1.39

Object

Representation ID: 3804

Received: 26/08/2021

Respondent: Mr Paul Woolmer

The proposed Dennybrook development is flawed on so many levels.
Environmentally it will bring chaos to small local lanes which in many cases cannot be widened without major impacts on local residents & wildlife.
The overall infrastructure is already inadequate with no mains sewerage, inconsistent electrical supply, very poor broadband & mobile phone connectivity.
The development would make St.Neots a much busier centre, to the detriment of Bedford town.
The rural nature of the site would encourage car usage, which is completely to opposite of government policy.
There are much better sites which apparently for political reasons have been ignored.

Object

Representation ID: 3955

Received: 29/08/2021

Respondent: Mr Mark Potts

The scoring system used appears to score the same for 7 of the 15 criteria for all options including
protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system
is insufficiently sensitive if it produces so little variation between the options. In the favoured
options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect
in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting
Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 4131

Received: 30/08/2021

Respondent: Mr paul giles

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land

Object

Representation ID: 4163

Received: 30/08/2021

Respondent: Mrs MARGARET TURNER

The scoring system used appears to score the same for 7 of the 15 criteria for all options including
protecting a maintain biodiversity and landscape character. The criteria / scoring system
is insufficiently sensitive if it produces so little variation between the options. In the favoured
options 2a to 2d, Bedford Borough Council have failed to properly consider / reflect
in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting
Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 4169

Received: 30/08/2021

Respondent: Mr Keith Turner

The 15 criteria, 7 criteria have the same score for all options, so make no difference to the
assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape
character
The remaining 8 criteria where scores vary between options, 3 are effectively the same: 1.
AirQuality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of
the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or
sufficient.
Landscape character – all options score the same and the words fail to fully recognise
the impact of new settlements on the existing landscape.

Object

Representation ID: 4470

Received: 31/08/2021

Respondent: Mrs Lucy Crawford

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. I believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 4543

Received: 01/09/2021

Respondent: Mrs Kathryn Smith

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character.
The criteria / scoring system is insufficiently sensitive if it produces so little variation between the options.
In options 2a to 2d, it seems that BBC have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 4636

Received: 01/09/2021

Respondent: Mr Melvyn Chase

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. I believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 4694

Received: 01/09/2021

Respondent: Mr Joshua Zwetsloot

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.
The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 4825

Received: 01/09/2021

Respondent: Mr Andrew Murray

The Site Selection Methodology is clearly flawed as it is founded on out of date data such as the SETTLEMENT HIERARCHY document from SEPTEMBER 2018, which is now 3 years out of date

Object

Representation ID: 4881

Received: 02/09/2021

Respondent: Ms Tara Skey

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting and maintaining biodiversity and landscape character. I believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 4926

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

We raise a number of concerns in relation to the Site Selection methodology Update.
As an overarching observation, we note that the 430 call for sites submissions have already been assessed against a range of criteria – we comment on the specific assessments in our responses to the Site Assessment Pro formas. These assessments go beyond a factual recording of the call for sites submissions, and apply an analysis on specific topics (for example in relation to heritage matters the Site Assessment Pro formas make clear that heritage matters could lead to a site not being allocated). Two important matters arise – firstly, site assessments are already underway when the site selection methodology is in draft form only and has not benefited from this current consultation exercise which should inform and refine the methodology process. Secondly, it is not clear how the assessments in the Site Selection Pro formas feed in/relate to the Site Selection Methodology and whether the assessments already completed are intended to be in addition to the site selection process to be undertaken, or are a substitute for some part(s) of the site selection process set out in the Site Selection Methodology Update.
Turning now to specific comments in relation to the content of the Site Selection Methodology Update.
Paragraph 7 sets out that there are 3 discrete assessments to be applied to each site. It is not clear whether this is intended as a sequenced assessment – such that a site must pass each of the three stages in turn before being taken forward to the next stage assessment – or whether the assessments are undertaken in combination/concurrently. The former would provide for a more transparent approach to site selection – if the latter then it is difficult to discern which elements of the assessment each site scored well against and which elements bear against a site.
Related to our point above, we raise concerns in relation to Paragraph 8 and the overarching approach to site scoring. It does not appear that there is any weighting being applied to each assessment criteria which we consider is unjustified. It could be the case, in a neutral scoring system, that a site fails the assessment because it includes land in FZ2 or 3 which is never intended to be built upon in the same way that a site fails the assessment because it has a substantial harm to heritage assets incapable of being mitigated. In such circumstances otherwise well performing sites are excluded from being considered for allocation. Conversely, by applying a weighting to the assessment enables a more refined and justified assessment reflective of the significance of the site constraints and opportunities.
Furthermore, in relation to Paragraph 10 it is not clear what role mitigation is to play in the assessment methodology. It is often the case that there are constraints weighing against a site that can be mitigated either in full or in part. It would not be appropriate for sites to be excluded from consideration for allocation without consideration being given to the extent of mitigation.
So far as the sustainability objectives – which are set out after Paragraph 10 – it is evident that a number of these cross over (for example 1b, 1c, 1d, 3c, 3d, 3e, 15a, 15b, 15c and 15d all deal with accessibility by foot). In such circumstances a site failing one question would fail all questions, and as a result would be scored more poorly than a site failing a single self-contained objective (such as 11a). This would be to misrepresent the site assessment, and a more uniform approach should be considered so as not to undermine the outcome of the assessment work.
Turning to Paragraph 11, here it is stated that the constraints known to the Council are rolled forward from the Allocations Plan. However, no cross check/re-assessment as to the relevance of the constraints is being undertaken, and as a result these constraints may no longer apply, apply to a lesser magnitude, or indeed be greater than as reported in the Allocations Plan. As such, a wholesale review is required rather than a simple roll forward.
For similar reasons, we raise concerns in relation to the provisions of Paragraph 12. This relates to education and appears to be a roll forward of the work undertaken in relation to the Local Plan 2030 without a review or reconsideration as to accuracy or appropriateness in guiding sites to be selected to deliver housing in the period to 2040. This work should therefore be re-evaluated.
Finally, it is to be noted in respect of Paragraph 13 that the development strategy is yet to be set, whilst in relation to the fourth bullet, it is not clear if accessibility considerations include accounting for rural school transport provision – if not (as it appears) then the assessment should be reconsidered to factor this provision in.

Object

Representation ID: 4978

Received: 02/09/2021

Respondent: Mr Chris Giles

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Support

Representation ID: 5490

Received: 06/09/2021

Respondent: Mr Stuart Ledwich

See comments under 1.44 Sustainability Appraisal

Object

Representation ID: 5587

Received: 06/09/2021

Respondent: Mrs Julie Kilby

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 5637

Received: 07/09/2021

Respondent: Mr Phillip Yockney

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 5689

Received: 07/09/2021

Respondent: Miss amber scally

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.




c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 5744

Received: 07/09/2021

Respondent: Miss Hannah Hambleton-Jewell

Please note the Brownfield site register is incomplete and needs to be revised to include all of the sites to allow the selection process to fully keep abreast of the Brownfield options which should be exhausted first to protect natural rural landscapes being chosen to make the developments easier/cheaper than manage the more challenging and costly options of redevelopment of brownfield sites.

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 5780

Received: 07/09/2021

Respondent: Mrs Gillian Tagg

If numbers (2,1,0,0,-1,-2) are used to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So, in reality, of the 15 criteria only 6 criteria make a difference. I do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, I believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However, this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
100-word Summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. I believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, I believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 5849

Received: 08/09/2021

Respondent: Mr Norman Hoy

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 5879

Received: 08/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

Paragraph 1.39 Site Selection Methodology Update
We raise a number of concerns in relation to the Site Selection methodology Update.
As an overarching observation, we note that the 430 call for sites submissions have already been assessed against a range of criteria – we comment on the specific assessments in our response to the Site Assessment Pro formas.
These assessments go beyond a factual recording of the call for sites submissions, and apply an analysis on specific topics (for example in relation to heritage matters the Site Assessment Pro formas make clear that heritage matters could lead to a site not being allocated). Two important matters arise – firstly, site assessments are already underway when the site selection methodology is in draft form only and has not benefited from this current consultation exercise which should inform and refine the methodology process. Secondly, it is not clear how the assessments in the Site Selection Pro formas feed in/relate to the Site Selection Methodology and whether the assessments already completed are intended to be in addition to the site selection process to be undertaken, or are a substitute for some part(s) of the site selection process set out in the Site Selection Methodology Update.
Turning now to specific comments in relation to the content of the Site Selection Methodology Update.
Paragraph 7 sets out that there are 3 discrete assessments to be applied to each site. It is not clear whether this is intended as a sequenced assessment – such that a site must pass each of the three stages in turn before being taken forward to the next stage assessment – or whether the assessments are undertaken in combination/concurrently. The former would provide for a more transparent approach to site selection – if the latter then it is difficult to discern which elements of the assessment each site scored well against and which elements bear against a site.
Related to our point above, we raise concerns in relation to Paragraph 8 and the overarching approach to site scoring. It does not appear that there is any weighting being applied to each assessment criteria which we consider is unjustified. It could be the case, in a neutral scoring system, that a site fails the assessment because it includes land in FZ2 or 3 which is never intended to be built upon in the same way that a site fails the assessment because it has a substantial harm to heritage assets incapable of being mitigated. In such circumstances otherwise well performing sites are excluded from being considered for allocation. Conversely, by applying a weighting to the assessment enables a more refined and justified assessment reflective of the significance of the site constraints and opportunities.
Furthermore, in relation to Paragraph 10 it is not clear what role mitigation is to play in the assessment methodology. It is often the case that there are constraints weighing against a site that can be mitigated either in full or in part. It would not be appropriate for sites to be excluded from consideration for allocation without consideration being given to the extent of mitigation.
So far as the sustainability objectives – which are set out after Paragraph 10 – it is evident that a number of these cross over (for example 1b, 1c, 1d, 3c, 3d, 3e, 15a, 15b, 15c and 15d all deal with accessibility by foot). In such circumstances a site failing one question would fail all questions, and as a result would be scored more poorly than a site failing a single self-contained objective (such as 11a). This would be to misrepresent the site assessment, and a more uniform approach should be considered so as not to undermine the outcome of the assessment work.
Turning to Paragraph 11, here it is stated that the constraints known to the Council are rolled forward from the Allocations Plan. However, no cross check/re-assessment as to the relevance of the constraints is being undertaken, and as a result these constraints may no longer apply, apply to a lesser magnitude, or indeed be greater than as reported in the Allocations Plan. As such, a wholesale review is required rather than a simple roll forward.
For similar reasons, we raise concerns in relation to the provisions of Paragraph 12. This relates to education and appears to be a roll forward of the work undertaken in relation to the Local Plan 2030 without a review or reconsideration as to accuracy or appropriateness in guiding sites to be selected to deliver housing in the period to 2040. This work should therefore be re-evaluated.
inally, it is to be noted in respect of Paragraph 13 that the development strategy is yet to be set, whilst in relation to the fourth bullet, it is not clear if accessibility considerations include accounting for rural school transport provision – if not (as it appears) then the assessment should be reconsidered to factor this provision in.

Object

Representation ID: 5969

Received: 08/09/2021

Respondent: Staploe Parish Council

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; Zero Carbon, which will affected by the proposed new train from Oxford to Cambridge as diesel. 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
100 word summary
I’ve noticed that the scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. I believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 6014

Received: 08/09/2021

Respondent: Mrs Christina Farmer

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 6104

Received: 09/09/2021

Respondent: Jen Giles

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Support

Representation ID: 6151

Received: 09/09/2021

Respondent: Mrs Sandie Tusting

See comments under 1.44 Sustainability Appraisal

Object

Representation ID: 6208

Received: 09/09/2021

Respondent: Peter Coles

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 6309

Received: 10/09/2021

Respondent: Mr Paul Zwetsloot

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.
The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 6342

Received: 10/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

We raise a number of concerns in relation to the Site Selection methodology Update.
As an overarching observation, we note that the 430 call for sites submissions have already been assessed against a range of criteria – we comment on the specific assessments in our response to the Site Assessment Pro formas.
These assessments go beyond a factual recording of the call for sites submissions, and apply an analysis on specific topics (for example in relation to heritage matters the Site Assessment Pro formas make clear that heritage matters could lead to a site not being allocated). Two important matters arise – firstly, site assessments are already underway when the site selection methodology is in draft form only and has not benefited from this current consultation exercise which should inform and refine the methodology process. Secondly, it is not clear how the assessments in the Site Selection Pro formas feed in/relate to the Site Selection Methodology and whether the assessments already completed are intended to be in addition to the site selection process to be undertaken, or are a substitute for some part(s) of the site selection process set out in the Site Selection Methodology Update.
Turning now to specific comments in relation to the content of the Site Selection Methodology Update.
Paragraph 7 sets out that there are 3 discrete assessments to be applied to each site. It is not clear whether this is intended as a sequenced assessment – such that a site must pass each of the three stages in turn before being taken forward to the next stage assessment – or whether the assessments are undertaken in combination/concurrently. The former would provide for a more transparent approach to site selection – if the latter then it is difficult to discern which elements of the assessment each site scored well against and which elements bear against a site.
Related to our point above, we raise concerns in relation to Paragraph 8 and the overarching approach to site scoring. It does not appear that there is any weighting being applied to each assessment criteria which we consider is unjustified. It could be the case, in a neutral scoring system, that a site fails the assessment because it includes land in FZ2 or 3 which is never intended to be built upon in the same way that a site fails the assessment because it has a substantial harm to heritage assets incapable of being mitigated. In such circumstances otherwise well performing sites are excluded from being considered for allocation. Conversely, by applying a weighting to the assessment enables a more refined and justified assessment reflective of the significance of the site constraints and opportunities.
Furthermore, in relation to Paragraph 10 it is not clear what role mitigation is to play in the assessment methodology. It is often the case that there are constraints weighing against a site that can be mitigated either in full or in part. It would not be appropriate for sites to be excluded from consideration for allocation without consideration being given to the extent of mitigation.
So far as the sustainability objectives – which are set out after Paragraph 10 – it is evident that a number of these cross over (for example 1b, 1c, 1d, 3c, 3d, 3e, 15a, 15b, 15c and 15d all deal with accessibility by foot). In such circumstances a site failing one question would fail all questions, and as a result would be scored more poorly than a site failing a single self-contained objective (such as 11a). This would be to misrepresent the site assessment, and a more uniform approach should be considered so as not to undermine the outcome of the assessment work.
Turning to Paragraph 11, here it is stated that the constraints known to the Council are rolled forward from the Allocations Plan. However, no cross check/re-assessment as to the relevance of the constraints is being undertaken, and as a result these constraints may no longer apply, apply to a lesser magnitude, or indeed be greater than as reported in the Allocations Plan. As such, a wholesale review is required rather than a simple roll forward.
For similar reasons, we raise concerns in relation to the provisions of Paragraph 12. This relates to education and appears to be a roll forward of the work undertaken in relation to the Local Plan 2030 without a review or reconsideration as to accuracy or appropriateness in guiding sites to be selected to deliver housing in the period to 2040. This work should therefore be re-evaluated.
Finally, it is to be noted in respect of Paragraph 13 that the development strategy is yet to be set, whilst in relation to the fourth bullet, it is not clear if accessibility considerations include accounting for rural school transport provision – if not (as it appears) then the assessment should be reconsidered to factor this provision in.

Object

Representation ID: 6442

Received: 13/09/2021

Respondent: Mr Steven Kent

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.
The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 6536

Received: 13/09/2021

Respondent: Mrs Susan Trolley

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.