Policy HOU15 Land South of Wixams

Object

Representation ID: 9086

Received: 05/07/2022

Respondent: Mr James West

Legally compliant? No

Sound? No

Duty to co-operate? No

This is being classes wixams south but in fact in the boundary of Wilstead so being miss sold. Not enough infrastructure to support the existing houses at Wilstead and wixams, let alone 300 new houses. We have food shortages due to wars, Brexit and COVID taking more farm land for houses will increase the problem. The United Kingdom need to be more sustainable. This is not helping.

Object

Representation ID: 9112

Received: 17/07/2022

Respondent: Mr Richard Oxlade

Legally compliant? No

Sound? No

Duty to co-operate? No

I think Wixams and Wilstead are linked closely enough already. We do not want Wilstead to be lost in a Wixams urban sprawl. You (BBC) have already demonstrated a lack of commitment & understanding to what Wixams residents need and I don't think you should provide any further development in this area until you have at least delivered what was originally promised.

Object

Representation ID: 9116

Received: 18/07/2022

Respondent: Ken Cook

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The proposed development is misnamed as it is within the parish of Wilstead.
It will have a disastrous effect on Wilstead due to a vast increase in east west traffic
It is too far from the proposed railway station
Wilstead has too few facilities to be a Key Service Centre
Wilstead does not have facilities for a development of an extra 300 houses alone if with HOU16 development it will treble its size.
It will hamper the Borough's target of zero carbon emissions and does not meet the aims of Bedford Borough Local Plan 2040 Para. 2.2 Theme 1.

Object

Representation ID: 9131

Received: 21/07/2022

Respondent: Mrs Linda Cook

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The proposed development is within the parish of Wilstead and will directly effect the village and is in fact a village extension. Wilstead should not be regarded as a Key Service Centre as it has few facilities only sufficient for the existing population size. The increase in traffic on roads which are not built nor can be improved to take the increase that it will bring, will have a direct negative impact on health and safety.

Object

Representation ID: 9140

Received: 23/07/2022

Respondent: Mrs Caroline Brady-Watts

Legally compliant? No

Sound? No

Duty to co-operate? No

This development would take away important green spaces
The roads would be unable to cope with traffic
The village already has problems with flooding,this would be worsened
There is no doctor facilities,so local ones would be overwhelmed
And the gap between Wixams and Wilstead would be lost
Wilstead is a rural village,not a Wixams extension,it could not cope with such large developments
Please leave our village as a village,and not ruin the countryside

Object

Representation ID: 9150

Received: 23/07/2022

Respondent: Mr Bruno Viscogliosi

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Clearly the small village of Wilstead doesn't factor into these plans, as even though the this is seen as a Wixams extension they all fall within Wilsteads Parish Boundary.

The infrastructure in place for the current number of homes is insufficient, so tripling the size of Wilstead will increase the problems further. Poor public transport, school places, doctors etc.

Object

Representation ID: 9415

Received: 29/07/2022

Respondent: O&H Land

Agent: Varsity Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Consideration should be given to the impact of this allocation on the local landscape as well as the functional relationship with planned development in Central Bedfordshire Council.

Object

Representation ID: 9506

Received: 27/07/2022

Respondent: Mr Leslie Pearson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

My comments relate to issues that would directly affect the village of Wilstead (within the Parish of Wilshamstead ) where I have lived for the past 46 years.

I wish to OBJECT to the proposal included in the Bedford Local Plan 2040 to build a further 2100 homes within the Parish of Wilshamstead.

The reasons for my objections are as follows;
(i) The Bedford Local Plan 2040 proposes 2100 new homes within the Parish of Wilshamstead but under the label of ‘Wixams Extension’. This is misleading and needs to be addressed. If this proposal is eventually approved then, in reality, this would result in a massive housing expansion within the Wilstead community and conflict with the Wilstead Neighbourhood Plan 2030.

(ii) If the proposed building within Wilshamstead Parish goes ahead, it will result in the loss of hundreds of acres of rural countryside, much of which is highly productive agricultural land. It is widely accepted, nationally and internationally, that there is a need to grow more food for the growing population, so why remove the ability to do so?

(iii) If the proposed building within Wilshamstead Parish goes ahead, it will totally change the character and nature of Wilstead village away from a traditional rural community. A move in this direction has been fiercely resisted over recent years by the community of Wilstead who wish to retain its rural character in a sensible and sustainable way.

(iv) If this proposed building goes ahead, it will put unsustainable pressure on the ‘Key Service Centre’ of Wilstead. In my opinion Wilstead DOES NOT meet the defined criteria for a Key Service Area. The criteria used for Wilstead to carry this classification have in some cases been over-stated, or are incorrect or simply do not exist in reality. This classification needs to be reviewed.

(v) If this proposed building goes ahead in Wilshamstead Parish, it will place much more pressure on the local transport infrastructure which I fear will fail to adequately to cope with this and other building expansions bordering the parish. A new rail station (long promised but yet to materialize) at the Wixams will do little to help alleviate the road traffic situation to the south of Bedford. In addition, the once ‘pride of Bedford’ Park & Ride Service, which could demonstrably contribute to reducing traffic volume into and out of Bedford, no longer exists as a genuine P&R service despite the very large signs on the A421 and A6 advertising this service.

Object

Representation ID: 9545

Received: 17/07/2022

Respondent: Andrew Shenton

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I wish to object to the proposal for more housing to be built on green space land to the South and East of the Wixams development. The reason I find the proposals outrageous, is because the original plan for Wixams included land for more housing, yet just 6 years ago the Council approved a request from the developer to change the use of this land from housing to commercial use. Several large distribution centres now occupy this site, resulting in an articulated vehicle driving through the village at a rate of one every two minutes. These slow, heavy vehicles have already impacted and caused damage to the surrounding roads and clog up the A6 and help to pollute the area. Plastic waste along A6 road verges next to Wixams has increased noticeably. Its an embarrassment to the town.

This knee jerk approach to long term planning policy will result in an urban sprawl, lacking infrastructure, further polluting the environment and decimating green space and the few bits of wildlife we have left.

Comment

Representation ID: 9550

Received: 19/07/2022

Respondent: Nehemiah Anderson

I live in Wixams and am aware of the plan for 2100 extra. I understand the need for more housing so have no objection to that but with the building of more homes you need more infrastructure. It is totally irresponsible to build these homes with no plans for school's shops and alike. We keep talking about being green and carbon neutral but with this new development even if people need to pop the shop this will involve getting into the vehicles and the same goes for taking their children to school. New homes yes but also infrastructure is essential not just another concrete jungle.

Object

Representation ID: 9564

Received: 20/07/2022

Respondent: English Regional Transport Association

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy HOU15 A new bus stop should be provided for an extension to the existing bus service route in Wixams, including the new railway station.

Comment

Representation ID: 9578

Received: 20/07/2022

Respondent: L&Q Estates Limited

As indicated previously, L&Q is already investing in the South of Bedford area at Wixams. In
that context, it supports the intention to deliver sustainable future urban extensions within the
South of Bedford area for 7,050 new homes (alongside appropriate infrastructure), and
specifically the identification of broad areas of growth at Draft Policies HOU15 (Land South of
Wixams) and Policy HOU16 (Land at East Wixams). We note that a more detailed strategic
place making framework for the South of Bedford policy area will be adopted as a
Supplementary Planning Document, but that the Stepped Trajectory Topic Paper (April 2022)
indicates capacity of 300 dwellings at Land South of Wixams and 1,800 dwellings at Land East
of Wixams.
In our view Wixam is a sustainable location for housing growth; that is, it benefits from good
access to employment centres, it located in the Oxford – Cambridge Arc growth area, it
benefits from existing infrastructure, and has the potential to deliver additional new
infrastructure where required.

Object

Representation ID: 9606

Received: 29/07/2022

Respondent: Wilshamstead Ward

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

I am totally opposed to the proposals for development at Wixams South, and believe that proposals are unsound for the following reasons:

Misleading representation:
• The sites at Wixams East and Wixams South have been erroneously labelled and are in fact entirely within Wilstead Parish. This appears to be a deliberate attempt by Bedford Borough Council to mislead the people of Wilstead into believing that it is a Wixams issue and doesn’t affect them. It is misleading and wrong.

Lack of clear links to Wilstead parish
• The sites will be within Wilstead Parish, but with roads existing onto the A6. Wilstead will not benefit in any way and will only be adversely affected by noise, pollution and additional traffic. It seems likely that a Community Governance Review would result in the new dwellings being annexed to Wixams Parish, so Wilstead would not even benefit from any parish precept money and a debate may well be had over which parish should benefit from any resulting CIL money.

Overdevelopment of Wilstead
• Wilstead is currently a settled village of just over 1150 dwellings. To add an additional 2100 would be to treble the size of the village over the life of the Local Plan. This is more like wanton destruction that sustainable development.
• The proposals also result in the removal of clear lines of green open space between Wilstead and Wixams, resulting in the merging of both villages, without any clear boundaries between the two.

Traffic through Wilstead
• Wilstead already endures a significant amount of through traffic along Cotton End Road as a result of commuters from Wixams. The addition of 2100 new homes, with a likely additional 4000+ vehicles will only add to this problem and destroy the rural village nature of Wilstead.

Wilstead Neighbourhood Plan
• Wilstead has been working on a Local Neighbourhood Plan for some time and is almost complete and at the point of going to a Local Referendum. The Local Plan 2040 takes no account of this and as the Wilstead plan is a long way through the process, the Borough should have taken this into consideration.

Wixams Infrastructure:
• The existing infrastructure at Wixams has been long delayed and is still woefully insufficient. It will not be able to cope with the additional pressure of 2100 new dwellings. The existing Wixams villages have become a good case study for the consequences of ‘development without infrastructure’.
• Wixams is a living example of “development without infrastructure”. Any proposal to drop even more houses on us, without first addressing the infrastructure deficit, is only going to make matters worse.
• Wixams currently lacks suitable pedestrian crossings outside schools and has recently witnessed accidents with children hit by cars. The Borough Council still has no concrete plans to address this deficit and the building of 2100 new dwellings with a likelihood of over 4000 additional vehicles will add further pressure to Wixams roads (including the A6) as residents of the proposed new developments gravitate towards the existing Wixams settlement.
• There is still a missing link of cycle path from Wixams into Bedford Town. This results in cyclists having to take a dangerous route along the A^, or a long detour via Elstow. If such a small basic piece of infrastructure can’t be delivered, what hope do we have for the bigger items? It’s a nonsense to even suggest that the local infrastructure will be able to accommodate such significant additional development.

Roads and Highways
• The opening of Wixams station, scheduled for late 2024 will act as a ‘pull’ for yet more traffic into Wixams from the surrounding areas.
• There are currently significant HGV movements through WIxams as a result of local distribution depots and warehousing. Additional housing so close to the existing Wixams development will result in a dangerous combination of more cars mixed with significant existing HGV traffic.

Environmental concerns
• The potential loss of green space on the sites proposed is worrying and goes against the need for protection of the environment. There is currently a clear and obvious divide between the villages of Wixams and Wilstead. However, the proposed development at Wixams East and Wixams South looks like it will result in a major loss of green space and wildlife habitat, with the two separate villages merging into one, as a continuous sprawl of development, with no clear delineation between the villages.

Object

Representation ID: 9621

Received: 26/07/2022

Respondent: Mr John Dillnutt

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I am writing this email to object to the proposed housing developments planned for Wixams East which falls into the Wilstead parish and the Wixams South development which also falls into the Wilstead parish, my objections are, the surrounding villages and road networks will not be able to cope with the extra vehicles that will potentially be using them, the impact on the wildlife that use the area's for their habit, the outstanding beauty of the area's which people enjoy walking and studying the wildlife and it's inhabitants, there is a possibility off that the nearby villages will have deal with the extra school places which the schools are near to capacity and would not be able to cope with the extra children.

Object

Representation ID: 9652

Received: 26/07/2022

Respondent: Ms Natalie Brine

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

As a resident of Wilstead for the past two decades, I wish to formally object to the planned 2,100 new houses ie Land South of Wixams (300 houses) and Land East of Wixams (1,800 houses) that are part of the Bedford Borough Council Local Plan 2040. These developments are within the Wilstead Parish although they have been shown in the draft Local Plan as a “Wixams Extension”, which means that the Plan itself is inaccurate and could be misleading for residents when assessing the plan. There are a further 1000 homes proposed for Shortstown, which are next to the Wilstead Parish Boundary.
I have serious concerns about the detrimental impact that this large-scale development will have on both the environment, and on the health and quality of life of the current residents in this area.
These are my main concerns:
1. The development will result in the loss of over 400 acres of rural countryside, home to numerous species of wildlife. This represents a significant loss of the natural beauty of the area, with negative repercussions on residents’ well being. We are all acutely aware of the benefits of green outdoor spaces on good mental health. There would be a substantial loss of public footpaths and bridleways, so important for exercise and wellbeing. Current residents, who chose their homes for their rural location, would end up living within an urban sprawl, as Wilstead would be swallowed up by the development, merge with Wixams and no longer be a village in its own right.
2. The addition of such a large number of houses equates to the influx of several thousand cars, with the resulting high levels of traffic congestion, noise and pollution, with detrimental effects to the quality of air. There is already a high level of traffic congestion in the area with long queues forming on the A421, around the A6 and the A600. A large volume of cars already cut through Wilstead to get between the A600 and A6 and the substantial increase in cars would only aggravate the traffic problems leading to even more pollution.
3. There is an increased risk of flooding from the replacement of natural green belts with concrete resulting in excessive run off of rainwater. Given the extreme weather events of recent times, flash flooding is far more likely.
4. Equally, the addition of so many homes and the migration of 1000s of people to the area would put strain on the natural resources, such as the water table and result in the oversubscription of key service such as hospitals, GPs, schools and care homes.

I would be very grateful for your consideration of the points I have raised as my objection to the planned housing developments in Wixams/Wilstead.

Comment

Representation ID: 9686

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, there are a number of listed buildings nearby at Duck End and Wilstead. These include All Saints Church, listed at grade II* and a variety of grade II listed buildings. Any development of this site has the potential to impact upon these heritage assets and their settings.
A historic environment desk-based assessment has been prepared for land to the south of Wixams (although the report on the website is entitled Land to the east of Wixams). The report states that there will be no impact on designated assets and does not recommend any mitigation or enhancements.
However, we consider that some planting along the eastern site boundary would help to soften and impact of the development in the landscape including any (winter) views from heritage assets in the villages to the east. Figure 8 shows green space along this eastern edge which is welcomed. This should also be referred to in the policy wording.
We welcome criterion x. It would be helpful if specific mitigation measures were included in this criterion to read ‘with appropriate landscaping along the southern and eastern boundaries of the site.’
We welcome criterion xiii.

Comment

Representation ID: 9730

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.

Object

Representation ID: 9763

Received: 27/07/2022

Respondent: Mr David Stone

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I wish to strongly object to the proposals to the building of over two thousand homes shown in the plan as “Wixam’s Extension,” which would have devastating consequences for the residents of Wilstead. I have lived in the village since 1978 and my two sons also live here with their families in Wilstead. In this time, I have seen considerable increases in the developments in the village, but also the huge complex at Wixam’s, still to be completed. There has been no increase in the local facilities, no doctor’s surgery, pressure on the local school, small post office and a few shops. The main roads are totally unsuitable for the present traffic flow particularly vehicles travelling through the “rat run “at Cotton End Road leading to the A6 and A421 bypass.
The proposal to build more houses on the two new Wixam’s developments would seriously encroach on the rural nature of Wilstead, which is already under severe pressure. As already stated, the village is not a key service centre and therefore unsuitable for major development. The merging of our village is an extremely backward step, consequences being harm to our local heritage, threat to the green spaces, wildlife, rural landscape, footpaths, and recreation. These examples are not exhaustive and in our local area the developments at Cotton End, Stewartby & Shortstown are also adding further pressure to Wilstead.
I can only describe the proposals as the destruction of Wilstead which will be surrounded by hundreds of houses without serious thought of the lack of amenities and infrastructure to support the increase in population in the hundreds.

Object

Representation ID: 9765

Received: 27/07/2022

Respondent: Lola Stone

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I wish to strongly object to the proposals to the building of over two thousand homes shown in the plan as “Wixam’s Extension,” which would have devastating consequences for the residents of Wilstead. I believe the plan has named ‘Wixam’s’ wrongly as the land proposed for building is in fact part of Wilstead. This has proved to be very misleading for residents.
I have lived in the village since 1968. I live here with my husband, my son’s, and their families. In this time, I have seen considerable increases in the development of the village, not all of which has been negative. However, over recent years little thought has been given to the historic rural nature of the village. Wilstead is not a key service centre and should not qualify for major development.
When Wixams was first developed there was an agreement that the villages would not merge. There would be distinct separation by green space to allow our rural identity to remain. Protect our green space, views, and wildlife habitats.
The risk of flooding is significant as proposed building is in place on the flood plain.
To date there has been no increase in the local facilities, no doctor’s surgery, pressure on the local school, and a small post office. Bus travel is inadequate and unreliable.
The main roads are totally unsuitable for the present traffic flow particularly vehicles travelling through the “rat run “at Cotton End Road leading to the A6 and A421 bypass. Anybody who visits the village during school times is met by chaos.
The proposal to build more houses on the two new Wixam’s developments would seriously encroach on the rural nature of Wilstead, which is already under severe pressure. As already stated, the village is not a key service centre and therefore unsuitable for major development. The merging of our village is an extremely backward step, consequences being harm to our local heritage, threat to the green spaces, wildlife, rural landscape, footpaths, and recreation. These examples are not exhaustive and in our local area the developments at Cotton End, Stewartby & Shortstown are also adding further pressure to Wilstead.
I can only describe the proposals as the destruction of Wilstead which will be surrounded by hundreds of houses without serious thought of the lack of amenities and infrastructure to support the increase in population in the hundreds.

Object

Representation ID: 9779

Received: 27/07/2022

Respondent: Mr Marc Abbott

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I am opposed to the plan for 2100 homes to be built in “Wixams South and Wixams East” sites that are actually in Wilstead!

Considering the actual size that Wixams will eventually become, I do not understand the need to build on green land around Wilstead. The infrastructure is already struggling to cope with what is currently here. The roads are in a terrible state, trying to get to Bedford is a nightmare because the roads can’t cope with the constant flow of HGVs thanks to the amount of industrial warehouses/units that have been built in Wixams.

The schools are already at capacity, there are no additional amenities being proposed like a doctors surgery, dentist etc. There are only proposals for yet more houses that are not affordable.

The proposed houses will disrupt life for the people that already live here, not to mention the wildlife that will be displaced and destroyed. Wilstead should be left as a village and not eventually overtaken by the Wixams development.

In the last few years we have had a new estate built on the back of Whitworth Way, which has cause the crime rate to increase, including a drugs raid on one of the houses.

Object

Representation ID: 9829

Received: 28/07/2022

Respondent: Mrs Joy Levitt

Legally compliant? No

Sound? No

Duty to co-operate? No

I am against the 2040 Local Plan of 2100 new homes for the “Wixams Extension” for the following reasons:
1. South of Bedford has had more than its fair share of house building – i.e. Wixams and Cardington developments
2. Neither of these developments have had sufficient infrastructure – especially in regards to doctors and dentists, etc
3. The new developments in the 2040 plan are incorrectly labelled as “Wixams Extension” but are within Wilstead parish boundaries. This would treble the size of the current village and implies a lack of clarity and attention to detail from the Planning Department.
4. People live in Wilstead because it IS a village – not a town – and clearly would rather it remain so.
5. The A6 is a very busy and in parts dangerous road as it is; more housing will have a negative impact. The A600 is not such a busy road but is not suitable for higher volumes of traffic. It is single carriageway throughout.
6. There is much development being proposed along the A^ near Barton-Le-Cley and Silsoe – Central Bedfordshire Council jusrisdiction. It is likely that in the future all these ribbon developments will mean that Luton and Bedford will be joined, with little or no countryside between.
7. We are fortunate to have foxes, badgers, muntjac and fallow deer visit our garden; all this wildlife comes from the area and direction of the planned buildings. We need to preserve what wildlife we can.
8. This volume of building does not make the area a pleasing one in which to live. It is particularly difficult to employ GPs as they are able to find far nicer areas to live in.
9. We are in a drought area in the country. More housing requires more water which is unsustainable, with current environmental issues.

Comment

Representation ID: 9840

Received: 28/07/2022

Respondent: Mr Roger Mant

Whilst appreciating the need for housing I am concerned about the expansion of Wixams towards Wilstead. In particular the area showing 1800 houses to the East of Wixams and the A6 and is being called the Wixam’s Extension.
This is also in the area/boundary currently allocated to the Wilstead Parish Council.
One can only assume that the desire is to swallow Wilstead up.
Also this is prime farming land and with this country needing to think seriously about home grown produce. Is this a wise move.

The subsequent increase in traffic and the current use as a cut through to the large warehousing facilities near wixams, this is taking away the rural atmosphere of this popular village.
Living on Cotton End Road for over 40 years I can only say that too many think it’s a racetrack being so straight. 6 accidents we know of in the time here, the good fortune being no one has been seriously injured. Average speed camera’s are a necessity with the extra traffic that is merely using the village to get from the A600 to the A6

Shortstown has its houses and 1000 more to be added there.
Land South of Wixams is 300 houses. Looking at the map, then Wilstead will soon be completely swallowed up.

Wilstead is not a keyservice centre and should not qualify for such a development.

We do not have a Doctors Surgery at all and such an increase is going to put a huge requirement on the area.

Object

Representation ID: 9901

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Policy HOU15 Land south of Wixams and Policy HOU16 Land at East Wixams
5.33 The site is located to the east of the A6 and the existing Wixams development. Figure 8 shows this to be a disparate allocation of three residential parcels one of which (HOU15) is a logical extension to the village. The other two parcels (HOU16) are on the opposite side to the A6 and the largest parcel is a standalone development. In the Settlement Hierarchy Wixams scores 55 points whereas Wootton scores 92 points. Despite this clear difference Wootton has not been allocated. As with HOU13 residents will rely on vehicular connections to more sustainable locations.
5.34 The spatial strategy and distribution of development in the Plan requires a fundamental change and greater concentration of sites adjacent to existing settlements. At present Policy DS5(S) is not justified when utilising the evidence base, is not in accordance with national policy and is not effective in delivering housing needs in the most sustainable locations.

Support

Representation ID: 9992

Received: 29/07/2022

Respondent: Wates Developments

Agent: Boyer

2.1 These representations have been prepared by Boyer, in response to the current ‘Local Plan 2040: Plan for Submission Regulation 19’ consultation, which runs until 29 July 2022.
2.2 Boyer has been appointed by Wates, in respect of their ongoing promotion of Land South of Wixams1 (‘the site’). This land lies to south east of Wixams and is almost entirely situated to the west of the A6 road. A Site Location Plan is provided at Appendix 1.
2.3 At present, the site adjoins but is located outside of the defined Wixams settlement boundary2. However, at Policy HOU15 (‘Land South of Wixams’) the Draft Local Plan proposes that the site be allocated for residential development, alongside the provision of extensive areas of green infrastructure, including a new woodland.
2.4 The allocation therefore envisages a sustainable extension to the Wixams New Town, which Wates fully supports. Wates is therefore committed to working proactively with Bedford Borough Council (‘BBC’), both to bring forward a high-quality residential development and to contribute to the regeneration of the Forest of Marston Vale.
2.5 To confirm deliverability, a number of initial technical reports, surveys and plans have been prepared. These consider the site's constraints and opportunities and identify how development at the site could integrate with the adjoining new settlement. Respectively, these are:
• Illustrative Masterplan (Appendix 2);
• Vision Document (Appendix 3);
• Baseline Transport Appraisal (Appendix 4);
• Historic Desk Based Assessments and Heritage Technical Notes (Appendix 5);
• Ecology Technical Briefing Note and Ecological Appraisal (Appendix 6);
• Phase 1 Preliminary Risk Assessment (Appendix 7);
• Agricultural Land Quality Report (Appendix 8);
• Acoustics Assessment (Appendix 9); and,
• Preliminary Drainage Strategy (Appendix 10).
2.6 The Illustrative Masterplan and Vision Document indicate that around 430 homes and related development could be delivered at the site, alongside blue and green infrastructure, in the form of Sustainable Urban Drainage Systems (SuDS) and biodiversity and landscape enhancements. These benefits are in addition to new areas of woodland planting, which will contribute to the Community Forest project.
2.7 The accompanying technical reports demonstrate that the site could come forward without generating unacceptable heritage, landscape, arboricultural, ecological or flood risk impacts. Likewise, the appended Transport Technical Note confirms that new pedestrian and cycle connections can be successfully provided, and that a new primary point of vehicular access can be achieved from the A6 Road.
2.8 Accordingly, Wates supports the principle of the allocation proposed at draft Policy HOU15 and regards the site as deliverable. Nonetheless, these representations recommend that a number of changes be made to improve the effectiveness of both this policy and the Draft Local Plan in general. This will help ensure that the Plan addresses the tests of soundness, as described below.

Comment

Representation ID: 10011

Received: 29/07/2022

Respondent: Wates Developments

Agent: Boyer

8.1 Wates supports this draft policy in principle and agrees that Land South of Wixams represents a sustainable and suitable site for growth. A residential development at this location would relate logically to the current and permitted extent of the Wixams New Town, with the site adjoining ‘Village 2’ to the north west.
8.2 In addition to adjoining the settlement, the vast majority of the site is bound by the A6 road. Whilst a small parcel within the proposed allocation lies to the east of the A6, this is only included in order to allow for the formation of a new vehicular access, via a roundabout junction. The development of the land would therefore present an opportunity to ‘round off’ the south eastern extent of Wixams, without significant encroachment into the open countryside.
8.3 To the south, the proposed allocation extends along the route to the A6, as far Wilstead. This part of the site is not promoted for residential development. Rather, it presents an opportunity to provide a new area of (publicly accessible) woodland, contributing to the broader objectives of the Forest of Marston Vale strategy and exceeding the draft Policy HOU12 objective of achieving 30% woodland coverage within the Forest of Marston Vale Area.
8.4 As we detailed below, the site is free from any significant constraints that would prevent a sustainable development being achieved. It is deliverable and capable of making an early contribution to the supply of land for housing.
8.5 However, Wates considers that the precise wording of the proposed policy requires modification in potentially significant ways, in order to improve the potential for early delivery, and hence the effectiveness of the policy overall. As such, Wates objects to the policy as presently worded.
Consideration of Constraints and Opportunities
8.6 Land South of Wixams currently comprises approximately 50 hectares of predominantly arable land, which is intensively farmed. Consequently, an Extended Phase 1 Habitat Survey (included in the Ecological Appraisal at Appendix 6) confirms that the majority of the site is of low ecological value. Habitats of interest are largely limited to boundary hedgerows and trees, and ponds. The baseline ecological value of the land is such that it will be possible to achieve the 10% biodiversity net gain sought by draft Policy DM7.
8.7 In terms of arboriculture, a Tree Survey has been undertaken. This confirms that no Tree Preservation Orders (TPOs) apply to the site, nor are there any areas of Ancient Woodland within or adjoining the land. A small area of mature woodland is situated in the far south of the proposed allocation. However, this is located a considerable distance from the envisaged developable area and would form part of the proposed woodland.
8.8 The Tree Survey has been used to inform the emerging masterplan, which will retain existing trees and hedgerows wherever possible. Development at this site would therefore be comply with adopted Local Plan 2030 Policy 39 (‘Retention of Trees’) which is proposed to be ‘saved’. The development also has the potential to facilitate the creation of a large new woodland, greatly increasing canopy coverage. In this way, the proposals will contribute to the requirements of draft Polices HOU12 and HOU15, as well as adopted Policy 36 ‘Forest of Marston Vale’ (as is proposed to be saved).
8.9 Consistent with the requirements of draft Policy HOU15, the accompanying Historic Desk Based Assessments and Heritage Technical Note (Appendix 5) indicates that conventional assessments of below ground archaeology11 will be required to support a future planning application at the site. The draft policy also makes reference to above ground heritage assets at Duck End and Wilstead, indicating that these will need to be preserved and (where possible) enhanced.
8.10 The appended details confirm that all of the heritage assets in Duck End and Wilstead are dislocated from the site by the A6 Road and other intervening built form. On this basis, the site makes no apparent contribution to the setting of any of the assets identified, with this inherently reducing the potential for detrimental impacts to occur. The site could therefore be developed in a manner consistent with adopted Local Plan Policy 41 ‘Historic Environment and Heritage Assets’ (as proposed to be saved) and NPPF Section 16.
8.11 Regarding landscape, the site is not within any designations for ‘valued landscapes’, such as AONBs or National Parks. It does currently fall within a ‘Local Gap’, as identified at Policy AD42 of the ‘Allocations and Designations Local Plan Policies’ (2013). However, a landscape-led approach, the introduction of appropriate buffers and the proposed new woodland, means that the effectiveness of the retained gap will be maintained (in a manner consistent with draft Policy HOU15).
8.12 It is also the case that the northern extent of the site, where the developable area is envisaged, is less sensitive in landscape terms. This is because the localised character of this area is influenced by the A6 and the urbanised context of the Wixams New Town. These characteristics are consistent with the classification of the ‘Clay Vales – North Marston Clay Vale’, as identified in the conjoined Bedford Borough and Central Bedfordshire Landscape Character Assessment (January 2015). The site’s development is therefore expected to accord with adopted Policy 37 (‘Landscape Character’), which is proposed to be saved.
8.13 Noting the presence of the A6 road (and consistent with the requirements of draft Policy HOU15) an Acoustics Assessment (Appendix 9) has been undertaken at the site. This confirms that a future residential development can meet required standards and secure an acceptable acoustic environment, subject to the inclusion of conventional mitigation measures. The Assessment further confirms that it may be appropriate to include a buffer towards the road. However, the width of the recommended buffer (as identified through this technicalassessment) is more limited than that presented on the Strategic Concept Plan at Figure 5 of the Draft Local Plan.
8.14 The accompanying Preliminary Drainage Strategy (Appendix 10) confirms that the site is generally situated within ‘Flood Zone 1’, which denotes a low probability of flooding from fluvial sources. A small area along the northern boundary of the site is identified as ‘Flood Zone 2’, with this being associated with an existing watercourse. No development is proposed within the area.
8.15 A surface water drainage strategy will support a future planning application at the site. In-situ ground investigation and infiltration testing surveys have been undertaken to inform this. These suggest that surface water run-off will need to be addressed though SuDS, in the form of conveyancing swales and detention basins. The SuDS infrastructure will be integrated into a holistic strategy for green and blue infrastructure, which will contribute to landscape enhancements and net gains in biodiversity.
The Proposed Development
8.16 A Vision Document accompanies these representations, which provides a comprehensive account of the development proposals envisaged at the site.
8.17 However, in summary, the guiding principle for the site’s development will be the pursuit of a landscape-led approach. This will be achieved primarily through the distribution of land uses, with development being limited to those parts of the site which best relate to the existing extent of Wixams and which are less sensitive. Conversely, a new area of publicly accessible woodland is proposed in the more sensitive land to the south / south east.
8.18 A buffer is envisaged along the western part of the site, towards the A6. This will assist in preserving the amenity of future residents, whilst also providing separation from the existing dwellings at Duck End. A further green buffer is envisaged within the northern extent of the site, where the allocation adjoins the existing / permitted extent of Wixams. Following from this, development at the site will aim to create a distinct ‘village’, thereby pursing an approach that is consistent with the existing pattern of development at the settlement.
8.19 Extensive areas of Green Infrastructure will be provided in the form of public open space, not least a large new area of woodland and country park, that will support the Marston Vale Community Forest project and which will benefit residents of both Wixams and Wilstead. Significant areas for biodiversity enhancement will be provided across the site, ensuring that net gains above 10% will be secured12. New SuDS features will include ponds and swales, which will further contribute to landscape and biodiversity objectives.
8.20 In terms of vehicular access, the site is to be served by a new three arm roundabout taken from the A6 to the east. For non-motorised users, access will be delivered to the PROW network and to Bedford Road where there are opportunities to deliver either a dedicated shared footway and cycleway connection and / or a bus connection onto Bedford Road. The key principle in this regard, is to promote pedestrian / cycle connectivity into Wixams and Wixams Train Station, when this is delivered.
8.21 It is considered around 430 dwellings could be achieved across a net developable area of 11.5 ha, representing an average net density of 38 dph (net). Development densities will in practice vary across the site, with the development being structured around a number of distinct character areas. In this way, the proposals strike a balance between an efficient use of land, whilst also responding appropriately to the site’s context.
8.22 The new homes will include policy-compliant levels of affordable housing, with the mix and composition of the new dwellings ranging from flats to townhouses and detached / semi-detached homes. All of the new homes built at the site will conform to national and local planning standards and building regulation requirements relating to energy efficiency and ‘zero carbon ready’ development.
Development Density
8.23 An important consideration for any development is that of density. In this respect, it appears that BBC has underestimated achievable net densities at the site. Specifically, a density of around 30 net dwellings per hectare (dph) appears to have been assumed by BBC, in the reports associated with the consultation13.
8.24 The level of density appears combatively low when compared to the Wixams Park development, and Wixams Villages 1 and 2. This is illustrated by the analysis of built / approved density strategies within the accompanying Vision Document (at pages 36 to 37). The analysis illustrates the prevalence of densities within the ranges of up-to 35 dph, 35 to 40 dph and 40 to 50 dph, with densities even exceeding 50 dph in particular locations.
8.25 Localised densities therefore vary greatly across the existing settlement, as they will indeed vary across Land South of Wixams when it is developed in future, as an extension to the New Town. Indeed, Wates proposes a range of house types and sizes, in accordance with draft Policy DM3. Achieving a well-conceived design will result in natural variation, as townhouses and/or apartments might front main streets, whilst lower density detached / semi-detached properties would line secondary streets.
8.26 Nonetheless, average net developable densities should not be lower than 35 dph at the site. Wates maintain that this is appropriate and reasonable, as new development with this allocation will form part of Wixams, which (as a contemporary New Town) is already characterised by higher densities than might be associated with a historic or post-war settlement. Indeed, there do not appear to be any character-related constraints that would point to a need to limit expected densities to just 30 dph (net).
8.27 Wates consider that an average density of 38 dph could be comfortably achieved, which suggests that capacity of the site is around 430 homes. This is based on our assessment of the available developable area (11.15 ha), taking account of the proposed strategy for SuDs and infrastructure provision, and applying appropriate buffers for to account for landscape and acoustic constraints. The approach to scheme design and developable area is detailed in the appended Illustrative Masterplan, Vision Document and supporting technical reports.
8.28 This volume of development appears to be achievable and would be appropriate in the context of the existing pattern of settlement at Wixams. Increased densities are also consistent with the pursuit of low / zero carbon development, as set out in draft Policies DS1, DS2 and HOU12.

9.2 Within the context of the proposed spatial strategy, it is entirely consistent for further development to take place at Wixams. The settlement is already identified as a key service centre, that benefits from an expanding range of modern local services. Indeed, Wixams will soon benefit from additional strategic transport infrastructure in the form of the new Railway Station. Having been established as a new town, the settlement has continued to develop and deliver significant volumes of new housing.
9.3 The development proposed through Policy HOU15 ‘Land South of Wixams’ therefore represents a logical approach to meeting housing needs, through a modest extension to the settlement. The developable area within the north of the site is well contained by the A6 road and the current extent of Wixams, whilst the southern part of the proposed allocation is capable of accommodating large new areas of public open space and woodland.
9.4 Contributing to the Forest of Marston Vale project, the new accessible area of woodland / country park would provide tangible benefits for residents of both Wixams and Wilstead, particularly in terms of health and outdoor recreation. The introduction of this new woodland will also dramatically increase canopy coverage in the local area, and will create widespread opportunities for biodiversity gain and (over-time) carbon sequestration. In this way, the proposed allocation addresses sustainable development, and particularly the environmental and social aspects of the NPPF paragraph 8 definition.
9.5 Land South of Wixams is actively promoted by Wates and consideration has been given to key design principles, including a landscape-led approach and promoting connectivity. A Vision Document accompanies these representations, which sets out the proposed strategy in more detail. This is supported by a range of technical surveys and reports, which confirm that the site is free from any technical constraints that would impede its delivery. The development will therefore make a timely contribution to the supply of market and affordable housing.
9.6 Whilst Wates strongly supports the principle of both Policies HOU12 and HOU15, Wates raises objections to the current wording on these policies. Subject to the modifications outlined in these representations, we believe that these policies can be made sound. Wates also objects to the wording of Policy DS3, as (on reviewing aspects of BBC’s identified housing supply), there would appear to be an opportunity for greater delivery, within the early to middle part of the Plan-period. With modification, it is considered that this draft policy can be made sound.

Object

Representation ID: 10026

Received: 27/07/2022

Respondent: Mr Neil Robertson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

I wish to formally object to the planned 2,100 new houses ie Land South of Wixams (300 houses) and Land East of Wixams (1,800 houses) that are part of the Bedford Borough Council Local Plan 2040. These developments are within the Wilstead Parish although they have been shown in the draft Local Plan as a “Wixams Extension”, which means that the Plan itself is inaccurate and could be misleading for residents when assessing the plan. There are a further 1000 homes proposed for Shortstown, which are next to the Wilstead Parish Boundary.
I have serious concerns about the detrimental impact that this large-scale development will have on the environment.
These are my main concerns:
1. The loss of over 400 acres of rural countryside, affecting numerous species of wildlife.
2. Loss of village identity.
3. Increase in pollution and traffic congestion.
4. Lack of sufficient public services.
5. Loss of food producing farmland.


Thank you for your consideration of the points I have raised as my objection to the planned housing developments in Wixams/Wilstead.

Object

Representation ID: 10030

Received: 27/07/2022

Respondent: Sheila Mousley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

THE NEED FOR HOUSING/SUSTAINABLE DEVELOPMENT
I object to the size of the community trebling in size. This is far too high. AT present the infrastructure is insufficient not enough GPs, bus services, post offices, general shops to accomodate 27,100 houses. I moved here as I wanted to live in a village and not an urban sprawl.
The proposal does not represent sustainable development.
TRAFFIC/TRANSPORT
I have huge concerns regarding traffic travelling on A6 towards Bedford and Luton. At present I experience congestion at roundabouts coming up to A421 and approaches to Interchange Park, more houses more congestion.
Cycling is not realistic as there are no continous pathways people can use on the approach to Bedford.
I object to having to put up with heavy construction traffic in this area for the rest of my life.
UNSPOILT COUNTRYSIDE
I object to the area outside the SPA which is designed as green space area between the settlements being built on. This should be left for food production, wildlife preservation and walks.
I cannot support these plans in their present form I hope my objections are listened to.

Comment

Representation ID: 10091

Received: 28/07/2022

Respondent: Wilshamstead Parish Council

The Parish Council immediately on publication of the formal consultation and related publicity material raised concern directly with Planning Policy Officers at the local authority on the misleading naming of proposed local plan locations as a “Wixams Extension”. Officers outlined that sites were being classified by their geographical locations, this however, has not been a helpful representation for the Wilstead community and it was noted at our open day repeatedly that the Local Plan was misleading and confusing as many residents believed it was a further extension to Wixams on the other side of the A6. Both HOU15 and HOU16 should have been known as Land West of Wilstead (HOU15) or Land North of Wilstead (HOU16), just like policy HOU5 Abbey Field, West of Elstow which makes a clear reference to the parish it is in. In response to a question during an on-line discussion about this misrepresentation the Planning Department replied that they were sure Wilstead Parish Council would make it clear to Wilstead residents that the proposals were within the Wilshamstead Parish. This is unacceptable. The Parish of Wilshamstead is severely affected by the proposals in the Plan in that it appears to propose reducing the size of the Parish by approximately one fifth, significantly impacting upon walking routes, biodiversity and dramatically increasing through traffic whilst also transitioning this land and the applicable services within it to Wixams. Nowhere in the document is this made clear.
Wilstead is mentioned only 7 times in the document and only in terms which support the preservation of the village in its current form.

It could be predicted that in shifting one fifth of the current Parish of Wilshamstead to Wixams the Wilstead community would not only suffer the effects described at length within this document but would also not benefit from any Community Infrastructure Levy received from developers that could act as some mitigation for the loss and overburdening of current resources.

The inaccurate naming of the two proposed allocations within the draft Local Plan and consultation documents is a significant issue in that it is misleading the public and inaccurate in its nature, casting doubt on the accuracy of the Plan as a whole and something that may become subject to legal challenge at a later stage.

At most, members of the public will glance or briefly scan such a local authority document at best, whether that is the literature produced in text, or visual format. For many, on doing that, it appeared that the Local Plan 2040 document aligned with the adopted and well supported Wilshamstead Neighbourhood Plan allocation of no additional housing.

However, both HOU15 and HOU16 clearly sit entirely within the parish boundary of Wilshamstead, as illustrated on the map below. (see attachment)

This misrepresentation of information will have resulted in many not understanding the proposals. Often, when individuals see no direct impact, they do not go into a more in-depth review of the consultation and therefore are unlikely to give feedback or engage in the consultation process. This is relevant to those that live in Wilstead, as well as those who live nearby in Wixams who have also been misled. The knock-on impact of this inaccurate site naming will also spread beyond the nearest settlements, with many across the borough believing that the proposed developments are in Wixams, which is well known in terms of having been a new town, created to serve a growing new community. Totally distinct from ‘Wilstead’ which is recognised across the borough as a rural village.

Removing Wilstead from the policy site names, feels like an attempt from the local authority to disguise significant development for the village community and to directly mislead the public in order to establish new development without significant objection.

SECTION 2 : CAPACITY OF EXISTING RESOURCES

Overview
The village has already had to accept development of 105 houses as its contribution to the Local Plan 2030. This is an increase of over 10% which has already threatened to overwhelm local facilities, such as the local village school and the secondary school at neighbouring Wixams, both of which are at full capacity.

Local Plan 2040 Specific
The village is now faced with Policy HOU15 and HOU16 which bring an increase of 2,100 houses over the lifetime of this new Local Plan. It is unclear in the consultation on how Wilstead is expected to cope with such an influx of housing development as it certainly does not have the infrastructure to manage this, and the proposed developments do not bring such facilities to support the drastic growth without substantial funding which, in the past, has not been forthcoming.

Furthermore, the road network locally is already an issue with Wilstead being the connecting road from Wixams (as it is today) through to the A600. Notable speeding issues have not yet been sufficiently addressed by BBC and we are now faced with a potential increase in not only traffic once the site is built, but also a huge amount of polluting vehicles bringing goods and materials, workmen and equipment during build.

It is not clear from this document how such a rural village would cope with a population increase of circa 5,000. It might be argued that such densely populated areas may look to Wixams Town Centre, however, that still remains some time off in the future. Initially new residents will look to Wilstead or Village 1 at Wixams, both of which have very limited facilities (see the argument below on inaccurate Settlement Hierarchy evaluation).

Whilst the consultation document places generic aspirations for the development growth areas it is important to remember there are specific local factors that need to be taken into account. Development cannot be in the direct path of water draining from the Southern escarpment (Greensand Ridge) or in the lower levels north of the village centre, which are shown on Water Authority documentation as at risk of flooding from drainage ditches. Each housing policy area has an overarching ‘mitigation required for all sources of flood risk where necessary’ but they are site specific. Cumulative impact does not appear to be referenced which has a knock-on effect to all residents who can then find water draining problems occurring. Since the development at land off Whitworth Way known as Wooding Way the knock-on effect has been noticeable further afield in the village.

Public transport or cycling are not realistic alternatives for people in the area to get to work or to go shopping. The bus service in Wilstead is very limited. There is no East to West or West to East service despite the village stretching nearly 2 miles in that direction. In addition, bus stops for the service to Bedford are located more than 800m from the majority of residents. The existing bus service along Luton and Bedford Roads in Wilstead is unreliable and infrequent leaving gaps of one hour at many peak times.

For cycling or walking it would be necessary to cross the A6 from HOU 17 to reach existing facilities in Wixams which would be extremely dangerous and the draft Plan shows no suggestion as to how this danger may be mitigated.

A full study was commissioned by the Borough Council for the current Local Plan 2030 on the effect of proposed additional traffic on the A6 approaching from the North into Bedford. This was the main reason that large developments north of the town have been ruled out. The research carried out by AECOM on the effect of the increase in traffic approaching from the South if these developments were to go ahead is inadequate and does not show the effect of so much more traffic being generated by the proposed developments in Wilstead, by the cut-through traffic from, and to, the A600 and the large developments proposed close to the A6 by Central Bedfordshire Borough Council. The build-up of traffic approaching the A421 or the new Wixams station would be extreme and no proposals are evident of mitigating road changes. There is also no evidence of any air quality targets or measures to mitigate the impacts of climate change beyond very high level statements and an ever increasing amount of tailbacks on the northbound A6 as it meets the A421.

The biggest cumulative impact that will be seen within the parish will naturally be around highways and further increases in traffic on the already overwhelmed existing busy rural roads which have become very congested at school opening and closing times throughout the rush hour period as the village is used as a ‘rat run’. The Parish Council have extensive data from local surveys, Police and local authority survey with the problems experienced, particularly along Cotton End Road. Traffic originates from outside the village and is an indication of how development outside of the Parish Council’s area has in turn adversely affected the resources within the village. There is still no local Health facility in Wixams or Wilstead and the weekly access to doctor’s services in Wilstead has been discontinued. In addition the number of new houses proposed in the Central Bedfordshire Local Plan will mean that doctors used by Wilstead residents in Ampthill will become even less available. There is no indication in the draft Plan as to how the additional 28 GPs identified in the AECOM Infrastructure document could be recruited to serve the number of new residents proposed in the South of Bedford Policy area.
Further concerns exist around schooling. A 9-form entry (FE) secondary school and two 2-FE Primary Schools within HOU 16 is an ambitious target that would require massive funding and resources that would not be forthcoming in the short-term, thus putting even more pressure on existing schools in the area which are already at capacity.
Infrastructure concerns are further addressed in Section 8 of this response addressing the South of Bedford Policy contained within the proposed Plan.

SECTION 3: THE NEED FOR HOUSING, SUSTAINABLE DEVELOPMENT AND THE ENVIRONMENT

Wilshamstead Parish Council appreciate the work behind the document from the Campaign for Rural England dated July 2022 in which they question the need to find 27,100 additional houses between now and 2040. WPC accept that BBC has made the point to the Government that they “are obliged to plan for an excessive growth rate far in excess of that which the borough can sustainably accommodate.” But feel that the Borough should not just lie down and accept that no flexibility in the numbers can be shown.

The National Planning Policy Framework (NPPF) states that pursuing sustainable development includes making it easier to create jobs in villages, promoting gains in biodiversity, achieving better quality design, improving people’s quality of life and providing a wider choice of high-quality homes. It is unclear how these can be achieved based upon the broad terms included in the draft Plan.

Within the Wilshamstead Neighbourhood Plan we list what sustainable development should mean for the village. It should be:
• At an appropriate scale and in locations where it would support the community,
• Of a high standard of design, reflecting the rural and historic character of the surroundings,
• Contributing towards community infrastructure,
• Providing superfast broadband (fibre-optic) connections,
• Ensuring that there is no increase in the risk of flooding,
• Meeting contemporary construction, energy efficiency and water management standards,
• Located and designed to enable safe walking and cycling to local services and facilities, preferably within a 400m radius of those locations.

WPC cannot find the detail within the draft Local Plan of how any of these can be achieved.

In addition the Neighbourhood Plan states that the following adverse impacts must be avoided:
• Reduction in the physical separation between the village and Wixams,
• Avoidable intrusion into open countryside,
• The loss of or damage to wildlife habitats and hedgerows and trees,
• The loss or inappropriate diversion of public rights of way,
• A loss of amenity for existing residential properties and reduced efficiency for nearby businesses,
• Overloading existing utilities and services (water, drainage, sewerage and waste).

None of these concerns appear to have been addressed by the draft Local Plan 2040 and a number are directly contradicted by proposals in that Plan.

WPC support the CPRE Bedfordshire proposal that all open green space within new housing development should be handed over to Town & Parish Council's for long term maintenance and not held onto by developers who charge residents much higher maintenance costs. We receive regular complaints about this in existing developments in the village. We agree with CPRE and can ourselves find no reference in the Draft Plan to any steps taken to address this

Paragraph 6.62 of the Draft Plan refers to “environmental net gain” but nowhere can we find an explanation of what action is to be taken to achieve this.

Other aspects of sustainability are that you should not use sites that are valuable from an agricultural/environmental/recreational perspective for development. All of the land proposed for development is on key agricultural land and HOU 16 borders an important footpath used daily for recreational activity and a Community Woodland planted recently for that very purpose.

SECTION 4: POTENTIAL ADVERSE EFFECT OF MAJOR DEVELOPMENT IN WILSHAMSTEAD PARISH

Village Overview
There are only approximately 900 houses in the village (plus 196 park homes), therefore any substantial development would completely alter the character of the community and overwhelm its already overstretched facilities. The addition of 2100 houses would mean the village housing number would become three times the current size until such time as the land is annexed off into Wixams at which point the village would become dwarfed by its neighbour and would further lose its small, rural feel.

Wilstead is a rural community, which it is vitally important to retain. Securing its rural feel is essential and emphasised repeatedly in responses from villagers to the consultations on the Neighbourhood Plan. This should be achieved by maintaining a large number of green spaces, strategic gaps between settlements and important views into the surrounding open countryside.

The village has consisted for centuries of separate “Ends” (e.g. Duck End, Church End, Littleworth). These should remain separate to preserve that rural Bedfordshire heritage, not only in the timeline of this Plan but for future generations to come. The map on page 67 of the Plan shows arrows to denote “Local Gaps”, This completely ignores the fact that the Duck End community is next to the proposed area for development under HOU 16.

The existing, very stretched, “Ribbon Development” of Wilstead would not tolerate further development on its edges (or moreover on land completely disjointed from the traditional development style seen to date) without these developing into separate communities in themselves and necessitating additional car journeys and the further and unnecessary use of natural resources which is in itself unsustainable and unnecessary. Wilstead is a settled community and the Parish Council do not wish development to introduce separation, meaning therefore, that any development to the village would have to be more central and consistent with the existing size of the village. It should be noted that further development in the village has been managed successfully to that end to date whilst simultaneously maintaining a rural and peaceful area.

Wilstead is incredibly lucky to have a wonderful range of footpaths and bridleways and quiet country roads within the parish; perhaps most notably the historically important John Bunyan trail. They are very popular with cyclists, walkers, bird watchers and horse riders. A wide range of people not only from Wilstead but also surrounding villages, including Wixams, use them to enjoy the tranquillity, the wildlife, the views or just to get exercise and for mental well-being. There are 11 miles of footpaths and bridleways within the Parish Footpaths, the use and enjoyment of rights of way would be detrimentally impacted with the proposed allocations, especially as the proposed HOU 16 would adjoin a much-used footpath (part of which is on the John Bunyan trail) and HOU 15 would be dissected by an existing footpath.

Proposed Allocations Objections
Substantial development has been included in the Local Plan document with Policy HOU15 and Policy HOU16. The Parish Council is also mindful of the sizeable allocation for Policy HOU17 Land at College Farm, Shortstown which will be addressed as well in this response.

The Borough Council indicates that as a result of previous consultation it is going ahead with a recommendation for “Option 2b” of its previous proposals. This Option refers to an additional 5,500 houses in Kempston Hardwick, Stewartby and Wixams and 1,500 spread between Wootton, Kempston, Shortstown , Cotton End and Wilstead. Policies HOU 15, HOU 16 and HOU 17 show 3,100 houses for Wilstead and Shortstown alone. Option 2b is therefore not what is being proposed and the detail within the proposed Local Plan has therefore not been consulted upon.

All three of the allocations above if taken forwards as strategic growth options by the local authority, would most likely consist of estate-type development which would be out of character with the rural, multi-age and mixed style of the current range of dwellings.

In addition for sites HOU15 and HOU16 if they were to be developed it would be mean for both major developments in Wilstead it would necessitate people travelling by car into other communities, as these resources do not exist locally in the parish. Examples include:
 Schooling (insufficient places available locally)
 Shopping (local store cannot supply the range of goods required)
 Health facilities (none locally)
 Onward bus or train travel (very limited services)

Policy HOU 15 Land South of Wixams (i.e. West Wilstead)
In addition to the Parish Council objecting to this proposed allocation for the planning policy reasons set out above, the Parish Council wish to highlight in particular for this site, the detrimental impact in terms of coalescence (see Section 5 below). The location of this site is key to retaining segregation of the two distinctively different communities. Development in this area places a huge risk to Wilstead and the Longmeadow Drive area of the parish becoming subsumed as part of Wixams.

The Parish Council also feel it is important to highlight specific areas of the associated planning policy which if the site remains allocated, must be amended prior to Secretary of State scrutiny.

Paragraph 4.86 makes no reference of the site within Wilstead parish or its proximity to Wilstead, these omissions are not acceptable.

The policy wording makes a brief reference to a long-term buffer between Wixams and Wilstead, however, this is not reflected in Figure 8 of the consultation document within the site boundary. This is concerning as in many other site maps illustrating proposed allocations there has been distinct reference already included of important areas identified as key open spaces even at this strategic level. Such safeguarding of areas can be included at this stage of the Local Plan. Again this omission is concerning for the Parish Council.

In light of the landowner/site agent representations within the ‘Call for Sites’ process it is clear the aspirations for this site are considerably more than the 300 proposed allocation. Given recent experiences of sites that have come forward, the Parish Council are mindful it is often the wish of the developer when bringing a site forwards to place as many houses on as possible to maximise revenue output. It is therefore reasonable that if this site remains included that it must have written into the strategic policy robustly a definite number of houses, alongside the key earmarked open space areas to act as a strategic buffer. Without this change and inclusion within the policy there is no safeguard or protection for the site to not be fully developed and given the site has capacity to hold well over 1,000 houses this is really a concern for the Parish Council.

Policy HOU15 wording is not clear enough on a number of important factors that must be stated within the overarching policy if this site goes forward. There are too many ‘loose’ words which during the development of Wixams resulted in so many expectations not being met. Together with the limited local authority powers, it caused a lot of distress that facilities were not being progressed in a timely manner and resulted in many ultimately never being delivered or being many years late.

The Parish Council feel that there needs to be more included with the Transport Assessment, with higher expectations and aspirations for further enhancements to the local network to maximise more sustainable methods of transport, such as a clear and specified Local Transport Decarbonisation Plan, following the Government’s commitment to Net Zero, the national EV Infrastructure Strategy and supplementary Transitioning to zero emission cars and vans: 2035 Delivery Plan which will incorporate not only the traffic related to the construction activity (which typically sees large diesel-powered HGVs operating) but also the longer-term operation of fleets and commercial vehicles in these areas. This plan must include the provision of sufficient e.g., charging hubs, destination charging and on-street charging to supplement the now mandatory home charging sockets. It should also be a requirement of the development to provide sufficient non-motorised options for sustainable transport, such as cycling routes and walkways away from the roadside (for safety and emissions reasons).

In item iv. it talks of ‘provision of a mobility hub’, this needs to be defined in more detail as otherwise it becomes just a piece of land that is allocated but has nothing of any useful benefit on it. Infrastructure is critical to ensuring a community can grow. Further to this, the provision of energy for the site should be mandated within the policy document to come from localised generation.

Again there needs to be more robust wording in items vi. viii. and ix. With some more substantial statements referenced.

Item x. makes reference to preserving and enhancing heritage assets and their setting, ‘including assets located in Duck End and Wilstead.’ Whilst it is important that Duck End is recognised as an important area which includes 3 listed buildings, there are plenty more assets in close proximity to this site allocation that should be included and specifically named in the policy wording, including All Saints Church and 19 other Listed Buildings within the Village.

Object

Representation ID: 10243

Received: 29/07/2022

Respondent: Wilstead Footpath Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

HOU15 Land south of Wixams.
The Wilstead P3 Footpath Group object to this proposed development (HOU15) on the grounds of its impact on the Public Right of Way Wilstead Footpath 3.
Background. The Group with assistance from Bedford Borough Council (Rights of Way dept and Councillor G Coombes (Ward Fund)) and Wilshamstead Parish Council monitor and help maintain all of the Public Rights of the Way in the Parish including Footpath 3. They survey all the paths every two months and where necessary cut back overgrowth and maintain the surface of the Footpaths and Bridleways as well as installing furniture such as kissing gates, culverts and waymark posts.
The purpose of this work is to provide accessible off road routes in the countryside not only within the village but also to provide good connectivity with neighbouring communities. Wilstead Footpath 3 is one of these important recreational routes, linking Wilstead with Houghton Conquest and beyond (possibly connecting to the proposed new Kempston Hardwick settlement) as well as with numerous parts of Wixams (via its connection with the Wixams Greenways.
Way Forward. The Footpath Group understand that the effect on Public Rights of Way will not in itself mean that the development will not proceed but they want to identify the impact on these local recreational facilities, that may be overlooked, and at the same time identify how the impact of any development on these Rights of Way could be lessened.
This proposed development in HOU15 will envelope Wilstead Footpath 3 changing it from a path through open countryside, with views south to the Greensand Escarpment, to a path through housing.
The Footpath Group would propose a new path is created around the southern edge of the proposed housing (the northern part of HOU15) and on the northern edge of the proposed Country Park (the southern part of HOU15). This new path should be screened from the development by a green buffer of hedges and trees. This would ensure that some of the rural characteristics of the existing Footpath 3 are copied, especially the view south to the escarpment.
There must be potential for this footpath and the Wixams Greenways to be part of the rim of the Bedford Green Wheel, the off road / quiet lane circular cycle route around Bedford with spokes from the rim of the wheel into Bedford. Currently the route of the Wheel south of Bedford doesn’t appear to be settled
The creation of this development would also give the opportunity to investigate how Footpath 3’s crossing the A6 road on the level can be avoided.
Country Park. The inclusion of the County Park in HOU15 is welcome. This should be made Access Land similar to that created under the Countryside and Rights of Way Act 2000. This would give open access to the Country Park and give it greater protection against any future development south along the western side of the A6.
The route of Wilstead Footpath 4 through the proposed Country Park shouldn’t be effected by HOU15. However access to this Park from Wilstead would currently mean crossing the A6 on the level . Again alternative ways of crossing the A6 should be provided as part of this proposed development.
Safety. If development is permitted then the Footpath Group would be happy to work with the Developer and Bedford Borough Rights of Way to derive amended routes of Footpath 3 and 4 which would include avoiding crossing the A6 on the level. The use of an existing culvert and re-opening a former cattle creep, both going under the A6 are potential ways to do this. An alternative for Footpath 4 is a footbridge as currently the A6 runs in a cutting at this point.
Summary. Relatively minor amendments to the existing routes of both Footpaths could preserve some of the rural feeling of these paths and mean they could continue to provide good recreational routes for not only the new and current residents of Wixams but also the residents living in the arc of countryside to the south of Bedford and the A421. In light of the large amount of development planned and proposed in this area having a linked up, safe Rights of Way network in this area which avoided crossing major roads would be seen as a beneficial result of these proposed developments and go some of the way to balance the impact of these developments on existing residents of this area.

Comment

Representation ID: 10264

Received: 29/07/2022

Respondent: Central Bedfordshire Council

HOU15 - Land South of Wixams
10.14 The submission plan identifies that the proposed allocation forms part of the wider South of Bedford Area, it is however, unclear how many homes would actually be delivered within the allocation.
10.15 CBC generally supports the further expansion to the south of Wixams within Bedford Borough. However, due to the cross boundary nature of the Wixams site as a whole, coordination between CBC and Bedford will need to be ongoing to ensure the area as a whole is delivered cohesively. CBC and BBC will also need to look at wider cross-boundary issues, including an access strategy and particularly treatment of the A6 junctions and extension of bus routes to create a network for the wider Wixams site.