Site ID: 1004

Object

Representation ID: 3778

Received: 24/08/2021

Respondent: Ken Cook

This proposal breaches the principle that there should be a natural gap separating the village of Wilstead and Wixams due to its size and proximity.

Object

Representation ID: 5127

Received: 03/09/2021

Respondent: Wilshamstead Parish Council

Development of this site would result in immediate coalescence between Wilstead and Wixams which would be fiercely resisted.

Support

Representation ID: 5131

Received: 03/09/2021

Respondent: Mr Keith Turner

Poor grade agricultural land
Near train station
Access to good roads
Near town centre

Object

Representation ID: 8479

Received: 02/09/2021

Respondent: Wates Developments

Agent: JLL

1) Aspect Ecology, Technical Briefing Note, dated August 2021.
2) Orion Heritage, Bedford Borough Council Regulation 18 Draft Local Plan Strategy Options
and Draft Policies Heritage Technical Note (undated)
3) Lichfields, Economic and Wellbeing Benefits Assessment, ref 18690189v1
4) Response to Call for Sites Site Assessment Pro Forma and Transport Access Assessment, itransport,
dated 26 August 2021, ref: TW/JW/ITB15565-003b
5) Phase 1 Preliminary Risk Assessment, Ramboll, dated 23 August 2021, ref: 1620011691
6) Feasibility Noise Assessment, RSK Acoustics, dated 31 August 2021, Ref 206/0466/R1
Our response to the selection criteria assessments is as follows:
Site Selection Criteria 1a – Air Quality – Within or Adjoining UAB SPA or Built Form of a
Small Settlement
This criteria includes an assessment whether or not the site is within or adjoining UAB (Urban
Area Boundary) SPA (Settlement Policy Area) or built form of a small settlement and grades
the site accordingly as either having a positive effect (+), uncertain effect (or insufficient
information) (0) or a negative effect (x).
The assessment of the subject site identifies that the ‘site is not within or adjoining the urban
area or a defined settlement policy area, or within the built form of a small settlement’ scoring
the site x (‘negative effect’).
The Bedford Local Plan 2030, adopted in January 2020 indicates the settlement policy area
boundary of Wixams. The northern boundary of the site adjoins the settlement policy area so
the site should be assessed as having a positive effect rather than a negative effect and scored
‘+’ as a result.
The image below shows an extract from the adopted Local Plan Proposals Map (Wixams inset)
on the left, and the site plan submitted with the Call for Sites submission in August 2020, on
the right. The boundary of the settlement policy area direct adjacent to the subject site.
(see attachment Site Assessments Rep for map)
The site should be scored ‘+’ as a result on the Site Assessment proforma
Site Selection Criteria 2a - Within or adjoining site of nature conservation importance?
A Preliminary Ecological Appraisal (PEA) was submitted with the Call for Sites submission in
20201, and further work has been undertaken by Aspect Ecology on this point (Aspect Ecology,
Technical Briefing Note, dated August 2021, see appendix 1 of this report). Both documents
note that no ecological designations are located within or bounding the site, the nearest
statutory ecological designation being Kings Wood and Glebe Meadows, Houghton Conquest
Site of Special Scientific Interest (SSSI) and Local Nature Reserve (LNR), located approximately
2.2km to the south of the site, whilst the nearest non-statutory designation is Wilstead
Meadows County Wildlife Site (CWS) located approximately 400m to the east of the site.
The proposed ‘+’ rating set out under the Site Assessment is therefore considered to be
appropriate.
Site Selection Criteria 2b - In an Area where Protected Species are Known or Likely to
Exist?
This criteria considers whether the site is in an area where protect species are known or likely
to exist which potential ratings ranging from ‘+’ -where no protected species have been
recorded or are likely on the site - to ‘x’ where protected species could be affected and ‘xx’
where protected species are or have been recorded on the site.
The site has been categorised ‘xx’ signalling protected species have been recorded.
Aspect Ecology have undertaken a Technical Briefing Note (dated August 2021) included as
appendix 1 of this report which specifically responds to the BBC site Assessment.
This Briefing Note notes that the survey work undertaken at the site in January 2020 did
confirm presence of the protected species Badger, with several setts recorded at the
boundaries of the site. It also notes that the site is also considered to offer potential for
protected species including bats, Dormouse, breeding birds, Great Crested Newt and reptiles
and specific Phase 2 surveys are recommended at the planning application stage to determine
presence/absence of such species.
However, it identifies that no Badger setts were recorded within the area of the site proposed
for development, whilst potential for other faunal species is largely limited to field boundary
habitats which could readily be retained under the proposals. It also identifies that there are
also substantial opportunities for mitigation and enhancement within the site given the large
areas of land available.
The report concludes on this point that the wording of the criteria does not take into account
whether protected species are likely to be impacted. It notes this clearly disadvantages sites
that have been subject to specific ecology work (with field surveys likely to identify one or
1 Preliminary Ecological Appraisal, Aspect Ecology, report dated11th August 2020, ref 5820 PrelEcoAp dv1/DM
more protected species, whereas this is unlikely to be confirmed by a desk based appraisal
only).
The Aspect work notes that given that the identified Badger setts are located outside of the
proposed development area, whilst further information is required in relation to other
protected species, a rating of ‘?’ (uncertain or insufficient information) is considered to be
more appropriate in this instance.
As a result we would request the pro forma assessment score is amended to ‘?’ accordingly.
Site Selection Criteria 2c - Potentially Able to Achieve a Net Gain in Biodiversity?
This criteria assesses the potential ability of the site to achieve a net gain in biodiversity
ranking the site ‘?’, meaning there is uncertain or insufficient information.
Aspect Ecology’s Technical Note (August 2021), included as appendix 1 indicates that there are
substantial enhancement opportunities available under the proposals.
Aspect have used the Defra Biodiversity Metric 3.0 calculation tool has to quantify the level of
Biodiversity Net Gain (BNG) that can be achieved under the proposed development.
Whilst the development proposals shown in the call for sites submission are illustrative and
therefore requiring a number of assumptions to be made at this stage, the BNG assessment
shows that a 31.96% biodiversity net gain could be achieved under the proposals. This only
includes the northern part of the site (shown via a red line boundary in the Call for Submission
Vision Document, August 2020) and excludes other land within Wates’ control to the south.
This additional land offers further opportunity for substation further net gain, over and over
this 31.96% gain, as noted in the Aspect Briefing Note (para. 4.4).
The criteria assesses the potential ability of the site to achieve a net gain in biodiversity. Given
the additional certainty applied by the BNG metric which shows the significant net gains which
are likely to be achieved by the current proposals, the assessment score should be amended
accordingly to achieve a ‘+’ score.
Site Selection Criteria 2d – Able to Link with the Green Infrastructure Opportunity
Network
The assessment notes that ‘no answer chosen’ presumably meaning no answer was selected
by Bedford Borough Council officers during the assessment of the site. Whilst the site is not
within or directly adjoining the green infrastructure opportunity network, the site is within
250m of the Greensand Ridge Fringes Green Infrastructure Network Opportunity Zone
(GINOZ), as can be seen from the adopted Local Plan extract below, and the Bedford
to Milton Keynes – Marston Vale GINOZ located approximately 1,250m to the north.
As identified in the submitted Aspect Technical Note (August 2020, see appendix 1), the site is
well located to contribute to a new green infrastructure link between these two zones, linked
by existing green infrastructure including the Wixams New Town green corridors and clearly able to enhance the network. The Technical Note identifies that the creation of new wetland,
woodland and grassland habitats would correspond with the identified green infrastructure
opportunities for the adjoining zones to the north and south.
As the site is able to link with the two GINOZs, north and south of the site, the Site Assessment
Pro Forma should be amended to include a plus (‘+’) score.
( see map in site assessment rep attachment)

3a. Proposing a Renewable Energy Scheme or Extra Energy Efficiency Standards?
Again, the assessment notes ‘no answers chosen’, so it assumed the officer the assessing the
site did not select an answer.
The site is not specifically proposed for a renewable energy scheme (assuming this refers to a
standalone renewable energy development). However the proposed residential development
will meet and where possible exceed any energy standards in the emerging Local Plan.
The draft local plan consultation document (dated June 2021) notes that policy 54 of the
adopted Local Plan 2030 will be amended to reflect national standards in respect of energy Council response notes the following:
“x 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.”
As well as on the site assessment proforma, additional heritage comments were made on the
submitted sites. In relation to the subject site, these comments were as follows:
“Potential high harm to (?)locally significant archaeological remains = low/moderate overall
impact?: The location of a possible medieval/post-medieval moated farmstead in the northeast
corner of the study site. Two neighbouring sites produced settlement activity from the
Iron Age, Roman and Saxo-Norman periods suggesting moderate to high archaeological
potential. Pre-determination archaeological evaluation will be required as signalled by
submitted heritage statement.
“Potential to have a minor impact on listed buildings in Wilstead, including Parish Church of All
Saints (grade II*). Also potential to impact on grade II listed buildings in Duck End. Impact likely
mitigated by relative distance, intervening A6 and rural setting in closer proximity to assets. “
As part of the Call for Sites consultation in 2020, the site was the subject of a historic
environment desk-based assessment by Orion Heritage (March 2020)2. This was undertaken in
accordance with the CIfA Standards and Guidance for Historic Environment Desk-Based
Assessments (2017). It included a site survey to assess the potential survival of as yet
unrecorded archaeological non-designated heritage assets as well as the potential effects on
the significance of nearby designated heritage assets.
2 Historic Environment Desk Based Assessment, Orion, March 2020 ref PN2497/1
Following the publication of the site assessment by BBC as part of the Local Plan consultation,
Orion Heritage have undertaken further work in the form of a review in the form of a Heritage
Technical note3 which is included at appendix 2 of this report.
The technical note identifies that there are three designated heritage assets that could
potentially be affected by the development of the site. These are The Vicarage Farmhouse
(NHLE 1114196) in Duck End, The Parish Church of All Saints (NHLE 1321582) and The Little
Church Farmhouse (NHLE 1114206), both in Wilstead. The assessment considered the
potential effects of the proposed development of the site in the significance of these three
assets. It concluded that while the site forms part of the wider rural landscape of these assets,
the contribution that the site makes to the significance/experience of these assets is negligible
to minor. The note concludes that the development of the site would consequently not harm
the significance of the Vicarage Farmhouse, the Parish Church of All Saints and the Little
Church Farmhouse.
The Bedford Borough Council Sites Assessment also references that there is the potential for
listed buildings within the wider area to be impacted. However the Orion Technical Notes
identifies that the proposed Wates development site is beyond the setting of these designated
assets, as well two grade II buildings at Chapel End listed buildings. It states that the Ducks End
listed buildings are both relatively distant from the site and are also separated by the later
houses of the built-up area of Ducks End and that consequently, the proposed development
would not result in any adverse harmful effects to the significance of these designated
heritage assets.
In terms of archaeology, the Heritage Assessment (2020) considered the archaeological
potential of the proposed development site. It established the following in relation to the
potential for the non-designated archaeological remains on site:
• There are no prehistoric, Roman, Saxon or post-medieval archaeological remans
recorded within the site.
• The cropmarks of a possible medieval/post-medieval moated farmstead have been
recorded in the north-east corner of the site. The eastern part of the proposed
roundabout for the proposed development will occupy the western part of the field
within which this feature is located. The construction of this roundabout will not
impact upon these remains.
• Although there are no Iron Age or Roman remains recorded within the site, based on
the results of previous archaeological investigations to the east, west and north of the
site, it is considered that there is a moderate potential for Iron Age to Romano-British
remains. Should such remains be present, they are considered unlikely to be of more
than local significance and therefore, will not be a design or a planning constraint.
However, it is possible that no such remains are present within the site. In accordance
with Bedford Borough Local Plan 2030 policy 42S clause ii, a programme of
archaeological evaluation comprising geophysical survey and evaluation trenching will
3 Land West of Wixams, BBC Regulation 18 Draft Local Plan Strategy Options and Draft Policies Heritage technical Note, Orion (undated).
be undertaken to support a future planning application. Should these investigations
have positive results (i.e. reveal archaeological remans), the layout of the scheme
could designed to avoid impacting upon them should the significance of the remains
merit preservation or a programme of archaeological excavation and recording can be
agreed with the Borough Council in accordance with policy 42S clause vii where such
remains are considered to not merit preservation.
• The site of a former WWII military camp has been recorded in the south of the site.
This is within the extensive area of proposed open space and so should remains
associated with this camp survive, they will not be impacted by the proposed
development.
Overall, the Heritage Technical Note concludes that the proposed development of the site will
not result in adverse impacts on the significance of designated built heritage assets. It
identifies that the two areas of the site where archaeological remains have been identified as
surviving on site will not be impacted upon by the proposed development. The site has a
theoretical potential to contain Iron Age and/or Roman non-designated archaeological remains
but these are only likely to be of local significance.
The report notes that a programme of archaeological evaluation will be undertaken to inform
the design of a future planning application and to inform the scope of any necessary
archaeological mitigation works and as a result, the potential impact on built heritage and
archaeology is not a reason for the site to not be allocated for development.
As a result of the above, it is our view the assessment should be revised to grade the site as a
‘0’ ‘appears to have no impact on heritage assets and their significance’ , rather than ‘x’,
‘having the potential to cause harm’.
5a. Likely to increase future economic and employment opportunities?
The criteria methodology notes that this part of the assessment considers the proposal’s
ability to increase future economic and employment opportunities.
The assessment notes that no answer is chosen. Whilst the proposal is not specifically
‘employment’ related as it is a residential proposal, there are significant economic benefits
of the proposal. These have been outlined in an Economic and Wellbeing Benefits
Assessment produced by Lichfields and submitted with the Call for Sites submission in
August 20204. This is re-included in this submission (appendix 3) and includes the following:
 340 temporary construction jobs and 515 supported supply chain jobs;
 £55.5m capital investment in Bedford, generating £64.4m of economic output (GVA
per annum).
 £2.3m first occupation expenditure and £13.1m annual resident expenditure on
shopping and services.
4 Economic and Wellbeing Benefits Assessment, Lichfields, ref 18690189v1
access/capacity issues requiring
mitigation and give the site an associated rating of ‘?’. The accompanying highway comments
note:
“THIS SITE REQUIRES MORE DETAILED REVIEW DUE TO ITS SCALE AND POSITVE/NEGATIVE
IMPACTS ON SURROUNDINGS. Main vehicular access proposed from a new roundabout off the
A6 to the east of the site. Emergency access from Bedford Road to the north. Pedestrian access
— [sic] various points. All accessibility considerations are thoroughly described in the
Transport Assessment. The A6 would require investment in order to be provide for improved
pedestrian and/or cycle access. There are bus stops on Luton Rd, less than 400m from the site.
Stakeholder discussion with bus providers to provide new routes or extensions to serve the site.
Wixams has a small cycle infrastructure network, which could potentially be expanded.”
Aside from the proforma assessment, the Council has undertaken a “Transport Access
Assessment” for each of the sites coming forward in the Call for Sites submission consultation.
This assessment scores the sites against five assessment criteria:
• Vehicle access constraints;
• Conflicts with traffic/highway capacity;
• Public transport accessibility;
• Pedestrian access/footway connectivity; and,
• Cycle route connectivity.
This assessment rated the site 2.4 out of 5 against various criteria, giving the site an Amber
rating, but notes mitigation is feasible.
To support the promotion of the site, a Baseline Transport Appraisal was prepared and
submitted in August 2020 as part of the Call for Sites submission which demonstrated that the
site is deliverable in transport terms5.
Further technical work by i-transport has now been undertaken in the form of a Response to
the Call for Sites Assessment6 to review in order to assess the highways matters further. The
enclosed i-transport report at appendix 4 sets out why the Council’s ‘Transport Access
Assessment’ scores do not reasonably reflect the transport aspects / deliverability of the
proposed site. Additional information is presented by i-transport alongside an alternative
scoring assessment of the scheme, which concludes that the site should be considered as a
deliverable site, and therefore attract a Green RAG rating.
It establishes the reason why the current BBC assessment does not fully address the scheme
proposals or opportunities for access and sustainable movement.
It concludes that the site is located in a well-connected location, devoid of significant access
constraints and can be intuitively integrated into the existing urban fabric of Wixams. The
scheme offers a good opportunity to deliver sustainable development and a revised
assessment of the scheme has been considered.
The current Transport Access Assessment scores, and the suggested revised scores are
summarised below, taken from table 7.1 of the i-transport report: (see attachment)
The i-transport assessment presents a revised score for the site of 3.7 out of 5, increasing from
the BBC score of 2.4. This represents a change in the overall assessment, moving from Amber
to Green in the RAG Assessment. This more reasonably reflects the scheme proposal and site
opportunity and demonstrates that in transport terms, the scheme should be considered
positively.
Given the above, it considered that in terms of question 15e, the site should be considered as
not having access constraints and scoring ‘+’ as a result- i-transport consider give access issues
a score of 5/5 in their assessment.
5 i-transport, Baseline Transport Appraisal, dated 14 August 2020, ref: TW/ITB15565-001c
6 i-transport, Response to Call for Sites Site Assessment Pro Forma and Transport Access Assessment, ref:
TW/JW/ITB15565-003b
In relation to 15f, the i-transport assessment accepts that further, more detailed, assessments
would need to be carried out as the proposals are developed and to consider the need for any
further mitigation schemes. However, they identify at this stage there is sufficient evidence
available to conclude that there are no overriding highway capacity constraints to the delivery
of the site. We therefore consider the score should be reassessed as a ‘+’ rating (‘No highway
or junction capacity constraints’).
Other Considerations
Aside from the above issues, the Site Selection Methodology notes the assessment of
constraints examines a number of additional factors to those considered against the
sustainability objectives. These include contamination and Environmental Health. Each are
considered below, in turn:
Contamination
The proforma assessment notes that ‘No answers chosen’ presumably as the assessing BBC
officer did not input a response to this question.
Ramboll have undertaken a Phase 1 Preliminary Risk Assessment in August 2021, which is
included in appendix 5 of this report. The main objective of the assessment was to assess the
potential for soil and groundwater contamination, both at and in the vicinity of the site, and
their likely implications in a residential land use scenario.
In relation to potential contaminants that could impact the site’s future development, the
assessment notes that the site has been occupied by agricultural uses for its entire history and
that there is only a moderate to low risk from contaminants. It concludes there are limited
potential contaminant sources at the site.
Given the findings of the phase 1 assessment, given the limited risks associates with
contamination, development will not be constrained by contamination issues and it is
considered contamination should not precludes the site’s allocation.
Environmental Health
The response to this question simply states “road noise from the A6”. RSK acoustic consultants
have prepared a feasibility noise assessment for the proposed development to establish if it is
suitable for residential development (RSK, Feasibility Noise Assessment, dated 31st August
2021, report reference 206/0466/R1). A copy of the report is included in appendix 6 of this
statement.
The assessment has shown that the majority of the site falls into the ‘Negligible’ and ‘Low’ risk
categories detailed within the Acoustics, Ventilation and Overheating, residential design guide
(AVO). A small portion of the site is within the ‘High’ Risk category, which RSK note is expected
given the site is adjacent to the highway. Using the illustrative layout submitted as part of the
submitted ‘Vision Document’ as part of the Call for Sites, the consultants note this would impact upon only a very limited number of the units proposed on the eastern fringe of the
development area.
RSK note that if dwellings are to be constructed within the high risk area, mitigation can be
provided and that the exact extent of this would be assessed during the detailed design. The
acoustic assessment however notes that general information regarding how this can be
achieved has been provided within the report.
Given these findings, it is not considered that noise impacts are a constraint to development
and noise should not be a constraint on the allocation of the site for development.
Conclusions
In summary, the site assessment for the subject site should be reviewed and revised in light of
the technical work undertaken as part of both this current submission, read in conjunction
with the Call for Sites submission in August 2020.
The subject site provides an outstanding opportunity to allocate a significant quantum of
residential land on a sustainable site adjoining Wixams. The proposal is fully in accordance
with several of the proposed development options identified in the current Local Plan review
(Regulation 18 consultation), including the council-assessed most sustainable development
strategy. The site is deliverable, available now and offers a suitable and sustainable location
for new development, complimenting the emerging Wixams community.
We note that the site assessments are not complete and the full range of assessment criteria
in the Site Selection Methodology have not been answered. We look forward to the
opportunity to review the other site assessment criteria assessments once available.