Site ID: 1247

Object

Representation ID: 3475

Received: 25/07/2021

Respondent: Mr Peter Gell

This land is opposite a Victorian cemetery, and small and historic cottages, and would not be in keeping with existing developments in what is Kempston Rural, not Kempston Urban. This would also put significant additional pressure on the junction with Cemetery Road There are much better areas of land submitted for consideration in the Kempston area including nearer Box End.

Object

Representation ID: 3704

Received: 20/08/2021

Respondent: Mrs Janet Symington

With so much of the rural land in Kempston made available for development, the rural living many strive will be completely lost if all the land is developed on. This is a nice location near the cemetery, with a quite road, for the sake of building 120 houses, can not a more suitable location be identified. Development here will transform for the worse the lives of all those residents currently living on the road.

Support

Representation ID: 8877

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

3.0 RESPONSE TO SITE ASSESSMENT PRO-FORMA
Introduction to Site and Proposals
3.1 The site was previously submitted to the Council for consideration as part of the Council’s ‘call for sites’ exercise in August 2020. The land area being promoted is shown below.
Figure 1: Land at Green End, Kempston
3.2 The site, extending to circa 7 ha, comprises an area of grass land and lies on the western side of Kempston. To the north the site is bounded by Cemetery Road, to the east by the A428 Branston Way and the Kempston urban extension, to the south by Kempston nurseries and residential development on Ibbett Close, and to the west by Green End Road and housing within Green End.
3.3 Access can be achieved via Cemetery Road or Green End Road.
3.4 The site is well related to the urban area of Kempston, and the extensive range of services
and facilities provided there and within the urban extension development area. This includes a broad range of retail facilities including supermarkets, doctors/dentist surgeries, schooling (primary and secondary) and a range of leisure. There is also access to public transport providing services to Bedford and the surrounding towns and villages.
3.5 The site is sustainably located relative to the wider highway network and surrounding settlements but is detached and capable of substantial development for a range of uses without impacting upon neighbouring uses and without resulting in physical coalescence with the main urban area.
3.6 There are no known physical, environmental, ecological, or archaeological constraints that would prevent development from coming forward.
3.7 Although a substantial site, the land has the potential to accommodate a variety of scales and types of development subject to design. For the purposes of these representations further site analysis has been undertaken on behalf of our client by BE1 Architects with input from Transport Consultants SDD. A copy of this work is included at Appendix 2 and has been used to respond to comments in the Council’s Site Assessment proforma.
3.8 The analysis undertaken takes account of current and historic land use designations affecting the site area, including its previous allocation as part of the Land West of Kempston expansion (Policy H7). However, our client’s land is not included within the specific land use proposals associated with this expansion. The areas assessed for development sit beyond the Bedford to Milton Keynes Green Infrastructure Opportunity Zone (Policy AD24) and are not subject to proposals for further planting as part of creation of the Forest of Marston Vale (Policy 36S) but could make a valuable contribution towards both of these policy aims.
3.9 The Site Analysis concludes on the ability to identify a developable area of approximately 3.5 hectares across those parts of the land with the greatest capacity to accommodate new development and with feasible access options.
Figure 2: Land at Green End, Kempston – Development Opportunity Diagram
3.10 The developable area identified is comparable to the requirements for the delivery of specialist accommodation for older people as part of a Retirement Village model focusing on the provision of Extra Care facilities. This option should be subject to further testing by the Council for the purposes of site selection.
3.11 The developable area within the wider site would also be compatible with providing for general needs housing where the level of development proposed would be proportionate to the size of the settlement and the site’s setting and context.
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 1247)
Site Assessment Criteria
3.12 We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Within or adjoining the urban area or a defined settlement policy area boundary
3.13 The Council’s assessment pro-forma records the location as adjacent to the Urban Area Boundary, which correctly reflects the sustainability of the location and its proximity to services and facilities. However, despite this physical and functional relationship with the urban area the developable parts of the site would remain separate from the main urban area as a result of the existing green infrastructure corridor west of Kempston. This enables the opportunity to deliver growth commensurate to the built settlement at Green End and in-keeping with its local character and settlement pattern and without impacting on the important gap between the site and the urban area (Policy AD42).
3.14 It should be noted that this site would maintain sustainable patterns of development in this regard. The Council has on multiple occasions previously accepted the A428 bypass does not comprise a fundamental barrier to the extension of development west of Bedford. The bypass has been breached by various developments, including new employment west of the A428 encroaching into the Green Infrastructure corridor. Our client’s land would avoid any further harmful impacts in this regard while continuing to represent a sustainable location for growth accessible to the main urban area.
Impact on designated or non-designated heritage assets or their setting
3.15 The Council’s site assessment proforma finds that the proposal has the potential to cause harm to heritage assets, which may range from low to high. There are no designated heritage assets within the site itself and the nearest assets are located north of Green End Road within the existing settlement (3no. Grade II Listed properties).
3.16 Development of our client’s land may result in some impact upon one aspect of their setting resulting from their relationship with the surrounding rural area. There will be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons. In the case of our client’s land further assessment will be undertaken to more fully
explore impacts on significance and to ensure that any impact would represent less than substantial harm in terms of Paragraph 202 of the NPPF, which is the expected outcome given the context described above.
Protected Species and Ecological Value
3.17 The Council’s assessment notes that the site is not located within an area of importance for nature conservation but states that protected species have been recorded on the site. This could be addressed through an ecology survey and protected species surveys, if appropriate, and the recommendations and mitigation strategy could be incorporated into any development scheme.
3.18 Site Analysis undertaken by our client demonstrates that the proposed developable areas would be focused upon areas of existing paddock and grassland. This indicates that those areas of greatest habitat value are likely to be unaffected, including trees towards the site boundaries the may provide habitats for protected species such as bats and badgers. These areas of the site could be subject to appropriate measures for protection and enhancement of their biodiversity value as part of the wider scheme proposals.
Green Infrastructure Opportunity Network
3.19 The Council’s own site assessment proforma fails to recognise the location of the northernmost and eastern portions of the site within the Bedford Milton Keynes Opportunity Area. The Site Analysis undertaken on behalf of our client seeks to keep areas with this area free from the development while the wider scheme proposals on unconstrained land would offer opportunities for further enhancement and access for recreation and leisure.
Access, Highways and Sustainable Transport
3.20 The Council’s assessment pro-forma notes no in-principle access constraints but would seek improvements in pedestrian and cycle connectivity from the site to surrounding services and facilities. This has been reflected in the Site Analysis and development opportunities identified on behalf of our client, including the excellent opportunities that the site provides in terms of connections to the existing Public Rights of Way network. In-particular:
• Vehicular access off (northernmost) part of Green End Road, located within a 30mph speed limit with street lighting and an existing footway on the opposite side of the carriageway, is considered a suitable location (for accessing residential development) and would require connecting into the existing footways.
• If no vehicular access is proposed along Cemetery Road, it nevertheless feasible that a pedestrian / cyclist access is proposed in this location, to connect into the existing infrastructure.
• From an access at Cemetery Road, there is an opportunity to extend the existing shared footway / cycleway facility from the A428 / Cemetery Road roundabout towards the site along the northern edge of the carriageway. This would be the key desire line for future residents travelling to Kempston Town Centre. Alternatively, there appears to be adequate verge width along the southern side of Cemetery Road to provide a new footway along the site frontage with would extend east towards the A428 roundabout.
• The closest bus stops are also located on Cemetery Rd to the southeast, approximately 400m from a potential access at Cemetery Rd, or circa 700m from the centre of the site. The stops are served by Route 24, operating at an hourly frequency, between Great Denham and Bedford.
• Public footpath ‘A6’ and ‘39’ are located within the site, noting that footpath A6 extends beyond the site northeast towards the A428 roundabout. There could be an opportunity to improve this PROW so that it is more attractive for future residents, as it provides a shorter route for residents within the southern parcel of the land to the bus stops and Kempston Town Centre, linking to local facilities such as schools, small retail facilities, churches, pub, and employment areas. Footpath 19/A6 enters the site from the southwest and forms part of an important rural pedestrian link between Green End and Kempston, and footpath 15/39 provides further permeability, offering a potential for enhance connectivity to further north to Box End.
For figures and appendices see attachment