Plan for submission evidence base

Object

Representation ID: 9588

Received: 29/07/2022

Respondent: Arrow Planning Limited

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

4.1 The land at West Park Farm sits immediately south of Wilstead, as shown on the Site Location Plan enclosed at Appendix 1. The land measures c.21ha and was submitted to BBC through the Call for Sites process in 2020. Enclosed at Appendix 3 is the Council’s
assessment of the site contained in the Site Assessment Pro Formas.
4.2 The land has previously been put forward for a residential development, with the Council’s assessment suggesting 525 homes. Curiously, whilst considering the site for residential development, the appraisal concludes stating that the site is not a preferred location for employment. This is a concern and suggests the site has not been correctly assessed compared to what it has been proposed for.
4.3 Furthermore, the assessment concludes that the site was excluded from further assessment as its location is not in accordance with the Development Strategy. Again,
this is a fundamental flaw as the site location does accord with the development strategy, namely growth south of Bedford including in the parish of Wilstead.
4.4 Our previous representations (August 2020) set out a thorough consideration of the site against the assessment criteria, repeated below for the Inspector’s benefit. Having reviewed against the updated proforma, the Council’s assessment has not failed to consider these proposals. Of particular note is the response to question 3a, concerning renewable energy. As those representations evidenced (and seen below), the site is
proposing a net zero carbon scheme with wind and solar. This is further evidence that the site has not been correctly assessed by the Council.
4.5 A full and thorough assessment of the site, carried out in accordance with the full evidence base and the proposals as put forward on behalf of the landowner, would find that the site should be allocated. The Local Plan is, therefore, unsound as it is not justified. The Local Plan should be modified to allocate the land at West Park Farm for housing and renewable energy development. This is necessary to both respond to the evidence base, and to make up the shortfall of housing that will result from the correct assessment and planning of the other south of Bedford sites, as set out in Section 3 of
these representations.
4.6 As set out in our previous submission, a more detailed land use assessment of the site and the enclosed illustrative masterplan (Appendix 2) demonstrates how the site could provide the following net zero carbon development1:
• 13.6 hectares of residential (511 dwellings at around 37.5 dph - 1.9 hectares is shown as 'multi-generational housing)
• 5.5 hectares of solar, a large scale (potentially 6MW) wind turbine and ground sourced heating infrastructure to supply homes with hot water 1 Definition of Next Zero Carbon for operational energy: “When the amount of carbon emissions associated with the building’s
operational energy on an annual basis is zero or negative. A net zero carbon building is highly energy efficient and powered from on-site and/or off-site renewable energy sources, with any remaining carbon balance offset”. Source: Government Property
Agency, Net Zero and Sustainability Design Guide – Net Zero Annex, August 2020
9 Pre-Submission Local Plan Consultation Response ● APL–046
• 1 hectare school site (single form entry)
• 2 hectares playing fields
• 3.3 hectares of woodland in addition to woodland buffer planting
• Allotments
• Community Hub
• Retail/café with EV charging
• A new roundabout on the A6 at the Chapel End Road junction
• A new cycle/footpath connection into Wilstead along the ‘old’ route of the A6
4.7 The proposals are a comprehensive approach to delivery of a net zero carbon, highly
sustainable development within the southern parish of Wilstead. The proposed development would meet the requirements of national policy, particularly in relation to
climate change, and would be an exemplar development that would assist the Council as a flagship scheme to lead the way for other developments to follow, so assisting the Borough in moving towards becoming a net zero carbon Borough.
4.8 The Site is in a single ownership, is available and is deliverable, being actively promoted by the landowner. It is not reliant upon any third parties and would be
capable of “consuming its own smoke” in terms of infrastructure. The Site could, therefore, be delivered early within the plan period.
4.9 The proposed development has several key benefits that meet the aims and vision of both the Local Plan, and national policy. In addition to being a net zero carbon
development with renewable energy and heat alongside development, it would deliver multi-generational housing and a new school, as well as major highway improvements. The ability to connect to the settlement of Wilstead with a new cycle/footpath connection enhances the sustainability of the Site, and enhanced by the
topography, it is in an excellent location to connect to the new Wixams station, the proposed East-West rail station north of Stewartby, and the nearby proposed Bedford
Business Park. The homes would therefore be in an excellent location by providing opportunities for people to live and work locally and reduce reliance upon the private
car.
4.10 The Site Proforma confirms that the land is adjoining a defined settlement area, and that there are no major issues that would preclude the allocation of the Site. Turning to more detailed aspects of the Council’s assessment and, in turn, the evidence base for this Local Plan, there are a number of positive matters which further point towards the case for allocating this Site.
Highways and Access
10 Pre-Submission Local Plan Consultation Response ● APL–046
4.11 The Bedford Borough Local Plan Transport Access Assessments document2 (site ref 686)
finds that the proposed highway mitigation is possible and scores the Site with an amber rating. It does not highlight any technical issues with the Site and, those matters that score less well (namely bus stop and cycle connectivity) would be addressed as part of the development. The subsequent proforma assessment (Appendix 3) does not identify any highway or access constraints that cannot be mitigated against and does
not raise any objections to the mitigation proposed in the submission.
4.12 The highway summary of the Site correctly notes that a development of this scale would have the ability to either provide its own bus stop or deliver a flexible public transport service. Thus, the scoring of the Site regarding public transport would improve and, given the proximity to both the Wixams rail station and new East-West rail station near Stewartby and the proposed Bedford Business Park, it would be realistic for a shuttle
bus service (or similar) to connect this development, local villages, and those locations.
4.13 Turning to cycle, the layout at Appendix 2 shows how the Site would connect to Wilstead, with a new cycle connection along the former route of the A6. The
topography in this area is relatively flat, and thus conducive to cycling, and therefore the Site is one that would be a realistic cycling option for residents to choose to cycle.
4.14 Finally, the delivery of a new roundabout at the Chapel End Road/A6 junction (as shown in Appendix 4) would deliver wider highway benefits. Presently this junction is one which has experienced several accidents over recent years, a risk that may be increased given future development pressures in the locality. The delivery of a new roundabout would have considerable benefits in terms of highway safety, whilst not resulting in congestion issues on the A6 given the distance to other junctions.
Heritage
4.15 The summary Site Proforma refers to potential harm to heritage assets. However, upon examination of the Historic Environment Assessments that forms part of the evidence base, the assessment finds that there are no known heritage assets, and only that a
“pre-determination evaluation will be required”.
4.16 The document also confirms that there is unlikely to be an impact on Listed Buildings.
The concluding comments in the assessment, that, in effect, find that there ‘may or may not be’ a harmful impact on heritage assets or their setting is misleading, if not completely incorrect.
4.17 There is, therefore, no reason to find that the Site should be excluded on heritage grounds. This is in direct contrast to other allocated sites, in particular HOU13 with
several heritage assets (not just buildings but features such as ridge and furrow) identified as requiring mitigation within the Policy wording.
Landscape
2 Link in paragraph 5 of the Site Assessment Pro Formas June 2021
3 Link in paragraph 5 of the Site Assessment Pro Formas June 2021
11 Pre-Submission Local Plan Consultation Response ● APL–046
4.18 The Site sits within the East Marston Clay Vale (5E) as identified in the Landscape Character Assessment (2014, updated 2020) (‘the LCA’). The LCA finds that this area has a number of urban and built form influences, namely:
• Large scale industrial features such as distribution warehouses
• Roads, such as the A6, with a strong visual and audible presence
• The urban edge of Bedford and development along the A6 associated with Wilstead brining urban fringe characteristics.
4.19 The vale is low lying, and the Site itself sits within this low topography. The Site benefits from the change in levels to the east and south, and the Ancient Woodland to the east of the Site. This change in topography, along with the woodland, provides a sense of enclosure for the Site, separating it from the changing character further south and preventing the feeling of encroachment into the wider countryside.
4.20 The LCA in particular identifies that the settlement edge expansion of Wilstead is a potential future change to the landscape4, thus acknowledging that growth in this area is something the landscape is likely to accommodate. Moreover, the LCA identifies (para
SE.1.42 p.120) that this future growth must prevent linear expansion and the merger of villages, with specific reference to the potential for the merger of Wixams with
Wilstead.
4.21 This means that, based on the LCA, the only possible location for growth of Wilstead is to the south. Any growth to the north or west would lead to a potential merger with Wixams, whilst to the east there is the risk of coalescence with Littleworth.
4.22 Plainly, therefore, allocating the Site for development would be a logical approach considering the landscape evidence base for the Local Plan.
Summary
4.23 The land at West Park Farm, south of Wilstead, is being actively promoted for a net zero carbon development of some 515 homes, with a school, multi-generational housing, transport infrastructure and large-scale renewable energy and heat.
4.24 The Local Plan evidence base finds that this location is a logical and appropriate location for development; indeed the LCA actively points to this location (by process of elimination) for future growth. The Site would accord with the emerging development
strategy for BBC and would deliver housing in a sustainable location, together with renewable energy, as advocated in the NPPF.
4.25 The land at West Park Farm should therefore be allocated for development (housing and renewable energy) within the Local Plan.
4 Page 119, Landscape Character Assessment (2014, updated 2020)