1.40
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 3573
Received: 12/08/2021
Respondent: Mrs Sophie Towler
Obejection to Denybrook also know as Dennybrook. Please read my comments in full. In short, the devastation caused by such a big project in a rural, relatively un-touched part of our countryside would be horrific and a terrible decision. Traffic, noise, environmental impact, the expense, the location, access to stations etc. all point to this being a terrible idea.
Objection to Denybrook also know as Dennybrook (page 358), this will destroy acres of peaceful, working countryside. It is largely Grade A agricultural land which is used for growing crops. There is no brownfield elements to the site which are a priority for the governments planning. It will bring an over whelming amount of traffic and disturbance to quiet, historic villages. Not to mention the effect on the environment because the majority of people will need to commute, privately, to work in towns which are further away than the average commute. The black cat is already congested and this would only make the problem worse. Access to Bedford is poor which will result in the majority of people using St Neots, driving people away from Bedford and not helping its development at all. There are hundreds of other smaller sites proposed, in brownfield areas, which would achieve the number of houses required, offer a better environmental solution and drive people into Bedford. Anyone who is planning to commute into London will need to drive to the nearest station as no stations will be on that side of the A1 and it is simply not feasible to expect people to cycle or walk to the new proposed rail stations.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 4171
Received: 30/08/2021
Respondent: Mr Keith Turner
This assessment was done in Nov 2020. There was significant flooding in Honeydon and St Neots in
December 2020. There are 5 watercourses which run from Staploe Parish into the rivers just
upstream of St Neots. A development of up to 10,800 homes at Dennybrook
(site 977) is inappropriate and it would increase the chance of flooding.
The methodology for preparing a strategic flood risk assessment was updated in Sept 2020 and the
risk assessments became more stringent therefore this flood risk assessment is out of date and
needs to be updated.
This assessment was done in Nov 2020. There was significant flooding in Honeydon and St Neots in
December 2020. There are 5 watercourses which run from Staploe Parish into the rivers just
upstream of St Neots. A development of up to 10,800 homes at Dennybrook
(site 977) is inappropriate and it would increase the chance of flooding.
The methodology for preparing a strategic flood risk assessment was updated in Sept 2020 and the
risk assessments became more stringent therefore this flood risk assessment is out of date and
needs to be updated.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 4928
Received: 02/09/2021
Respondent: Kler Group
Agent: Cerda Planning Ltd
We have submitted a series of sites to the Council as part of the call for sites exercise. We have reviewed the pro formas prepared by the Council and have the following observations to make. The site references below are taken from the site pro formas for ease of cross referencing.
[Comments saved separately against site number.]
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5138
Received: 03/09/2021
Respondent: Mr Trevor Monk
Against the destruction of remaining airfield and land surrounding Shortstown and the Cardington Sheds.
All the extra proposals for housing round the Cardington Sheds and Shortstown, against.
Flood risk will be very high, lots of the airfield and field on the other side of the airfield has standing water on it for lots of the year during wet times, the area is on the water table.
More housing in that area will basically mean any aviation jobs for the sheds will be unable to be carried out at the sheds, this removes a possible future use of the sheds and should be a warning to all concerned.
If housing surrounds the sheds so closely it will impede on filming there, the filming industry is very secretive due to the nature of the work and having houses surrounding it poses a threat to that. Any comments the studio tenants of Shed 1 come out with in support of building should be disregarded as their landlord is one of the developers, it's a conflict of interest. Shed 2 is separate to shed 1 and should give a more unbiased look at the possible issues these new houses will create.
Housing built on land that floods is not a good idea, the balancing lakes will not cope, the lakes built so far on the approved housing site on the airfield still did not stop water laying on the airfield where houses are to be built.
The sheds are meant to have a protect view status, the council have already let this go on the Cardington side of the sheds by allowing building there, the village from where the sheds get their name and where the crew of the R101 are buried is to be blocked off from view by already approved housing, I hope this is not a precident for the developers to push this rule to be dropped, their "Corridor" plans are a joke.
The sheds need to be surrounded by open fields, this includes the other side of the A600 round Shortstown, this rural area is being decimated and and the road infrastructre is anadaquate with many bottlenecks, drainage too as the land all round that area is low lying.
These plans show absolutely no respect to the area, its history, its wildlife and work for the sheds to be able to fund there own maintanance.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5924
Received: 08/09/2021
Respondent: Mr Tom Tagg
Please refer to my comments in item 3.17 for option 2b regarding Dennybrook 977.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 6343
Received: 10/09/2021
Respondent: Glenalmond Developments Ltd
Agent: Cerda Planning Ltd
We have reviewed the pro formas prepared by the Council and have the following observations to make. The site reference below is taken from the site pro formas for ease of cross referencing.
[See Site Assessment Pro Formas]
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 7050
Received: 17/09/2021
Respondent: Glenalmond Developments Ltd
Agent: Cerda Planning Ltd
We have reviewed the pro formas prepared by the Council and have the following observations to make. The site reference below is taken from the site pro formas for ease of cross referencing.
• Site 3235 – Land West of Templars Way, Sharnbrook
Question 1a – the site adjoins a settlement policy area and as such should be scored ‘+’ as per question 8b.
Question 2b – A Vision Statement has been prepared (appended to these submissions). Birds and bats have the potential to be found at the site (albeit not recorded as being on the site), but no other protected species (bats, GCN, reptiles, Badgers) are identified. The development of the site provides the opportunity to enhance existing habitat as well as create new habitat of greater value to wildlife. An ecologically guided management plan should be implemented in order to maximise the biodiversity value of the habitats and features retained by the scheme. Sensitive management of woodland, wetland, and hedgerows would provide the most benefit. Retained hedgerows could be bolstered and enhanced by planting additional native species to increase species richness. As such the site should be scored ‘+’.
Question 2c – the site has the ability to achieve net gain through an ecologically guided management plan in order to maximise the biodiversity value of the habitats and features retained by the scheme. As such the site should be scored ‘+’.
Question 4a – There are no designated or non-designated heritage assets either on the site or adjacent. Development of the site is not considered to have any material impact upon any heritage assets or their setting. As such the site should be scored ‘+’.
Question 15f – It is proposed that the residential development is accessed from a priority junction with Templars Way. Visibility at the junction has been shown at 2.4 x 59 metres, which is considered suitable for typical 85th percentile speeds on a 30mph road, in accordance with MfS guidance. New trips (to the local highway network) resulting from the proposed residential development will be low during the peak hours, significantly less than one vehicle a minute (two-way) during any peak period. The site benefits from a regular bus service to employment, leisure and shopping destinations immediately adjacent to the site, and a wide range of facilities are located within a reasonable walk distance in Sharnbrook Village Centre. As such the site should be scored ‘+’.
Contaminated land – the site is greenfield, and in any event is not contaminated. No issues have been identified in relation to ground conditions. As such the site should be scored ‘+’.
Noise - to quantify the existing noise levels, a noise survey has been undertaken. A 3D noise model has been developed including the existing topography, ground type and buildings, as well the proposed dwellings. The assessment has shown that recommended noise levels in both external amenity areas and inside habitable rooms are likely to be achieved with appropriate garden fencing and façade element acoustic performance specifications. Most habitable rooms should achieve the recommended thresholds with open windows, and all habitable rooms should be able to utilise natural ventilation methods and achieve the thresholds. It should be noted that it may be possible to reduce the acoustic performance requirements of the façade elements, as well as noise levels in external amenity areas, by utilising a barrier along the north-east boundary of the site, adjacent to the railway. This would typically be earth bunding or fencing and would provide screening of the railway across the rest of the site. However, use of any such measure would be subject to landscape and visual impact constraints but it is expected that recommended internal and external noise levels can be achieved with suitable fencing and façade element specification alone. As such the site should be scored ‘+’.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8854
Received: 29/09/2021
Respondent: Mr Alex Simpson
Agent: Bidwells
The Site Assessment process to date has not been thorough in terms of the assessment of the suitability of sites and in the general conclusions reached.
6.2 The site assessment forms have not been underpinned by a detailed review of the evidence available to the Council. For example, the site assessment form for Site ID 1337 states that the site “has the potential to cause very high harm to a heritage asset”, however, this site submission was accompanied by an initial heritage appraisal which has not been referred to in the response and does not recognise the conclusions stated. No evidence to disregard the conclusions of the heritage appears to be provided, calling into question the justification for such a conclusion by the Council.
6.3 The site assessment forms also fail to provide any detailed assessments or conclusions on key topics. For example, in relation to Site ID 1332, it states in 11a of the site assessment that “the majority of the site is within flood zone 2.” However, as noted in the original Call for Sites submission, whilst it is recognised that some of the site is located outside of Flood Risk Zone 1, there is a significant area outside of this and it will be possible to focus development in such locations, with potential enhancements to flood risk overall. This is recognised in the recent changes to the NPPF (2021) at Paragraph 161c which state that opportunities within new development should be used to reduce the causes and impacts of flooding.
6.4 Generally, a more detailed and informed assessment of all sites is necessary 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, with conclusions backed up by an evidence base. Without this, the process is not sound.
6.5 Additionally, the site assessment form also does not allow for a consideration of the potential benefits that sites may offer. For example, as a result of the potential scale of development proposed, the larger site (ID 1332) has the ability to accommodate new local services such as a convenience store, local sports centre or health centre and play a significant role in supporting the viability of existing services.
6.6 Generally, there should be a greater degree of transparency in the site assessment and selection process – it is noted that plans in other local authorities have been brought down in recent years for failure to do this on the basis that it undermined the conclusions made.
Summary
The site assessment process should thoroughly assess the suitability of sites reaching conclusions on key areas of interest and should draw upon all available evidence to substantiate the information. This should allow proper consideration of site suitability.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 9030
Received: 04/10/2021
Respondent: Historic England
Site Assessment
We are pleased to note that a considerable degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the Site
Assessment pro-formas as well as the historic environment Excel spreadsheet. We welcome the additional table. This helps to ensure the process is both robust and transparent. To date, the assessment of sites is fairly high level and brief but provides a useful
starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber and the table notes that further assessment in
terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed.
As we have discussed previously, further assessment will be needed of the sites. This further assessment, known as Heritage Impact Assessment (HIA) should
follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/imagesbooks/
publications/historic-environment-and-site-allocations-in-local-plans/.
HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment
impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid
merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.
Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at
risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.
Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available
evidence base. Cumulative effects of site options on the historic environment should be considered too.
The following broad steps might be of assistance in terms of assessing sites:
• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced
The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area
could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.