Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

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Representation ID: 7917

Received: 03/09/2021

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 draft policies and evidence base of the regulation 18 Bedford
Borough Local Plan 2040 (BBLP 2040). These representations are for land at Little Barford, east
and west of Barford Road, east of the East Coast Mainline (ECM) railway and west of the Black Cat to
Caxton Gibbet A428 road improvement (refer to enclosed drawing 068-001-012).

These representations and the accompanying technical documents demonstrate that following further
assessments and refinements to the proposals submitted to the call for sites and issues and options
consultations during August and September 2020, land within the control of the Alington Estate, Little
Barford can deliver a new settlement of circa 4,000 new homes and 3.61ha of employment land within
the plan period. Alternatively, a smaller area around the core of the existing settlement for circa 200
new homes and 3.61ha of employment land as a “transport corridor – east: parish growth” is also viable.

The focus of these representations is on the new settlement and parish growth options for Little
Barford identified under the “Growth and Spatial Strategy Options 2b, 2c and 2d” of the BBLP 2040
– Draft Plan Strategy Options and Draft Policies Consideration, June 2021.

These representations are accompanied and supported by the following technical documents:
• Drawing 068-001-012: Areas available for local plan promotion;
• Drawing 60830-PP-500 A: Highway access and development parcels – new settlement (BBLP
2040 reg 18 options 2b, 2c and 2d);
• Drawing 60830-PP-501: Highway access and development parcels – parish growth (BBLP 2040
reg 18 option 2d);
• Preliminary Ecological Appraisal, September 2021 (issue 3) prepared by Southern Ecological
Solutions;
• 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;
- 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;
• 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, September 2021 (revision A) prepared by Southern Ecological Solutions
incorporating the following:
- Tree Survey Schedule;
- Tree Survey and Constraints Plan.

2 Proposals being promoted
Two proposals are being promoted by the Executors; one for a new settlement in support of the broad
principles set out in Growth and Spatial Options 2b and 2c; and separate alternative proposals (a new
settlement or parish growth) in support of the broad principles set out in Growth and Spatial Option 2d
(refer to drawings 60830-PP-500 A and 60830-PP-501).

The site areas are 310ha for the new settlement proposal and 28.68ha for the parish growth proposal.
In both scenarios not all the land is proposed for development. Technical assessments are on-going to
establish a net developable area and a capacity study will be submitted at an appropriate stage in the
preparation of the BBLP 2040.

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
circa 4,000 new homes and 3.61ha of employment land. The parish growth proposal is capable of
delivering circa 200 new homes and 3.61ha of employment land. Development of the chosen proposal
will be supported by appropriate infrastructure.

The new settlement and parish growth proposals have assumed the following:
• retention of listed buildings1;
• 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 trees1;
• 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.

In addition to the above, the new settlement proposal assumes the following:
• no development within the inner and middle HSE zones of the high pressure gas main on the east
side of the ECM railway;
• subject to the capacity of existing education provision, on site provision of two primary schools (2ha
each) and one all through school or one secondary and an additional primary school (10ha);
• on site provision of schools will share facilities (eg hall, playing fields etc) with the community;
1 The completion of technical assessments will determine the extent of the settings of the listed buildings and the quality and management requirements of the woodlands.

• a site for a supermarket/convenience food retail store (2ha);
• facilities commensurate with a designation as a key service centre;
• 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 (the second point of access could be the second railway bridge, a new
junction with the A428 Black Cat to Caxton Gibbet road improvement, or improvements to links via
the Potton Road).

It is proposed that the policy wording within the BBLP 2040 allocating either site, would incorporate,
inter alia, the elements listed above.

3 Approach to site capacity
Technical assessments are on-going to establish a net developable area and a capacity study will 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.

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’:
• settings of listed buildings;
• anomalies arising from non-designated heritage assets;
• community facilities and local services (eg key service centre);
• bridge structures;
• junction on to A428;
• noise buffers (ECM railway andA428 improvement); and
• biodiversity net gain.

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 parish growth option and new settlement option for
Little Barford could (if required by BBC) 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 circa 200 and circa 4,000 new homes respectively and 3.61ha of
employment land is deliverable within the plan period. Housing trajectories will be provided at an
appropriate stage in the preparation of the BBLP 2040.

4 Spatial Strategy
Development should be focused in locations that can maximise the gains from connections to the
economic centres in Bedford, Cambridge, Milton Keynes and Oxford.

The Issues and Options consultation paper notes that, “Bedford borough has a skilled workforce, an
above average rate of employment and a high proportion of ‘top level’ occupations. The economy of
Bedford is diverse and vibrant, however many of the most skilled jobs are located outside of the borough
as Bedford benefits from good strategic connections to nearby economic centres.”

Locating housing in areas with convenient and safe access to the rail network through the stations,
improved and created by the EWR, will allow the borough to continue to attract residents with ‘top level’
occupations who may work outside of the borough but spend locally. The Oxford Cambridge Arc
declaration highlights the issues of housing affordability in Oxford and Cambridge where the affordability
ratio is 12.34 and 13.35 respectively. By enhancing the connectivity to these two cities, Bedford can
capitalise on its relative affordability in comparison and provide an alternative location for employees to
reside.

There is also the opportunity to attract high level businesses to the area due to the connections across
the region and Oxford Cambridge Arc that Bedford Borough’s location provides. The central location
between Oxford and Cambridge would be an attractive proposition to business looking to take
advantage of the high calibre work force available. Collaboration and clusters are often at the heart of
promoting successful business locations and this is something that needs to be emphasised by BBC to
attract these high-quality businesses.

To realise either of these opportunities BBC needs to ensure that residential and employment
development is located in areas with or the potential to have the highest connectivity. Development at
Little Barford, together with the completion of the EWR and construction of a new station in proximity
to the site, could serve as a destination for collaboration in employment and a suitable location for
people working at either end of the Oxford Cambridge Arc.

We consider the EWR route is a significant infrastructure development to enhance the connectivity of
Bedford Borough with other economic centres. Locations with convenient and safe access to the
gateways to the rail network should be the focus of growth. It is acknowledged that the proposals for
EWR are required to successfully pass through several development stages and approvals before they
become a committed infrastructure project. However, even without EWR Little Barford is strategically
located within the Oxford Cambridge Arc sufficient to justify a new settlement allocation.

5 Conclusions
The assessments identified under paragraph 1.4 of this representation have influenced the extent of
the proposals (parish growth and new settlement options).

Evidence prepared to date in respect of the proposals for the Alington Estate is proportionate to the
stage of plan preparation. The completion of further technical assessments will, in combination with a
recognition that development can be a catalyst for sustainable development, as described in the NPPF,
define the scale of allocation at Little Barford. However, at this stage of the plan making process
evidence demonstrates that the proposals for the Alington Estate, Little Barford are “effective” in that
they are deliverable over the plan period.

These representations and the technical documents that accompany them demonstrate that both the
transport corridor – east: parish growth and new settlement elements of the growth and spatial strategy
options 2b, 2c and 2d are deliverable in respect of the proposals at the Alington Estate, Little Barford.