Site ID: 977

Showing comments and forms 61 to 90 of 129

Object

Site Assessment Pro Formas

Representation ID: 5816

Received: 07/09/2021

Respondent: Mrs Gillian Tagg

Representation Summary:

Land west of Wyboston (Dennybrook) Site 977

I consider the land west of Wyboston (Dennybrook) to be unsustainable and the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single-track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that they adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 (or up to 10,150) dwellings would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that the Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoter) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Staploe Parish Council Highways Technical Note which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include: Small scale development in villages which could lead to loss of their distinctive character; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 (or up to 10,150) new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the verges and hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. This spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
I believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.
100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots; it would engulf Honeydon; the location is high quality agricultural land; it is valued as a rural location by its residents; there are no services; the roads are very narrow; it is too far from the new E-W rail station to offer sustainable transport; there are many nature reserves and listed buildings, and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Site Assessment Pro Formas

Representation ID: 5868

Received: 08/09/2021

Respondent: Mr Norman Hoy

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.
100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Site Assessment Pro Formas

Representation ID: 5886

Received: 08/09/2021

Respondent: Staploe Parish Council

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.

I’d also like to add that the local plan was misleading in that it mentioned 2,500 homes for Dennybrook upto 2040, however when we received the developers (Taylor Wimpey) vision document for call for sites I clearly states 11,000 homes in the longer term. I believe this should have been MADE clearer and more transparency should have been adopted. Plus in BBC issues and options paper in August 2020 our Stapole Parish was shown as an urban / brownfields site and there are NO brownfield sites in the parish, as Honeydon is classed as open countryside, so feel this should be investigated and re review due the error.

The proposed site at Dennybrook falls mostly within Honeydon, my home of over 13 years. It’s entirely within a rural setting with many narrow, single track roads (many of which NOT suitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021.

ANY significant development within our parish would make a permanent change to the magnificent landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.

Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.

When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots (St Neots less than 3 Miles / Bedford 10 miles!!) , with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots.




Dennybrook site has poor access to Bedford, as many new residents will favour St Neots or Biggleswade retail park which adds further economic damage to Bedford Town and Stations which is in serious decline.

Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots.

It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.

In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.

These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.

The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.

The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.

There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.

A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.

In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.

Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.

The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. I choose to live in Honeydon back in 2007 due to the rural location, and idyllic surroundings. We keep livestock and are concerned that this may no longer be possible adjacent to a new town due to the traffic. My panorama views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.

I and other residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.
100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would entirely engulf Honeydon, the location is high quality grade 2 agricultural land, it is valued as a rural location by myself and other residents, there are no services, the roads are very narrow and would total overwhelm the local road network, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Site Assessment Pro Formas

Representation ID: 5937

Received: 08/09/2021

Respondent: Carmen Hardisty

Representation Summary:

I am a rural resident in Colmworth and have being for the last 30 years.
In these three decades we have being witness to the increase traffic that he present road infrastructure has to endure.
After the improvements to the Black Cat round about, at pic time, drivers still have to wait for 20 minutes or more to access the A1 or the 421-428
The rural lanes, which has access to only one car at the time, are getting more and more dangerous as drivers without experience and knowledge of the proper code to give way or how to overtake tractors is used.
The plans for these new town with an over extensive number of new residents are not upgrading the Infrastructures of the A1 or 421- 428.
My first point to object to the Local plan 2040 is that, the new number of drivers will elevate the Main roads infrastructure to a chaotic situation.
Rural communities have an unspoken code of conduct. During lock down we have an increase number of people from other towns exercising the right of using the countryside.
These have turn into the abuse of the countryside. People walking their dogs in our Country Park or the country lanes have made a mess of it, leaving dog and food waste everywhere.
Dogs let to run free, attaching wild life and farm animals.People leaving the footpaths and wondering in private land, destroying crops.
My second point to object to the Local plan 2040 is that, the new number of town people, with no understanding of the country life will cause irreparable damage to a precarious ecosystem.
My third point to object to the Local plan 2040 is that, this agricultural land is extremely productive, you are taking away prime arable land from food production. I know there is a need for housing but it is short sighted to build in the green belt, when the world is leading to a shortage of food production, also increased with climate change. I am sure there is less productive land available to build on.
My final point, and I could carry on, is that, this consultation has not being democratic and included every house hold affected by these planning proposal. I talk to people in my village who are total unaware of their right to object to these plans, other people who would like to make a point are unable to do so because they do not have computer skills.
The number of responses you are receiving are not a real representation of the feelings in the villages affected.
A house to house consultation by post is needed, in order for the consul to consolidate a democratic right of each resident in the area.

Object

Site Assessment Pro Formas

Representation ID: 6009

Received: 08/09/2021

Respondent: Mr Larry Gooch

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.
100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips

Object

Site Assessment Pro Formas

Representation ID: 6228

Received: 09/09/2021

Respondent: Peter Coles

Representation Summary:

Dennybrook
Land west of Wyboston (Dennybrook) Site 977
Land west of Wyboston (Dennybrook) is considered the least preferred option and should be
discounted as a sustainable location for development by Bedford Borough Council. The following
comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new
settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725
Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the
site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely
rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs)
and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly
valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by
a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within
the Parish would make a permanent change to the landscape and the setting of the small hamlets
and rural nature in the locality. Such physical changes cannot be reversed, and the Council would
need to be satisfied through a thorough review of the supporting documents to the site submissions
that adequately address the impacts, and in terms of achieving sustainable development – in line
with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the
Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated
December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to
26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall
provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the
plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum.
Regardless which of the figures proposed, the strategy of option 2a (including 2,500 homes at Little
Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new
settlement.
When looking at the spatial approach to locating new development, the proposed site at
Dennybrook would be located within close proximity to St Neots, with a possible merging into
Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development.
Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a
potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the
Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy
37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the
landscape setting and contribute to maintaining the individual and distinct character, and separate
identities of settlements by preventing coalescence…’. It should also be taken into consideration that
St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha
of employment land over the plan period. Therefore, a new settlement directly to the west of the
existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within
the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 6328

Received: 10/09/2021

Respondent: Mr Paul Zwetsloot

Representation Summary:

Dennybrook
Land west of Wyboston (Dennybrook) Site 977
Land west of Wyboston (Dennybrook) is considered the least preferred option and should be
discounted as a sustainable location for development by Bedford Borough Council. The following
comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new
settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725
Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the
site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely
rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs)
and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly
valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by
a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within
the Parish would make a permanent change to the landscape and the setting of the small hamlets
and rural nature in the locality. Such physical changes cannot be reversed, and the Council would
need to be satisfied through a thorough review of the supporting documents to the site submissions
that adequately address the impacts, and in terms of achieving sustainable development – in line
with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the
Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated
December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to
26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall
provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the
plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum.
Regardless which of the figures proposed, the strategy of option 2a (including 2,500 homes at Little
Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new
settlement.
When looking at the spatial approach to locating new development, the proposed site at
Dennybrook would be located within close proximity to St Neots, with a possible merging into
Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development.
Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a
potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the
Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy
37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the
landscape setting and contribute to maintaining the individual and distinct character, and separate
identities of settlements by preventing coalescence…’. It should also be taken into consideration that
St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha
of employment land over the plan period. Therefore, a new settlement directly to the west of the
existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within
the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 6352

Received: 10/09/2021

Respondent: Mr Martin Phillips

Representation Summary:

This propose development is on high quality agricultural land and building on this site will reduce grop growing capacity and will have a big impact on the natural biodiversity in this area. On this site I have seen many birds including sky larks, red kites, barn owls and Buzzards, I have also a large number of Brown Hares The footpaths and bridleways going through this site are continually used by the local residents and visitors from nearby towns as we are encouraged to walk and exercise
Developing this site will lead to an increase of traffic on small rural roads regardless of any planned road developments as the small rural roads will be used as a rat run to access the nearby towns for work and transport etc.
As this development is nearer St Neots, this will economically disadvantage the growth and development to Bedford town center
This site has no brown field areas and is all on high grade agricultural land
If this development goes ahead it will lead to decades of disruption to this very quiet rural area which will have an impact on the residents physical and mental health

Support

Site Assessment Pro Formas

Representation ID: 6353

Received: 10/09/2021

Respondent: Jen Giles

Representation Summary:

Dennybrook
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.

Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.

The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2a (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.

When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.

The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.

In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.

The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.

The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.

There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.

A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.

In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.

Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.

The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 6386

Received: 13/09/2021

Respondent: Mrs Kay Wade-Gery

Representation Summary:

Please accept this letter to register my objection to the planned development of 10,800 residences at your proposed Local Plan at the area known as Dennybrook.

I fully understand the need to provide housing in the Bedfordshire County, however, this proposal of area is unacceptable. The three hamlets, or four if you include the oldest estate in the County that is Bushmead Priory Estate, are a rural community of many years standing. The Bushmead Priory Estate has the oldest standing Priory in its condition in the Country along with a SSSI known as the Moats. The historical area has been in my husband’s family for almost 500 years and the reason these beautiful sites still exist is that this area has been kept as rural as it currently is. There are several other families that have been in this area for centuries and this development will change this ancient rural area.

The Bushmead Road is already a “rat run” for those motorists who are trying to avoid the major roads and over the years there have been multiple accidents and fatalities. Infrastructure is not a valid argument for not having such a development on our precious doorstep, as I am sure you and the powers that be would argue, that this will be taken into account, but should you wish to access the major roads I am left in no doubt that the winding and country roads will be made into even more than a death trap. Most deaths and road traffic collisions are on these such roads.

The historic local town of St Neots will be engulfed by a satellite housing mass and the benefits of this plan are outweighed by the negatives. The Dennybrook Town will become a dormitory town, with people commuting to the south-east, for higher salaries but lower cost housing and bring little to the local with them spending their monies elsewhere rather than locally and not supporting local businesses.

Your need to fulfill the need for housing is admirable but to ruin this quiet area of unspoilt countryside is an abomination. I am sure, as many of my fellow local residents feel, that rather than a whole new town, and that what this proposed development will become, adding smaller areas of housing into the current village populations would only help this area prosper and not invade the village and rural way of life. After all, many people that have moved into this area have come for just that…a rural life.

The agricultural land that you are proposing to develop is Grade Two farming land and not either brown field nor low grade cropping land. In these uncertain times with the UK leaving the European Union and the pandemic which the entire world finds ourselves in has highlighted the need for locally produced food and the need for the UK as a whole to become more self-sufficient.

Your obligation to meet the Government’s housing requirements are being put above the people who are living in this county currently and we feel that our voices are not being heard. The size and location of this proposed site is inappropriate and out of context to this very special part of idyllic North Bedfordshire. The loss of the prime agricultural land and rural life should not be traded for a development of this scale and on this proposed site. The development of the Cambridge to Oxford Arc is important to link the east of the country to the west but surely there must be more suitable sites for a development, even at this level than the proposed.

I implore you NOT to grant permission for this project.

Object

Site Assessment Pro Formas

Representation ID: 6388

Received: 13/09/2021

Respondent: Mr Humphrey Chetwynd-Talbot

Representation Summary:

I am responding to the above consultation, in which four proposals for housing development are outlined. I am outlining my key reasons
for objecting to the Dennybrook Garden Village Site ID 977
and proposing that Little Barford (site ID 907), Twinwoods (site ID 883 ) or Colworth (site ID 1002) would be better, more suitable and sustainable alternatives.
1. Inappropriate and Inaccurate Disclosure
I have lived in Staploe Parish for over 30 years and most of the planning applications of which I have been aware have been rejected because Staploe is designated open countryside. Bedford Borough Council’s options paper in August 2020 for some, unexplained reason, designated most of Staploe parish as a brown option, rendering it appropriate for urban development. There are no brownfield sites in this parish and this misrepresentation should be explained and should render the formal consultation invalid. In the future, greenfield sites will be increasingly important for food production and to combat climate change and should be valued as such.

2. Destruction of Greenfield Site
Most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: “recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…”. and that “where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality”.
Grade 2 agricultural land is considered to be the best and most versatile agricultural land so constructing Dennybrook would be contravening Government Planning Policy which requires that brownfield sites be selected as a much greater priority than greenfield sites.

3. Poor Local Road Infrastructure
The road infrastructure is totally inappropriate to sustain a significant increase in volume of traffic; the southerly exit from Dennybrook is ¾ mile from the A1/A421 junction and there is likely to be significant disruption in the next ten years with the A428 dualling and alterations to the Black Cat roundabout layout. The northern exit would be on to the Bushmead Road. This is already a dangerous road, which is prone to flooding and enters a residential area in St Neots with a school and traffic-calming measures. Anyone living nearby knows that traffic congestion is significant, particularly at rush-hour and at the start and end of the school day.
Most of the roads inside the parish and going towards Bedford and villages to the west are single track, many with high verges and poor visibility. Many of them are designated as unsuitable for heavy goods vehicles. Verges have been nurtured as nature reserves over the years and are highly valued wildlife habitats. Bath asparagus, small eggar moths, sulphur clover, crested cow wheat and orchids grow along the verges and red kites, corn buntings, badgers, owls, egrets, skylarks and dragon flies are frequently seen in the lanes. The peace and tranquillity of the roads is appreciated by walkers, horse-riders and cyclists.
The transport model used by AECOM has significantly under-valued the number of vehicle trips and Dennybrook is too far from the proposed new East/West railway station or St Neots station to avoid a significant increase in car-use.

4. Town Centre Appropriation
Those of us living in the parish know that we are between 8 and 13 miles from Bedford and “out of sight, out of mind”. Dennybrook residents would look to St Neots and not Bedford for shopping and business-access, negating any valued of the development to Bedford and Bedford town centre and putting significant strain on already overstretched resources in St Neots.

5. Flooding
There are several water courses which feed into the River Ouse just upstream of St Neots from the Dennybrook area. There is regular flooding in several sites in the parish when we have heavy rainfall and St Neots had significant flooding in August and December 2020. The risk of flooding will be compounded with housing development, and an increase in surface-water drainage would further increase this flood-risk in both St Neots and Honeydon.

6. Listed Buildings and Areas of Importance
Buildings which would be affected by this development include Grade 1 listed St Denys Church Colmworth, Grade 2 listed Chestnuts and Dairy farm Cottage, Honeydon, Tythe Farm, Manor Farm and the Old Chapel.

Preferred choices of options
The consultation asks for suggested preferred options, including other alternatives not included in the consultation:

Option 2a: Proven Most Suitable Alternative
Bedford Borough Council’s own sustainability appraisals demonstrated and concluded that the alternative Option 2a is the preferred and most suitable option because urban development is more sustainable than rural.
Importantly, development within urban areas performed best particularly in reducing carbon emissions, promoting town centres (which incidentally are in decline), encouraging physical activity, delivering residents’ needs, access to community services (which are so important to mental wellness) and reducing the need to travel and promoting sustainable types of travel. New stations south of Bedford are planned and the A421 has capacity for additional traffic.
Option 2b: Alternative Preference
Of the other options that have been presented in the consultation Little Barford (site ID 907 – option 2b) is by far the most appropriate alternative, but excluding Wyboston / Dennybrook, which would provide additional 3,085 dwellings in the rail corridor, for the following reasons:
• A development in and around the urban area plus A1 and A421 transport corridor with rail-based growth parishes
• Access to a large number of services and facilities including existing employment which would reduce the need to travel by car
Further Alternatives Not Proposed in the Consultation – Twinwoods (site ID 833) or Colworth (site ID 1002)
A new development of up to 3,000 homes at Twinwoods (site ID 883) or Colworth (site ID 1002) could provide the infrastructure funding to support improvements to the A6 which has been needed for some time to provide residents with access to the east west rail station in Bedford. A northern parkway station or guided busway could be considered in the future to provide sustainable transport for those in the north of the Borough.
Twinwoods (site ID 883) would provide a significant proportion of brownfield land and Colworth (site ID 1002), which was supported in the 2035 plan, includes lower quality grade 3 agricultural land and so would comply with the NPPF requirement to use brownfield land or lower quality agricultural land before high quality agricultural land. These sites would also support Bedford Town Centre.
On these grounds alone, as a further alternative to Dennybrook or even an urban development, the brownfield site on Twinwoods is much more suitable particularly as:
• It does not flood
• It has no major watercourses and is distinct from other settlements – so no loss of identity for existing settlements
• Government planning policy seeks to develop brownfield land ahead of greenfield land (open countryside)

In conclusion, the proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single-track roads and no settlement policy area. The proposed site would destroy the hamlets of Begwary and Honeydon. It is interesting that there have been no proposed incremental benefits to any of the existing villages. The site is all on grade 2 (high quality) agricultural land and is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Accordingly, and for the reasons outlined, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 6393

Received: 13/09/2021

Respondent: Mr Brian Smith

Representation Summary:

I am responding to the above consultation, in which four proposals for housing development are outlined. I am outlining my key reasons
for objecting to the Dennybrook Garden Village Site ID 977
and proposing that Little Barford (site ID 907), Twinwoods (site ID 883 ) or Colworth (site ID 1002) would be better, more suitable and sustainable alternatives.
1. Inappropriate and Inaccurate Disclosure
I have lived in Staploe Parish for almost 44 years and most of the planning applications of which I have been aware have been rejected because Staploe is designated open countryside. Bedford Borough Council’s options paper in August 2020 for some, unexplained reason, designated most of Staploe parish as a brown option, rendering it appropriate for urban development. There are no brownfield sites in this parish and this misrepresentation should be explained and should render the formal consultation invalid. In the future, greenfield sites will be increasingly important for food production and to combat climate change and should be valued as such.

2. Destruction of Greenfield Site
Most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: “recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…”. and that “where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality”.

Grade 2 agricultural land is considered to be the best and most versatile agricultural land so constructing Dennybrook would be contravening Government Planning Policy which requires that brownfield sites be selected as a much greater priority than greenfield sites.
When I first moved into this area there were huge acreages of brassicas such as broccoli, Brussel sprouts, cabbage, cauliflower, collard greens etc. (These vegetables contain SUBSTANCES THAT MAY PROTECT AGAINST CANCER also known as cruciferous vegetables ). Having left Europe surely we should be reinstating these crops along with other food products (Along with other commodities allowed out of this country) and cut imports. We need to think about the future of this country with its increasing population, THINK IF WE HAVE A SERIOUS FALLOUT WITH EUROPE THEY COULD CUT OF A LOT PRODUCTS WE RELY ON LEAVING US IN A VERY SERIOUS SITUATION. LETS GET AS SELF SUFFICIENT AS POSSIBLE ASAP. There are plenty of less fertile areas in this country of less productive soil up north for example which could be developed and create employment, relieving the over-populated south. Build new infrastructure to northern ports creating further employment, relieving eastern and southern ports. THE LIKES OF DENNYBROOK ARE NOT REQUIRED OR WANTED HERE, PUT IT WITH MANUFACTURING FACILITIES, WHERE GREATER EMLOYMENT OPPORTUNITIES WOULD BE APPRECIATED.
3. Poor Local Road Infrastructure
The road infrastructure is totally inappropriate to sustain a significant increase in volume of traffic; the southerly exit from Dennybrook is ¾ mile from the A1/A421 junction and there is likely to be significant disruption in the next ten years with the A428 dualling and alterations to the Black Cat roundabout layout. The northern exit would be on to the Bushmead Road. This is already a dangerous road, which is prone to flooding and enters a residential area in St Neots with a school and traffic-calming measures. Anyone living nearby knows that traffic congestion is significant, particularly at rush-hour and at the start and end of the school day.
Most of the roads inside the parish and going towards Bedford and villages to the west are single track, many with high verges and poor visibility. Many of them are designated as unsuitable for heavy goods vehicles. Verges have been nurtured as nature reserves over the years and are highly valued wildlife habitats. Bath asparagus, small eggar moths, sulphur clover, crested cow wheat and orchids grow along the verges and red kites, corn buntings, badgers, owls, egrets, skylarks and dragon flies are frequently seen in the lanes. The peace and tranquillity of the roads is appreciated by walkers, horse-riders and cyclists.
The transport model used by AECOM has significantly under-valued the number of vehicle trips and Dennybrook is too far from the proposed new East/West railway station or St Neots station to avoid a significant increase in car-use.

4. Town Centre Appropriation
Those of us living in the parish know that we are between 8 and 13 miles from Bedford and “out of sight, out of mind”. Dennybrook residents would look to St Neots and not Bedford for shopping and business-access, negating any valued of the development to Bedford and Bedford town centre and putting significant strain on already overstretched resources in St Neots.

5. Flooding
There are several water courses which feed into the River Ouse just upstream of St Neots from the Dennybrook area. There is regular flooding in several sites in the parish when we have heavy rainfall and St Neots had significant flooding in August and December 2020. The risk of flooding will be compounded with housing development, and an increase in surface-water drainage would further increase this flood-risk in both St Neots and Honeydon.

6. Listed Buildings and Areas of Importance
Buildings which would be affected by this development include Grade 1 listed St Denys Church Colmworth, Grade 2 listed Chestnuts and Dairy farm Cottage, Honeydon, Tythe Farm, Manor Farm and the Old Chapel.

Preferred choices of options
The consultation asks for suggested preferred options, including other alternatives not included in the consultation:

Option 2a: Proven Most Suitable Alternative
Bedford Borough Council’s own sustainability appraisals demonstrated and concluded that the alternative Option 2a is the preferred and most suitable option because urban development is more sustainable than rural.
Importantly, development within urban areas performed best particularly in reducing carbon emissions, promoting town centres (which incidentally are in decline), encouraging physical activity, delivering residents’ needs, access to community services (which are so important to mental wellness) and reducing the need to travel and promoting sustainable types of travel. New stations south of Bedford are planned and the A421 has capacity for additional traffic.
Option 2b: Alternative Preference
Of the other options that have been presented in the consultation Little Barford (site ID 907 – option 2b) is by far the most appropriate alternative, but excluding Wyboston / Dennybrook, which would provide additional 3,085 dwellings in the rail corridor, for the following reasons:
• A development in and around the urban area plus A1 and A421 transport corridor with rail-based growth parishes
• Access to a large number of services and facilities including existing employment which would reduce the need to travel by car
Further Alternatives Not Proposed in the Consultation – Twinwoods (site ID 833) or Colworth (site ID 1002)
A new development of up to 3,000 homes at Twinwoods (site ID 883) or Colworth (site ID 1002) could provide the infrastructure funding to support improvements to the A6 which has been needed for some time to provide residents with access to the east west rail station in Bedford. A northern parkway station or guided busway could be considered in the future to provide sustainable transport for those in the north of the Borough.
Twinwoods (site ID 883) would provide a significant proportion of brownfield land and Colworth (site ID 1002), which was supported in the 2035 plan, includes lower quality grade 3 agricultural land and so would comply with the NPPF requirement to use brownfield land or lower quality agricultural land before high quality agricultural land. These sites would also support Bedford Town Centre.
On these grounds alone, as a further alternative to Dennybrook or even an urban development, the brownfield site on Twinwoods is much more suitable particularly as:
• It does not flood
• It has no major watercourses and is distinct from other settlements – so no loss of identity for existing settlements
• Government planning policy seeks to develop brownfield land ahead of greenfield land (open countryside)

In conclusion, the proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single-track roads and no settlement policy area. The proposed site would destroy the hamlets of Begwary and Honeydon. It is interesting that there have been no proposed incremental benefits to any of the existing villages. The site is all on grade 2 (high quality) agricultural land and is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Accordingly, and for the reasons outlined, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 6484

Received: 13/09/2021

Respondent: Mrs Gail Browning

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 6493

Received: 13/09/2021

Respondent: Miss Becky Browning

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 6614

Received: 14/09/2021

Respondent: Miss Nicola Tagg

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

I consider the land west of Wyboston (Dennybrook) to be unsustainable and the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single-track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that they adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 (or up to 10,150) dwellings would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that the Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoter) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Staploe Parish Council Highways Technical Note which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include: Small scale development in villages which could lead to loss of their distinctive character; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 (or up to 10,150) new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the verges and hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. This spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
I believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots; it would engulf Honeydon; the location is high quality agricultural land; it is valued as a rural location by its residents; there are no services; the roads are very narrow; it is too far from the new E-W rail station to offer sustainable transport; there are many nature reserves and listed buildings, and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Site Assessment Pro Formas

Representation ID: 6631

Received: 14/09/2021

Respondent: Mr Mark Potts

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Site Assessment Pro Formas

Representation ID: 6774

Received: 14/09/2021

Respondent: Ms S Kelly

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 6784

Received: 14/09/2021

Respondent: Mrs JENNIFER ELLISON

Representation Summary:

I am responding to the consultation re Denybrook garden Community.
I am concerned and worried about the permenate damage that the proposed housing will cause in the local area, road congestion, litter, crime, with a total 10000+ houses, together with the lack of consultation that our local Parish council have with the residents during Covid for Wyboston, coupled with the late ness of Denybrook some 9 mths after deadline, I feel that the whole consulttion process has been far less than fair. In light of this could there be a further consultation period, as I feel there has been insuffient time for all to have a fair say, as during covid there have been few opotunities to meet and discuss, and for lengthy periods no meetings at all.

Object

Site Assessment Pro Formas

Representation ID: 6785

Received: 14/09/2021

Respondent: Mrs Amanda Norman

Representation Summary:

I Amanda Norman of 5 Rookery Road, Wyboston MK 44 3AX wholeheartedly an against The whole plan re-Dennybrook.
Two years ago we bought out rural property in theis hamlet to live a peaceful retirement.
Out hime will be overlooked by dennybrook visa versa.
Our huge picture window overlooks he fields ..
but it’s not just the building it’s the construction. On green field. The loss of wildlife habitat abs agricultural land.
We moved to a village Dennybrook will change Wyboston into a town and not fair!
I speak of behalf of my Husband David Norman who also 100% objects .!
So please count oit objection.
The forms you gave us tk gil in ti complex abs complicated.
7 suspect that was done in purpose to put people like me off.. responding!
I think that small amount of growth all across the county is ok but not all in one place !!!

Object

Site Assessment Pro Formas

Representation ID: 6786

Received: 14/09/2021

Respondent: Mr David Norman

Representation Summary:

I Amanda Norman of 5 Rookery Road, Wyboston MK 44 3AX wholeheartedly an against The whole plan re-Dennybrook.
Two years ago we bought out rural property in theis hamlet to live a peaceful retirement.
Out hime will be overlooked by dennybrook visa versa.
Our huge picture window overlooks he fields ..
but it’s not just the building it’s the construction. On green field. The loss of wildlife habitat abs agricultural land.
We moved to a village Dennybrook will change Wyboston into a town and not fair!
I speak of behalf of my Husband David Norman who also 100% objects .!
So please count oit objection.
The forms you gave us tk gil in ti complex abs complicated.
7 suspect that was done in purpose to put people like me off.. responding!
I think that small amount of growth all across the county is ok but not all in one place !!!

Object

Site Assessment Pro Formas

Representation ID: 6826

Received: 15/09/2021

Respondent: Mr Damian Smith

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 6916

Received: 15/09/2021

Respondent: Mrs Tina Mills

Representation Summary:

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe, and is close to a number of other village parishes. The majority of the development area is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents/neighbours. Any significant development like the one mentioned would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
If the DennyBrook development is approved and the surrounding villages (e.g Little Staughton for one, with a maximum current view of 85 houses listed in call to sites, if each house had average of 3 bedrooms, 255 people could potential have cars in this one village, all using the surrounding roads/facilities/infrastructure which combined with the proposed new DennyBrook area, rural life would be severely impacted and any trip in the car not through rural roads but met with monolithic housing, roundabouts and traffic. Addiitonally as St Neots is more the local town for many village residents (not Bedford), capacity for traffic, shops, and retaining countryside living, could be severely limited and rural enjoyment lost
The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.

The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that some of the land is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance. Countryside and farms in this and surrounding areas should be retained for many reasons, people need farmland to survive with food if problems with overseas supplies or disease in crops ever occurs, housing built on farm land is an irreversible decision, why not develop brown field sites like Thurleigh Airfield and surrounding areas, not erode the lovely countryside that people live in, visit and enjoy.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.

Object

Site Assessment Pro Formas

Representation ID: 7094

Received: 09/09/2021

Respondent: June Coles

Representation Summary:

Dennybrook
Land west of Wyboston (Dennybrook) Site 977
Land west of Wyboston (Dennybrook) is considered the least preferred option and should be
discounted as a sustainable location for development by Bedford Borough Council. The following
comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new
settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725
Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the
site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely
rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs)
and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly
valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by
a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within
the Parish would make a permanent change to the landscape and the setting of the small hamlets
and rural nature in the locality. Such physical changes cannot be reversed, and the Council would
need to be satisfied through a thorough review of the supporting documents to the site submissions
that adequately address the impacts, and in terms of achieving sustainable development – in line
with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the
Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated
December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to
26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall
provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the
plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum.
Regardless which of the figures proposed, the strategy of option 2a (including 2,500 homes at Little
Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new
settlement.
When looking at the spatial approach to locating new development, the proposed site at
Dennybrook would be located within close proximity to St Neots, with a possible merging into
Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development.
Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a
potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the
Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy
37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the
landscape setting and contribute to maintaining the individual and distinct character, and separate
identities of settlements by preventing coalescence…’. It should also be taken into consideration that
St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha
of employment land over the plan period. Therefore, a new settlement directly to the west of the
existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within
the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 7141

Received: 09/09/2021

Respondent: Stephen Coles

Representation Summary:

Dennybrook
Land west of Wyboston (Dennybrook) Site 977
Land west of Wyboston (Dennybrook) is considered the least preferred option and should be
discounted as a sustainable location for development by Bedford Borough Council. The following
comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new
settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725
Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the
site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely
rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs)
and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly
valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by
a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within
the Parish would make a permanent change to the landscape and the setting of the small hamlets
and rural nature in the locality. Such physical changes cannot be reversed, and the Council would
need to be satisfied through a thorough review of the supporting documents to the site submissions
that adequately address the impacts, and in terms of achieving sustainable development – in line
with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the
Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated
December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to
26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall
provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the
plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum.
Regardless which of the figures proposed, the strategy of option 2a (including 2,500 homes at Little
Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new
settlement.
When looking at the spatial approach to locating new development, the proposed site at
Dennybrook would be located within close proximity to St Neots, with a possible merging into
Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development.
Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a
potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the
Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy
37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the
landscape setting and contribute to maintaining the individual and distinct character, and separate
identities of settlements by preventing coalescence…’. It should also be taken into consideration that
St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha
of employment land over the plan period. Therefore, a new settlement directly to the west of the
existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within
the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 7221

Received: 17/09/2021

Respondent: Mr Peter Knight

Representation Summary:

Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 7230

Received: 17/09/2021

Respondent: CM Ryland

Representation Summary:

I would like to express my opposition to Taylor Wimpey’s plans to build a development of 1000s of new homes in a rural area with high quality agricultural land. There is no public transport meaning new residents will rely on cars adding to the already highly congested road junction on the A1 and increasing the considerable delays already seen. Roads in the area are small, often single track and completely unsuitable to HGVs during development or 1000s of new cars afterwards. Furthermore, the development is only likely to add to sprawl of St Neots with large developments already in progress to the east and provide no benefit to Bedford, whose plan it is supposedly part of.

My opposition is detailed below.

Dennybrook
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.

Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.

The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2a (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.

When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.

The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.

In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.

The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.

The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.

There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.

A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.

In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.

Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.

The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Site Assessment Pro Formas

Representation ID: 7261

Received: 01/09/2021

Respondent: Miss Laura Jones

Representation Summary:

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S.
n addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of n addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of n addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Site Assessment Pro Formas

Representation ID: 7319

Received: 02/09/2021

Respondent: Miss Emma Pegler

Representation Summary:

The location of Dennybrook is unsustainable. For employment purposes, for example, many residents will have to commute above average distances reliant on private cars. The distances will not allow for walking or cycling – the suggested new stations will NOT be close enough for anything other than cars to be used. In my years of commuting from Bedford Station, I have not seen bicycles coming from the countryside – it is too far, the roads are dark and often slippery. When there is ice on the roads in the winter, most of the roads are not gritted unless for the major B660 there is gritting if there is a threat of snow. It is completely out of the question that anybody can do anything other than use a car and if you have young adults on the estate, they need to drive or be driven everywhere – sports, stations, shops, cafes, bars. The demographic of people moving to such an estate. Has that been identified? If it’s young people and people in employment, this site is totally unsuitable.

Please be reminded that back in 2019, BBC noted in their assessment of the site: ‘the site is located in a relatively convenient location for vehicle journeys on the strategic road network, which may be a deterrent to non-motorised travel.’

A very important point about Dennybrook is that the Draft Local Plan assumes the development for 2500 dwellings but the site promoter’s Vision document talks about up to 10,000 and what they have put in is on the basis of that and NOT the 2500. This feels like it is tricking Colmworth and my local community. This is so important and so momentous and yet we are given inconsistent and vague assumptions without a firm evidence base. So little precision has also meant that there is a lack of consistency as to whether the site proposal is Dennybrook or Denybrook and yet this will fundamentally change the area beyond recognition. Does BBC or the Mayor care about evidence base and our communities enough to respect us with proper evidence? As a lawyer I would expect far more precision and respect for honouring previous statements and conclusions, the NPPF and climate.

The scale of this project is promising significant disruption even at 2500 houses with construction traffic extending beyond 2055 – this is an unacceptable burden on our neighbouring communities.

There are very few access roads to Dennybrook. Apart from the far east end of the site near St. Neots, the only road access points are unclassified roads incapable of supporting thousands of cars and lorries. Several roads are single-tracked .

There have been statements by the developer for Dennybrook that the site has opportunities to integrate with the new East-West Rail and new station. This is misleading and unrealistic. They are as far away as Bedford and St Neots stations. People will have to have a car so in a family of 4 – 2 adults and 2 teenagers, one needs at least 2-3 cars or reliance on taxis to get to work/school which is pollution/congestion and cost. The reference by the developer to a cycle link is a token to appeal to the current environmental agenda and cannot be considered realistic. You cannot cycle to work or a station on a narrow unlit back road with lots of traffic on it in the dark for over 8km – and that is as the crow flies.

Further you can’t cycle on the A1. And getting on to the A1 will be severely congested for cars.

Water is also an issue. The Environment Agency’s Draft Sustainability Report 2021 recommends that the Local Plan considers water resources as a key issue and yet there is no evidence how the water supply will be provided/safeguarded and there is no evidence base around how waste water will be dealt with. These are extremely important issues and we have to assume that the Dennybrook site adversely impacts existing and future water supplies in the absence of any statements showing otherwise.

Heritage

BBC has not prepared Heritage Impact Assessments on its options to comply with the NPPF and Historic England’s Advice Notes. This shows the disregard for our area. People live in and preserve historic homes dating back to the Middle Ages. For a listed property, anything I want to do to it needs pre-approval and I cannot do anything that impacts its views or appearance, but one can totally alter the complexion of an historic area without any kind of impact assessment. I refer to a recent appeal regarding 49 dwellings in a Suffolk village which was partly dismissed because the inspector deemed there to be too high an impact on a manor house, barns and a Grade II* Church. Please bear in mind the Colmworth Church is Grade I listed.

Landscape and Biodiversity

The Bedford Borough Landscape Character Assessment (2020) states that the Thurleigh Clay Farmland (the landscape character area in which the Dennybrook Garden village site sits) is characterised as “dominated by arable farmland generally with large irregular fields plus smaller fields around settlements…” with “hedgerow trees are prominent in the level of landscape, many of them mature, including remnant trees within fields…”. Regarding future management it states that a key guideline is to “conserve the character of the rural roads and limit urbanising influences” and to “resist any development that will result in further loss/fragmentation of hedgerows and hedgerow trees.”

Dennybrook clearly conflicts with this.

Chapter 15 of the NPPF requires decisions to enhance the natural and local environment. The site promoter has merely referenced a wildlife corridor. This demonstrates that there is no proper application of the Ecology Strategy 2021. Smaller developments do not systematically destroy habitat for wild bird species and mammals in the way Dennybrook will. All those cars, the pollution, the light pollution – a corridor is not enough. All that destroyed farm land takes away wildlife habitat – how can a decision to impose a town the size of Biggleswade on the countryside be taken without proper consultation with our communities and without properly considering other more appropriate sites – smaller sites, brownfield sites, urban spaces. There is nothing coming from the Local Plan that shows that biodiversity/landscape/wildlife is considered or matters. And yet during COVID, we saw masses of people using our country park and walking in our fields to improve their frames of mind. Do these things not matter? That people who do not live in our communities have the power to destroy them rather than looking at smaller sustainable development.

Agricultural Land eradicated

A Green Future: Our 25 Year Plan to improve the Environment sets out the Government’s 25 year plan to improve the health of the Environment by using natural resources more sustainability. It says the best agricultural land needs to be protected.

Under Agricultural Land Classification, out of the 5 grades of agricultural land, the best is 1,2 and 3a.

Dennybrook is comprised mostly Grade 2 and some Grade 1. This means that out of all the promoted sites, Dennybrook has the best agricultural land. It should be protected. Twinwoods and Little Barford have previously developed land. Colworth is Grade 3.

Object

Site Assessment Pro Formas

Representation ID: 7321

Received: 02/09/2021

Respondent: Miss Becky Browning

Representation Summary:

and west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Site Assessment Pro Formas

Representation ID: 7342

Received: 19/09/2021

Respondent: Mr Ross Thomson

Representation Summary:

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.

The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.

Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.

When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.

The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.

In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.

These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.

The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.

The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.

There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may 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. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.

In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.

Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.

The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.

Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.