Plan for submission evidence base

Object

Representation ID: 9513

Received: 27/07/2022

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Please not that CPC’s representations on this matter are in relation to CPC’s support of the conclusions of BBC’s new settlement selection however CPC’s representations also address a number of inaccuracies within the Sustainability Appraisal that it wishes to see addressed.
3.1. CPC supports the Council’s decision to not select the new settlement proposals known as ‘Land west of Wyboston – Denybrook Garden Community’. BBC has rightly concluded in its Pre-Submission Local Plan that this site is not well located in relation to any of the East
West Rail interchange options and that its development would result in the loss of high quality agricultural land.
Figure 3.1: ‘Reasons why not allocated’ Sustainability Appraisal (April 2022), Page 108
3.2. BBC explains that it selected the Little Barford new settlement option as it considered that it performed best in relation to air quality, carbon dioxide emissions and travel objectives as it states in its Development Strategy Topic Paper:
“The planning of a new settlement at Little Barford similarly presents an opportunity to maximise the benefits associated with such a well-connected
location. A new rail station at the junction of the East West Rail and East Coast Main Line offers excellent sustainability credentials allowing the settlement to
be planned in a way that makes walking and cycling to the station the mode of choice.”14
“The Council prefers Little Barford because it is more conveniently located to the planned East West Rail interchange and avoids the loss of high quality agricultural land.”15
3.3. Given that BBC concluded that ‘Denybrook’ is not well located to the East West Rail interchange options and that it is not possible to integrate sustainable travel solutions into the Denybrook scheme, in terms of East West Rail, it considers that the assessment of the site should be scored in the Sustainability Appraisal against the following Sustainability Objectives as a ‘Major Negative’ in the Sustainability Appraisal rather than
its current score as a ‘Negative’:
Objective 1: ‘Improve Air Quality
Objective 3: Reduce emissions of carbon dioxide and improve energy efficiency
Objective 15: Reduce the need to travel and promote sustainable modes of transport
14 Development Strategy Topic Paper (May 2022), paragraph 5.17
15 Sustainability Appraisal (April 2022), paragraph 9.10
3.4. CPC challenges the Sustainability Appraisal’s assertion that the potential new East West Rail station will have ‘beneficial effects’ for ‘Denybrook given its remoteness from all of the railway station options. The Council’s Sustainability Appraisal states:
“The testing shows that the negative effects are less severe for both Little Barford and Wyboston in relation to air quality, carbon dioxide emissions and travel objectives than for Colworth and Twinwoods. This is because of the
beneficial effects that derive from the provision of a railway station16.
3.5. CPC’s Regulation 18 representations provide analysis and evidence which demonstrates the remoteness and lack of connectivity between ‘Denybrook’ and the East West Rail station options, as well as the lack of achievable connectivity to any major roads and the promoted scheme’s reliance on using unsuitable country roads for all of its access points.
We include a summary of these below for consideration at the Regulation 19 stage of the plan-making process as well given that we consider that these provide evidence that justifies a ‘Major Negative’ score against Objectives 1, 3 and 15 in the Sustainability Appraisal and provides evidence that further supports BBC’s decision to reject the ‘Denybrook’ scheme.
3.6. As CPC set out in its extensive representations to the Regulation 18 consultation it considers the ‘Denybrook’ site location to be unsustainable and located a very
considerable distance from any existing infrastructure. The amount of infrastructure required to make such a location a sustainable and resilient location to deliver a new settlement is unrealistic.
Distance to Potential New Stations
3.7. The site promoter’s very rough drawing of a dotted line for a cycle link which would link the southern end of the site with one of the railway station options is void of any technical assessment whether such an idea is feasible, and it is therefore a theoretical idea and
should not be relied upon. We have undertaken mapping analysis of the distance and cycle times between Denybrook and the potential stations below.
Figure 3.2: Distance between Denybrook and potential new railway stations
3.8. As one can see the distances based on our calculations are as follows:
• Dennbrook – Option 1: 7.07 km (4.4 miles)
• Denybrook – Option 2: 7.28 km (4.5 miles)
• Denybrook – Option 3: 7.62 km (4.7 miles)
• Denybrook – Option 4: 7.81 km (4.8 miles)
3.9. These distances are clearly the ‘best case scenario’ even though they are calculated from the furthest distance of the site. This is because the distances are calculated ‘as the crow flies’ whereas the road or cycle network to access these stations would be considerably
further.
Cycling Distances and Times
3.10. Without any detailed proposals for road and cycling infrastructure from the site promoters we have made some technical assumptions in order to arrive at a more
accurate idea of the likely distance and cycling times to the potential new railway stations. To do this we have used the shortest route from the centre of the site along a
network composed of the existing network and a straight line extension to the proposed station where no other access route was built. We used Google Maps API to determine the shortest route distances combined with a GIS calculator to determine the length and time for cycling speeds of 13.8km/h.
• Denybrook – Option 1: 9.87 km (6.13 miles) 43 minutes
• Denybrook – Option 2: 8.86 km (5.50 miles) 39 minutes
• Denybrook – Option 3: 8.69 km (5.40 miles) 38 minutes
• Denybrook – Option 4: 8.63 km (5.36 miles) 38 minutes
Figure 3.3: Cycling Distance and Time Estimates from Denybrook site to potential new railway stations
3.11 Any suggestion that the Denybrook site can be considered as ‘integrated’ with the potential new railway station is clearly unfounded by the distance between locations of the site and the potential station locations. There is no clear proposed road link that could link the site to any of the potential railways station options so it is not possible to justify public transportation linking with a railway station. Cycling will clearly not be possible as
a legitimate option for residents as clearly the distance of approximately 5 miles is not something an ordinary person could endure for regular or even occasional use of a railway station.
3.12 Clearly CPC is supportive of walking and cycling as the most sustainable forms of travel and that any new settlement proposals in the borough would need to deliver walking and cycling infrastructure to the public transport network, however such plans need to be
realistic and these are not.
The Best and Most Versatile Agricultural Land
3.13 CPC supports the Sustainability Appraisal’s assessment of the ‘Denybrook’ site’s potential effects on the ‘loss of high quality agricultural land’ (SA Objective 9). The SA gives the site a score of ‘Major Negative’ and it is the only new settlement option to be scored this way and justifiably so.
“Wyboston is the only new settlement to show a major negative effect in relation to the loss of high quality agricultural land.”17
3.14 This assessment alone should be reason enough to reject ‘Denybrook’ to ensure the protection of this finite resource of the best and most versatile agricultural land to help ensure food security locally and nationally. Clearly, this is a resource that cannot be replaced once developed.
3.15 The NPPF states (our emphasis):
“Planning policies and decisions should contribute to and enhance the natural and local environment by:
b) recognising the intrinsic character and beauty of the countryside, the wider benefits from natural capital and ecosystem services – including the economic
and other benefits of the best and most versatile agricultural land, and of trees and woodland”
3.16 A Green Future: Our 25 Year Plan to Improve the Environment18 sets out the government’s 25-year plan to improve the health of the environment by using natural
resources more sustainably and efficiently. It plans to:
• protect the best agricultural land
• put a value on soils as part of our natural capital
• manage soils in a sustainable way by 2030
• restore and protect peatland
17 Sustainability Appraisal (April 2022), paragraph 8.26
18 https://www.gov.uk/government/publications/25-year-environment-plan
3.17 Planning Practice Guidance (PPG) states that following about assessing agricultural land to enable informed choices about its future”
“How can planning take account of the quality of agricultural land?
The Agricultural Land Classification assesses the quality of farmland to enable informed choices to be made about its future use within the planning system.
There are five grades of agricultural land, with Grade 3 subdivided into 3a and 3b. The best and most versatile land is defined as Grades 1, 2 and 3a.
Planning policies and decisions should take account of the economic and other benefits of the best and most versatile agricultural land. In the circumstances set out in Schedule 4 paragraph (y) of the Development
Management Procedure Order 2015, Natural England is a statutory consultee:
a local planning authority must consult Natural England before granting planning permission for large-scale non-agricultural development on best and most versatile land that is not in accord with the development plan. Natural
England has published guidance on development on agricultural land.”19
3.18 The PPG explains why planning decisions should take account of the value of soils and agricultural land classification (ALC) to enable informed choices on the future use of agricultural land within the planning system20.
3.19 The Denybrook site is comprised mostly of Grade 2 Agricultural Land and some Grade 1 as evidenced by the map prepared below which means that if developed the borough would lose some of its best agricultural land and would be lost to future generations at a time when climate change is having immediate impacts.
3.20 Of all the promoted new settlements Denybrook has the best agricultural land and it should clearly be protected. Whereas Twinwoods has a considerable amount of previously developed land as does Little Barford. The whole of the Colworth site is comprised of Grade 3 and further assessment would be needed to determine if this is 3a or 3b.
3.21 We also note that most of the Denybrook site promoter’s off-site transport improvements are proposed in the area to the southeast of their site on land that is Grade1 Agricultural Land which would also be lost as a result of their proposals.
19 Paragraph: 001 Reference ID: 8-001-20190721
20 Paragraph: 002 Reference ID: 8-002-20190721
3.22 One of BBC’s Local Plan Themes is Theme 1: Greener with one of its stated objectives being to protect and enhance natural resources which includes soil (our emphasis):
“Protect and enhance our natural resources including air, soil, minerals and water to minimise the impacts of flooding, climate change and pollution”.
Figure 3.4: Provisional Agricultural Land Classification (ALC) - provided by Natural England (May 2020) under
Open Government Licence v3
Heritage
3.23 CPC notes BBC’s Heritage Assessment of ‘Denybrook’ in the Council’s Sustainability Appraisal which concludes based on BBC’s Heritage Team that the scheme would likely result in harm to approximately 21 Grade II listed buildings. CPC supports the Council’s
conclusion in the Sustainability Appraisal that “the scheme is likely to have a high cumulative impact on designated heritage assets”21.
3.24 On this basis CPC considers that the Sustainability Appraisal should score ‘Objective 4 – conserve, sustain and enhance the historic environment’ as a ‘Major Negative’ rather than its current rating as ‘Negative’.
3.25 CPC is concerned that the Council appears to be relying on the site promoter’s evidence in relation to heritage rather than preparing its own Heritage Impact
Assessment evidence base.
3.11. Historic England has prepared a number of Advice Notes with its guidance on how authorities should approach heritage in the Local Plan and in their selection of potential sites including the potential impacts on heritage that might result from the proposals. There are two of these Advice Notes we would like to bring to the attention of BBC:
• The Historic Environment and Site Allocations in Local Plans (Historic England Advice Note 3) October 201522.
• Statements of Heritage Significance: Analysing Significance in Heritage Assets
(Historic England Advice Note 12) October 201923
21 Sustainability Appraisal, Additional Site Assessments including New Settlements Land Ownership
3.12 The land promoted for development at Denybrook is owned by multiple landowners and by our estimate approximately 56 land parcels. This highlights the complexity of the land assembly and delivery issues that the scheme would likely face if it were to be selected. Please note the landownership map is based on an initial assessment of HM Land Registry information and would need to be confirmed by BBC and the landowners
as to its accuracy.
3.13 Land assembly and multiple landowners does not appear to have been assessed by BBC in its considerations of the potential new settlements. CPC considers that the extent of multiple landownerships at ‘Denybrook’ is another reason for rejecting the site as it
will lead to complications in the land assembly, masterplanning and delivery process ultimately leading to a fragmented, piecemeal scheme.
Figure 3.5: Landownership parcels Dennybrook area. Source of parcel data: HM Land Registry and Ordnance Survey;
Reference used for Denybrook Garden Village Boundary: drawing “Figure 1: Designated Heritage Assets”, Drawing
No. CSA/5041/103, drawn for Taylor Wimpey.
22 https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/
23 https://historicengland.org.uk/images-books/publications/statements-heritage-significance-advice-note-12/heag279-
statements-heritage-significance/