Plan for submission evidence base

Object

Representation ID: 10161

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Introduction
On behalf of J.C Gill Development Ltd, I am pleased to formally submit representations to the Bedford Borough Local Plan 2040 Regulation 19 (Pre-submission) consultation together with the Response Form accompanying this letter.
We object to the spatial strategy set out in the draft Local Plan as matter of principle because it does not propose to allocate the most suitable site’s in the most suitable locations. The approach taken by the Council is flawed, not only because it fails to recognise the more sustainable locations for growth, but also because it overly relies upon the delivery of site’s that are in less sustainable locations and rely on the delivery of substantial infrastructure projects that are uncertain and likely to cause delay. The full details of the objections are presented in this representation.
In order to assist the Council in preparing a sound and credible plan we advocate those additional site’s are allocated in locations that are sustainable, meet the vision and objectives set out in the plan and present a significantly more deliverable and robust housing allocation.
The Proposed Allocation
Site Details
The site is located between no.34 and no.36 High Street, Riseley. It has not previously been promoted for inclusion in the Local Plan, however, following assessment of the draft document it is considered it could prove valuable in quickly delivering short term housing need. The site, approximately 0.65ha, is located in the southern area of Riseley, a Group 3 village. Access is available directly from High Street on the northern corner of the site. The satellite location plan of the site is shown in figure 1 below and the site identification plan is available in appendix 1.
[See attachment for Figure.]
The site comprises of an open field, lined by trees and hedgerows on three boundaries and post and rail fencing on the south eastern boundary. It adjoins existing residential development on its north eastern and south western edges and a Police Station and further residential development to the north west beyond High Street. Land to the south east, beyond post and rail fencing, comprises open countryside. This site slopes from the highest point on the south east down to the High Street.
The site is located within Flood Zone 1, with areas of Flood Zone 2 abutting the north western edge as a result of Riseley Brook. It is located outside of the settlement policy area, has been identified as a key view and forms part of the Riseley Conservation Area as outlined in the Local Plan 2030 Policy Map shown in figure 2.
[See attachment for Figure.]
Site Assessment
Optimis propose that the land between no.34 and no.36 High Street, Riseley be allocated for residential development. The site has not previously been considered as part of the Bedford Borough Local Plan but presents a logical development opportunity within an established, sustainable settlement.
Whilst the site is currently located outside the Settlement Policy Area, it presents a logical infill to the village well located to existing built form on three sides. Through the creation of a strong boundary on the south eastern edge the site could be contained, and any future development could easily be incorporated in to the existing pattern of development.
It is acknowledged that the site is currently allocated as an important view. Upon review of the site from High Street, the north western boundary comprises established trees and hedgerows providing comprehensive screening. This thereby limits views into the countryside significantly and potential impacts on the visibility of the landscape are not considered to be adverse. Nonetheless, further assessment of landscape impacts and consideration of these throughout the design of the scheme could be facilitated through the site’s allocation. It should also be noted that rural settlements such as Riseley have many sections where views extent into the countryside. This site is not of any great importance and its designation is not sufficient to prevent the much needed delivery of homes in sustainable locations such as this. Form this site, public footpaths extend into the wider landscape where long distance views are afforded.
It is also acknowledged that the site is located within the Riseley Conservation Area. The heavily landscaped north western boundary has the potential to provide significant screening, aiding in the mitigation of visual impacts on the Conservation Area. It is recognised that the site would still be likely to give rise to less than substantial harm on a designated heritage asset and sufficient public benefits should accompany any future scheme to outweigh this. The provision of housing on a site well related to an existing sustainable settlement in response to housing need alongside the delivery biodiversity net gain, associated contributions and further public benefits identified throughout the design process could reasonably overcome this.
Constraints identified in relation to this site are therefore not detrimental to its development and could be overcome throughout the design process to ensure the scheme is deliverable without resulting in adverse harm.
The suggested Policy wording is as follows:
[See attachment for Figure.]
The below indicative parameter plan has been prepared to demonstrate how the site could be developed, identifying landscaping and green space on the site’s northern and southern boundary and residential development enclosed in the centre of the site’s in line with existing residential development on High Street.
[See attachment for Figure.]
Conclusion
To conclude, it is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic site’s and new settlements. The potential of smaller sustainable settlements throughout the borough in meeting housing need has been overlooked in favour of this, having extensive implications on the timescales for housing delivery throughout the plan period.
Riseley presents a logical location for development, comprising one of the most sustainable settlements in the northern area of the borough that would benefit from policy support. Additional but proportionate development in this location could be delivered quickly and provide valuable economic, social and environmental benefits to an existing community. The site outlined above presents a logical option for delivering development of this nature and should be considered by the Council for allocation alongside other extensions to existing sustainable settlement in the borough to alleviate reliance on substantial strategic site’s throughout the plan period.
Although designated in the Local Plan as an open view from the village, we consider that the scheme can be developed to retain views from the wider countryside from the southern edge of the site through the positioning of a sensitive viewpoint.

Object

Representation ID: 10238

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Site 726 The Walled Garden Willington
Settlement Assessment - Willington
Willington is located in the eastern portion of the administrative area and is an established rural settlement. There are a number of advantages in allocating residential development in Willington such as good public transport links to Bedford, a post office, public house, church, coffee shop, primary school, memorial hall, and recreational space. Appendix 4 of the Settlement Hierarchy (2030) with Addendum (2022) categorises the settlement as a Group 2 Rural Service Centre. The Council states that Group 2 villages have “good or reasonably good road and public transport links to Bedford and have better levels of service provision than settlements lower in the rankings”. On this basis, the settlement is considered sustainable, presenting a logical location for proportionate residential development. Willington as 5th highest ranking settlement under the Group 2 bracket, scoring 54.
The Bedford Local Plan 2030 describes Rural Service Centres as settlements that provide a “more localised convenience and service role to meet the day to day needs of residents and businesses in the rural area”. Policy 4S of the Local Plan 2030 addressed the amount and distribution of housing development in the Borough allocating Willington 25-50 homes throughout the plan period. This allocation suggests that Willington therefore presents a logical location for delivering housing in the eastern area of the borough which has been significantly overlooked for the provision of new homes throughout the adopted and emerging plans.
The Proposed Allocation
Site Details
The site is located to the southwest of Church End in Willington. It has not previously been promoted for inclusion in the Local Plan, however, following assessment of the draft document it is considered it could prove valuable in quickly delivering short term housing need.
The site, approximately 0.46ha, is located in the western area of Willington, a Group 2 village. The potential for site access is available from a private road to the north of the site. The site is relatively flat and has not previously been developed. The satellite location plan of the site is shown in figure 1 below and the site identification plan is available in appendix 1
[See attached for plan]
The site currently comprises open land, lined by walls and landscaping on all boundaries. Landscaping containing established trees and hedgerows is denser on the southern boundary of the site. St Lawrences Church and associated grounds abut the site’s eastern boundary, Willington Stables sits to the north of the site and Manor Farmhouse is situated to the south west. Existing residential development is located to the west of the site and either side of Church Road extending east away from the site.
Willington Stables comprises a Grade l listed building and St Lawrences Church and Manor Farmhouse comprise Grade ll listed buildings and wall structure. The site is located within Flood Zone 1 and it sits outside the Settlement Policy Area. The Local Plan 2030 Policy Map is shown in figure 2.
[See attached for plan]
Site Assessment
Optimis propose that The Walled Garden at Church End, Willington be allocated for residential development. The site has not previously been considered as part of the Bedford Borough Local Plan but presents a logical development opportunity within the built area of an established, sustainable settlement.
Despite the site sitting outside the Settlement Policy Area, it presents a logical extension to the village as it is well located with residential development situated to the west of the site and east of the site on either side of Church Road.
Whilst Willington has a made Neighbourhood Plan, it covers the period to 2030. This Local Plan covers the period 2040 and therefore there is an opportunity to identify this site for development in the latter stages of the plan post 2030.
The site is not within a conservation area and is not subject to any policy designations. The site is bounded by a soft edge to the south comprising of established trees and hedgerows extending west, providing screening. Views into the countryside are therefore not substantial and development in this location would have limited impact on the surrounding landscape. Despite this, further assessment of landscape impacts and consideration of these throughout the design of the scheme could be carried out through its allocation. There are a number of listed buildings within Willington, some in close proximity to the site, any scheme for the site will require sympathetic design and assessment and justification of these features, the potential impacts of the development and mitigation and public benefits that could be employed to outweigh harm.
The constraints identified will not be detrimental to its development and can therefore be overcome provided careful consideration is adhered to throughout the design process. This will ensure the scheme is deliverable without causing adverse harm.
Policy x – The Walled Garden, Church End, Willington
The Walled Garden, Church End, Willington will be developed for residential use. Key principle for development:
i. Provision of a range of housing types and sizes.
ii. Provision of a landscaping and tree planting scheme within the site and along site boundaries to reduce the impact of the development on wider views and in particular minimise impacts on heritage assets.
iii. The preparation and submission of a Desktop Archaeological Assessment and the preparation of further information recommended thereafter.
iv. Provision of a strategically designed and phased Sustainable Urban Drainage Scheme
v. Submission of a biodiversity report with appropriate mitigation and enhancements.
vi. Development should protect, preserve and where opportunities arise enhance heritage assets and their settings, including:
- Grade I listed St Lawrence’s Church
- Grade II listed Manor Farmhouse
- Grade II listed Wall at Manor Farm
Figure 3. Proposed Allocation Wording (Authors Own)
Conclusion
To conclude, it is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic site’s and new settlements. The potential of smaller sustainable settlements throughout the borough in meeting housing need has been overlooked in favour of this, having extensive implications on the timescales for housing delivery throughout the plan period.
Willington presents a logical location for development; it can deliver short term housing quickly and would benefit from policy to support this objective. Development that is sensitive and proportionate in this location will provide the existing settlement with economic, social, and environmental benefits. The site outlined above presents an option for delivering development of this nature and should be considered by the Council for allocation either immediately or post 2030 to align with the Neighbourhood Plan period.

Object

Representation ID: 10246

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Settlement Assessment - Wootton
Located in the southern portion of the administrative area, Wootton is a rural settlement. The Settlement Hierarchy (2030) with Addendum (2022) designates Wootton as a Key Service Centre within the Marston Vale growth area, classified as a Group 1 village. Wootton benefits from a number of services including a post office, public house, coffee shop, a number of schools, recreational and sports facilities, a convenience store and GP surgery. It benefits from good main road and public transport links to Bedford and has generally improved levels of service provision when compared to settlements that score lower in the rankings. The nature in which Group 1 settlements are distributed across the administrative area means that they can serve their surrounding rural area independently.
The Settlement Hierarchy (2030) with Addendum (2022) places Wootton as the 3rd highest in the ranks against all settlements in the Group 1 bracket, scoring 72 within Appendix 4. As one of the highest scoring settlements in Group 1 key service centres, Wootton is considered well-established and has good connections within Bedford Borough. Its strategic location and range of facilities make it a logical location for housing, capable of supporting a growing community. Its proportionate expansion would not only provide economic and social support for the settlement in isolation but also facilitate further improvements to these facilities through financial contributions and investment to the benefit of surrounding rural settlements that rely on the services it provides.
Paragraph 2.23 of the Local Plan 2030 addresses recent growth and change within the Borough. Wootton is described as a ‘growth area’ despite being allocated only 105 dwellings in the Neighbourhood Plan within the plan period. The settlement is able deliver significantly more development than this in the context of its sustainability. Only 105 dwellings over 20 years amounts to 5.25 dwellings per annum and is significantly disproportionate to the size and importance of the settlement.
The Proposed Allocation
Site Details
The site is located off Cranfield Road, south of Wootton. Despite not being promoted previously for inclusion in the Local Plan, it could prove valuable in quickly delivering short term housing need following assessment of the draft document. The site is approximately 5.3ha and is situated south of Wootton, a Group 1 settlement. The site is accessed directly off Cranfield Road, on its southern corner and its location is shown below in Figure 1. The site identification plan is available in appendix 1.
[See attached for plan]
The site comprises of an open field with a cluster of structures in the south-western corner. On three of its boundaries, the site is lined by trees and hedgerows. The site abuts existing residential development and Maple Tree Cottage self-catering accommodation on its southern edge creating a defensible boundary to the south. Residential development adjacent to the eastern boundary of the site beyond Cranfield Road was permitted in 2018 (LPA Ref. 15/02060/MAF) for the Erection of 600 dwellings, including vehicular access, pedestrian and cycle links, public open space, car parking, landscaping, drainage and associated infrastructure works. This demonstrates that substantial strategic development has been considered and approved on the boundary of Wootton, confirming its suitability as a settlement for expansion. Further south on Cranfield Road is additional residential development.
The site and its surroundings are located in Flood Zone 1. As shown in figure 2 below, the site is not within the Settlement Policy Area however is closely related to existing residential development on the southern boundary of Wootton. The site is not located in a conservation area and is not covered by any further policy designations. There are no listed buildings within the vicinity of the site.
[See attached for plan]
Site Assessment
Optimis propose that Land at Cranfield Road, Wootton be allocated for residential development. The site has not previously been considered as part of the Bedford Borough Local Plan however it has been assessed as part of the Wootton Neighbourhood Plan. Wootton has been recognised as a strategic area for development that has the potential to bolster the sustainability and growth objectives as set out in the previous and emerging Local Plan. The site presents a logical development opportunity adjacent to the built area of an established, sustainable settlement.
Although the site sits outside the Settlement Policy Area, it would create a proportionate extension to the existing development located off Cranfield Road acting as a gateway into the settlement of Wootton, particularly if delivered alongside land to the north which is Council owned. Land to the north of the site was assessed within the Wotton Neighbourhood Plan also. The allocation of this site would create a more sustainable gateway development into Wootton as opposed to the existing ribbon development that creates a scattered appearance with dwellings that have no succinct relationship and pattern. The site would create an extension that is logical for a settlement of its nature and scale.
The site is not located within any conservation areas and has not been allocated any policy designation and the site would therefore not pose any major policy constraints to residential development. The landscaping on three boundaries of the site provides valuable screening limiting the potential impacts of future development on the surrounding landscape and open countryside.
The provision of housing on a site in a high scoring settlement is a logical response to the housing need. The delivery of biodiversity net gain, associated contributions and additional public benefits identified throughout the design process would deliver further benefits to this settlement, enhancing its sustainability
The site presents no technical or legal constraint for the delivery of residential development and it is a logical option for allocation within the plan.
The suggested Policy wording is as follows:
Policy x – Land at Cranfield Road, Wootton
Land at Cranfield Road, Wootton will be developed for residential use. Key principle for development:
i. Provision of a range of housing types and sizes.
ii. Provision of a strategically designed and phased Sustainable Urban Drainage Scheme
iii. Submission of a biodiversity report with appropriate mitigation and enhancements.
iv. Cohesion with the adjacent residential development to the eastern boundary of the site on Cranfield Road for the promotion of a sustainable gateway for Wootton
v. Provision of a landscape buffer to the west and south of the site to protect views from long distance and the amenity of adjacent residents.
Figure 3. Proposed Allocation Wording (Authors Own)
The below indicative parameter plan has been prepared to demonstrate how the site could be developed, identifying landscaping and green space on the site’s western and southern boundary and residential development to the north eastern corner of the site to meet existing residential development on Cranfield Road.
[See attached for plan]
Conclusion
It is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic site’s and new settlements. The potential of sustainable settlements such as Wootton to meet the housing need has been overlooked which will have extensive implications on the timescales for housing delivery throughout the plan period.
Wootton demonstrates a logical location for development, comprising one of the highest scoring Group 1 settlements in the south-western area of the borough that would benefit from policy support for further housing. The site outlined above presents a logical option for delivering development of this nature and should be considered by the Council for allocation to alleviate reliance on substantial strategic site’s throughout the plan period.

Object

Representation ID: 10259

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Settlement Assessment – Brick Kiln Field, off Butler Road, Ravensden
Situated in the northern section of the administrative area, Ravensden comprises an established rural settlement. Despite its size, the settlement benefits from good public transport links to Bedford and surrounding settlements, a village hall, public house, corner shop, church, primary school and recreational space. Appendix 4 of the Settlement Hierarchy (2030) with Addendum (2022), that support the emerging Local Plan, categorises the settlement as a Group 3 village with a score of 28. It therefore benefits from a higher score than some of the settlements identified for draft allocations in the plan such as Gibraltar Corner, which scores only 8 in the Settlement Hierarchy.
The current level of housing provision allocated in Ravensden does not support the range of services presently available. In order to maintain these services, additional rural residential development would be beneficial in providing additional investment and economic support. On this basis, It is also important to note the value of development in this location in supporting the rural economy in line with the National Planning Policy Framework. Paragraph 84 notes that planning policies and decisions should enable “sustainable growth and expansion of all types of business in rural areas” and “the retention and development of accessible local services and community facilities, such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship”. As such, there is clear benefits to the provision of proportionate residential development in Ravensden which will aid in bolstering the existing economy, making full use of the sustainable services available in the settlement.
Whilst the settlement of Ravensden is small and covers several clusters of development, it is in a strategic location regarding its connections to Bedford. The village is situated less than 1km away from the urban boundary of Bedford and, therefore, benefits from good access to the wide range of services, facilities and transport links available in this area. The presence of services within the village and its proximity to Bedford Town, make it a unique locations for the delivery of sustainable rural development.
The Proposed Allocation
Site Details
The site is located off Butler Road at the crossroads onto Bedford Road, Ravensden. The surrounding area comprises of built form on three sides, two of which are residential. Beyond the built form on its northern boundary, the site abuts a green field site. Access to the site is currently gained off Butler Road. The site has not previously been promoted for inclusion in the Local Plan. The satellite location plan of the site is shown in figure 1 below and the site identification plan is available in appendix 1.
[See attached for plan]
Bedford Road (B660) sits less than 50m from the site’s entrance and runs south in to Bedford Town, reaching its boundary in 4 minutes. The site is located next to a bus stop that services routes to Bedford, Kimbolton and Pertenhall.
The site comprises of an open field lined by trees and hedgerows on three of its boundaries and a fence on either side of its entrance off Butler Road. The site is located in Flood Zone 1 and a Grade II listed building sits to the east of the site comprising the Old White Lion. The site sits outside the Settlement Policy Area for Ravensden and is not included the adopted policy map for the settlement.
Site Assessment
Optimis propose that Brick Kiln Field, off Butler Road, Ravensden be allocated for residential development. The site has not previously been considered as part of the Bedford Borough Local Plan but presents a logical development opportunity for rural housing located within a residential cluster associated with the settlement of Ravensden.
Whilst the site is currently located outside the Settlement Policy Area, it presents a logical expansion to the built form of Ravensden, well located to existing development on three sides. Through the creation of a strong boundary on the north western edge the site could be contained, and any future development could easily be incorporated in to the existing pattern of development.
As discussed above Ravensden comprises a sustainable rural settlement with unique access to surrounding Group 1 and primary service centres. It is therefore concluded that development in this location provides an opportunity to not only support the existing services within the settlement, thereby enhancing the rural economy, but also delivering increased economic support to existing services further afield.
It is acknowledged that a Grade ll Listed building is located to the east of the site on the corner of Bedford Road and Oldways Road. However, the site’s position to the rear of development on Butler Road and Bedford Road mean there is no clear sight lines or relationship between it and the listed building. As such, the development of this site is not considered to give rise to any impacts on the setting or appearance of this building.
The site does not present any technical constraint and is therefore a logical and sustainable site for the allocation of rural homes within the emerging Local Plan.
The suggested Policy wording is as follows:
Policy x – Brick Kiln Field, off Butler Road, Ravensden
Brick Kiln Field, off Butler Road, Ravensden will be developed for residential use to deliver housing. Key principle for development:
i. Provision of a range of housing types and sizes.
ii. Provision of a Sustainable Urban Drainage Scheme
iii. Submission of a biodiversity report with appropriate mitigation and enhancements.
iv. Provision of a landscaping and tree planting scheme within the site and along site boundaries to reduce the impact of the development on the wider open countryside
Figure 3. Proposed Allocation Wording (Authors Own)
Conclusion
It is considered that the emerging Local Plan 2040 and the proposed distribution of housing within it presents an over-reliance on substantial strategic site’s and new settlements. The potential of smaller sustainable settlements throughout the borough in meeting housing need has been overlooked in favour of this, having extensive implications on the timescales for housing delivery throughout the plan period.
Ravensden demonstrates a logical location for development, comprising a range of services and facilities that would benefit from additional economic support. The settlement is also sustainably located amongst other key sustainable settlements. The site outlined above presents a logical option for delivering sustainable rural development and presents negligible constraints preventing its use for this purpose. Development in this location would benefit from policy support and should be considered by the Council for allocation alongside other extensions to existing sustainable settlement in the borough to alleviate reliance on substantial strategic site’s throughout the plan period.