations are expected to be made as evidenced by the Outline Planning Application. There is no indication of any viability issues here.
The site forms a natural extension of the settlement being directly adjacent to the existing settlement boundary and there are no major contraints or viability matters to prejudice the development or allocation of the site for housing. There are no legal issues. The landowners are party to a promotion agreement with Land Allocation Ltd. Consequentially, the site is deliverable, available and developable now.
Please refer to the

Support

Representation ID: 6402

Received: 13/09/2021

Respondent: Mrs J Clements

Agent: Brown & Co Barfords

Our client would also like to highlight the land at Manor Farm Duloe as a appropriate location for growth as part of a new settlement at Wyboston and would welcome further discussion on inclusion of this site in any ensuing strategic allocation.

Support

Representation ID: 6664

Received: 14/09/2021

Respondent: Stevington Parish Council

It is difficult for SPC to comment on individual sites within the Parish as none of the assessments are as yet fully completed or certainly appear to be missing elements from at least one or more of the assessment categories, we assume this will be more widely publicised when the exercise is complete.

Object

Representation ID: 6693

Received: 14/09/2021

Respondent: The British Horse Society

The Society does not express any opinion as to the suitability of particular sites for development.

However, many of the proposed sites do impact on the existing rights of way network which needs to be protected through the planning process.

But they also offer opportunities to enhance the network by creating circular routes or connections to bridge gaps in the network. Such opportunities do not appear to be given much emphasis in the assessment of sites nor in the planning consent process. If greater focus were given to such ‘planning gains’ the ROWIP aim 3.2c: Identify opportunities to increase the size of the bridleway/multiuser network to provide more links and loops for circular rides might better be realised.

Although produced for another county, ‘Equestrians in Hampshire – a reference guide for Transport, Planners, Developers and other decision makers’ published by Hampshire Countryside Access Forum with support from Hampshire County Council and the BHS has been widely circulated beyond Hampshire, sparking interest from other authorities outside the county. We would like to work with you to create a similar document for Bedford Borough so that any proposed new bridleways, when implemented, will restore connectivity within the wider rights of way network in a way that will benefit all users, including equestrians.

Support

Representation ID: 7790

Received: 23/09/2021

Respondent: Mr A Sarro

Agent: Phillips Planning Services

4.3 It is assumed that any sites within Parishes adjoining the urban edge including Renhold would qualify for consideration in the Adjoining the Urban Area’ category. If this is the case, we support the four preferred growth options which all include growth adjoining the urban area.

4.4 Notwithstanding this general support, concern is raised in respect of what could be an over-reliance upon uncertain urban sites. Sites adjoining or close to the main Bedford Urban area offer similar sustainability advantages to sites within it, whilst exhibiting far fewer viability / deliverability issues. We therefore consider that sites adjoining the urban area should be allocated a slightly higher proportion of the housing numbers (2000) than currently suggested.

4.5 In parallel to this submission, Mr Sarro is promoting Land To The East Of Hookhams Lane, Salph End, Renhold through the Call For Sites process (Site 680). This land is available and deliverable, and provides an opportunity for residential development in a sustainable location adjoining the urban area. This site can therefore make a meaningful contribution towards the objectives of this strategy.

Support

Representation ID: 7873

Received: 23/09/2021

Respondent: Central Bedfordshire Council

Due to the early stage of these proposals, we do not intend to make detailed comments on specific sites at this stage. However, we do wish to continue to be involved throughout the process. Effective and ongoing engagement will be vital to the success of new development in both of our authorities due to the close links and interconnected nature of the two. We look forward to reviewing the future stages of work, once the detailed evidence is available to support the emerging proposals. We would like to request to be kept informed of decisions relating to sites and would request early engagement where a site is likely to affect Central Bedfordshire or our residents.

We note that the proposed strategy will not include allocations for small sites (of less than one hectare), on the basis that evidence shows the number of dwellings built on small sites is consistently above the 10% required by the NPPF. Whilst the national policy requirement is being met, BBC may wish to consider a smaller threshold to ensure that it can appropriately plan for growth and vitality in smaller villages and towns, rather than relying on windfall.

Support

Representation ID: 7935

Received: 20/09/2021

Respondent: Pavenham Parish council

The work that the BC has already undertaken with regard to the “call for sites” exercise and consequent allocation is noted and appreciated. To an extent, the proposed site allocation in the draft Neighbourhood Plan will confirm the Parish’s view once its draft Plan is finalised.

Object

Representation ID: 8497

Received: 27/09/2021

Respondent: Gladman Developments Ltd

Renhold
Salph End, Renhold is less than half a mile from the Bedford Urban Area boundary and is therefore  considered  to  be  a  suitable  location  for  growth  within  each  of  the  emerging preferred options. Salph End was previously identified as a location suitable for growth in the region of 500 dwellings early stages of the adopted Bedford Local Plan 2030 without this  being  recognised  in  the  final  plan.  No  growth  ended  up  being  allocated  here  in  the  adopted Local Plan. Opportunities for growth in this location should be central to any strategy to meet the revised housing requirement over the period to 2040.
Through the Local Plan Review it would be appropriate for this previous recognition to be now realised with a proportionate amount of growth directed to Salph End as a component part of the spatial strategy within the Local Plan Review. The site Gladman is promoting in Salph  End  was  previously  a  preferred  option  (Site  198)  and  is  therefore  a  contender  for  allocation in the Local Plan Review.
Shortstown
Shortstown is well located close to the A421 corridor at the southern edge of the Bedford Urban Area with employment and recreational facilities close by. The village is defined as a  ‘Key  Service  Centre’  comprising  a  good  range  of  services  and  facilities  and  being  well  connected to larger town centres by public transport and cycling. It is acknowledged to be a sustainable location for growth within Bedford’s existing settlement hierarchy and should play  a  central  role  in  meeting  the  revised  growth  requirement  to  2040.  Gladman  has  submitted separate representations relating to Land off The High Road, Shortstown. The location of the site, to the north of the settlement would represent a logical extension in a location  that  is  well  related  to  the  services  and  facilities  in  Shortstown  and  the  Bedford  Urban Area to the north.
Wootton
Wootton  is  a  key  service  centre  in  the  southern  transport  corridor  where  an  element  of  further growth is being considered in 3 of the 4 preferred strategies. Gladman agree that further growth should be directed to Wootton through the Local Plan Review as no further growth  is  directed  to  Wootton  as  part  of  the  adopted  Bedford  Local  Plan  2030  due  to  existing commitments and completions at the start of the plan period.
Gladman recognise that the parish is preparing a neighbourhood plan but notwithstanding the outcomes of the pending examination, this should not dictate the emerging strategy for Wootton through the Local Plan Review which will cover an extended plan period and need to meet a greater housing requirement. Growth in Wootton should certainly form a part  of  the  strategy  for  the  Local  Plan  Review,  and  as  recognised  through  the  site  assessment work undertaken by the Wootton Neighbourhood Plan Steering Group, land at Hall End Road is a strong contender for allocation for residential development.
Willington
Willington  is  a  designated  rural  service  centre  situated  in  the  eastern  transport  corridor,  which in one of the four preferred options being considered. Whichever strategy is ultimately carried forward, Willington is a sustainable settlement on the A421 corridor and can play a role in sustainably accommodating the level of growth needed in the Borough over the plan period. New homes and accessible open space in this location will also assist in sustaining and enhancing the services and facilities in the village as well as contributing to the local and affordable housing needs of the village and the Borough.

Support

Representation ID: 8708

Received: 28/09/2021

Respondent: Hollins Strategic Land

Agent: Emery Planning

5.1 We set out below an overview of the site HSL are promoting for residential development in
Wootton for up to 81 homes.
Site Location and Description
5.2 The site is generally rectangular shape, on the edge of the western built-up area of Wootton,
which lies south west of Bedford. The site, as identified by the red line boundary, covers
approximately 6.5 hectares (ha) or 16 acres.
5.3 The northern edge of the site is defined by Hall End Road (also National Cycle Route 51) and the
John Bunyan Trail. There is a field access gate to the northeast corner of the site. From this
direction, the settlement of Wootton has recently been expanded towards the site with the
construction of 58 dwellings (Ref: 14/02939/MAF) (Allocation AD2) and is a prominent feature. An
allocation for a school extension is also located north east of the site on the opposite side of Hall
End Road and is yet to be implemented and extends the settlement edge outwards.
5.4 The eastern boundary runs alongside an unnamed road that provides access to Wootton Upper
School and commercial/ farm premises. The southern boundary is contiguous with Wootton
Wood, an area of ancient and semi-natural woodland. The western boundary is shared with an
adjacent field, laid to pasture. These boundaries are all formed from native hedgerow with a
combination of post and rail or post and wire fencing within.
Sustainable and Suitable Location
5.5 The village centre of Wootton is located approximately 900 metres to the east of the site. The
village benefits from many amenities including local convenience stores, pubs and restaurants,
several churches, a petrol station, pharmacy, public library and football club. The wider parts of
the village contain community services such as the village hall, memorial hall, play areas, skate
park and tennis courts.
5.6 In terms of transport links, bus services serve Wootton and can be accessed within a short walk of
the site. These services provide regular daily services to destinations such as Bedford, Milton
Keynes and other local villages, providing residents with the opportunity to access a wide range
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of employment, shopping, leisure and cultural opportunities without having to rely upon the
private car. The site location therefore would accord with NPPF §109.
5.7 The Environment Agency Flood Maps show the appraisal site lies entirely within Flood Zone 1
indicating it has a low probability of flooding and is suitable for residential uses.
5.8 The village of Wootton has a historic character, with buildings and monuments dating from as
early as the 14th Century. Wootton Church End Conservation Area is located approximately 250
metres to the east of the appraisal site and encompasses the Grade I listed Church of St. Mary
and several other listed buildings. These heritage assets are separated from the site by Wootton
Upper School and so development of the site would not have a negative impact upon their
setting. The westernmost part of the site is within an Archaeological Interest Site. The LPA also
agreed in the committee report (see EP4).
The Proposed Development
5.9 This proposal submitted to the LPA sought outline planning permission for the construction of up
to 81 dwellings with access. The final layout, scale, landscaping and appearance would be the
subject of a reserved matters application. The proposed illustrative site layout and Design and
Access Statement submitted with the application shows how the dwellings could be comfortably
accommodated on the site along with open space and the conserved and managed meadow.
These are enclosed as Appendix EP2.
5.10 All of the proposed dwellings within the site would be served by a single access road which would
be taken from Hall End Road. The main internal access road is shown and the precise details
would form part of the reserved matters application. Pedestrian and cycle connectivity can be
explored at the reserved matters stage.
5.11 The TA states that the proposed site is situated approximately 950m west of Wootton village
centre, and coupled with the site’s proximity to frequently serviced bus stops, cycle routes and
viability to access the nearest rail station, accessibility from the site is considered to be of a good
standard with opportunities to promote sustainable travel from the site. A Travel Plan was also
submitted with the application to help promote more sustainable choices of travel.
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The Application and Appeal
5.12 Following their consideration of the proposal, the professional officers of the Council concluded
that planning permission should be granted and recommended this to the planning committee
on 28th October 2019. The application was deferred for a site visit and it was considered again on
the 25th November (Appendix EP3). The members of the Planning Committee voted to refuse the
application solely on highway grounds contrary to the advice of the planning and highway
officers.
5.13 The committee report sets out the detailed 22 planning considerations that were examined and
the planning officer was informed by statutory and non-statutory consultees and other
consultation letters during the determination period with the conclusion that permission should
be granted.
5.14 An appeal was submitted and determined. However, following a High Court challenge the
Inspector’s decision on the appeal dated 15 September 2020 was quashed and the Court has
ordered that the appeal be re-determined. The proposal has the following benefits:
• the delivery of open market housing to assist in boosting the supply of housing in
Bedford and can meet the 145 homes identified in the evidence base for the WNP as
well as borough housing needs;
• delivery of a medium sized site by HSL who have a proven track record of delivery
which would accord with the clear objective of the Government in paragraph 69 of
the Framework.
• the development accords with the spatial strategy as expressed in Policy 3S of the
Local Plan which identifies Wootton as a Key Service Centre which can accommodate
strategic residential development in a sustainable location.
• the proposed development helps to meet the objectives set out in the Bedford Green
Infrastructure Plan (2009) and the provision of open space to meet the needs of
existing and proposed residents and maintain a Green Corridor as required by saved
policy AD24.
• residential development at the site through the proposed scheme will result in an
improvement to the biodiversity value of the site and the net gain benefits to be
achieved and secured by the scheme outweigh the estimated loss of c. 3.1 hectares
of the neutral grassland at the CWS to achieve compliance with the paragraph 180(c)
of the Framework.
• the delivery of 30% affordable housing accords with Policy CP8 and would assist in
addressing the very significant and persistent shortfall in affordable housing delivery.
Paragraphs 4.23 to 4.30 of the Application Planning Statement confirm that there is a
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shortfall of 552 affordable homes since 2003 and the need going forward is 278
affordable homes per annum. There is also a need for 24 affordable homes as set out
in the Housing Needs Survey.
• highway works that will improve highway safety; and;
• a range of social and economic benefits and increase spending for local services and
facilities.
5.15 In the Site Assessment Pro-Formas June 2021 the subject site is Site ID 371. However the assessment
does not take account of the Officers Report to committee for the application and HSL sent an
email to the LPA on 2nd August 2021 setting out our comments which were noted in an email
dated 11th August 2021. The email exchange is Appendix EP4. The site is deliverable.
5.16 Our position is that the site can be delivered in full in the first five years of the plan period. This is
because the land is controlled by HSL, an experienced land promotion company complete with
its own housebuilding division. The site is controlled by a willing landowner, and there are no legal
or ownership issues that would prevent development. Appendix EP5 is a summary of the delivery
record of HSL in recent years. The Council can proceed in the confidence that the site is
deliverable and can be delivered in the first 5 years of the housing land supply and should be
allocated on that basis.
5.17 To conclude, with the need for further housing to meet the requirement to 2040 we request that
the site is proposed for allocation. We would welcome discussions with the LPA on what the site
can offer so that a deliverable site can be allocated to meet the housing needs in the first 5 years
of the plan period. HSL has a good track record in seeking to positively engage with communities
preparing neighbourhood plans as they have done with the Willington neighbourhood planning
group in Bedford on their land at Sandy Road. That NP is now at examination stage with HSL land
allocated for up to 50 dwellings to meet local needs alongside a range of community benefits
and HSL have a planning application pending. HSL undertook technical survey work to help
inform the NPG as they consulted with the community, which resulted in the allocation of the site
for development with the support of the local community and Parish Council.
5.18 This concludes our representations.

Support

Representation ID: 8970

Received: 03/09/2021

Respondent: East West Railway Company Limited

Agent: Mrs JANE PARKER

EWR Co’s proposed track alignment south of Ford End Road Bridge may require the relocation of some
of the existing railway sidings in that area (known as Jowett Sidings).
EWR Co is currently exploring different solutions to the layout in this area. This exercise has highlighted a
potential opportunity to use additional railway land for residential or other development. Such further
development would require the relocation of additional sidings beyond those which need to be relocated
to facilitate the EWR scheme. The necessary works to facilitate this additional development are beyond
the scope of the EWR scheme. However, EWR Co would support such a scheme were it to be taken
forward by Bedford Borough Council and / or Network Rail. EWR Co recognises that there could be
benefits (such as an overall reduction in construction-related disruption) in the delivery of such a scheme
being co-ordinated with the delivery of the EWR works in the Bedford area and would be prepared to work
with the relevant parties to assist with this co-ordination.

EWR welcomes the emerging growth development options set out in the emerging Bedford Local Plan
2040. These appear in principle to align with EWR Co’s proposed route alignment and station options as
set in non-statutory consultation undertaken earlier this year.
EWR Co welcomes ongoing discussions with the Council and requests that the emerging local plan
strategy options, policies and proposals retain sufficient flexibility to ensure that the final preferred strategy
growth options align with the preferred EWR options, due to be consulted on in 2022. Bedford Council
should note that at this stage it is considered that adopted Policy S14 in the Bedford Local Plan 2030 is
likely to need to be replaced or supplemented by a revised or new local plan policy in the emerging Local
Plan 2040 to take account of EWR Co proposals for St Johns Station.

Object

Representation ID: 8983

Received: 03/09/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

From an initial review of the potential employment sites submitted to the Local Planning Authority for consideration, the conclusions to not appear to be underpinned by a detailed evidence base or all of the available to the Council.

The site assessment forms also fail to provide any detailed assessments or conclusions on key topics. Before any site selection process is undertaken, each site should be properly assessed and a firm conclusion reached on whether key areas such as highways, heritage, noise, etc. are an insurmountable issue or not. Additionally, and importantly, the site assessment form also does not allow for a consideration of the potential benefits that sites may offer.

The assessment process for sites should be thorough and draw information from an existing evidence base held by the Council. To be sound, and justify the selection of sites, there should be a greater degree of transparency in the site assessment process. This is an important consideration as it is noted that plans in other local authorities have been found unsound in recent years due to the failure to justify decisions and properly back up why certain sites have been chosen over others.

With regard to the land at Manton Lane, the only constraint to development is the historic use of the site as a sports pitch – the development of which could trigger a Sports England objection. This is effectively a policy constraint and should not be a reason for not allocating the site which is otherwise suitable for development.

On the site proforma, there are unsubstantiated references to potential harm to unmanned heritage assets. It is unclear what these assets are and how the conclusion has been drawn and indeed whether they take into consideration the impact of building out the consented school on the heritage assets. Similarly, there are ‘uncertain’ conclusions around matters such as ecology and biodiversity. These are examples of where the Council will need to commission further evidence to fully assess sites and enable a robust consideration of alternatives.

The benefits of allocating the site should also be recognised in the assessment process, particularly the fact that the use of the site can effectively replace the employment land lost to the approval of a secondary school on the adjacent site.

Object

Representation ID: 9043

Received: 03/09/2021

Respondent: Mr and Mrs Trevor and Susan Stewart

All would represent a breach of the borough's stated green environmental vision and objectives in that they would represent further loss of trees, agricultural land, natural drainage etc and would exacerbate the existing problems of increasing traffic, natural drainage, light pollution and air pollution dur to increased traffic.