Policy EMP4 Land south of Goldington Road, Bedford

Object

Representation ID: 9242

Received: 26/07/2022

Respondent: Ms Claudia Dietz

Legally compliant? No

Sound? No

Duty to co-operate? No

The proposed allocation does not present a sustainable form of development and should be excluded from the Plan.
It is neither physically nor visually connected to Elms Farm Industrial Estate; and results in unacceptable encroachment into open countryside.

Comment

Representation ID: 9427

Received: 29/07/2022

Respondent: Mr Peter Norris

There is no evidence that iv is being realized in the plans so far presented. This site is on the Urban boundary of Bedford and so would be more appropriate to form part of an Eastern Gateway to the Borough rather than the proposals put forward at EMP6 - which is not a logical gateway.

Comment

Representation ID: 9467

Received: 29/07/2022

Respondent: Anne Dorber

The adjacency of this site to the River Gt Ouse means that it is particularly sensitive in terms of biodiversity, as a wildlife corridor, and for its visual impact across the river from flood-plain open space. Plans need to take these factors into account.

Comment

Representation ID: 9680

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, there are several scheduled monuments to the south of the river. These cropmark sites have been partly excavated. The Howbury Hall Estate, including several listed buildings, lies to the north of the site. The site lies adjacent to the non-designated earthwork of Risinghoe Castle. We have previously advised that this merits further assessment through a Heritage Impact Assessment (HIA). There is also high potential for other buried archaeological remains at the allocation site based on elsewhere along the valley floor. Any development of this site has the potential to impact upon these heritage assets and their settings.
A heritage assessment was prepared to accompany a planning application for this site in 2019.
The heritage impact assessment helps further our understanding of the Castle. Further to our site visit, and in light of the HIA, we understand that the archaeological advisers at BBC are satisfied that the castle is of regional importance and is not likely to meet the criteria for scheduling. To that end, Historic England is content to leave the decision to BBC in this regard.
We welcome criterion iv and v. However, no detail is given of the mitigation or enhancement required. These measures should be informed by the heritage assessment, and development management process and then the wording incorporated into the policy.
The heritage assessment recommends the following mitigation measures:
• Geo-physical survey followed by trail trench evaluation
• Careful design in particular in relation to height and density to minimise harm to the setting of the Castle • Sensitive landscaping along the southern boundary and careful landscaping to enhance the immediate setting of the Castle mound
We suggest that these measures are incorporated into the policy wording.

Comment

Representation ID: 9727

Received: 26/07/2022

Respondent: Historic England

The final category of sites include those sites where an HIA has been prepared but the recommendations from the HIA have not been incorporated into the policy
wording for the site.
These include sites HOU1, EMP4, HOU13, HOU14, HOU15, HOU16, HOU17, HOU18 and HOU19. We suggest including a diagram for HOU6 to illustrate the
extent of open space,
It is important that policies include sufficient information regarding criteria for development. Paragraph 16d of the NPPF states that policies should provide ‘a clear
indication of how a decision maker should react to a development proposal’.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002- 20190315Revision date: 15 03 2019 also makes it clear that, ‘Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.’
Historic England’s Advice Note on Site Allocations HEAN3 includes a section on site allocation policies at paragraphs 3.1 – 3.2. It states, ‘The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to
be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are
implemented.’
Therefore, should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
In these cases, please ensure that the policy wording is amended to include the recommendations from the HIA. It is helpful if the recommendations are also shown
on a diagram in the Plan.
Without the completion of this evidence base, some sites are not justified and so are not sound. Furthermore, without suitable amendments to policy wording, some
of the policies are not effective and so are not sound.

Support

Representation ID: 9807

Received: 24/07/2022

Respondent: Alexandra Delger

Development of land to the south of Goldington Road
I welcome these proposals which include a range of employment uses and opportunities and which will extend the development corridor opposite Elms Farm Industrial estate with little obvious environmental impact.

Comment

Representation ID: 9910

Received: 28/07/2022

Respondent: Newcrest Bedford Limited

Agent: Town Planning Services

Newcrest Bedford Limited supports the proposed allocation of land south of Goldington Road, Bedford for employment purposes as set out in the proposed Policy EMP4.

It is considered that the site can make an important and significant contribution to the provision of employment land and the creation of jobs within Bedford. The site is the subject of a current application for outline planning permission (Reference 20/00076/MAO). The application seeks permission for the:

" … Demolition of existing workshop premises and development of land for employment purposes with up to 21,500sqm gross internal floorspace, comprising a mix of B1a 'Offices', B1c 'Light Industrial', B2 'General Industrial' and B8 'Storage and Distribution' uses, together with parking provision and landscaping, alterations to existing access, creation of landscaped area and associated works. Outline application with all matters reserved except access … "

The Council's assessment of the site is set out within the Council's 'Site Assessment's Proforma' June 2021. We would broadly concur with the appraisal set out within this. In particular, we would note:

• The site could provide 21,500 sqm gross floorspace;
• The site is well-related to the existing urban area;
• The existing road can provide an 'efficient and safe access point';
• There are no highway capacity issues or access constraints;
• The site occupies a sustainable location and is accessible by public transport; and
• There is scope to enhance pedestrian accessibility.

We would similarly not identify any overriding constraints that would prevent the development of the land. For example, it is not within any designated landscape or site of nature conservation importance. While there are heritage assets within the vicinity, a detailed Heritage Impact Assessment was submitted in support of the outline application (Orion 'Heritage Desk Based Assessment' 2019). An archaeological investigation has also been undertaken including intrusive field work and submitted to the Local Planning Authority (AOC Archaeology Group 'Archaeological Evaluation Report' 2022). These demonstrate that there are no unacceptable impacts on heritage assets, that would prevent the allocation and development of the site.

In support of the site, it is considered that:

• The development could generate significant number of employment opportunities;
• The site provides an area of high quality employment land to the east of Bedford;
• It will consolidate and enhance existing employment and commercial uses in this area;
• Landscape and biodiversity improvements can be delivered within the site;
• Development can positively contribute to objectives of the Bedford River Valley Park; and
• The site is highly accessible and offers good access to the strategic road network.

For the above reasons, Policy EMP4 'Land South of Goldington Road' and the allocation of the site for employment purposes is supported.

The proposed allocation is consistent with the existing provisions within the adopted 'Bedford Local Plan' and in particular:

• Policy 3S 'Spatial Strategy';
• Policy 72S 'Additional Strategic Employment Development';
• Policy AD24 'Green Infrastructure Opportunity Zones'; and
• Policy AD26 'Bedford River Valley Park'.

The development of the site also complies with more detailed policies concerning matters of development management.

Similarly, the allocation of the site complies with the provisions and advice within the National Planning Policy Framework.

Object

Representation ID: 10428

Received: 29/07/2022

Respondent: Mr Trevor Stewart

Legally compliant? No

Sound? Yes

Duty to co-operate? Yes

Goes against the Borough Council's stated green objectives.
The use of this picturesque part of the Great Ouse River Valley for industrial purposes is unnecessary and unjustified.
There are many more suitable brownfield sites that could be used instead.
Once this beautiful part of the Great Ouse Valley has gone to industry, it is gone forever.
The Plan should not contradict itself.