Plan for submission evidence base

Object

Representation ID: 9962

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

REPRESENTATIONS TO SUSTAINABILITY APPRAISAL REPORT

The sustainability appraisal process for development plans tests the social, economic and environmental impacts of various plan options to help choose the most sustainable policies and allocations. Paragraph 31 of the NPPF expects development plans to be underpinned by evidence that supports and justifies policies. Paragraph 32 expects development plans to avoid significant impacts on sustainability objectives and where such impacts cannot be avoided to identify mitigation measures, with those impacts tested through the sustainability appraisal process. As set out below, it is considered that findings of the PSBLP Sustainability Appraisal for two of the preferred allocations are not robust, in that mitigation measures to address significant impacts are not taken into account in the assessment process. The Southill Estate owns two parcels of land that are identified as draft allocations in PSBLP: land at Abbey Field West of Elstow site for residential development (Policy HOU 5); and land at Pear Tree Farm Elstow for a science and innovation park (Policy EMP 5). The assessment of these two draft allocations in the SA conclude that negative effects would still arise for some sustainability topics in the medium and longer term, which cannot be correct when each policy includes requirements to effectively mitigate the impacts of the promoted developments.

Policy HOU5: Abbey Field, West of Elstow
OBJECT

The assessment for Policy HOU5: Abbey Field, West of Elstow against sustainability objectives is provided at SA Appendix pg. 174 to 175. It is noted that the assessment identified a number of positive effects, which are mostly related to the location of the site within the urban area and to the delivery of additional housing. The assessment identified negative effects in the short, medium and long term for the following sustainability objectives: No.2 biodiversity; No.4 historic environment; and, No.13 access to community services and facilities. Policy HOU5 includes policy requirements to address significant impacts on a range of matters. The negative effects in the medium and longer term cannot be correct, because this implies that the mitigation measures identified in the site allocation policy would be ineffective.

Criteria i(a) of Policy HOU 5 requires the design of the promoted development to preserve the setting of heritage assets. The Heritage Impact Assessment prepared for the promoted development demonstrates that the change to the rural setting of heritage assets would result in no more than a minor adverse impact to their wider rural setting and would have no impact on the immediate setting of the assets. It is concluded in the Assessment that the impact on the wider rural setting of these designated heritage assets would amount to less than substantial harm to the significance of these assets. In addition, there is a policy requirement for the promoted development to include open space to the north and east, which would separate built development from heritage assets and retain views of those assets. Therefore, the significant effects from the promoted development on heritage assets would be effectively addressed by mitigation measures. If there are any short term impacts on heritage assets, the design and layout of the promoted development including substantial areas of open space would reduce those impacts in the medium and longer term. It is requested that the score for sustainability objective No.4 (historic environment) is changed to neutral effects in the medium and longer term.

Criteria vii of Policy HOU 5 requires an assessment of ecological impacts of the promoted development, and criteria i(d) requires the promoted development to identify opportunities to include green infrastructure and to connect to existing networks. In addition, Policy DM7 includes a policy requirement for major development to deliver a minimum 10% biodiversity net gain through enhancement of existing features or creation of new habitats. It is anticipated that the promoted development would protect and enhance the biodiversity of the site, and would deliver further enhancements through green infrastructure. Therefore, any significant effects from the promoted development on ecology would be effectively addressed by mitigation and enhancement measures. If there are any short term impacts on ecology, the delivery of green infrastructure as part of the promoted development would reduce those impacts in the medium and longer term. It is requested that the score for sustainability objective No.2 (biodiversity) is changed to positive effects in the medium and longer term.

Criteria iii of Policy HOU 5 requires connections to neighbouring areas by walking and cycling. The site is within the urban area and there are community facilities available in Elstow. There will be additional facilities delivered within the existing and planned new settlements of the South of Bedford Area. It is considered that the pedestrian and cycle connections to be delivered as part of the promoted development would enable future residents to access community facilities in the surrounding area. Pedestrian and cycle connections to the neighbouring areas. Therefore, any significant effects from the promoted development on access to community services and facilities would be effectively addressed by the delivery of pedestrian and cycle connections. It is requested that the score for sustainability objective No.13 (access to community services and facilities) is changed to positive effects in the medium and longer term.
A negative effect score would remain for sustainability objective No.9 (previously developed land). However, the identified development needs for PSBLP will require both previously developed land and greenfield sites.

The requested changes set out above would confirm that the site should continue to be identified as a preferred allocation in PSBLP.

Requested Change

The following changes are requested to the assessment of Policy HOU5: Abbey Field, West of Elstow at SA Appendix pg. 174 to 175:
• The score for sustainability objective No.4 (historic environment) is changed to neutral effects in the medium and longer term.
• The score for sustainability objective No.2 (biodiversity) is changed to positive effects in the medium and longer term.
• The score for sustainability objective No.13 (access to community services and facilities) is changed to positive effects in the medium and longer term.
Policy EMP5: Land at Pear Tree Farm Elstow

OBJECT

The assessment for Policy EMP5: Land at Pear Tree Farm Elstow against sustainability objectives is provided as SA Appendix pg. 210 to 212. It is noted that the assessment identified a number of positive effects, which are mostly related to the location of the site adjacent to the urban area, good accessibility by sustainable modes of transport, and to the delivery of employment land. The assessment identified negative effects in the short, medium and long term for the following sustainability objectives: No.2 biodiversity; No.4 historic environment; and No.7 physical activity. Policy EMP 5 includes policy requirements to mitigate significant effects on a range of matters. The negative effects in the medium and longer term for biodiversity and the historic environment cannot be correct, because this implies that the mitigation measures identified in the site allocation policy would be ineffective.

Criteria ix of Policy EMP 5 includes a requirement for the promoted development to protect and enhance heritage assets and their setting. In addition, Policy EMP5 includes landscape and open space criteria for the promoted development, to protect the views of Elstow Abbey and the setting of Elstow village and separate development from heritage assets – see criteria iii and criteria iv. Criteria x requires an archaeological evaluation to be prepared for the site and submitted with a planning application for the promoted development. Therefore, the significant effects from the promoted development on heritage assets would be effectively addressed by mitigation measures. If there are any short term impacts on heritage assets, the design and layout of the promoted development including substantial areas of open space would reduce those impacts in the medium and longer term. It is requested that the score for sustainability objective No.4 (historic environment) is changed to neutral effects in the medium and longer term.

Criteria xi of Policy EMP 5 requires the submission of a wildlife and habitat survey with mitigation and enhancement measures for the promoted development, criteria vii requires the promoted development to include a green corridor, and criteria vi requires a contribution to the Forest of Marston Vale through tree planting on the site. In addition, Policy DM7 includes a policy requirement for major development to deliver a minimum 10% biodiversity net gain through enhancement of existing features or creation of new habitats. It is anticipated that the promoted development would protect and enhance the biodiversity of the site, and would deliver further enhancements as part of the green corridor and tree planting. Therefore, any significant effects from the promoted development on ecology would be effectively addressed by mitigation and enhancement measures. If there are any short term impacts on ecology, and the delivery of biodiversity enhancements, tree planting and a green corridor as part of the promoted development would reduce those impacts in the medium and longer term. It is requested that the score for sustainability objective No.2 (biodiversity) is changed to positive effects in the medium and longer term.

The assessment of the site against sustainability objective No.7 (physical activity) is not relevant to the promoted development. It is not normally a requirement for employment sites to include recreation facilities. Although, the promoted development would provide pedestrian and cycle connections to enable active travel to and from the site, and includes a green corridor to provide informal recreation opportunities for future employees. It is requested that the score for sustainability objective No.7 (physical activity) is changed from negative effect to neutral effect.

A negative effect score would remain for sustainability objective No.9 (previously developed land). However, the identified development needs for PSBLP will require both previously developed land and greenfield sites.

The requested changes set out above would confirm that the site should continue to be identified as a preferred allocation in PSBLP.

Requested Change

The following changes are requested to the assessment of Policy EMP5: Land at Pear Tree Farm Elstow at SA Appendix pg. 210 to 212:
• The score for sustainability objective No.4 (historic environment) is changed to neutral effects in the medium and longer term.
• The score for sustainability objective No.2 (biodiversity) is changed to positive effects in the medium and longer term.
• The score for sustainability objective No.7 (physical activity) is changed to neutral effects in the short, medium and longer term.