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

Support

Representation ID: 8584

Received: 27/09/2021

Respondent: Elstow Parish Council

BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from ELSTOW PARISH COUNCIL September 2021
OVERVIEW
This document represents the considered response of Elstow Parish Council to the strategic
proposals set out by Bedford Borough Council (BBC) in their consultation conducted June to
September 2021.
Our Approach to the Consultation
Elstow Parish Council is experienced in understanding the due process relating to public
consultations and is therefore mindful of the importance of presenting clear and robust evidence
even at this consultation stage, to ensure that Elstow Parish Council makes clear its view as the
first tier of local government. The Parish Council, have a further roll as always, serving its
electorate and ensuring they are supported through this process, so there has been additional
work done ensuring residents are not only aware of the proposals, their direct impact on Elstow,
but also in further encouraging residents to effectively engage in this consultation process.
The Parish Council also feels at this stage of drafting such a significant development strategy
document that it is important to reiterate to the Borough Council, Elstow specific items that have
previously been expressed.
Elstow Parish Council, as usual, has been active in attending the local authority led consultation
events directed at local parishes. As a small parish Elstow Parish Councillors have spent time
studying the consultation documents, however, must feedback that it has been very challenging
for Councillors to do this within the consultation timeframe. Elstow has a number of new
Councillors who have not been through a Local Plan process before so it has been quite over
whelming at times for them to come forwards with feedback on a topic which is so new to them.
The many different technical and complex items being considered mean it has been difficult to
ensure that all areas receive sufficient scrutiny and appropriate coverage within this Parish
Council response. More so when Councillors are all volunteers and the Clerk is only part time
for a few hours a week. Naturally this has been frustrating for those representing Elstow as it
understood the significance of the proposals within this consultation given Elstow’s geographical
location in relation to the A241 transport corridor. Trying to decipher not only so many different
strategic options, in addition to a huge number of important accompanying planning policy
documents which will shape the future of Elstow and all local communities across the Borough,
really has been testing.
The Parish Council have tried during the consultation to support Elstow residents to make sure
they are aware of the enormity of the proposals, and that they can have their say and their voice
heard. This has included communicating via a leaflet to every household in the whole parish, to
set out why it is important to become involved and how to respond to the consultation.
The Parish Council as previously detailed – all volunteers and all laymen in this particular field -
have become increasingly conscious of the level of technical detail contained in the many, often
large local authority documents which need to be read and understood before attempting to
communicate with our residents and before collating this response to this consultation. This has
been compounded further because of the government Covid restrictions, new Councillors and
some Councillors being unable to support their colleagues as they would have liked. Elstow
Parish Council would also like to highlight that they do not have access to specialist planning
professionals so have very much wished to focus on their local knowledge of the historic parish
they are proud to call home.
1
BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from ELSTOW PARISH COUNCIL September 2021
It should also be noted that due to the challenges set out above during this consultation, it has
impacted on any opportunity for any meaningful engagement with neighbouring areas. Elstow
always look to work collaboratively and cohesively with its neighbouring rural communities,
however this has simply not been possible on this occasion.
As a result, for this stage of consultation on strategic development options, it was important to
Elstow Parish Council that they focus on Elstow only. Local communities around the borough
area will be better equipped to represent with their superior local knowledge of the area(s) they
serve.
The Parish Council response will focus on these six key areas:
1. Draft Plan: Strategic Options
2. Draft Plan: Overall Strategic Policy
3. Draft Plan: Draft Policies
4. Urban Area - Safeguarding Elstow
5. Elstow Important Local Factors
6. Consultation Accessibility
The consultation submission will reflect the supporting evidence collated, thus enabling Elstow
Parish Council to provide information on how truly detrimental and catastrophic poorly thought
out development strategy options would be and how negatively they would impact on a small
rural village such as Elstow.

Support

Representation ID: 8585

Received: 27/09/2021

Respondent: Elstow Parish Council

The Parish Council has provided feedback to the specific development options, it is also very
mindful that the areas east of the A6 and south of the A421 are not truly reflected in terms of
their landscape value. Given their location, and proximity within the Greensand Ridge and
South Eastern River Valley. Whilst they are located near to transport links this must not be an
automatic assumption that they are suitable for substantial development. These areas in and
around Elstow deserve to be viewed and valued as unique and valuable in their rural setting
between the River Valley and Greensand Ridge.
An area such as this which includes copious amounts of ancient rural landscape includes many
important historical and natural features which are protected rightly so to enable them to be
preserved as they are of such a special heritage value. Items range from remains of medieval
field systems, villages, water courses and listed buildings and provide a beautiful contrast to,
the view from the Greensand Ridge. Naturally large scale development in these two sensitive
areas would irreversibly alter the rural character and unique landscape setting of the Eastern
Clay Vale villages (5E in the Landscape Character assessment).
Any such development within this area, would also clearly be in contradiction to the Landscape
Management Guidelines 5E.1.31 through to 5E.1.40 and Development Guidelines 5E.1.41-51.
These guiding principles set out conserving the open large scale setting of Cardington Airship
sheds, preserving the clear views and visual relationship with the Mid Greensand Ridge, as well
as conserving the dispersed pattern of settlements. Particular attention should be given to this
as an important factor to prevent the merger of villages and coalescence.
Elstow Parish Council feel this area should continue to provide an open, agricultural setting to
Bedford and contrast to the Greensand Ridge as stated in the landscape strategy for this area.
This reinforces the Parish Council’s selection of Option 2c as the preferred option as it seeks for
growth closer to new train stations. Thus preserving the unique character and rural nature of
the southern and eastern parishes like Elstow that would then be protected.

Support

Representation ID: 8586

Received: 27/09/2021

Respondent: Elstow Parish Council

The Parish Council has provided feedback to the specific development options, it is also very
mindful that the areas east of the A6 and south of the A421 are not truly reflected in terms of
their landscape value. Given their location, and proximity within the Greensand Ridge and
South Eastern River Valley. Whilst they are located near to transport links this must not be an
automatic assumption that they are suitable for substantial development. These areas in and
around Elstow deserve to be viewed and valued as unique and valuable in their rural setting
between the River Valley and Greensand Ridge.
An area such as this which includes copious amounts of ancient rural landscape includes many
important historical and natural features which are protected rightly so to enable them to be
preserved as they are of such a special heritage value. Items range from remains of medieval
field systems, villages, water courses and listed buildings and provide a beautiful contrast to,
the view from the Greensand Ridge. Naturally large scale development in these two sensitive
areas would irreversibly alter the rural character and unique landscape setting of the Eastern
Clay Vale villages (5E in the Landscape Character assessment).
Any such development within this area, would also clearly be in contradiction to the Landscape
Management Guidelines 5E.1.31 through to 5E.1.40 and Development Guidelines 5E.1.41-51.
These guiding principles set out conserving the open large scale setting of Cardington Airship
sheds, preserving the clear views and visual relationship with the Mid Greensand Ridge, as well
as conserving the dispersed pattern of settlements. Particular attention should be given to this
as an important factor to prevent the merger of villages and coalescence.
Elstow Parish Council feel this area should continue to provide an open, agricultural setting to
Bedford and contrast to the Greensand Ridge as stated in the landscape strategy for this area.
This reinforces the Parish Council’s selection of Option 2c as the preferred option as it seeks for
growth closer to new train stations. Thus preserving the unique character and rural nature of
the southern and eastern parishes like Elstow that would then be protected.

Support

Representation ID: 8587

Received: 27/09/2021

Respondent: Elstow Parish Council

The Parish Council wish to highlight within this section, as previously stated, it is very important
that any employment site selected should also be subject to environment and biodiversity net
gain.

Support

Representation ID: 8588

Received: 27/09/2021

Respondent: Elstow Parish Council

The Parish Council feel it would be a better approach by the local authority if they set clear
objectives within the document immediately which show a proactive stance, as well as the
important value from net gain requirements from the start of this plan being developed. National
planning policy will come into effect shortly and it would be logical for this to be built in as the
Plan emerges, rather than potentially being not included, which would be a pity. This re-enforced by Natural England who recommend that a commitment to biodiversity net gain
is made within a bespoke policy to demonstrate best practice. If the policy is not active than it
will be impossible for the local authority Officers not only at Planning Policy level but also when
planning applications come forward, any potential benefit in terms of biodiversity will be lost.

Support

Representation ID: 8589

Received: 27/09/2021

Respondent: Elstow Parish Council

The Parish Council were encouraged to highlight to Officers that there appears to be insufficient
detail in the Natural Capital assessment. It would be helpful to have access to this, as well as
the inclusion of this to show that the management and development guidelines in the
Landscape Character Assessment are considered within the Natural Capital network as the
maps of opportunities seem rather sparse in this 5E Eastern Clay Vale area. The fields below
the Ridge are plentiful in small springs / ponds / watercourses that may not have shown in
general habitat assessments but are oases of biodiversity which could be valuably enhanced.
This area is also home to a variety of farmland birds which may not fit with development plans,
even for net gain opportunities as they require farmland and hedgerow habitats. This may not
be reflected properly in the assessment of development in the Southern and Eastern parishes
against Objective 2 of the sustainability appraisal which is rather broad brush when assessing
biodiversity impact.

Support

Representation ID: 8590

Received: 27/09/2021

Respondent: Elstow Parish Council

The consultation references a significant number of accompanying policy documents that are
being reviewed as part of the Local Plan process. Again this is a huge challenge to fully
understand the terminology, digest the technical nature of the documents, and to fully
appreciate and understand the context of which these policies will be used by the local authority.
These policies will effectively underpin the strategic development through to 2040, so they are
hugely important. The Parish Council understand the need for robust and effective planning
policy documents to support positive experiences for all stakeholders involved within the
planning process. Whilst the Parish Council are sympathetic to the difficulty in balancing all the
different needs and consideration, it is absolutely critical that these policy documents enable the
local authority decision making process to be secure.
Housing growth allocation numbers calculated by BBC that have been identified are of concern
to the Parish Council. Whilst the Council are not familiar with the calculations of such data, it
was interesting to read Bedfordshire Campaign to Protect Rural England’s submission to this
consultation which raised some alarmingly and most worrying discrepancies with BBC’s growth
when compared to nearby local authorities. Therefore, the Parish Council wish to seek clarity
on the questions raised given the presented evidence within the CPRE response that clearly
show Bedford Borough having a disproportionate amount of growth.
Given Elstow’s locality the Parish Council will set out in 4. Urban Area Boundary Safeguarding
Elstow further specific feedback to the part of the consultation regarding the urban area
boundary.
Frustratingly, with the limited resources of the Parish Council it has not been possible to study in
greater depth all the detail within these documents which relate to Elstow However, there are
some specific policy items that it is wished to raise, these are set out below.

Support

Representation ID: 8592

Received: 27/09/2021

Respondent: Elstow Parish Council

4. URBAN AREA - SAFEGUARDING Elstow
Elstow Parish Council is passionate when it comes to the amazing historic, gem of a rural
village that Elstow is.
Local authority Planning Policy Officers have been involved during meetings with Parish
Councillors to hear first hand the importance of safeguarding Elstow, whether it is protecting the
green buffer area behind Thomas James Close, or the magical setting of Elstow Abbey.
As a village proudly steeped in history, Elstow Parish Council as part of their response have
worked on ensuring these elements, plus many more, are presented to this Local Plan 2040
consultation, as it is important that it is all formally recorded. Not just for this consultation
process, but for those that will follow, why Elstow must retain its unique setting given its
abundance of character. This part of the Parish Council response looks to set out clearly the
many different, but all equally important factors, of why Elstow’s rural identity must be kept.
Village Development History Overview
Elstow has seen change of a massive scale in recent years. There is the development of
Progress Way/Hillesden and Abbeyfields estates [which quadrupled the number of residents
living in Elstow], the huge Interchange Retail Park, which is expanding further with the B&Q and
M&S additions, whilst the access road is nowhere near suitable. The development of the A421
bypass split the village and the construction of the BP station and hotel simply added to the
police crime list. There have been a number of infill developments within the village with more in
the “pipeline”, including the old school site. There is also the park and ride, the massive Health
Care Logistics/Audi complex, in addition to the large retirement complex.
Apart from the re-location of the school to its current site, and increased size, in Abbeyfields,
there has been no increase at all in the facilities in the parish as a result of these changes, in
fact there's been a decrease following closure of the Swan pub, a middle school, and shop at
Peartree View.
There has continued to be significant increases in through traffic and their speed in the village,
to the disadvantage of local residents, and clearly this would increase if further development
were to come to Elstow or the surrounding area.
The Parish Council's aspiration, and the strong feelings amongst residents, is that Elstow is
essentially a very unique and historic village. The Parish Council want to protect the character of
the village, including the ancient Abbey and Moot Hall, and to prevent any further damaging
coalescence with Bedford or changes to the village parish boundary. It has to be taken into
account that Elstow has a fantastic conservation area and adopted Plan which is designed to
protect the village, and its history, and it cannot be right to add further development, to a village
which must rank as the most developed village in Bedfordshire, which, by any view, is entirely
detrimental and contrary to such a Conservation Plan.
Important Local Planning Information
The Parish Council would like to draw Officers attention to the recent planning application for
development of 34 houses at Village Farm, which was recommended for refusal by Borough Officers. This again re-enforces the supporting planning policy reasons as to why these areas
are so important in terms of Elstow’s character and history. Below is the extract from the 2015
report prepared by Planning Officers:
The Urban Gap was identified in the Urban Area Boundary Review as a means of preventing
coalescence and to contribute to the separate character and identity of the settlement. The
quality of the landscape is not considered in the designation of an Urban Gap. Whilst the Urban
Area Boundary Review states that the green spaces cannot be considered countryside due to
being surrounded by development, it does identify this particular area of Elstow as having a
rural-like character, which is contributed to by the historic farm buildings that front onto Wilstead
Road. It notes generally that the Urban Gaps in this area provide a separation between the
historic core of Elstow village and the more suburban character of more recent surrounding
development.
The proposal does not allow for the retention of any green corridor to the northern Urban Open
Space, occupying as it does the entire space between the rear of the buildings on Wilstead
Road to the west and Elstow School to the east. The proposal includes an area of open space
between the southern and northern parcels, but this does not address the reasons for the
Urban Open Space and Gap designations. The site assessment that was completed as part of
the Allocations and Designations Local Plan acknowledged that the site would represent
development into an open space that provides a buffer against coalescence, a point backed up
by the reason for the Urban Open Gap designation. In its present form the proposed
development would conflict with the rural “feel” of the area. It would effectively remove the
green corridor linking in to urban open space in the north as well as the gap between the
suburban development of Abbeyfields and the more rural feel of Wilstead Road and it is
considered that this compromises the purpose of the Urban Open Space and Urban Gap. - 83 -
Heritage Issues
Section 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 imposes
a statutory duty on LPAs to have special regard to the desirability of preserving listed buildings,
their settings and any features of special architectural or historic interest they may possess; and
preserving or enhancing the character or appearance of a Conservation Area. Saved Local Plan
Policies BE11 (setting of Conservation Areas), BE21 (setting of listed buildings) and Policy
CP23 of the Core Strategy reflect those duties. Chapter 12 of the NPPF sets out the
Government's national policies on the conservation of the historic environment. The site lies to
the southeast of the designated Elstow Conservation Area and the Grade I listed Hillersdon
Manor, also a Scheduled Monument. There are numerous listed buildings along Wilstead Road,
including Acacia Cottage, Village Farm and curtilage listed barns, 193 Wilstead Road, Merrick
Cottage and Lynn Farmhouse, all listed Grade II.
Part of the significance of these listed buildings is their historic interest. The character of the
road, including both the settings and contexts of the above heritage assets, is the semi-rural
nature of this ribbon development. This road distinguishes the change in character on entering
and leaving Elstow Conservation Area. Therefore, the retention of the semi-rural character of
this area is important both to the context of the Elstow Conservation Area and the setting of the
identified listed buildings.
A development of 34 dwellings on the site would undermine the semi- rural character of this
area and would thus create a much more urban setting to the identified listed buildings. The
semi-rural setting of Village Farmhouse and associated traditional agricultural buildings is
important to the historical development of the original farm complex and further erosion of the
setting would be considered harmful to this identified significance. Two access points into the
development have been proposed, in particular that adjacent to Village Farm barns has the
potential to over formalise this area through the hard landscaping required. This could further undermine the semi-rural character of the settings of the identified barns and Village
Farmhouse. The historical significance of the ribbon development pattern along Wilstead Road
would also be further undermined by the infill of land to the rear of the properties to the east of
Wilstead Road.
The Conservation Officer therefore advises that that the application would fail to preserve or
enhance the setting of the identified listed buildings.
The proposed development site is located in an area of cropmarks comprising a number of ring
ditches and linear features some of which have been previously investigated both as part of the
bypass investigations and also the school to the east. The investigations identified remains of
Late Neolithic/Early Bronze Age ring ditches, an Iron Age settlement, and settlement from the
Saxon through Medieval period also. In addition to this the HER records the presence of a
possible small Quaker burial ground within the site, traces of gravestones are recorded as being
visible possibly as late as the 1950s in local newspaper articles.
In conclusion, the proposed built development would result in a significant incursion into the
urban open space and gap which would be harmful to the character and appearance of the
area. The development would also undermine the semi- rural character of the area and would
thus create a much more urban setting which would be detrimental to the setting of the Grade II
Listed Buildings at Acacia Cottage, Village Farmhouse and barns, 193 Wilstead Road, Merrick
Cottage and Lynn Farmhouse. It would thus fail to meet the statutory duty under s66 of the
Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to
preserving the setting of listed buildings.
RECOMMENDATION: Refuse Permission for the following reasons:-
1. The proposed built development would result in a significant incursion into the urban open
space and gap which would erode the visual break between the historic core of Elstow village
and the more suburban character of more recent surrounding development and result in the
loss of the green corridor linking in with the urban open space to the north. The development
would therefore compromise the purpose of the urban open space and urban gap and be
harmful to the character and appearance of the area, contrary to saved Policy BE30 (i) of the
Bedford Borough Local Plan 2002; Policy CP21 (iii, vii) of the Core Strategy and Rural Issues
Plan 2008; and Policy AD43 (viii, ix) of the Allocations and Designations Plan 2013. - 90 -
2. The proposed development, by virtue of its scale, siting and layout would undermine the
semi- rural character of the area and would thus create a much more urban setting which would
be detrimental to the setting of the Grade II Listed Buildings at Acacia Cottage, Village
Farmhouse and barns, 193 Wilstead Road, Merrick Cottage and Lynn Farmhouse. The
development would therefore be contrary to saved policy BE21 of the Bedford Borough Local Plan 2002 and policy CP23 of the Core Strategy and Rural issues Plan 2008.

5. ELSTOW IMPORTANT LOCAL FACTORS
The Parish Council feel it is important even at this early stage of the strategic development
framework process to outline some vital, important local factors, which will enable Planning
Policy and local authority colleagues to be more aware of the issues within the parish when
reviewing potential sites.
In addition to the Conservation area, historic architecture of both Moot Hall and Elstow Abbey,
plus proximity to the urban edge of Bedford, which have been touched on, there are are also
some other items to be aware of.
The village is an established 'rat run' which is well documented, as traffic comes into the village
travelling in huge volumes during peak times. The most popular route is from the A6 travelling
in both directions, along Wilstead Road, onto the High Street, then West End, through to the
Cowbridge junction which even after numerous redesigns still suffers from monumental levels of
congestion. There is also the Progress Way traffic flows which are significant as a popular route
on the local network. The cumulative impact of both these makes highways a real issue in the
local area throughout the week.
The popularity of Elstow Primary School attracts pupils from a wide area. It is located in
Abbeyfields many travel to the school by car and on regular occasions cars are parked and
there is total grid lock at the end of the school day. There has been a number of incidents in
recent years involving pedestrians being knocked down. The school has been extended by two
additional forms to create a primary school which has resulted in further pressure for parking.
Elstow is rightly proud of its local environment, wildlife and heritage assets found throughout the
village. The abundant wildlife along Elstow Brook, in the meadows along Abbeyfields through to
its infamous connection to John Bunyan. The Parish Council have a range of resources
evidencing this which all act as further proof that Elstow is a unique parish. To change the
setting of these world renowned connections that really are at the centre of Elstow would be
devastating.
As mentioned earlier within this response, Elstow sits in a very rich local landscape, any
development would impact negatively, in particularly in regards of visual impact. For example
any current open spaces or green areas in the parish, if development were to be sought then it
would have a visual intrusion on either the John Bunyan Trail, Cardington Air Sheds or Elstow
Abbey. In addition to this, there is the heritage asset of the Medbury medieval village
earthworks.
Much work, effort and volunteer time has gone into improving and strengthening the visual
appearance of the village. The manicured grass at the Playing Field, the award winning
Abbeyfields Roundabout Group with their colourful floral displays, through to the popular tourist
attraction destination of Moot Hall. Growth within a community evolves over many years, it is a
concern of the Parish Council if a large housing allocation were to be be allocated to Elstow
then it would not sit naturally within the close knit community.
In recent years, Elstow has seen a significant change in the local landscape in terms of flooding
and drainage. Reports of issues with watercourses within Elstow have not only become more noticeably frequent but also more wide spread, these have been reported to and followed up by
the Internal Drainage Board as well as the Environment Agency.
Also the local authority need to be mindful of the different, but exceptionally characterful parts of
Elstow which differ greatly. The area off Wilstead Road, around South Avenue has no street
lights, there is a strong sense within that community that if this were to change it would totally
alter the setting.

Support

Representation ID: 8593

Received: 27/09/2021

Respondent: Elstow Parish Council

6. GENERAL CONSULTATION ACCESSIBILITY
As mentioned earlier in this consultation response it has been a very challenging time to engage
in a process like this during a transition phase in a global pandemic. Not only is this
unprecedented, it is very clear, not just in the local community, but further afield that individuals
are adjusting to changes in government guidance in different ways depending on their personal
circumstances. This has meant enormous complexities for stakeholders and consultees, in
Elstow, which has a sizeable demographic who are not online, a generation who much prefer
face to face interaction, yet understandably at present do not feel comfortable attending an
event with lots of people. The practicalities of trying to make this consultation on something as
significant as this, has simply not been able to be done in a way that is accessible to all.
Elstow is a pro-active parish, even as a close knit village it has been exceptionally difficult to
arrange volunteers to raise awareness of the consultation, whilst managing and supporting
residents’ questions, fears and upset from afar.
The Parish Council are concerned that the consultation paperwork is ambiguous and already
shows a preference, which then removes integrity from the local authority consultation process,
which is a worry.