Site ID: 703

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Site Assessment Pro Formas

Representation ID: 8912

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Representation Summary:

The site was previously submitted to the Council for consideration as part of the Council’s ‘call for sites’ exercise in August 2020. The land area being promoted is shown below.
Figure 1: Land off Moor End Lane, Radwell (Radwell Lakes)
3.2 Land off Moor End Lane, Radwell extends to approximately 135 hectares and comprises, in addition to farmland, substantial areas of former gravel workings that over time have become lakes that are currently used for fishing and other open-air, informal leisure uses (see figure 1 below). There is a crescent of lakes west of the A6 and the River Great Ouse. There is also a small lake on the southwest corner of the site. A designated cycle route runs parallel to the A6. Moor End Lane lies to the north of the site forming the boundary along its northern tip.
There is a railway line which is located on the western side of the site.
3.3 The village of Radwell is located circa 230 metres to the west of the railway line. The eastern part of the site is in flood zone (3b) (functional floodplain) and there is a small pocket of land in flood zone (3a) to the northwest. Access to the site is provided via a private road that is owned and controlled by parties related to Bedfordia Developments Ltd. There are two existing access points onto into the public highway in the vicinity of Radwell. The site forms part of the Upper Great Ouse River Valley.
3.4 Owned entirely by one party, the site offers an opportunity to provide for an expansion of tourism and leisure use, including, but not limited to, water sports and water-based recreation; ancillary restaurants, cafes and/or public houses; recreational based retail outlets; and accommodation - lodges, eco camping; camping pods or glamping.
3.5 Similar examples of such development have been seen elsewhere in the region at Stanwick Lakes (East Northants) and on a smaller scale and linked with a specific pastime at Box End Aqua Park (Bedford Borough).
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 703)
Site Assessment Criteria
3.6 We have reviewed the Council’s assessment of the site and wish to make a number of comments below. In terms of the assessment proforma more generally the Council has failed to take account of the potential net benefits associated with the proposed leisure and tourism uses, referring incorrectly to (for example) proposed industrial development in assessing potential impact on groundwater and indicating the potential to generate congestion.
Within or adjoining the urban area or a defined settlement policy area boundary
3.7 The proposed nature of uses at the site indicates that its location in the rural area outside of existing settlements does not represent a constraint to leisure and tourism uses. The site offers significant potential to provide mixed use leisure development including pub/restaurant/hotel and holiday homes in an attractive location. As part of the details submitted for our client’s site at Radwell Lakes we confirm that this location is free from overriding constraints to availability or suitability and that access can be provided.
Habitats and Protected Species
3.8 While the Council’s proforma notes the presence of protected species and uncertain impacts on habitats given the site’s importance for nature conservation this fails to take account of the extensive land area (over 145ha) or existing uses within the site. Subject to further consideration by the Council it would be appropriate to ensure that areas of greatest potential impact are avoided and opportunities for mitigation and enhancement can be provided based initially on the findings of a Preliminary Ecological Appraisal including Phase 1 Habitat Survey and protected species surveys including reptiles and bats.
Impact on designated or non-designated heritage assets or their setting
3.9 The Call for Site’s assessment found that the proposal has the potential to cause harm to heritage assets, which may range from low to high. This is a finding applied to the majority of the Council’s assessment pro-forma.
3.10 In relation to the proposed leisure and recreation uses at the site, and given the substantial land area, these would not represent any significant change to the contribution that the site makes to the setting of any designated or non-designated heritage assets. There will be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation.
Impact on highways
3.11 The Council’s assessment notes that the site is located east of Radwell village approximately 7.5 miles north of Bedford town centre. The closest bus stop located west in Radwell village approximately 750m of the site. The Council’s assessment takes no detailed account of the proposed leisure and tourism uses at the site nor its existing function including the provision of fishing lakes and open air leisure. Assessment for the intensification of these uses would result in materially less impact on the highways network than development of the whole site (as implied by the suggestions in the Council’s pro-forma).
3.12 A Transport Assessment will be developed to assess the impact of the development on the highway network, particularly along the Moor End Lane, together with an assessment of feasibility of the numerous options available to improve access, if required. Appropriate policy criteria could also be provided to support development of a Travel Plan taking account of existing walking routes within and adjoining the site.
See attachment for plans.