Policy EMP5 Land at Pear Tree Farm, Elstow

Object

Representation ID: 9273

Received: 27/07/2022

Respondent: Mr Andrew Sharples

Legally compliant? No

Sound? No

Duty to co-operate? No

Elstow is an historic village. It should not be subsumed within Bedford itself.

Elstow already suffers as a rat run during peak morning and evening times. Our house physically vibrates when buses and heavy vehicles travel past. There is also already significant traffic congestion at peak times (for example congestion at the top of the village and the A6/A421 roundabout).

A business park with overbearing properties, additional noise, and further traffic will be another nail in the coffin of historic Elstow. Experience shows that The Waste Transfer Station although initially restricted in operation is now virtually full time.

Object

Representation ID: 9274

Received: 27/07/2022

Respondent: Mrs Claire Sharples

Legally compliant? No

Sound? No

Duty to co-operate? No

Elstow is an old historically residential community. It is low density and low rise. Over the years the village has been increasingly spoilt by increased traffic volume and noise. Our house shakes when heavy vehicles pass. Were the Pear Tree Farm business park to proceed it would further erode the nature of the village (with buildings out of keeping with a residential village looming over the village/our own property, drawing in yet more traffic to a congested area and creating more noise).

Object

Representation ID: 9289

Received: 27/07/2022

Respondent: Mr Simon Peryer

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The proposed site has to be reconsidered in view of the proposed access. The approach from the A6 is unsound due to the speed and view of on coming traffic. The second access at Wilsted is into an Access only road to prevent traffic entering a Historic Village and causing environmental damage. Bedford doesn't need any more low paid warehousing jobs.

Object

Representation ID: 9290

Received: 27/07/2022

Respondent: Mr Claudio Scippo

Legally compliant? No

Sound? No

Duty to co-operate? No

1 - Elstow is the only historic village in the area with its Abbey and links to John Bunyan. Adding an industrial area will ruin its character.
2 - The site is in a rural location. This large development with high buildings is out of keeping with its surroundings.
3 - The development would bring urbanisation to the village making it just another suburb of Bedford.
3 - The development will increase traffic through the village. Commuters from north Bedford will rat-run along Wilstead Rd, High St, and Progress Way instead of using the A6 and Ampthill Rd.

Object

Representation ID: 9294

Received: 27/07/2022

Respondent: Mrs Maria Scippo

Legally compliant? No

Sound? No

Duty to co-operate? No

1 - Elstow is the only village in the area with unique history because of Abbey and links to John Bunyan. Adding an industrial area will ruin its character.
2 - The site is in a rural location. This large development with high buildings is not suitable for the area.
3 - The development would bring urbanisation, making Elstow it just another suburb of Bedford.
3 - The development will increase traffic through the village. Commuters from north Bedford will rat-run along Wilstead Rd, High St, and Progress Way istead of using the A6 and Ampthill Rd.

Object

Representation ID: 9346

Received: 28/07/2022

Respondent: Mrs Christine McDonnell

Legally compliant? No

Sound? No

Duty to co-operate? No

Objection to EMP5
▪Original EMP6 was not delivered as it was unsustainable.
▪ Land is Grade 2 and BMV so contrary to National Policy.
▪Urban development is not appropriate in a rural area.
▪Traffic congestion is already at saturation point at peak times on A6 and A421; additional traffic is unsustainable.
▪Elstow roads are unsuitable for Business traffic; Wilstead Road is well used by pedestrians /cyclists.
▪2 identified Entrances to site are dangerous and appropriate.
▪ Large scale warehousing is inappropriate and visually intrusive in a rural setting.
▪Historic Elstow will be lost permanently.
▪Dark Skies Policy will be broken.

Comment

Representation ID: 9349

Received: 28/07/2022

Respondent: Mrs Christine Crouch

Strongly object to this development. This is the rural end of Elstow, cannot see how you can protect it from noise, light pollution and extra traffic is this proposal goes ahead. Already if there is an incident on the A6 or A421 Wilstead Road becomes extremely busy and the village has been gridlocked 8 times in the last 3 months.
The loss of valuable productive farmland is another issue. This end of the village also provides habitat for wildlife and bats.
Residents are worried about intrusive lighting, height of buildings and noise at night.
Elstow is unique, preserve it.

Object

Representation ID: 9373

Received: 29/07/2022

Respondent: Mr Ryan Tobias

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It's unclear where the road access would be.

Object

Representation ID: 9447

Received: 29/07/2022

Respondent: Mr Stephen Rutherford

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This and other developments in the plan create an 8 mile x 2 mile urban area to the south of Bedford.
If done well it will be a very big pleasant suburb. If done badly it will be a series of estates with small gaps of farmland in between.
Either way, very significant areas of countryside disappear.

Comment

Representation ID: 9480

Received: 29/07/2022

Respondent: Mr Graham Mills

The phasing of development in new settlements is a very positive aspect of this Local Plan. However, if the required new Bletchley-Bedford-Cambridge railway stations, or the new dual carriageway to Cambridge are not built then the housing targets and the new settlements must be postponed till transport capacity is provided. Otherwise the Plan is not sustainable.

Object

Representation ID: 9514

Received: 27/07/2022

Respondent: Mr David Fudger

Legally compliant? No

Sound? No

Duty to co-operate? No

There is acknowledged importance of Elstow remaining a rural village - The village of Elstow is unique, it is steeped in history with its distinctive character and the addition of housing, and a business park will be totally alien to this character.

Coalescence with Bedford Town
Developing these sites would bring urbanisation to Elstow village, with this housing and employment development, being in such proximity to one another, it will mean the village becomes submerged into Bedford.

Inappropriate and overbearing in height - if any structures are placed on the proposed sites, considering the demographic of the local land, along with the A421 bypass the buildings will be incredibly imposing on nearby settlements.

Impact on local landscape - the sites are in extremely rural locations, the sites are not near densely populated areas, so to have such large-scale development is totally out of keeping. The visual impact on the local setting needs to be considered from all angles, again using specific local knowledge on this is helpful. Being mindful as well of local rights of way, or recreational past times.

Highways - There is already significant congestion experienced at the nearby site junction(s) throughout the day. Detail experiences of impact this has on your own travel patterns as well as the disruption this causes within the village setting.
Traffic volumes and village road network are not suitable for vehicles that would be accessing this site. Access onto nearby village roads might require significant remodelling of the roundabouts and junctions.

Oxford to Cambridge Arc - the government has recognised that such a scheme servicing this local area is no longer necessary, therefore the project has been scrapped.

Working habit changes - consider the changes to how the population now work from home, draw on your own experiences and knowledge of changes to the workplace environment.

Evolution of technology - over time as technology evolves so does how industries operate, having such a specific designation limits the suitability of this proposed site.

Over allocation of employment sites - the Local Plan document has many allocations proposed to be designated for employment sites, concern over the site being redesignated for an alternative use such as housing.

Unsuccessful previous delivery of site EMP6 - the site at Land at Pear Tree Farm was previously allocated for employment with the site known as Land at Medbury Farm in the previous Allocations and Designations Local Plan several years ago. The site did not move forwards in the last 15 years, so it is unreliable in terms of deliverability.

Precedent - if any of the sites are taken forwards on the east of the A6 it will open that entire local area to being developed, with a swathe of housing and employment being built over term, effectively resulting in total urbanisation of the local area.

Sustainability - The proposed development area is not close to any immediate existing services and facilities.
'Levelling up' - central government White Paper sets out that opportunity would be spread more evenly for moral, social, and economic programme growth. Locating such development in the northern part of the country would be in line with government policy.

Wildlife impact - the local area is abundantly rich with wildlife, there will be significant loss of habitat. Local knowledge of how rich in wildlife these areas are, have not been taken into consideration. This needs to be, given the uniqueness of the area as a part of the rural countryside, habitat loss from such significant development and associated ground and hedge/tree works.

Loss of Agricultural Land - The sites comprise Grade 2 agricultural land, which is Best and Most Versatile (BMV) land, and according to national policy, should be protected from significant, inappropriate unsustainable development proposals.

Distinctiveness of village must be considered - Elstow is predominantly a parish with low density development. Having an enormous business park totally urban in character would be out of keeping. Elstow has always pursued a 'dark skies' policy around the parish where the employment site is proposed. This is a distinctive character; it would not be possible to retain a rural character with overbearing, multiple story employment units being imposed on the village.

Protection of the view to Elstow Abbey - the historic building, which is recognised nationally, must be preserved in its rural setting. Any building in the area Abbey Field West of Elstow will be detrimental to the view across to the Abbey from the A6.
Noise pollution - the sites are nearby to several residential properties so during the construction phase these could be subjected to unacceptable noise and disturbance.


Where else the development could go?

There are several housing growth areas identified in the Local Plan, with significant new settlements at Little Barford and Kempston Hardwick. There is a provision for some employment allocation at these two sizeable new communities. It would be natural for employment sites to be based at these locations, for those sites to be expanded to enable those new communities to grow with job opportunities nearby and in a sustainable way. It would be naturally for these areas to take housing development as well.

The Borough Council could also allocate more employment land at existing, established business park areas which have infrastructure in place already. Do also include any other thoughts you might have on where else development could go.

Object

Representation ID: 9589

Received: 29/07/2022

Respondent: Mr James Welling

Legally compliant? No

Sound? No

Duty to co-operate? No

Elstow is a historic village containing over 36 grade 1 and 2 listed properties. The proposed industrial site will butt directly against the sites of many of these listed properties. It is a legal responsibility of the council to maintain a distance between the listed properties and any new development and that is clearly not being done with the proposal.

The properties in the village have been listed due to their historic and architectural importance. The reason for listing a building is to preserve it's historic character. Elstow's character is defined by the number of listed properties it contains. The proposed industrial development will totally undermine the rural nature of the village and impact negatively on the lives of the existing residents who have lived in this setting for many years. The development will be unsightly and will cause an increase in the noise levels for existing residents.

There are numerous industrial sites located in the south Bedford area. The proposed site is away from any existing services and facilities and a previous proposal for a similar site in this same area was never taken up and therefore must be considered unviable.

The proposed site is on prime agricultural land at a time when it is recognised that our nation needs to produce more of it's own food. The building of this industrial site would fly in the face of this need. The building of the site would also lead to the loss of natural habitat for wildlife in the area.

Traffic through Elstow village is already in excess of what there should be due to drivers completely ignoring the 'prohibited vehicles' signs at each end of the village and zero enforcement taking place to ensure compliance with them. The addition of an industrial site with it's associated traffic will only serve to exacerbate this problem.

Object

Representation ID: 9602

Received: 29/07/2022

Respondent: Anita Welling

Legally compliant? No

Sound? No

Duty to co-operate? No

Elstow is a historic village containing over 36 grade 1 and 2 listed properties. The proposed industrial site will butt directly against the sites of many of these listed properties. It is a legal responsibility of the council to maintain a distance between the listed properties and any new development and that is clearly not being done with the proposal.

The properties in the village have been listed due to their historic and architectural importance. The reason for listing a building is to preserve it's historic character. Elstow's character is defined by the number of listed properties it contains. The proposed industrial development will totally undermine the rural nature of the village and impact negatively on the lives of the existing residents who have lived in this setting for many years. The development will be unsightly and will cause an increase in the noise levels for existing residents.

There are numerous industrial sites located in the south Bedford area. The proposed site is away from any existing services and facilities and a previous proposal for a similar site in this same area was never taken up and therefore must be considered unviable.

The proposed site is on prime agricultural land at a time when it is recognised that our nation needs to produce more of it's own food. The building of this industrial site would fly in the face of this need. The building of the site would also lead to the loss of natural habitat for wildlife in the area.

Traffic through Elstow village is already in excess of what there should be due to drivers completely ignoring the 'prohibited vehicles' signs at each end of the village and zero enforcement taking place to ensure compliance with them. The addition of an industrial site with it's associated traffic will only serve to exacerbate this problem.

Comment

Representation ID: 9609

Received: 29/07/2022

Respondent: Wilshamstead Ward

Elstow (EMP5)
This is proposed to be developed into a science park. However, the Borough Council has an appalling record on employment sites, failing to attract significant skilled employment in sufficient numbers.

The result is a vast network of warehouses with either low-skilled roles or serviced via automation, with little obvious benefit to the local community. Those in warehouse jobs that exist are often bussed in from elsewhere, which is against the principle of sustainable development. Therefore there will be little confidence that the Borough can follow through on its idea of a science park.

Even if the proposals for a science park were fruitful, it would again result in yet more vehicles coming along the A6 to access the site from outside and would bring an additional burden to already congested roads and be a contributing factor to the endless development sprawl from Stewartby and Wootton, via Wixams and Wisltead, through to Shortstown and Cardington.

Object

Representation ID: 9630

Received: 26/07/2022

Respondent: Miss Natalie Goldsworthy

Legally compliant? No

Sound? No

Duty to co-operate? No

The Local Plan provides for many allocations designated for employment sites and considering the placement of EMP5, which isn’t supported in the same way as the Little Barford and Kempston Hardwick sites with regards to housing, there is a very realistic chance that this will be redesignated for an alternative use such as housing, which will contravene the proposed policy to ‘avoid coalescence with Wixams and Elstow.’ This will also set a dangerous precedent and will open up the area east of the A6 for further development and will result in urbanisation of the local area. There has also been unsuccessful delivery of site EMP6 which has not moved forward in the last 15 years, so it is unreliable but also further enhances that this is not a suitable development otherwise this would have progressed with some level of success.

The loss of agricultural land will be immensely significant as I understand that the site comprises of Grade 2 agriculture land, which is considered BMV and accordingly to national policy should be protected from significant, inappropriate, and unsustainable development proposals, such as this one. In addition, there is an abundance of wildlife in these areas which will be disrupted and completely lost.

Comment

Representation ID: 9690

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, the site lies to the west of two grade II listed buildings (a barn and 199-200 Wilstead Road). To the north east of the site lies the Elstow Conservation Area, Elstow Manor House (Scheduled), Hillersdon House (grade I), the Church of St Mary and St Helena (grade I) , Church Tower (grade I, Moot Hall (grade II*) as well as many grade II listed buildings. Any development of this site has the potential to impact upon these heritage assets and their settings.
Elstow has a very high concentration of heritage assets and is one of the key jewels in Bedford’s heritage crown. The setting of the Abbey within the meadows, and glimpsed views of the Abbey from the approach into Bedford in this direction are important. Famous for its John Bunyan connections, the village is significant to the heritage of Bedford as a whole.
Elstow is a distinct medieval settlement on the southern side of Bedford, separate from the main built up area and with its own distinct identity and character. This separation is important to its significance.
Development of this scale carries with it the risk of a severe degree of harm to the significance of the important collection of heritage assets at Elstow. We therefore have considerable concerns about employment development at this site and question whether this is the most appropriate location for such a scale of development.
A heritage appraisal has been completed for the site. The appraisal suggests that there will be no impact on these assets from development of the site. However, we disagree with this conclusion.
It is our view that the scale and mass of employment development on the site is indeed likely to impact upon the wider rural setting of the Elstow cluster of heritage assets. The open rural aspect to the south west of Elstow and the rural approach from the south along this corridor, is important to the setting of these assets and would, in our view, be harmed by large scale development on this site. We therefore have concerns about development on this site.
We do appreciate that the policy does include some criteria aimed at protecting the nearby heritage assets (criteria iii, iv, vi, ix and x). However, the fundamental scale of warehousing and distribution could have a negative impact on this setting.
We therefore suggest that consideration is given to restricting the scale (particularly height and mass) of uses on the site in the policy to further protect the highly grade heritage assets to the north east.
We appreciate that an LVA has been prepared but this is really a baseline assessment and does not include wirelines, photomontages or other images. It also does not include a viewpoint from the Abbey and edge of Conservation Area or from the A6, close to the site. We find this document lacking.
Further assessment is needed prior to EiP to demonstrate whether mitigation may be possible or if development would still be harmful. If mitigation would be appropriate, the assessment should explore what this would mean in terms of height, mass, colour etc on this site, particularly in the context of the sensitive heritage setting of Elstow and the wider views to the countryside from the assets and the rural approach into Bedford at this point. If the site is still considered suitable, subject to mitigation, the policy wording should then be amended to establish key design parameters for the site, informed by the further assessment.
We consider that development of this scale would result in harm and that the existing supporting evidence is lacking. Without further evidence as advised above, the allocation is not justified and therefore is not sound.

Comment

Representation ID: 9714

Received: 26/07/2022

Respondent: Historic England

We have raised some concerns about the suitability of this site for employment development.
Further assessment is needed prior to EiP to demonstrate whether mitigation may be possible or if development would still be harmful. If mitigation would be appropriate, the assessment should explore what this would mean in terms of height, mass, colour etc on this site, particularly in the context of the sensitive heritage setting of Elstow and the wider views to the countryside from the assets and the rural approach into Bedford at this point. If the site is still considered suitable, subject to mitigation, the policy wording should then be amended to establish key design parameters for the site, informed by the further assessment.

Object

Representation ID: 9797

Received: 24/07/2022

Respondent: Mr Timothy Harris

Legally compliant? No

Sound? No

Duty to co-operate? No

The EMP5 proposal is totally inappropriate to the historically important village of Elstow. This is a rural village with unique links to John Bunyan Bedfords’s most famous son and
One of the most significant abbeys in the region dating back 10 centuries. For it to remain a place that national and international tourists feel sade and inclined to visit, the move towards urbanisation and industrialisation must cease.
There needs to be clear separation between Elstow village with its listed buildings, historic buildings and green spaces and suburban Bedford.
In particular the height of industrial buildings will impact on the skyline and horizons will be overshadowed from the west curtailing evening light to the village and dominating the skyline in an overbearing presence. Additionally light associated with the workings of any industrial units will affect negatively the dark skies at the Southern half of the village. This is an intangible quality which cannot be restored once taken away.
The linear character of Elstow village, becoming more sparsely populated as one progresses south down the former coaching route would be disrupted by plonking industrial units down there.
Not least would be the damage to wildlife which enjoys a green corridor, essential for uninterrupted transit of wildlife birds and mammals, down the old rural road.
Not to mention the loss of Grade 2 agricultural land. In future decades we need to respect the requirement for food security within our national borders post Brexit. Bedford, England UK cannot lose more good quality effective crop growing land
The impact of noise and disruption during construction and operation of any industrial site will have an unnecessary and severe impact on residents of Elstow who already suffer transport disruption on nearby link roads.
There is significant doubt over the need for this industrial employment site. There is already massive provision next to other main roads nearby and these are by no means full.
The economic argument for the growth of the supposed Oxford to Cambridge Arc is weak and floundering as recognised even by the current government. Post Brext Post pandemic work life is markedly different to economic models made 10+ years ago. So I can see no requirement for this proposed area being used for employment, especially as it is remote and away from basic facilities and infrastructure. Oftentimes these developments tend to have an adverse effect on power and water supply which is another reason to move away from this proposal.
My family has lived in this part of Bedfordshire for over 200 years and 4 generations of my family have attended Elstow Lower School. We do not want to see the essentially rural nature of the parish of Elstow changed. We want the rural nature to be retained, especially the views of Elstow Abbey
So future generations can live in peace and quiet without this unwanted, unjustified and inappropriate development.

Comment

Representation ID: 9844

Received: 28/07/2022

Respondent: Ms Nicola Chapman

I am writing to lodge my concerns regarding the policy EMP5 within the local plan 2040.

The part of Elstow proposed currently has no street lighting and that has been the way the residents have wanted to keep it. By creating this policy there would be a huge amount of lighting within that area. This has the potential to increase anti social behaviour and crime , which is relatively low in this part of Elstow due to the lack of lighting.

The village was bypassed to take traffic away from the village but on a daily basis it is used as a rat run to avoid the traffic jams on the A6. Looking on the maps provided the two access areas are the A6 and the corner of Wilstead Road as you enter the residential area. This corner would be very dangerous and that pathway is used daily by adults and children making their way to schools in Wixams or by Wixams children heading to Bedford Academy. To have lorries potentially coming out of there is an accident waiting to happen. Any cars leaving would certainly head through the village if going towards Bedford resulting in more traffic and pollution. Access from the A6 could have the potential to cause fatal accidents and people turn left off the A421 slip road to head towards Luton to be greeted with a slow moving lorry exiting from the proposed site.

In a village with such heritage and history and with listed buildings within the boundary of the proposed area, this could have damaging effects on the properties with the amount of traffic etc.
Currently this is being used as farm land. Given what is happening in the world and finding that relying on other countries to produce goods can cause major shortages of food or ingredients, surely farm land must be protected from building where possible.

I would urge you to consider removing this policy from your Local Plan.

Comment

Representation ID: 9914

Received: 28/02/2023

Respondent: Anthony Hare

My concern is the unfair focus to build housing south of Bedford and failing to look north of Bedford. We already suffer hugely increased traffic problems which will only increase with more traffic due to increased housing especially in an area such as Elstow having already seen housing triple+ in the past 30+ years, and that is to a village that has greater historic and heritage values than possibly any village in southern England. The housing referred below could easily subsume Elstow into a greater Bedford to simply become a residential ward estate like Putnoe or Goldington or Brickhill or Harper or Cauldwell.
EMP5 - Pear Tree Farm
In a further matter Mr Whitbread confirmed there will be no housing behind the planned Pear Tree Farm employment/science allocation along the A6, the problem is that plans can change given it is titled urban open space.

Comment

Representation ID: 10000

Received: 29/07/2022

Respondent: Michelle Gwyther

I am unable to access the public consultation system and wish to provide my views and ask some questions in relation to the local plan 2040. My views and questions are focused on paragraphs 4.9 and 4.10 and Policy EMP5 – Elstow and Pear Tree Farm.
My comments
1) 4.77 states “The newly opened station at Wixams will support expansion of the established new settlement in proximity to further innovation-based employment provision at Pear Tree Farm. Given the significant delays in the building of the Wixams station and still no guarantee of this being built, why is the Wixams station being given such significance to what happens at Pear Tree Farm? It may well be another 10 – 15 years before this train station comes to fruition.
2) 4.91 states a ‘high value business park with primarily research and development space”. What % of this will be research and development and what percentage will be warehouse and distribution. This percentage should be more explicit. It could be 51% research and 49% warehouse and still be true to be ‘primarily research’.
3) Why is a research and development space being considered when there are so many vacant buildings in the area between Priory Marina and the A421? Why is warehouse and distribution space required when there is significant development on the Wixams sites already?
4) Where is the identified research which states this research and development and warehouse and distribution space is required? Why would a train station be the sole reason for this to be located nearby?
5) Are we clear we can find the people to be employed at these locations given the mass migration of individuals and falling populations and identified in the 2021 census? Can this research also be shared please to state why all of employment sites across the whole local plan is required.
6) EMP5 stated “30% land to be added to Marston Vale”. That benefits Marston Vale but what about the deforestation and loss of hedges in Elstow? There is to be a wildlife survey. This will show a significant Montjac and Chinese Water deer population, stoats in the brook which runs south of Pear Tree Farm, rabbits and foxes. This is without the significant Red Kite population seen above the skies. Where and how will these be relocated and to a location where they can survive? Please don’t say to Marston Vale as that is the only place we will be able to go to in order to see some trees.
If something has to go in this area I would have a preference for housing rather than an industrial estate.

Object

Representation ID: 10024

Received: 29/07/2022

Respondent: Mr Timothy Court

Legally compliant? No

Sound? No

Duty to co-operate? No

This site is not supported by housing and road links (see later comments on congestion) etc like the other proposed sites .at Kempston Hardwick and Little Barford.As such this area will likely be re-designated for housing especially as the plan provides a number of alternative sites for employment. Re-designating this area for housing would then go against the proposed policy to avoid coalescence with Wixams and Elstow.
Th site of this development is on Grade 2 agricultural land which is considered BMV and according to National Policy should be protected from’significant, inappropriate and unsustainable development proposal’
The development site hosts an abundance of wildlife including deer, hare, foxes, owls etc. If the development should go ahead their habitat will be permanently destroyed.
The EMP6 proposal has not progressed in the last 15 years meaning that it is not feasible and therefore supports thatEMP5 is also not a suitable/ feasible proposal.
The EMP5 site will increase noise, light and air pollution in addition to traffic congestion, this will in turn change the character of Elstow from a quiet, rural, historic village into an extension of noisy, urban, industrial Bedford.

Object

Representation ID: 10027

Received: 29/07/2022

Respondent: Mrs Stephanie Court

Legally compliant? No

Sound? No

Duty to co-operate? No

This site is not supported by housing and road links (see later comments on congestion) etc like the other proposed sites .at Kempston Hardwick and Little Barford.As such this area will likely be re-designated for housing especially as the plan provides a number of alternative sites for employment. Re-designating this area for housing would then go against the proposed policy to avoid coalescence with Wixams and Elstow.
Th site of this development is on Grade 2 agricultural land which is considered BMV and according to National Policy should be protected from’significant, inappropriate and unsustainable development proposal’
The development site hosts an abundance of wildlife including deer, hare, foxes, owls etc. If the development should go ahead their habitat will be permanently destroyed.
The EMP6 proposal has not progressed in the last 15 years meaning that it is not feasible and therefore supports thatEMP5 is also not a suitable/ feasible proposal.
The EMP5 site will increase noise, light and air pollution in addition to traffic congestion, this will in turn change the character of Elstow from a quiet, rural, historic village into an extension of noisy, urban, industrial Bedford.

Object

Representation ID: 10038

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Southill Estate owns the land at Pear Tree Farm Elstow, and supports the draft allocation for a science and innovation park and agrees with the policy requirements for the promoted development. The draft allocation is on a smaller parcel of land that is allocated for the same use in the adopted Allocations & Designations Local Plan (Site Ref. AD11 – Land at Medbury Farm). The adopted allocation has already been assessed as sound, and it is proposed that the science and innovation park use is carried forward in PSBLP with a slightly smaller site area. The site is consistent with the spatial strategy and distribution strategy contained in PSBLP, and with the policy for the South of Bedford Area. The site is also consistent with national policy contained in the NPPF, in terms of supporting economic growth, meeting employment needs and the specific needs for high technology industries, the preferred location for strategic development, and accessibility by sustainable modes of transport.

Figure 10 provides the supporting site location plan for Policy EMP 5. An updated Bedford Innovation Campus Indicative Masterplan Document has been prepared for the promoted development at Pear Tree Farm (and the promoted residential development at Abbey Field West of Elstow allocation, also owned by the Southill Estate). The updated Masterplan Document includes a Concept Masterplan for the promoted development. It is requested that Figure 10 is amended to reflect the site area and Concept Masterplan in the updated Masterplan Document. It is amendments to Figure 10 that is the only basis for the Southill Estate’s objection to Policy EMP 5.

The decision to allocate the Pear Tree Farm site has been informed by the Economic Growth Ambitions Topic Paper, and the assessment of the site against selection criteria and constraints in the Employment Land Study Part 2, and the assessment of the site against sustainability objectives in the Sustainability Appraisal Report.

The Economic Growth Ambitions Topic Paper provides information on the ambitions in PSBLP to rebalance the local economy, with less reliance on Class B8 warehouse and distribution uses and an increase in higher value added jobs. The proposed allocation for a high value science and innovation park would meet the ambitions to rebalance the local economy.

The land at Pear Tree Farm (identified as land at Medbury Farm) is assessed against suitability criteria in the Employment Land Study Part 2 – see pg.41. It is recommended in the Study that the site is retained as an employment allocation.

The site was assessed against sustainability objectives in the Sustainability Appraisal Report and Appendices – see SA Appendix pg. 210 to 212. The Southill Estate’s representations to the Sustainability Appraisal comment in more detail on the findings of the assessment, and request changes to the scores for some sustainability objectives. In summary, negative effects are identified for biodiversity and habitats, historic environment, support for physical activity, and previously developed land. Policy EMP 5 includes policy requirements to address impacts on biodiversity and the historic environment and ensure that mitigation measures are provided as part of the promoted development. It is not normal for employment development to include land for recreational activities, but the promoted development would be accessible by walking and cycling and would connect with a green corridor. The identified development needs for PSBLP will require both previously developed land and greenfield sites. The medium and longer term impacts on biodiversity and habitats, and on the historic environment should be changed to neutral or positive because of the policy requirements in Policy EMP 5 for effective mitigation measures to be implemented as part of the promoted development.

A Landscape and Visual Statement has previously been prepared for the site. In summary, the site and surrounding area is a landscape where commercial and industrial buildings are a common feature. The site is visually and physically connected to the A6 junction with the A421. There is dense vegetation on the edge of settlements and around more recent developments to address landscape and visual impacts. It is recommended in the Report that buildings of a similar size and scale to those in the surrounding area could be provided at the site. It should be noted that Policy EMP 5 includes policy requirements for a masterplan and design codes to be submitted with a planning application (criteria i) and for the design of the promoted development to respect local landscape priorities including views of Elstow Abbey and separation from Elstow village (criteria iii). As such, there are policy requirements to assess landscape and visual impacts at planning application stage once more detailed information is provided on the design and layout of the promoted development.

An updated Bedford Innovation Campus Indicative Masterplan Document has been prepared for the promoted development. This confirms that the site’s developers and landowners will continue to work proactively with Bedford Borough Council to bring forward the development of the site for employment purposes. This includes a commitment to meet the emerging policy requirements set out by policy EMP5.

It is requested that Figure 10, which provides the supporting site location plan for Policy EMP 5, is amended to include additional details of the promoted development as contained in the Concept Masterplan in the updated Masterplan Document.

In conclusion, the Southill Estate supports the draft allocation for science and innovation park and agrees with the policy requirements for the promoted development. No changes are required to Policy EMP 5, but Figure 10 could be updated.

Comment

Representation ID: 10169

Received: 29/07/2022

Respondent: Mrs Elsie Hare

My concern is the unfair focus to build housing south of Bedford and failing to look north of Bedford. We already suffer hugely increased traffic problems which will only increase with more traffic due to increased housing especially in an area such as Elstow having already seen housing triple+ in the past 30+ years, and that is to a village that has greater historic and heritage values than possibly any village in southern England. The housing referred below could easily subsume Elstow into a greater Bedford to simply become a residential ward estate like Putnoe or Goldington or Brickhill or Harper or Cauldwell.
EMP5 - Pear Tree Farm
In a further matter Mr Whitbread confirmed there will be no housing behind the planned Pear Tree Farm employment/science allocation along the A6, the problem is that plans can change given it is titled urban open space.

Object

Representation ID: 10282

Received: 29/07/2022

Respondent: Mr Sheldon Reynecke

Legally compliant? No

Sound? No

Duty to co-operate? No

This site is not supported by housing and road links (see later comments on congestion) etc like the other proposed sites .at Kempston Hardwick and Little Barford.As such this area will likely be re-designated for housing especially as the plan provides a number of alternative sites for employment. Re-designating this area for housing would then go against the proposed policy to avoid coalescence with Wixams and Elstow.
Th site of this development is on Grade 2 agricultural land which is considered BMV and according to National Policy should be protected from’significant, inappropriate and unsustainable development proposal’
The development site hosts an abundance of wildlife including deer, hare, foxes, owls etc. If the development should go ahead their habitat will be permanently destroyed.
The EMP6 proposal has not progressed in the last 15 years meaning that it is not feasible and therefore supports thatEMP5 is also not a suitable/ feasible proposal.
The EMP5 site will increase noise, light and air pollution in addition to traffic congestion, this will in turn change the character of Elstow from a quiet, rural, historic village into an extension of noisy, urban, industrial Bedford.

Object

Representation ID: 10305

Received: 29/07/2022

Respondent: Mrs Rachel Reynecke

Legally compliant? No

Sound? No

Duty to co-operate? No

This site is not supported by housing and road links (see later comments on congestion) etc like the other proposed sites .at Kempston Hardwick and Little Barford.As such this area will likely be re-designated for housing especially as the plan provides a number of alternative sites for employment. Re-designating this area for housing would then go against the proposed policy to avoid coalescence with Wixams and Elstow.
Th site of this development is on Grade 2 agricultural land which is considered BMV and according to National Policy should be protected from’significant, inappropriate and unsustainable development proposal’
The development site hosts an abundance of wildlife including deer, hare, foxes, owls etc. If the development should go ahead their habitat will be permanently destroyed.
The EMP6 proposal has not progressed in the last 15 years meaning that it is not feasible and therefore supports thatEMP5 is also not a suitable/ feasible proposal.
The EMP5 site will increase noise, light and air pollution in addition to traffic congestion, this will in turn change the character of Elstow from a quiet, rural, historic village into an extension of noisy, urban, industrial Bedford.

Object

Representation ID: 10307

Received: 29/07/2022

Respondent: Mr Terry Webster

Legally compliant? No

Sound? No

Duty to co-operate? No

The Local Plan provides for many allocations designated for employment sites and considering the placement of EMP5, which isn’t supported in the same way as the Little Barford and Kempston Hardwick sites with regards to housing, there is a very realistic chance that this will be redesignated for an alternative use such as housing, which will contravene the proposed policy to ‘avoid coalescence with Wixams and Elstow.’ This will also set a dangerous precedent and will open up the area east of the A6 for further development and will result in urbanisation of the local area.

There has also been unsuccessful delivery of site EMP6 which has not moved forward in the last 15 years, so it is unreliable but also further enhances that this is not a suitable development otherwise this would have progressed with some level of success.

The loss of agricultural land will be immensely significant as I understand that the site comprises of Grade 2 agriculture land, which is considered BMV and accordingly to national policy should be protected from significant, inappropriate, and unsustainable development proposals, such as this one. In addition, there is an abundance of wildlife in these areas which will be disrupted and completely lost.

Object

Representation ID: 10334

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Elstow has seen change of a massive scale in recent years. There is the development of Progress Way/Hillesden and Abbeyfields estates [which quadrupled the number of residents living in Elstow], the huge Interchange Retail Park, which is expanding further with the B&Q and M&S additions, whilst the access road is nowhere near suitable. The development of the A421 bypass split the village and the construction of the BP station and hotel simply added to the police crime list. There have been a number of infill developments within the village with more in the “pipeline”, including the old school site. There is also the park and ride, the massive Health Care Logistics/Audi complex, in addition to the large retirement complex.

Apart from the re-location of the school to its current site, and increased size, in Abbeyfields, there has been no increase at all in the facilities in the parish as a result of these changes, in fact there's been a decrease following closure of the Swan pub, a middle school, and shop at Peartree View.

There has continued to be significant increases in through traffic and their speed in the village, to the disadvantage of local residents, and clearly this would increase if further development were to come to Elstow or the surrounding area.

Elstow is a rural community, which is vitally important to retain, through securing its rural feel by maintaining a large number of green spaces, such as through strategic gaps between settlements and important views into the surrounding open countryside.

Site EMP5 earmarked for ‘a modern research campus-style development, primarily for research and development with elements of manufacturing, warehousing and distribution’ in terms of local context does not sit naturally alongside a linear rural settlement.

Site HOU5 earmarked for residential use sits a substantial distance from any existing rural settlement, in fact being quite detached from the Elstow community.

Both EMP5 and HOU5 are not sensitive to the local landscape and setting which will be detailed greater below.

Current Local Planning Policy applicable to Elstow

Elstow has always been recognised as being unique in all previous framework and development strategy documents. This is even documented in the Borough Council's planning framework document, Allocation and Designation Local Plan 2013 which in Section 15 deals with the urban area boundary and local gaps. Policy AD42 specifically deals with coalescence between settlements and the importance of local gaps, aiming to prevent ‘coalescence between the urban area and nearby villages'. This 2013 Plan document has not been superseded by the adoption of the more recent Local Plan 2030 strategy framework document, so it is important to be aware of the policy as it is still relevant.

Furthermore, Policy AD42 (Local Gaps) with its supporting text clearly sets out that:
'In this respect local gaps will be protected, not only from development that would lead to a physical joining of settlements, including that which might normally be considered to be

acceptable development in the countryside, but where possible also from an increase in levels of activity which would reduce the distinction between leaving one settlement and arriving in another. This policy takes account of the principle that the essential feature of the gaps can be purely the absence of development and activity rather than necessarily its landscape quality.'

Paragraph 15.9 goes on to also explain that the policy “also takes into account that local gaps are generally narrow and limited in extent such that any development could seriously affect their openness and could be seen as contributing to visual or physical coalescence. The appropriate width of a local gap is likely to be no more than 1 mile (1600 m) in extent and may be much less.”

This is further reinforced by the reference that recognises Elstow

2.37 The settlement of Elstow can be considered in two parts (apart from the area south of the A421 which has been considered earlier in this project as a potential addition to the urban area). The northern part comprises an historic core along the High Street and around Elstow Abbey, together with later areas of housing along West End and at Bunyans Mead on the east side of the High Street. Most of the development in this area is currently within a defined settlement policy area. Open land separates this northern part from other areas of development to the west and east, however to the north it immediately abuts development within the main part of the urban area.

2.38 The southern part, between Elstow Brook and the A421 comprises development which primarily fronts Wilstead Road. This area does not currently have a defined Settlement Policy Area. Open land separates it from other areas of development to the west and east.

2.40 From this analysis, in terms of visual attachment it can be seen that the selected areas within the northern part of Elstow are distinct from the selected area south of Elstow Brook. The northern part is itself varied, with the Bunyans Mead area very similar in density, built form and type of building to the nearby built-up area, with both having a suburban feel. Conversely, the West End and High Street areas are quite different from nearby built-up areas to the north and east. The historic core of north Elstow, around Church End and the High Street retains a village- like character consisting largely of closely spaced individual dwellings in the High Street and a distinctive open character around Church End and Abbey Close. Nevertheless, this is only a small part of the current settlement and overall the northern part of Elstow can be considered to be primarily suburban in character.

2.41 The southern part of Elstow is completely different from the built-up areas to the east in terms of density, built form and type of building. It has a distinctly rural-like feel.

The extracts above show that Elstow manages in its current form to retain its rural nature. Paragraph 2.44 goes on to highlight: Looking at the land use and character of the open land in the northern part of Elstow, to the west the open land is used for agriculture between the Abbeyfields road and the A6. Between Abbeyfields road and the settlement the open land is variously rough grassland, woodland and mown grass. The character therefore changes from being distinctly rural in the west to becoming more managed and enclosed closer to the s ettlement.

Focusing on the policy wording, it would therefore be totally contradictory to place HOU5 in this pocket which is described as being a distinctly rural part of the village.


The AD41 Policy document goes on in Paragraph 2.47 to detail that the southern part of Elstow can be considered to be rural-like in terms of visual attachment. It would therefore be totally contradictory to place EMP5 in this area which is described as being rural and also contains ribbon like development along Wilstead Road which runs alongside the EMP5 site boundary.

During the preparation of the document previously known as Local Plan 2035, which went on to be adopted as the Local Plan 2030, at no point did it include any intended changes to the Urban Area Boundary policy AD41.

Located on Bedford Borough Council's Development Plan documents webpage is a link to the Bedford Borough Local Plan 2030 document that was adopted on 15th January 2020. On Page 189 of the document, it clearly shows that AD41 are current.
SEE ATTACHMENT

development of 34 houses at Village Farm, which is along Wilstead Road. The application was recommended for refusal by Borough Officers. This again re-enforces the supporting planning policy reasons as to why these areas are so important in terms of Elstow's character and history. Below is the extract from the 2015 report prepared by Planning Officers:

The Urban Gap was identified in the Urban Area Boundary Review as a means of preventing coalescence and to contribute to the separate character and identity of the settlement. The quality of the landscape is not considered in the designation of an Urban Gap. Whilst the Urban Area Boundary Review states that the green spaces cannot be considered countryside due to being surrounded by development, it does identify this particular area of Elstow as having a rural-like character, which is contributed to by the historic farm buildings that front onto Wilstead Road. It notes generally that the Urban Gaps in this area provide a separation between the historic core of Elstow village and the more suburban character of more recent surrounding development.
The proposal does not allow for the retention of any green corridor to the northern Urban Open Space, occupying as it does the entire space between the rear of the buildings on Wilstead Road to the west and Elstow School to the east. The proposal includes an area of open space between the southern and northern parcels, but this does not address the reasons for the Urban Open Space and Gap designations. The site assessment that was completed as part of the Allocations and Designations Local Plan acknowledged that the site would represent

development into an open space that provides a buffer against coalescence, a point backed up by the reason for the Urban Open Gap designation. In its present form the proposed development would conflict with the rural “feel” of the area. It would effectively remove the green corridor linking in to urban open space in the north as well as the gap between the suburban development of Abbeyfields and the more rural feel of Wilstead Road and it is considered that this compromises the purpose of the Urban Open Space and Urban Gap. - 83 - Heritage Issues.
Section 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 imposes a statutory duty on LPAs to have special regard to the desirability of preserving listed buildings, their settings and any features of special architectural or historic interest they may possess; and preserving or enhancing the character or appearance of a Conservation Area. Saved Local Plan Policies BE11 (setting of Conservation Areas), BE21 (setting of listed buildings) and Policy CP23 of the Core Strategy reflect those duties. Chapter 12 of the NPPF sets out the Government's national policies on the conservation of the historic environment. The site lies to the southeast of the designated Elstow Conservation Area and the Grade I listed Hillersdon Manor, also a Scheduled Monument. There are numerous listed buildings along Wilstead Road, including Acacia Cottage, Village Farm and curtilage listed barns, 193 Wilstead Road, Merrick Cottage and Lynn Farmhouse, all listed Grade II.
Part of the significance of these listed buildings is their historic interest. The character of the road, including both the settings and contexts of the above heritage assets, is the semi-rural nature of this ribbon development. This road distinguishes the change in character on entering and leaving Elstow Conservation Area. Therefore, the retention of the semi-rural character of this area is important both to the context of the Elstow Conservation Area and the setting of the identified listed buildings.
A development of 34 dwellings on the site would undermine the semi- rural character of this area and would thus create a much more urban setting to the identified listed buildings. The semi-rural setting of Village Farmhouse and associated traditional agricultural buildings is important to the historical development of the original farm complex and further erosion of the setting would be considered harmful to this identified significance. Two access points into the development have been proposed, in particular that adjacent to Village Farm barns has the potential to over formalise this area through the hard landscaping required. This could further undermine the semi-rural character of the settings of the identified barns and Village Farmhouse. The historical significance of the ribbon development pattern along Wilstead Road would also be further undermined by the infill of land to the rear of the properties to the east of Wilstead Road.
The Conservation Officer therefore advises that that the application would fail to preserve or enhance the setting of the identified listed buildings.

The proposed development site is located in an area of cropmarks comprising a number of ring ditches and linear features some of which have been previously investigated both as part of the bypass investigations and also the school to the east. The investigations identified remains of Late Neolithic/Early Bronze Age ring ditches, an Iron Age settlement, and settlement from the Saxon through Medieval period also. In addition to this the HER records the presence of a possible small Quaker burial ground within the site, traces of gravestones are recorded as being visible possibly as late as the 1950s in local newspaper articles.
In conclusion, the proposed built development would result in a significant incursion into the urban open space and gap which would be harmful to the character and appearance of the area. The development would also undermine the semi- rural character of the area and would thus create a much more urban setting which would be detrimental to the setting of the Grade II Listed Buildings at Acacia Cottage, Village Farmhouse and barns, 193 Wilstead Road, Merrick

Cottage and Lynn Farmhouse. It would thus fail to meet the statutory duty under s66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to preserving the setting of listed buildings.

RECOMMENDATION: Refuse Permission for the following reasons:-
1. The proposed built development would result in a significant incursion into the urban open space and gap which would erode the visual break between the historic core of Elstow village and the more suburban character of more recent surrounding development and result in the loss of the green corridor linking in with the urban open space to the north. The development would therefore compromise the purpose of the urban open space and urban gap and be harmful to the character and appearance of the area, contrary to saved Policy BE30 (i) of the Bedford Borough Local Plan 2002; Policy CP21 (iii, vii) of the Core Strategy and Rural Issues Plan 2008; and Policy AD43 (viii, ix) of the Allocations and Designations Plan 2013
2. The proposed development, by virtue of its scale, siting and layout would undermine the semi- rural character of the area and would thus create a much more urban setting which would be detrimental to the setting of the Grade II Listed Buildings at Acacia Cottage, Village Farmhouse and barns, 193 Wilstead Road, Merrick Cottage and Lynn Farmhouse. The development would therefore be contrary to saved policy BE21 of the Bedford Borough Local Plan 2002 and policy CP23 of the Core Strategy and Rural issues Plan 2008.

Summary

This clearly shows that the allocation of HOU5 and EMP5 are in breach of the Borough Council own planning policy, that aspects of Elstow and its immediately surrounding open countryside must be protected in order to retain its character, setting and separate identity.

Whilst the Parish Council have made their desire very clear on multiple occasions to Planning Policy Officers, to see greater protection for all local green and open space areas within Elstow that lay between the various ribbon areas of the village. It is understood that there is no intention for the Urban Area Boundary to be changed that affects Elstow parish, however, policy AD41 makes it clear what a rural community Elstow is.

Also referenced on the above diagram is Policy AD42 which also remains relevant regarding Local Gaps.

The above planning policies remain in situ, valid reasons as why development in Elstow would contravene the existing policies.

SECTION 5: COALESCENCE

The Parish Council can not reiterate how this aspect of the Local Plan as proposed allocations on multiple sides within and adjacent to Elstow are closing in, which bring increased worry over the rural village being totally engulfed. It is fundamental to safeguard the rural historic nature of Elstow that it is does not become lost into Bedford and end up as an urban suburb.

There really needs to be a distinct difference between Elstow village and Bedford (to prevent "coalescence") with the urban town, as well as between the very distinct communities of Elstow, Wilstead, Wixams, Cotton End and also Shortstown so that their historically separate identities are preserved. The potential size of major development would threaten the very heritage of a vil­lage that is described in the Domesday Book.

The existing very stretched parish of Elstow would not tolerate further development on its edges without these developing into separate, isolated, communities in themselves, or necessitating car journeys to the centre. This is a concern to the Parish Council, as well as Elstow residents who have first hand experience of some of the challenges that developing like this already have. It has taken a number of years to integrate Abbeyfields, a new area of the community in with the older part of Elstow village. Growth in the wrong parts of a rural community will be damaging for not just the short term, but also for future generations to come.
SEE ATTACHMENT

Figure 12 Key Diagram, Page 83 in the consultation sets out an overview of proposed develop­ meant for housing and employment sites. It shows a clear distribution of allocations heavily around the area south of the A421 now being defined as the South of Bedford Policy Area. However, the marking of the map again is misleading in how it represents the sites as it places Wixams and Elstow on the section of the map on the same side of the A6.
SEE ATTACHMENT

This is factually incorrect and is inaccurate.

Showing vague, poorly located blobs of roughly where allocations are is not helpful. Having spent more time looking at local policy maps relating to Elstow parish it has shown the clear is­ sue with the allocations EMP5, HOU5, HOU15, HOU16 and HOU17 in terms of coalescence. It has already been raised there is noticeable development closing in on Elstow and looking at the local maps it is really evident, please see below.

The Parish Council feel that there needs to be more done to protect the parishes otherwise it will be one large swathe of development.

Map 8 in Policy 52 Changes to the Policies Map shows the level of coalescence.
SEE ATTACHMENT

This will lead to the areas highlighted by the red arrows which are vulnerable, and them being lost along with the rural village identity of Elstow.

Object

Representation ID: 10341

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

SECTION 8: POLICY HOU5 ABBEY FIELD WEST OF ELSTOW, AND POLICY EMP5 LAND
AT PEAR TREE FARM, ELSTOW

General Issues applicable to both HOU5 and EMP5
The village is an established 'rat run' which is well documented, as traffic comes into the village travelling in huge volumes during peak times. The most popular route is from the A6 travelling in both directions, along Wilstead Road, onto the High Street, then West End, through to the Cow- bridge junction which even after numerous redesigns still suffers from monumental levels of congestion. There is also the Progress Way traffic flows which are significant as a popular route on the local network. The cumulative impact of both these makes highways a real issue in the local area throughout the week.

The popularity of Elstow Primary School attracts pupils from a wide area. It is located in Abbey- fields many travel to the school by car and on regular occasions cars are parked and there is total grid lock at the end of the school day. There has been a number of incidents in recent years involving pedestrians being knocked down. The school has been extended by two additional forms to create a primary school which has resulted in further pressure for parking. Elstow is rightly proud of its local environment, wildlife and heritage assets found throughout the village.

The abundant wildlife along Elstow Brook, in the meadows along Abbeyfields through to its in- famous connection to John Bunyan. The Parish Council have a range of resources evidencing this which all act as further proof that Elstow is a unique parish. To change the setting of these world renowned connections that really are at the centre of Elstow would be devastating.

As mentioned earlier within this response, Elstow sits in a very rich local landscape, any development would impact negatively, in particularly in regards of visual impact. For example any cur- rent open spaces or green areas in the parish, if development were to be sought then it would have a visual intrusion on either the John Bunyan Trail, Cardington Air Sheds or Elstow Abbey. In addition to this, there is the heritage asset of the Medbury medieval village earthworks.

Much work, effort and volunteer time has gone into improving and strengthening the visual appearance of the village. The manicured grass at the Playing Field, the award winning Abbey- fields Roundabout Group with their colourful floral displays, through to the popular tourist attraction destination of Moot Hall. Growth within a community evolves over many years, it is a concern of the Parish Council that if both these sites were allocated then they would not sit naturally in the village setting.

In recent years, Elstow has seen a significant change in the local landscape in terms of flooding and drainage. Reports of issues with watercourses within Elstow have not only become more noticeably frequent but also more wide spread, these have been reported to and followed up by the Internal Drainage Board as well as the Environment Agency. Also there needs to be consideration the different, but exceptionally characterful parts of Elstow which differ greatly. For ex- ample, the area off Wilstead Road, around South Avenue has no street lights, there is a strong sense within that community that if this were to change it would totally alter the setting.

EMP5 LAND AT PEAR TREE FARM, ELSTOW

EMP5 Policy Wording

Types of Employment
Throughout the Local Plan document Bedford Borough Council have draft allocated employment sites with the wording ‘a modern research campus-style development, primarily for research and development with elements of manufacturing, warehousing and distribution’. This is a very generic statement for a number of significant areas of land within the borough. By having made such a sweeping statement of uses (ranging from Use Classes B2 and B8 to Use Class E) enables a site to potentially come forward with any one of those or all of those outlined. Such a large site being used for research and development, differs hugely from such a large site being used for warehousing and distribution, including physical and technical requirements and space together with associated demands and consequences.

Planning policy words that are so broad are subjective, in that if it is not concise and clear on what the purpose of the site is, that it becomes unmanageable at masterplanning and outline planning application stages. What may be intended by Planning Policy Officers in reality is then broadly something quite different, and it is the local residents who have to live with that adverse changes and impact for generations to come.

The evidence within the subsidiary planning policy document (Employment Land Study 1 and 2) of there being a need for such a large site not only at EMP5 but also other sites to take ‘modern research style development’ is weak and imprecise, failing to meet the golden rule, which is that policies should be clear, concise, positive, relevant and capable of being delivered.

Site History
As local authority Officers know, the site known as Medbury Farm within the parish, was allocated in the Allocations and Designations Local Plan 2013 as a 31ha B1 business park. Elstow Parish Council were throughout the Plan consultation phase strongly in objection to this.

It is understood that despite discussions since allocation, no site-wide masterplan was forth- coming, no planning application was ever made and therefore, thankfully no planning permission was issued for this enormous site. Unsurprisingly, yet still very disappointingly, the site was submitted through the ‘Call for Sites’ 2020 process as a potential housing site with capacity up to 1400 dwellings. This has always been a great worry that this site would receive an employment allocation, that was clearly never going to be delivered, to then reappear as a site for housing.

Elstow Parish Council wish to make it abundantly clear that this site which has not in the last twenty years been so much even attempted to be progressed must not be considered for any type of allocation, employment or housing. Not just to the over-riding factors listed previously, also contained within this response, but in addition to the fact this site is clearly undeliverable. The Parish Council were concerned as well that the loss of such a large employment site previously allocated would put pressure on the local authority to meet the required deliver of such land in the immediate and near future.

As a result Officers have found themselves needing to allocate an exceptionally high number of employment sites to meet the lack of the former allocation at Medbury Farm coming forward. It is weak, that the site remains in situ again in the draft Local Plan given the poor history of the site. The effectively ‘lost’ employment allocation from Medbury Farm not being delivered appears to have now resulted in very high numbers of employment sites all being given a generic designation for research use. Surely if the need for such research was rampant in Bedford borough then the Medbury Farm allocation would have been snapped up.

Environment
The sites are best and most versatile (BMV) agricultural land as defined in the NPPF and should be protected from significant, inappropriate or unsustainable development proposals.

Building height
Any structures and associated infrastructure constructed on the proposed sites, particularly large distribution and warehouse units, would have an unacceptable height and scale, be imposing on nearby residential units and prominent within its rural landscape context, particularly given the elevated topography and openness of the land. The proposals would be visually intrusive on the local landscape, harmful to its character and qualities.

There is only some small linear housing settlement on Wilstead Road which would look totally out of keeping with a range of employment buildings, regardless of use.

Transport/Highways
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 Elstow, 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.

The biggest cumulative impact that will be seen within the parish will naturally be around high- ways 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 Cot- ton 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.

Technology advances and changes to industry/Pandemic
There have been a number of changes to how the population now work from home, with fundamental changes to the workplace environment. Is additional formal workspace really required when there are already so many vacant office and employment sites in the borough? There also over time been, as there will be also going forwards, the evolution of technology.

Need/demand
Direct competition with the other nearby allocations including the proposed new settlement and related employment provision at Kempston Hardwick.
In November 2020, there were 68,916 sqm of office units and 90,760 sqm of industrial units available in the Borough. Instead of allocating more ‘strategic road network’ employment sites, the Council should focus on managing and encouraging the development of the 3 already allocated sites, land at Medbury Farm (AD11, land west of B530 (AD17) and Bedford River Valley Park (AD23), totalling 72 ha, where development has not yet started. This would assist in meeting part of the identified additional B-class employment land between 118 and 142 ha.

Whilst the draft allocated site may be in proximity to a junction with the A421, they currently have no direct access to it, nor do they meet the Council’s requirement of being in a location with good access to existing or planned rail stations (para 10.22 of the Employment Land Study May 2022).

Para 10.23 of this study clearly identifies two sites:

“Sites at Broadmead and Kempston Hardwick offer an opportunity to provide a location with particular potential for an innovation hub and business / science campus primarily focussed on innovation, research, development and education in conjunction with significant residential growth centred on a proposed new station as part of East-West Rail in the Stewartby / Kempston Hardwick area.”

No other new sites are recommended in this study.

The EHH (England’s Economic Heartlands, where Bedford is located within) strategy sets out to focus on decarbonisation of the transport system by harnessing innovation and supporting solutions which create green economic opportunities; and promote investment in digital infrastructure as a means of improving connectivity, in order to reduce the need to travel. These proposals contradict this strategy and fail to:

• Support the delivery of low carbon transport by working towards reduced congestion, digital connectivity, and a net zero carbon system by 204027
• Promote connectivity and accessibility in new development, and link new and existing communities
• Support opportunities for active travel and green infrastructure
• Promote and support infrastructure development which reflects the ambitions of the three preceding principles.

Sustainability
Anything from electric charging points, solar panels or enhancement of the cycle and pedestrian routes could be included. Brownfield sites should be considered first before proposing development on greenfield sites. Previously developed land in or immediately adjoining the urban area of Bedford should be utilised in the first instance, with the opportunity to adapt against climate change, rather than encroaching into the open countryside.

Light pollution
The site will be lit and therefore dramatically change the local landscape for the residents in this part of Elstow community which currently have no street lighting and welcome the ‘dark skies’ policy in this rural setting.

Wildlife and habitat
Loss of wildlife, habitat, the wider ecological network, and valuable landscaping (trees and hedgerows), failing to conserve and enhance the natural environment, as required by the NPPF 2021.

S ECTION NINE: MITIGATION MEASURES

The purpose of this section is to outline the Parish Council’s comments, having engaged with parishioners, to understand what mitigation measures would in their opinion be needed. The Parish Council would like to reiterate that these comments are being made without prejudice in terms of Policy EMP5 and HOU5 and should not be taken that the Parish Council support the proposed employment allocation but are following feedback from residents:

POLICY EMP5 LAND AT PEAR TREE FARM, ELSTOW

1. Ensure that Elstow Parish Council takes an active role and is fully engaged and identified as a key stakeholder in the preparation of the Masterplan.
2. Policy amendments to include clear, robust wording within Figure 10 to safeguard the settlements in closest proximity to the development.
3. Policy amendment to include clear identification of protection for the site and growth coming of EMP5 from HOU16 located in close proximity to the south of the site.
4. Traffic management must be robust and measured given the ongoing issues Elstow has with speeding, volume of traffic and the use of the village highways network as a ‘rat run’ with large volumes of congestion stationary for long periods at peak flow times.
5. Environmental considerations include tree/hedgerow planting; creation of wildlife opportunities.
6. Sensitive lighting that recognises the dark sky policy within the southern part of the village.
7. Sensitive operational hours of work recognising the needs of the local community.

8. Community assets created and enhancements to recreational facilities, local amenities, cycle paths, safe footpaths, safe access to the site.
9. Noise control recognising the needs of local residents.
10. Enhancement of PROW and bridleway networks.

Given that the sites’ developments are meant to be in a landscaped setting/environment, a significant proportion of the sites should therefore be identified for meaningful landscaping and enhanced opportunities for biodiversity net gain (beyond the minimum requirement of 10%).