Policy HOU19 Little Barford New Settlement

Support

Representation ID: 9127

Received: 19/07/2022

Respondent: Sir Graham Fry

Assuming that the new E-W station will be built, this seems the least bad option for new housing, but:-
a) it needs to be tied in with an integrated plan for the future development of St Neots involving all the local authorities involved;
b) given its proximity to the river, the conditions relating to biodiversity are crucial. The developers/Council should obtain input from eg the Wildlife Trust so that nature is planned in from the outset not as an add-on.

Comment

Representation ID: 9129

Received: 20/07/2022

Respondent: South Cambridgeshire District Council

We consider it unlikely that the Plan as proposed would have direct impacts on Cambridge and South Cambridgeshire.
Notwithstanding, we note that the sustainability performance of this site is dependent on delivery of East West Rail. We note the relatively early stage of development of the East West Rail Bedford to Cambridge section project. We would be concerned about the transport and wider carbon impacts of locating a new settlement at Little Barford should development come forward ahead of an East West Rail station, or in the event that East West Rail was not delivered.

Comment

Representation ID: 9259

Received: 27/07/2022

Respondent: Mrs Alison Myers

The diagram for allocation of development is unacceptable. The development should be highly sensitive to the River `Great Ouse and be aware of the impact in long distance views.
The Design Code will be critical but this allocation is premature in view of EW Rail uncertainties.

Object

Representation ID: 9315

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investment LLP

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

The Local Plan is not legally complaint owing to failure to comply with the duty to co-operate and fails to meet the tests of soundness. The Council has not co-operated effectively with neighbouring authorities regarding strategic cross-boundary impacts of the proposed new settlement at Little Barford; the supporting evidence (New Settlements Assessment and Sustainability Appraisal) is inconsistent in its approach and does not represent a suitable, fair and objective assessment of the spatial strategy options; and the transport evidence (BBTM) is inconsistent with national policy, with serious concerns over the application of the BBTM results to the site selection process.

Object

Representation ID: 9320

Received: 28/07/2022

Respondent: i-Transport LLP on behalf of Martin Grant Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

MGH does not object to the principle of development at Little Barford but has concerns that the evidence underpinning the identified allocation is lacking. There is a need to demonstrate any allocation can come forward without or with EWR and supporting evidence must appropriately and robustly demonstrate the transport impact of an allocation here, and any sustainable transport strategy underpinning it, can function both without and with EWR and not to the detriment of the A428 corridor further east. This Reg 19 Plan does not provide this information and thus, MGH consider allocation HOU19 premature.

Comment

Representation ID: 9377

Received: 29/07/2022

Respondent: Huntingdonshire District Council

Huntingdonshire District Council (HDC) have several observations and points of concern relating to the proposed Little Barford new settlement, HDC’s response sets out detailed comments regarding:
1. Preparation of a strategic masterplan and design code SPD
2. Strategic transport infrastructure connectivity and delivery
3. Timing of housing delivery
4. Proposed land uses
5. Contingency land
6. Potential impacts on St Neots and infrastructure provision, in particular relating to landscape and physical impact; flooding and water impact; impact on local community facilities and infrastructure; impact on transport and travel
7. Nutrient neutrality

Object

Representation ID: 9438

Received: 29/07/2022

Respondent: Prologis

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Please see attached report

Comment

Representation ID: 9479

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.

Comment

Representation ID: 9568

Received: 20/08/2022

Respondent: Cambridgeshire County Council

Regarding the proposal for a 4,000-dwelling settlement at Little Barford (Policy HOU19)

It is noted that the proposed settlement is close to the Cambridgeshire border and the town of St Neots. Whilst we are pleased to see the inclusion of serviced sites for secondary and primary schools (including Early Years Provision), we note that there is no such reference within the Policy or the supporting documentation (Education Implications paper and the Infrastructure Delivery Plan) to a special school. We would expect a development of this size to generate demand for SEND places. Whilst we are aware there are plans to provide a new special school in Bedford, should the Little Barford settlement provide no special school places, the Samuel Pepys Special School in St Neots will remain the closest provision to the Little Barford settlement. This is likely to put additional pressure on place provision on services covered within Cambridgeshire where Cambridgeshire County Council do not have the capacity to cater for this additional development. Therefore, Cambridgeshire County Council request that the local planning authority provide evidence to demonstrate how the demand for SEND places from the Little Barford new settlement will be mitigated.”

Object

Representation ID: 9595

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

• U&C acknowledge and have no objection to the inclusion of allocations, focused upon the existing urban areas, where impacts and mitigation can be addressed largely within the bounds of the Borough. These allocations are therefore capable of being proven to be deliverable within the terms of the NPPF. The new settlement allocations are not, however, capable of being regarded as deliverable, having been assessed as the most sustainable option for longer term growth and allocated on the basis that they have potential to be served by East-West Rail. The Infrastructure Delivery Plan indicates that East-West Rail is


an infrastructure project which ‘is required’ over the Local Plan 2040 period, to meet the needs arising from planned growth (IDP, paragraph 7.2.1). It is not a nice to have. Yet, the new settlements are
allocated without any policy controls upon the timing or phasing of development relative to infrastructure and are not contingent upon the delivery of East-West Rail or other significant
infrastructure. Without such obligations, the Policy allows for development in advance of or even without the firm commitment of East West Rail or other significant infrastructure. Delivery without this infrastructure would make the new settlements location far less sustainable and would not be justified by the evidence base as it stands.

• Furthermore, the new settlement allocations are made without any consideration for the implications or the likely scale and location of development within close proximity, but outwith the Bedford Borough boundary. This includes, but is not confined to, additional development proposed along the A421 (for example options emerging through the South Cambridgeshire Local Plan) and in immediate proximity to Little Barford, at Tempsford. Tempsford is a highly sustainable location for substantial growth, which will be considered through early plan review in Central Bedfordshire.

Comment

Representation ID: 9691

Received: 26/07/2022

Respondent: Historic England

There are a number of designated heritage assets within the site boundary including St Denys Church (grade II*), Lower Farmhouse, a barn north of Lower Farm Farmhouse, and 1-4 – a row of cottages, all listed at grade II. There are also a number of other grade II buildings nearby, notably across the River Great Ouse. Any development of this site has the potential to impact upon these heritage assets and their settings.
New Manor House lies within the site boundary. Although not currently listed, this is an interesting building, dating from the 19th century.
There are extensive earthworks across the central part of the site comprising a complex, intact, good quality medieval landscape, largely untouched, including a Deserted Medieval Village and Ridge and Furrow.
A heritage impact assessment has been prepared for this site. An Archaeology DBA has also undertaken which are welcome.
The HIA and DBA reveal that there are extensive earthworks, a rich palimpsest and good quality medieval landscape in the central portion of the site. There is also an unlisted Manor House and associated buildings within the site boundary.
We do therefore have concerns about the potential impact of development on the historic environment in this area. We need a better understanding of its significance in order to make the judgement.
We note that the Historic Environment Topic Paper concurs that there is insufficient information, particularly in relation to archaeology and therefore suggests a detailed HIA to inform the masterplan. But in Historic England’s view, that would be too late. The principle of development would already have been established.
Historic England therefore strongly advise that further assessment of this area is required now to better understand the significance of this landscape.
We will also asking Historic England’s designation team to investigate whether parts of the site should be scheduled and whether the Manor House and associated buildings should be listed.
Depending on the findings of these assessments, this may affect the developable area and thus capacity of the site.
Significant further work is necessary now before progressing the site to EiP. Without the further evidence to support the allocation, the allocation is not justified and fails the test of soundness.
We strongly suggest an early meeting between BBC and Historic England to explore this issue in more detail. Notwithstanding this need for additional evidence, if upon further assessment, the site is found to be broadly suitable for development as a new settlement, the HIA makes a number of recommendations in relation to mitigation for heritage assets (broadly based on an illustrative masterplan) including:
• Retention of existing woodland and planting
• Retain open and green setting by Church of St Denys and the New Manor House
• Retain open area to the west of Lower Farm
• View corridors adjacent to heritage assets on east of Barford Road with open space to the south east
• Use local materials to create attractive and distinctive places where views of the surrounding rural context area maintained
• Careful masterplanning, and consideration of design, scale and built form
• Open space and woodland retained around former Council school
These measures are a helpful starting point in setting some of the important heritage parameters for the site but will need to be further refined in light of the findings of the additional assessment.
However, these recommendations are not currently set out in the policy or on the concept diagram. Also, the main heritage assets on site are not listed in the policy. The policy and diagram should be amended to incorporate these recommendations (and any others identified) and reference to the designated heritage assets.

Comment

Representation ID: 9715

Received: 26/07/2022

Respondent: Historic England

We have considerable concerns about the suitability of parts of this site for development.
Further assessment of this area is required prior to EiP to better understand the significance of this landscape.
We will also be asking Historic England’s designation team to investigate whether parts of the site should be scheduled and whether the Manor House and
associated buildings should be listed.
If, following further assessment, the site is found to be broadly suitable, the policy should be amended to incorporate reference to specific heritage assets. The
various heritage mitigation and enhancement recommendations for the site (identified in the HIA and further assessment) should also be included in the
policy wording. (see table for details). The diagram should also be amended to incorporate these recommendations.
Without this further evidence these allocations are not justified and so are not sound.

Comment

Representation ID: 9734

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.

Comment

Representation ID: 9870

Received: 28/07/2022

Respondent: Cambridgeshire County Council

The Council acknowledges the proximity of the proposed allocation at Little Barford to the town of St Neots in the district of Huntingdonshire, Cambridgeshire and would therefore like to make the following comments.

The County Council acknowledges the very early stage of the East West Rail Bedford to Cambridge section project and the reliance placed upon its delivery for the proposed allocation at Little Barford. The modelling for the Bedford Borough Local Plan is reasonable but there is an assumption that EWR will be in by the proposed future year horizon. The proposed allocation also appears to be reliant on the delivery of improvements to the A428 between Caxton Gibbet and the Black Cat junction. The Council is concerned about the transport, environmental and climate impacts of locating a new settlement at Little Barford, including from potential increased traffic on the A428 in Huntingdonshire and Greater Cambridge, should development come forward ahead of an East West Rail station, or in the event that East West Rail was not delivered. The Council would like to see an increased focus on active travel and low carbon transport in the new settlement, particularly for links into St Neots and Huntingdonshire. This would contribute towards the achievement of net zero carbon.

The Council would like to work with Bedford Borough Council regarding the proposed allocation of Little Barford regarding the impacts and any mitigation on the transport network in Cambridgeshire, particularly around St Neots. The Council is currently developing on an Active Travel Strategy for Cambridgeshire and this should be taken into consideration for active travel links into Cambridgeshire.

Object

Representation ID: 10139

Received: 29/07/2022

Respondent: Roebuck Land and Planning

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Figure 11: Little Barford New Settlement
The Figure 11: Little Barford New Settlement plan is inappropriate and confusing. The Council should replace the developer led plan with its own plan for consistency with the other proposed allocations (Figures 6-10) and to remove the elements that are not yet been tested such as the access options across the mainline and expressly, the land shown shaded blue that is labelled ‘contingency land’. This contingency land is not referenced within the policy text and is not part of the proposed allocation defined on the Policies Map. It is also land that would be severed by the realigned A428 and it has not been subject to any SA process within the current evidence base.

Object

Representation ID: 10143

Received: 29/07/2022

Respondent: Roebuck Land and Planning

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Policy HOU19 ‘Little Barford New Settlement’
The policy states:
“… land at Little Barford is allocated as a new settlement to create a landscape led beautiful, healthy and sociable community located in close proximity to the proposal for a new station on the East West Rail line delivering at least 4,000 new homes and in the region of 4 hectares employment.”
The policy is not capable of being implemented if this line is not delivered. In particular, Limb xix would be impossible to meet should the route or new station not materialise.
The justification for this policy is wholly reliant on the EWR scheme but does not include any safeguarded route based on the latest information. The Preferred Route Corridor E option should at the very least be referenced in the Draft Plan and the land safeguarded if it is to be advanced/adopted before the EWR scheme has progressed to a detailed stage. The extent of the search area within Route Corridor E is not acknowledged (it includes the entire site). Within this corridor, the latest non-statutory consultation held in June 2021 identified five potential route alignments and 4 potential station locations which have an impact upon the future masterplanning of HOU19. The proposed trajectory is not reliable, and it is difficult to see how any masterplan framework could be approved before the EWR scheme has proceeded to/through its DCO process which is several years away.
It demonstrates the fact that it is not possible to evidence that the proposed quantum of development can be achieved within the allocation boundary or delivered within the plan period.
[See attachment for insert.]
Whilst a non-statutory consultation, EWR did consult on two Preferred Route Alignments 1 and 9 which are reproduced below. Both would have different, but significant impacts upon the land available for development, general connectivity and the ability to deliver multiple road crossings over/under the existing east coast mainline track and any proposed EWR track to create internal connections within the proposed allocation to create an integrated new community.
[See attachment for 2 inserts.]
These extracts highlight that the section affecting the proposed allocation HOU19 is not yet crystallised and is dependent upon the selection of one of the potential preferred options of one of the two St Neots South station locations (St Neots Option A) over one of the long standing Tempsford options further south (Tempsford Option A). The final strategy or any other option/alignment that may need to be considered is subject to further investigation, surveys and consultation before the detailed DCO application can be made.
The future route alignment around St Neots is also heavily dependent upon the location of the proposed new Cambourne rail station further northeast within South Cambridgeshire District. Again, the link between either of the two St Neots based options versus the two Cambourne based options further east (Cambourne North or Cambourne west) directly affect the position of any rail line across the proposed allocation.
As the output of the second non-statutory consultation is currently under review, EWR is not yet able to confirm the date for the announcement of the final route or future programme. The project timetable has already slipped considerably.
The above diagrams illustrate the dramatic impact that all of the current route options may have upon future development considerations around Little Barford. Based on the current programme for the replacement BLP, and the Council’s stated urgency to submit a plan by January 2023, a future review of the emerging BBC local plan (i.e. beyond 2040) may be a more realistic timeframe for considering rail based growth in this location – i.e. once the parameters are confirmed.
A428 Black Cat to Caxton Gibbet Improvement Scheme
In relation to the A428 improvements, these are still at Inquiry, with a decision expected in August from the Secretary of State, which should be available at the examination of this Local Plan, providing more certainty in the delivery of this scheme. At the recent examination it was suggested that delivery of the scheme is currently approximately one year late due to the pandemic etc and as such it is likely to open in 2025/2026.
The plan in general, and Policy HOU19 does not reflect the A428 Black Cat to Caxton Gibbet Improvement scheme. The eastern boundary of the proposed allocation HOU19 should be shown as the safeguarded route and impacts considered on the extent of land available for development. The section that lies within the proposed allocation is reproduced below for ease.
[See attachment for insert.]
Should the DCO be approved (decision due by 18 August 2022) this includes Compulsory Purchase Powers to permanently take land for the scheme along with temporary land take for a given period of time. It further demonstrates that it is unlikely that all of the proposed allocation is available, or deliverable and this land should be excluded and the scale of development adjusted accordingly. We consider the any part of the route that falls within Bedford Borough boundary is shown as safeguarded within the policy map, potentially supported by a specific policy.
It is also of relevance that the A428 scheme will not include a road link connection onto the Barford Road where it crosses – DCO extract below.
[See attachment for insert.]
There is no opportunity for a direct connection onto the new A428 carriageway for vehicular movements from either the eastern or western half of the development which would all need to link back to the existing A428, adding a significant amount onto the local rural road network. This constraint is illustrated by reference to Figure 2.3 – Assumed Little Barford Development Highway Network within the Aecom Bedford Borough Transport Model – reproduced for ease below.
[See attachment for insert.]
Given the allocation is predicated on ‘rail based growth’ the EWR route options are not indicated. Should the either of the preferred routes mentioned above be taken forward, the impact of the new rail infrastructure on the model assumptions has not been undertaken. The proposed single rail crossing is a challenge and lacks connectivity and permeability within the new settlement proposal.

Object

Representation ID: 10232

Received: 29/07/2022

Respondent: Taylor Wimpey

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? No

TW object to the allocation of Little Barford under policy HOU19. The site is undeliverable and undevelopable in the 2040 Plan period, as it is reliant on key rail infrastructure which does not even exist and is unlikely to by 2030. The site has considerable environmental and physical constraints in any event, and further, until the route of the EWR is consented, it is impossible to masterplan the site to determine whether or not the required 4,000 (3,800 in the plan period) can actually be realised within the allocation. In addition, severance and connectivity is severely compromised resulting in serious concerns as to whether a cohesive, well planned, well connected community can actually be achieved on the site.
Please see attached representations…specifically section 3 paragraphs 3.1-3.28, paragraph 5.6 bullet 4, section 6, Appendices A,B,C.

Object

Representation ID: 10266

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

HOU19 - Land at Little Barford
10.22 Central Bedfordshire Council objects to this allocation on the basis of our transport concerns as detailed above.
10.23 Little Barford is proposed in the Submission Local Plan for a new settlement, delivering at least 4,000 new homes, approximately 3,800 of which would be within the plan period to 2040, and around 4ha of employment land. The draft policy suggests that the new settlement will be a community located in close proximity to the proposal for a new station on the East West Rail line and that it will provide all the key services and facilities to address its own needs, including health, education, retail, culture and community components.
10.24 This proposed allocation is particularly reliant on new strategic infrastructure that is outside of the authority’s control, including a new junction on the realigned A428 (not in the scheme currently subject to the DCO process) and a new EWR station, neither of which have a high enough level of certainty in our view to be included in a core transport modelling scenario at this stage. Given the levels of uncertainty surrounding significant infrastructure requirements associated with the proposed allocation, Central Bedfordshire has concerns about the overall sustainability of the proposals and would seek clarification as to whether the proposals could still be delivered without a new junction of the A428 and / or if the proposals for a new EWR station do not materialise within necessary timeframes.
10.25 Furthermore, a site of this size and scale in this location should also be identifying and delivering a specific mitigation strategy for the A1 junctions in the vicinity due to the likely implicatins for communities along the A1 corridor. We would also suggest, if the scheme is taken forward, that the design of the Barford Road bridge currently forming part of the package of works for the A428 scheme could benefit the site if the design was revisited in discussion with National Highways to allow for walking and cycling, to futher enhance the ‘accessible’ section of policy HOU19.
10.26 Given the above, and our detailed concerns set out in our review of the supporting transport modelling in sections 4 to 8 above, Central Bedfordshire cannot support this proposed allocation.

Comment

Representation ID: 10286

Received: 29/07/2022

Respondent: Roxton Parish Council

Section 4.96 – Development at Little Barford:
Without safeguards to prevent the proposed 2 x new primary schools and 1 x Secondary School taking pupils away from Roxton Primary School RPC object to this aspect of policy HOU19. By way of background the report states that there is a lack of capacity in local schools but according to the Headteacher of Roxton Primary School they are at only at 50% Capacity.
Should policy HOU19 become adopted RPC request any masterplan for the development should be environmental and landscape lead with particular emphasis on delivering linkage beyond the boundary of the allocation site to existing bridleways, cycle paths and walking routes to ensure sustainable modes of linking up to other local villages such as Roxton.

Support

Representation ID: 10302

Received: 29/07/2022

Respondent: Natural England

Policy HOU19: Little Barford New Settlement
Natural England notes the inclusion of the policy principle which states that a “biodiversity study with appropriate mitigation and enhancements” will need be required. As this allocation policy is situated approximately 14km away from Eversden & Wimpole Woods SAC, we welcome this commitment, as the SAC is designated for its Barbastelle bat (Barbastella barbastellus) interest, which can have a foraging range of up to 20km.

Support

Representation ID: 10409

Received: 29/07/2022

Respondent: The Executors of the late Nigel Alington

Agent: Code Development Planners Ltd

These representations have been prepared by CODE Development Planners on behalf of the Executors
of the late Nigel Alington in relation to the policies and evidence base of the regulation 19 Bedford
Borough Local Plan 2040 (BBLP 2040).
2 Proposals being promoted
2.1 The Alington Estate, Little Barford is proposed for allocation under Policy HOU19 of the BBLP 2040 for
a new settlement to delivery at least 4,000 new homes and in the region of 4ha of employment land.
The policy also identifies, inter alia, “walkable neighbourhoods which will enable residents to meet the
majority of their day to day needs locally” and “the new settlement will provide a range of community
services and facilities including health, education, retail, culture, community meeting spaces,
multifunctional open space and sports and leisure facilities.” However, there is no corresponding
recognition within Policy TC1(S) and paragraph 5.7 that the new settlement will create a local centre
and neighbourhood centres.
2.2 The Town Centres and Shopping Policies Topic Paper, April 2022 refers to the types of centres
(para 2.3). It states, “Local centres include a range of small shops of a local nature, serving a small
catchment. Typically, local centres might include, amongst other shops, a small supermarket, a
newsagent, a sub-post office and a pharmacy. Other facilities could include a hot-food takeaway and
launderette. In rural areas, large villages may perform the role of a local centre.” We recognise that until
a masterplan has been progressed for the new settlement at Little Barford the location and extend of
the local centre within it will not be spatially defined. However, the effective delivery of the ‘placemaking’,
‘accessible’ and ‘prosperous’ elements of Policy HOU19 would be enhanced by the inclusion of Little
Barford as a “Local Centre: Key Service Centre” within policy TC1(S) and an additional bullet point
within Policy HOU19.
Although Wixams is not a direct comparable, wording in paragraph 5.7 of the BBLP 2040 states,
“Wixams new settlement is identified as a potential Key Service Centre as, over the course of the plan
period, the planned town centre will be constructed and, once completed, will serve the settlement . . .”
It would seem reasonable that similar wording should be inserted into the policy in recognition of Little
Barford’s allocation as a new settlement.
2.4 The urban area of St Neots, Huntingdonshire is within 0.5 miles of the northern boundary of the Little
Barford New Settlement boundary. St Neots has been identified within the Huntingdonshire Local Plan
to 2036 as one of four spatial planning areas. This designation is the highest order settlement and
reflects St Neots’ status as a traditional market town and as one of the most sustainable centres for
development1.
2.5 The relative positions of St Neots and Little Barford within the settlement hierarchy, with St Neots
categorised as the equivalent of a strategic or district centre and Little Barford as a local centre: key
service centre (policy TC1(S)) recognises that whist the day to day needs of the residents of the new
settlement of Little Barford will be provided on site, residents would travel beyond the new settlement
for access to higher order facilities. The proximity of the two settlements to one another enables such
journeys to be made by sustainable and active modes of travel.
2.6 Identifying Little Barford within the settlement hierarchy, with St Neots designated in a higher tier of
settlement, protects St Neots from competition from Little Barford whilst recognising that there will be a
relationship between the two.

Support

Representation ID: 10410

Received: 29/07/2022

Respondent: The Executors of the late Nigel Alington

Agent: Code Development Planners Ltd

These representations and the accompanying technical documents demonstrate that land within the
control of the Alington Estate, Little Barford can deliver a new settlement of at least 4,000 new homes,
circa 4ha of employment land and associated infrastructure. Therefore, in broad terms Policy HOU19
Little Barford New Settlement is supported.
1.3 These representations are accompanied and supported by the following technical documents:
 Representations to the Regulation 19 BBLP 2040 in relation to Policy TC1(S) and associated
paragraphs, and paragraphs 4.12-4.13 and Table 2 of the BBLP 2040, and the Sustainability
Appraisal, April 2022;
 Drawing 068-001-014 Rev A: Areas available for allocation, March 2022 prepared by CODE
Development Planners;
 Drawing 60830-PP-500 B: Highway Access and Development Parcels – New Settlement (BBLP
2040 Reg 19 – HOU19);
 Preliminary Ecological Appraisal, September 2021 (issue 3) prepared by Southern Ecological
Solutions [land west of East Coast Mainline];
 Preliminary Ecological Appraisal, July 2022 prepared by Southern Ecological Solutions [land east
of East Coast Mainline line and west of A428 improvement];
 Botany Assessment of Grassland Component of Little Barford CWS, September 2021 (issue 2)
prepared by Southern Ecological Solutions;
 Botany Assessment of RWE Buffer, September 2021 (issue 3) prepared by Southern Ecological
Solutions;
 Transport Assessment, September 2021 prepared by Richard Jackson Ltd incorporating the
following:
Drawing 60830-PP-014A: Sustainable travel options plan [although this drawing is embedded
in the 2021 TA it has been superseded by drawing 60830-PP-018);
- Drawing 60830-PP-017: Proposed A428 grade separated junction location;
- Drawing 60830-S-004: Bridge at section 2 general arrangements and typical details;
- Drawing 60830-S-005: Bridge at section 9 general arrangements and typical details;
- Sustainable Transportation Technical Note, September 2021;
 Sustainable Transportation Technical Note Revision A, April 2022 prepared by Richard
Jackson Ltd
 Drawing 60830-PP-018: Little Barford Sustainable Travel Strategy, April 2022 prepared by Richard
Jackson Ltd
 Transport Technical Note, July 2022 prepared by WSP
 Site Specific Flood Risk Assessment (FRA), June 2021 (revision A) prepared by Richard
Jackson Ltd;
 Surface Water Strategy, August 2021 prepared by Richard Jackson Ltd incorporating the following:
- Drawing 60830-PP-200: Surface water strategy (sheet 1 of 5);
- Drawing 60830-PP-201: Surface water strategy (sheet 2 of 5);
- Drawing 60830-PP-202: Surface water strategy (sheet 3 of 5);
- Drawing 60830-PP-203: Surface water strategy (sheet 4 of 5);
- Drawing 60830-PP-204: Surface water strategy (sheet 5 of 5);
 Services Technical Note, September 2021 prepared by Richard Jackson Ltd incorporating the
following;
- Drawing 60830-PP-100A: Existing service records (sheet 1 of 5);
- Drawing 60830-PP-101A: Existing service records (sheet 2 of 5);
- Drawing 60830-PP-102: Existing service records (sheet 3 of 5);
- Drawing 60830-PP-103: Existing service records (sheet 4 of 5);
- Drawing 60830-PP-104: Existing service records (sheet 5 of 5);
 Tree Constraints Report, December 2021 (revision C) prepared by Southern Ecological Solutions
incorporating the following:
- Tree Survey Schedule;
- Tree Survey and Constraints Plan;
 Heritage Impact Assessment, October 2021 prepared by Bidwells’ Heritage;
 Archaeological Desk Based Assessment, December 2021 prepared by HCUK Group;
 Landscape and Visual Position Statement, October 2021 prepared by Fabrik;
 Drawing 60830-PP-502A Mineral Extraction Constraints Plan prepared by Richard Jackson Ltd;
 Noise and Vibration Constraints Technical Note, July 2022 prepared by WSP;
 Education Review, July 2022 prepared by Educational Facilities Management Partnership Limited

Proposals being promoted
2.1 The Alington Estate – Little Barford is in a single ownership and totals 453ha. It comprises 309ha that
will form site allocation HOU19, two areas of contingency land (one of 88ha and another of 28ha) and
land included as part of the A428 Black Cat to Caxton Gibbet improvement (circa 28ha). The
contingency land is available in the event that i) the route alignment chosen for East West Rail (EWR)
impacts on the delivery of elements of Policy HOU19; and/or ii) additional land is required for
biodiversity net gain, multifunctional green space or carbon off-setting. Drawing 60830-PP-500B
identifies that not all land is proposed for built development.
2.2 Based on technical assessments undertaken to date (the scope of which is considered proportionate
to this stage of the preparation of the BBLP-2040) the new settlement proposal is capable of delivering
at least 4,000 new homes and in the region of 4ha of employment land. A capacity study will be
submitted at an appropriate stage in the preparation of the BBLP 2040.
2.3 The achievement of this quantum of development has assumed the following:
 retention of listed buildings;
 settings of listed buildings to be defined to avoid ‘substantial harm’;
 no residential or employment development within fluvial flood zones 2 and 3;
 except for the area immediately south of the gas power station (required for bridge crossing the
ECM railway) retention of existing woodlands and belts of trees;
 no development within the County Wildlife Site (CWS);
 no development within easement of 100kv (or greater) high voltage overhead powerlines and
associated pylons;
 storage areas for surface water drainage detention basins currently calculated on a worst case
scenario based on desk based soil assessment;
 multifunctional recreational open space will include, inter alia, areas constrained by the high
pressure gas mains, and high voltage overhead power cables and will encourage healthy lifestyles
through the provision of safe routes to schools for walking and cycling in combination with green
corridors for wildlife;
 the definition of formal recreational open space provision is wider than the narrow definition of
playing pitches and can include trim trails etc (refer to Sport England’s Strategic Outcomes
Planning Guidance, 2019);
 an average residential density of 30-35 dwellings per hectare.
 no development within the inner and middle HSE zones of the high pressure gas main on the east
side of the ECM railway;
 education provision to serve the needs of the new settlement;
 on site provision of schools will share facilities (eg hall, playing fields etc) with the community;
 a site for a supermarket/convenience food retail store (2ha);
facilities commensurate with designation as “local centre: key service centre” and neighbourhood
centres under Policy TC1(S) of the BBLP 2040 and the Town Centres and Shopping Policies Topic
Paper, April 2022;
 subject to arboriculture constraints and livestock considerations, a continuous leisure route
adjacent to the River Great Ouse could be delivered on land within the control of the Alington Estate
(opportunities to create circular loops off this riverside leisure route to connect with St Deny’s
Church could be considered as further assessments are undertaken);
 development on the east side of the ECM railway, greater than circa 300 homes will require a
second point of access.
3 Approach to site capacity
3.1 Technical assessments have established a net developable area, with a full capacity study to be
submitted at an appropriate stage in the preparation of the BBLP 2040. However, a cautious approach
to assessing the dwelling capacity of the site has been taken. We have already netted out from the site
area the following features:
 flood zones 2 and 3;
 CWS;
 existing woodlands;
 areas constrained by high pressure gas mains;
 high voltage overhead electricity cables and associated pylons;
 surface water detention basins;
 schools; and
 a site for a convenience food store.
3.2 In addition to the above, assessments are on-going in relation to two areas to the east of the Barford
Road close to the existing settlement of Little Barford, to determine the extent of the areas within them
that could accommodate development without having an unacceptable effect on heritage assets. Again,
following a cautious approach these areas have, for the purpose of testing the capacity of the site to
deliver new homes, been excluded from the current net developable area. Subject to the conclusions
of the assessments we anticipate further areas to contribute to the provision of new homes.
3.3 Although further reductions to the net developable area are anticipated from the following, a generic
allowance has been made for these by applying a ratio for those elements that are accepted as being
included in and excluded from a ‘net site area’:
 community facilities and local services (in addition to the previously assumed food store);
 bridge structures;
 noise buffers (ECM railway, A428 improvement and gas power plant); and
 biodiversity net gain.
The Executors of the late Nigel Alington
Alington Estate, Little Barford – Representations to Regulation 19 of the BBLP 2040
29 July 2022
Page 5 of 11
3.4 Due to the ratio applied (whilst already having netted out the items in paragraph 3.1 above), it is likely
that the number of new homes achievable from the Little Barford new settlement will increase once a
capacity study and associated masterplan have been prepared. Such an approach provides confidence
at this stage in the preparation of the BBLP 2040 that allocations for at least 4,000 new homes, 4ha of
employment land and the necessary supporting social infrastructure is deliverable. Housing trajectories
will be provided at an appropriate stage in the preparation of the BBLP 2040.
4 Soundness of policy HOU19
4.1 Paragraph 35 of the National Planning Policy Framework (NPPF) states that, “Local plans and spatial
development strategies are examined to assess whether they have been prepared in accordance with
legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s
objectively assessed needs, and is informed by agreements with other authorities, so that unmet
need from neighbouring areas is accommodated where it is practical to do so and is consistent
with achieving sustainable development.
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on
proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on crossboundary
strategic matters that have been dealt with rather than deferred, as evidenced by the
statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustainable development in
accordance with the policies in this Framework.”
4.2 We contend that in broad terms the current wording of Policy HOU19 is sound, however the following
sections consider various elements of the policy wording to assess its robustness in relation to the tests
of soundness but also in relation to its ability to inform and guide a planning application.
5 East West Rail
5.1 The landowner support EWR. However, until there is an announcement on the chosen route, we
consider direct references to it within Policy HOU19 veil the sustainability credentials of the Little Barford
new settlement. Our representations to the Sustainability Appraisal, April 2022 and the Transport
Technical Note that accompany these representations, demonstrate that although the site’s proximity
to EWR was a factor in BBC’s allocation for a new settlement, there are additional reasons (which have
not currently been assessed by BBC in its SA) to justify the site’s selection. Even in the absence of
EWR the location of Little Barford and the extent of land within the ownership of the Alington Estate
means that it still out performs the reasonable alternatives against the SA objectives.
The Executors of the late Nigel Alington
Alington Estate, Little Barford – Representations to Regulation 19 of the BBLP 2040
29 July 2022
Page 6 of 11
5.2 Whilst the modifications we are seeking to Policy HOU19 remove direct reference to EWR, the
replacement wording “sustainable travel nodes” would include EWR.
6 Supplementary Planning Document (masterplan and design code)
6.1 Whilst the principle of a supplementary planning document (SPD) could be supported by the landowner,
it is not justified within BBC’s evidence base. The need for a strategic masterplan, design code and
site/development specific infrastructure delivery plan (IDP) is supported by the landowner. The site is
in a single ownership and will be delivered through the master developer model. The comprehensive
planning and delivery of the site will be achieved through other, more streamlined means that can still
be produced with stakeholder engagement and agreed ahead of or within the site wide planning
application process.
6.2 Furthermore, we contend that the process of preparing and adopting an SPD would fetter the
effectiveness of the plan to deliver the required number of new homes from the site within the plan
period. This element of the policy (and through extension the BBLP 2040) is unsound on the basis that
it does not meet the tests of “justified” or “effective”. The remedy would be for a strategic masterplan,
design code and site/development specific infrastructure delivery plan to be prepared by the master
developer through a series of stakeholder engagement sessions/events and for them to be approved
and conditioned as part of the site wide (outline except for strategic infrastructure) planning permission.
7 Strong local community based approach
7.1 There are different models for successfully managing the assets of the new settlement for the long term
benefit of the community that will be created. There is no justification provided within BBC’s evidence
base that community ownership of assets is a superior model than other examples. It is too early in the
development of the proposals to know which will be the most viable and beneficial to the new
community. This strategic policy should maintain sufficient flexibility that allows for a range of options
to come forward as the details of the proposals are established through later stages of the planning
process.
8 Conservation Area Designation
8.1 The landowner is supportive of the principle of a conservation area designation for an appropriate area
of the site and we are working with the Council in the preparation of suitable evidence to support the
process. However, the process of designating a conservation area is separate from the local plan
process and the delivery of the policy should not be intrinsically linked to the designation of a
conservation area. Development within a conservation area is controlled by the Planning (Listed
Buildings and Conservation Areas) Act 1990 and therefore it should not be necessary to include text in
the allocation policy, Gypsy and Travellers
9.1 The Gypsy and Traveller Accommodation Assessment, November 2021 only identifies the number of
pitches BBC considers are required within the plan period. However, the alternative options for the
number of pitches to be provide or options for how those pitches should be distributed does not appear
to have been assessed through the sustainability appraisal (SA) process. Although paragraph 4.12 of
the BBLP 2040 states that the identified need for additional Gypsy and Traveller pitches and additional
plots for Travelling Show People forms part of the borough’s overall housing need, it is not clear why
alternative options for the selection of allocation sites to include provision has not be subject to SA. We
therefore contend that the inclusion of reference to the provision of pitches for Gypsy and Travellers
and plots for travelling show people within Policy HOU19 is not justified and requires further
consideration by BBC to demonstrate that its strategy is appropriate.
9.2 The associated reference in paragraph 4.13 of the BBLP 2040 to Little Barford (Policy HOU19) should
also be amended to reflect the outcome of further SA.
10 Education
10.1 The landowner supports the onsite provision of new schools to support the development. Education
Facilities Management has reviewed BBC’s evidence base documents supporting the BBLP 2040
where their relate to education. The Education Review, July 2022 submitted with these representations
identifies that the detailed wording within Policy HOU19 is not justified and risks not being effective in
the delivery of the education provision that the new settlement will generate. This representation
suggests modification to the wording of Policy HOU19 to remedy our concerns.
11 Modifications required to Policy HOU19
11.1 The landowner broadly support Policy HOU19 and confirm that a new settlement at Little Barford will
deliver at least 4,000 new homes, circa 4ha of employment land and associated infrastructure to support
a new community. However, modifications are required to ensure robustness against the tests of
soundness and improve the legibility of the policy. To achieve both aspects the following modifications
are required to Policy HOU19.
[see attachment]

Object

Representation ID: 10493

Received: 29/07/2022

Respondent: Bedfordshire Police

Agent: West Mercia OPCC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Having worked with Bedford Borough Council during the preparation of its Local Plan and Infrastructure Delivery Plan, Bedfordshire Police (BP) is very disappointed with the outcome of this in two key respects:

1. Policies HOU1 – HOU 19 do not reference the police, or indeed the emergency services, infrastructure that will be required to support the developments they propose.

2. Although BP provided the Council and its consultants (AECOM) with a detailed Infrastructure Plan detailing precisely the police infrastructure required to support new housing growth in the Borough, only its contents in relation to premises requirements have been allowed for in the Council’s Infrastructure Delivery Plan (IDP) and even then inaccurately. The Council’s IDP also erroneously states that BP will eventually be able to meet the costs of delivering the infrastructure required to the growth envisaged by the Local Plan. In fact developer funding will be required to meet the costs. This was explained and evidenced at length in the Infrastructure Plan submitted by BP.

The above outcomes contrasts starkly with the basic expectation that when people move into a new housing estate or other development, they are protected by police and other emergency services that can operate efficiently and effectively in that vicinity. This applies to all levels of service, whether they ring 999 should the worst happen, or are simply benefitting from the reassurance of day-to-day neighbourhood policing for example.

It means in turn that the delivery of police and other emergency services infrastructure needs to be planned and funded in advance of a new development scheme, in the same way as utilities, education, health, transport and other public services that are currently specified in various places in Policies HOU1 – HOU19.

The potential impact on the police and other emergency services from a new development is not simply due to an increase in population, but also the location of where that new population is arising and the impact that it will have on the present disposition of emergency services resources. Delivery of services to the new communities is also not just about responding to crimes or incidents, but also includes community assurance, delivery of crime safety advice and where necessary providing referral responses when there are expressed concerns about the safety of children, the elderly or those with special needs, for example.

The experience of BP shows that new developments quickly take on the characteristics of surrounding areas in terms of calls, incident types and crime numbers, even from the point when materials are delivered to a site. Therefore, service provision needs to be expanded accordingly, as do those of other public service providers.

This is very important as development growth, particularly new housing development, has significant and permanent implications for the emergency services once delivered. Whether it takes place on green fields, urban centres or redundant factory sites, new schemes invariably result in an increased demand for ‘blue light’ services.

Hence why planning policies (i.e. HOU1 – HOU19) have a key role to play in ensuring that the police and other emergency services can provide the same level of service to the residents/occupiers of a new development as for existing residents, without compromising frontline services. After all, it is only possible to create successful places and support new communities if they are brought forward alongside adequate services and infrastructure.

BP would also like to point out at this juncture that mitigating the impact of a given scheme on the emergency services is not a false choice between design or infrastructure measures. These in fact go together to ensure a development is safe and secure. The emergency services want to see schemes that incorporate fire safety measures, adopt Secured by Design guidance, include suitable access for response vehicles (police cars, fire engines and ambulances alike) and provide the infrastructure necessary to enable service delivery and on-going coverage for the scheme in question. Current legislation and policy do not permit ambulance services, fire and rescue services and the police to downgrade the level of their provision to a new development scheme because it incorporates fire safety and/or crime prevention design measures. Appropriate new infrastructure for the police and other emergency services is therefore always required.

This is why sustainability of a development to the police and other emergency means two things. It firstly means schemes that both passively (through design measures) and actively (through infrastructure provision) preserve community safety. If a building or place does not provide these things, there can be no quality of life for the people who will reside, work or visit there, leading ultimately to an unsustainable development.

This is not only the view of our organisations. We are sure you will agree those who purchase properties on a development, who may bring up families there, or for whom it may be a place of work, will want to know that it is a safe environment underpinned by emergency services providing effective and efficient services. It is not only in the interests of the continual well-being of the new residential and/or business community that has been created, but also to protect those in existing communities that will border the development in question. Conversely, there would be great anxiety amongst all these people, new and existing, if the emergency services network was stretched to beyond capacity.

Turning to what is meant by ‘infrastructure’ in this context, the Council’s IDP takes the view that police infrastructure is purely new buildings or works to existing buildings. However, in an police and other emergency services context (and as BP showed in the infrastructure plan it submitted to the Council), infrastructure includes


• Vehicles of varying types and functions as needed to cover the development in question e.g. deployment for emergency response, patrol or follow-up for incidents.

• Personal equipment for officers and staff e.g. workstations, radios, protective equipment, uniforms and bicycles;

• Radio cover e.g. base stations, hardware and signal strengthening equipment;

• CCTV and Automatic Number Plate Recognition (ANPR) cameras;

• Mobile IT technologies e.g. body worn cameras and smart tablet computers; and

• Firefighting equipment such as Fire Lances and thermal imaging cameras.

This may seem an unnecessarily expansive definition, but what constitutes ‘infrastructure’ in any given case is what would not be otherwise directly needed by the emergency services but for the new development.

It is a view shared by the Government. Under Schedule 11 (204N(3) of the Levelling-up and Regeneration Bill, the emergency services are classified as infrastructure and the Bill also states that this encompasses facilities and equipment.

This is why we consider that in the absence of references to planning for police and emergency services infrastructure in Policies HOU1 – 19, they are unsound in the context of paragraph 35 of the National Planning Policy Framework.

Object

Representation ID: 10516

Received: 29/07/2022

Respondent: St Neots Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

The strategy of developing Little Barford as a location for potential Bedford Borough Council
housing fails three of the four tests under NPPF paragraph 182 Tests of Soundness.
SNTC feels that the inclusion of policy HOU19 within the current proposed Bedfordshire
Borough Council Local Plan fails:
the "justified test" ( the plan should be the most appropriate strategy, when
considered against the reasonable alternatives )
● option 2a is a viable alternative ( without the associated impact relating to
Little Barford )
the "effective test" ( the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities )
● limited if any cross boundary joint working in relation to the risks to St Neots
ranging from flood risk to demands on an already stretched infrastructure.
the consistent with national policy test ( the plan should enable the delivery of
sustainable development in accordance with the policies in the framework )
● fails to meet NPPF chapters:
○ ( section 13 ) protecting green belt land
○ ( section 14 ) meeting the challenge of climate change and flooding
○ ( section 15 ) conserving and enhancing the natural environment
○ ( section 16 ) conserving and enhancing the historic environment
The majority of SNTC's concerns remain as vocalised within the earlier St Neots Town
Council response document ( September 2021 ) and the related queries remain
unanswered.

During the earlier stages of the development of this plan, St Neots Town Council requested
cross boundary cooperation with Bedford Borough Council to ensure that proposals that
directly or indirectly affected the town were adequately investigated to mitigate or minimise
the impacts felt on the town and the residents.
St Neots Town Council is concerned that this Local Plan preempts the OxCamArc
consultations, and goes against this spirit of "region-wide planning". SNTC are disappointed
that no attempt has been made by Bedford Borough Council to engage with St Neots Town
Council during the consultation phase for the 2040 plan.
“To realise the full opportunities – and overcome the challenges – will require coordination
of planning functions across the region. Local councils cannot do this on their own because
of the level of coordination needed across the area, and because they do not have all the
levers needed to develop a genuinely integrated plan. Government needs to play a supporting
role to bring together a strategic approach at the Arc level to support better planning and
ultimately better outcomes for the economy, environment and communities.”
The proposed new settlement of Little Barford makes reference to the proposed upgrade of
the Caxton Gibbet to the Black Cat section of the A428 in isolation along with the proposed
East West Rail again in isolation. Nowhere are these entities combined to understand how
the area and therefore the proposed development would be impacted. If you then exclude
areas of the site at risk to flooding the site becomes less attractive.
There still remain too many unknowns relating to HOU19, the majority of these have been
left to be written and or developed after the consultation process and therefore too late in our
opinion ( see comments within policy wording in later section: NPPF Paragraph 182 ).
NPPF PARAGRAPH 182
The NPPF states that the local plan will be tested by the Planning Inspectorate as follows:
"NPPF paragraph 182 Tests of Soundness
The Local Plan will be examined by an independent inspector whose role is to assess
whether the plan has been prepared in accordance with the Duty to Cooperate, legal and
procedural requirements, and whether it is sound. A local planning authority should submit a
plan for examination which it considers is “sound”, namely that it is:
• Positively prepared – the plan should be prepared based on a strategy which seeks to
meet objectively assessed development and infrastructure requirements, including unmet
requirements from neighbouring authorities where it is reasonable to do so and consistent
with achieving sustainable development;
• Justified – the plan should be the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence;
• Effective – the plan should be deliverable over its period and based on effective joint
working on cross-boundary strategic priorities; and
• Consistent with national policy – the plan should enable the delivery of sustainable
development in accordance with the policies in the Framework."
SNTC feels that the inclusion of policy HOU19 within the current proposed Bedfordshire
Borough Council Local Plan fails:
the "justified test" ( the plan should be the most appropriate strategy, when
considered against the reasonable alternatives )
● option 2a is a viable alternative ( without the associated impact relating to
Little Barford )
the "effective test" ( the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities )
● limited if any cross boundary joint working in relation to the risks to St Neots
ranging from flood risk to demands on an already stretched infrastructure.
the consistent with national policy test ( the plan should enable the delivery of
sustainable development in accordance with the policies in the framework )
● fails to meet NPPF chapters:
○ ( section 13 ) protecting green belt land
○ ( section 14 ) meeting the challenge of climate change and flooding
○ ( section 15 ) conserving and enhancing the natural environment
○ ( section 16 ) conserving and enhancing the historic environment
The majority of SNTC's concerns remain as vocalised within the earlier St Neots Town
Council response document ( September 2021 ) and the related queries remain
unanswered.

Little Barford ( extracted from proposed local plan )
4.92
Land at Little Barford is allocated as a new settlement, contributing to the delivery of the
Bedford Local Plan’s spatial growth strategy. The development of Little Barford will make a
key contribution towards the additional homes required to be delivered across the borough
by 2040, delivering at least 4,000 new homes overall, of which an estimated 3,800 will be
within the current plan period.
SNTC: described as a 'key contribution' but is this 'justified' ( NPPF paragraph 182 ) due to
the remote location in relation to Bedfordshire Borough Council as a whole. Option 2a of the
earlier consultation documents contains similar numbers of housing but delivered in a more
logical form.
St Neots is already straining under the demands of historical growth ( the town has grown
significantly since the post war period ). It is currently undergoing expansion to the East of
the town ( well outside the influence of the River Great Ouse ) a core strategy within
Huntingdon District Council's local Plan. Development of the green field site at Little Barford
would see additional strain put on St Neots and the infrastructure.
4.93
The new settlement is located to the north east of Bedford, close to the neighbouring town of
St Neots. The East Coast Main Line railway line runs north to south through the site and the
proposed A428 Black Cat to Caxton Gibbet relief road runs through the site providing an
opportunity for a strategic road junction. In addition, EWR will be crossing in the vicinity,
possibly through the site, and will include a station offering the opportunity of a highly
sustainable site accessible by rail and the strategic road network. In addition to the allocation
site there is further land within the same ownership which is identified as a contingency area,
should land be required to facilitate the EWR route and / or station within the site. The
allocation site and contingency land are illustrated by the plan below.
SNTC: EWR route and planning is not confirmed and therefore policy HOU19 is somewhat
premature.
4.94
The proximity of the site to the existing Little Barford employment area to the north offers the
opportunity to locate new employment development by way of extension and / or in other
areas of the site to benefit the local economy and provide further employment opportunities.
SNTC: Little Barford employment area to the north of the proposed development is
landlocked by the river to the west, the county border to the east and St Neots to the north.
Therefore new employment development is not possible due to these constraints.
4.95 The site has unique locational strengths and qualities which, if properly realised and guided
by appropriate design principles, will enable it to be an exemplar for low carbon living and
innovation.
SNTC: Part of the unique locational strengths stem from the fact that this is good quality
farming land, sat adjacent to the Great River Ouse and on the flood plain of the same. There
are a number of historical assets within the proposed development and the area is used as a
local 'recreational asset'.
4.96
The potential to designate a conservation area at Little Barford is being investigated by the
Local Planning Authority.
SNTC: Surely this should have been investigated and confirmed prior to submission of the
local plan.
Policy HOU19 Little Barford New Settlement
As identified on the Key Diagram and Policies Map, land at Little Barford is allocated as a
new settlement to create a landscape led beautiful, healthy and sociable community located
in close proximity to the proposal for a new station on the East West Rail line delivering at
least 4,000 new homes and in the region of four hectares employment. It will provide all the
key services and facilities to address its own needs, including health, education, retail,
culture and community components, and will foster a strong local community based
approach to the ownership and long-term stewardship of assets.
SNTC: Zoning of good quality farming land as potential employment ( i.e. extending the
existing employment zone situated between the railway lines to the east and river to the west
) does not sit comfortably with the proposed ethos of "a landscape led beautiful, healthy and
sociable community".
The new settlement will have a distinct identity based on a landscape led approach which
values and enhances the natural environment and responds directly to its context. The
settlement will be developed to a high design quality achieved through a process of master
planning and design coding and will incorporate a range of homes, employment, an
integrated and multi-purpose green infrastructure network lending context and character to
walking neighbourhoods which will enable residents to meet the majority of their day to day
needs locally and achieve access to the new East West Rail station by active travel modes.
A strategic masterplan and design code is to be prepared by the Council in conjunction with
the landowners, stakeholders and local community and adopted as a Supplementary
Planning Document.
This document will need to be produced ahead of the submission of any planning application
and will demonstrate how the new settlement will deliver the policy principles below and will
include:
● A Natural Capital impact assessment and biodiversity study with appropriate
mitigation and enhancements;
● A Green Infrastructure strategy;
A transport and movement strategy including infrastructure needs and the
relationship to East West Rail;
● A phasing strategy to ensure that infrastructure investment is provided in
tandem with or ahead of the development it supports;
SNTC: what infrastructure investment is being proposed
● An infrastructure delivery plan setting out the timing, funding, and provision of
green, social, and physical infrastructure, including schools, community
facilities and local centres in tandem with housing development;
● Character assessment and master planning;
● Design coding;
● A strategy for sustainable long-term governance and arrangements for the
stewardship of community assets;
● A detailed assessment of the mineral resource within the Mineral
Safeguarding Area to examine quantity, quality and feasibility of extraction;
● A site specific flood risk assessment including identifying opportunities to
reduce surface water run-off and flood risk on and off site;
SNTC: the site is located on the flood plain of the Great River Ouse. Bedfordshire
catchment drains into the Cambridgeshire catchment of the Great River Ouse at St
Neots just to the north of this site. It is not acceptable that a flood risk assessment
would be restricted to the red line of the site but rather should include the potential to
increasing the existing risk of fluvial flooding to St Neots.
● A detailed heritage impact assessment.
SNTC: see 4.96 above
In order to ensure that the new settlement is brought forward in a high quality, strategic and
comprehensive manner, planning permission will only be granted following the adoption of
the strategic masterplan and design code. Development must demonstrate how it has been
holistically planned to accord with the objectives of the Local plan and the specific principles
below:
GREENER
i. The provision of high quality planning, design and place-making, and management
of built and public realm so that the Little Barford new settlement is characterised as
a distinctive place that capitalises on local assets and establishes environments that
promote health, and wellbeing;
ii. The provision of a multifunctional green infrastructure which: retains, enhances,
connects, and increases accessibility to the green infrastructure network including
the River Great Ouse and on site woodland areas; provides well-integrated green
space (formal, natural and allotments); and provides environmental net gains;
SNTC: the existing area is high quality countryside with existing access and rights of way.
The proposals do not retain and enhance these
iii. As part of the green infrastructure network, cycle and pedestrian links to facilitate
active travel within the neighbourhoods and surrounding areas iv. Integration of Sustainable Drainage Systems into the network of open spaces, to
mitigate potential flood risk, and measures to ensure resilience to climate change
including measures to ensure the efficient use of energy and water in accordance
with Policy 93;
SNTC: flood risk cannot be looked at in isolation as a site risk, but required to be integrated
with the broader area.
v. The Council will consider whether any areas of the Little Barford settlement merit
designation as a Conservation Area. In the event of its designation, development
must preserve and where opportunities arise, enhance its special interest.
vi. The protection and / or enhancement of heritage and biodiversity assets within
and surrounding the site, to include:
● Any new development should contribute positively to local character
and distinctiveness and enhance or better reveal the significance of
any designated heritage assets affected,
● Pre-determination archaeological evaluation in all areas which will
potentially be impacted by development and where the nature and
significance of the archaeological resource does not necessitate
preservation in situ,
● Development should also seek to sympathetically reuse built heritage
and retain those non-designated heritage assets of archaeological
interest in situ, including above ground settlement and associated
earthworks, which make a positive contribution to the appearance,
understanding, appreciation and interpretation of the historic
settlement,
● Submission of a biodiversity report with appropriate mitigation and
enhancements.
SNTC: development of this site would be detrimental to both heritage and
biodiversity within the site.
PLACEMAKING
vii. Place making based on a landscape led approach to creating a vibrant place
which is sensitive to local character and creates distinctive neighbourhoods;
viii. The provision of a range of house types and tenures in accordance with the most
up to date assessment of housing need, including affordable housing in accordance
with required levels as set out in Policy DM1(S) to meet the needs of the wider
community including the ageing population;
ix. The provision of a mix of beautifully and imaginatively designed homes at a range
of densities reflecting the context and character of different parts of the site, in
particular lower densities in accordance with the historic character of the western
side of the site and higher densities in areas with higher accessibility to the East
West Rail station and local centres;
x. The provision for a wide range of construction opportunities, offering prospects for
a variety of house builders and developers including small and medium sized enterprises and including the provision of serviced plots for self-build and custom
homebuilding in accordance with Policy DM5;
xi. The provision of serviced sites for secondary and primary schools including early
years facilitates at the heart of the local neighbourhoods to serve the new
development, (2 x 5.5ha 4FE primary and 1 x 10.1ha 8FE secondary schools);
Due to the lack of capacity in existing schools, additional capacity will be required to
be open prior to the occupation of the first dwelling. Financial contribution towards
secondary school provision;
xii. The provision of pitches for Gypsy and Travellers and plots for travelling show
people where need is identified in a Gypsy and Traveller Accommodation
Assessment;
xiii. The provision of leisure and sports facilities at accessible locations in line with
current standards to serve the settlement;
xiv. The provision of multi-functional community space and healthcare facilities within
local centres at the heart of walkable vibrant sociable neighbourhoods;
xv. The fostering of healthy living through access to green space as a key driver of
the settlement design and opportunities for local food production;
xvi. The establishment at an early stage in the development of the new settlement of
appropriate and sustainable long-term governance and stewardship arrangements
for community assets including green space, public realm areas and community and
other relevant facilities. Such arrangements are to be funded by the development and
include community representation to ensure residents have a stake in the long-term
development, stewardship and management of their community;
xvii. Layout and design of the new settlement should incorporate appropriate
mitigation measures in relation to high pressure gas pipelines, overhead power lines
and noise sources including railway lines.
ACCESSIBLE
xviii. In accordance with the transport and movement strategy, the provision of a
balanced package of measures to encourage smarter transport choices to meet the
needs of the new development including the integration of technology to deliver ‘ondemand’
travel information and measures to reduce the number of single occupancy
car trips;
xix. Measures should maximise the opportunities for active travel through the
provision of a network of footpaths, cycle ways and bridleways to enhance
permeability within the site and to the adjoining area and will include:
● connections between communities across the East Coast Main Line at
a minimum of two locations,
● new footway and cycle routes including the integration of National
Cycle Network (NCN) route 12 through the site
● links to the East West Rail station including the provision of a
dedicated shuttle bus service from the site,
● measures to facilitate access by bus services across the site,
provision of charging points for electric vehicles,
● car clubs and mobility hubs,
● appropriate measures to facilitate autonomous vehicles,
SNTC: no details of integration into the existing infrastructure of St Neots nor
the issues relating to the existing A428 running west east to the north of the
site, potentially limiting integration with existing routes.
xx. A programme of measures to facilitate accessibility and minimise and mitigate the
traffic impacts on the local and strategic road network to include:
● widening of Barford Road and any necessary new junctions,
● widening of the existing footway and conversion to a cycle / pedestrian
route on Barford Road up to the A428 roundabout,
● provision of a multi-user route alongside River Great Ouse and
potential to cross the river,
● The development is dependent on the delivery of transport
improvements which will need to be secured before development can
take place in accordance with an agreed Infrastructure Delivery Plan.
SNTC: major transport improvements are still in planning stages and are yet
to be confirmed, again it seems premature to be implementing a local plan
policy for Little Barford prior to understanding the impact of these on the
potential development.
PROSPEROUS
xxi. The delivery of new neighbourhoods that are sociable, vibrant, and walkable (20
minutes) neighbourhoods with equality of access for all. The new settlement will
provide a range of community services and facilities including health, education,
retail, culture, community meeting spaces, multifunctional open space and sports and
leisure facilities;
xxii. Approximately 3.6 ha of industrial and warehousing employment land, to be
located adjacent to and act as an expansion of the existing Little Barford employment
area;
SNTC: clause xxii. is in direct conflict with earlier statements of "a landscape led beautiful,
healthy and sociable community"
xxiii. Installation of super-fast broadband for all businesses and community facilities
and also for all dwellings to support home working, at the outset of each phase of
development.

See attachment - a map is included followed by a copy of the representation made to the draft plan.