Site Assessment Pro Formas

Object

Representation ID: 8076

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

The Council’s Site Assessment Pro Forma published June 2021 in relation to Site 761 includes a high level assessment of the site. Having considered the summary provided a number of clarifications are provided.

Ecology (2b, 2c, 2d)

Criterion 2b queries whether protected species may be impacted. In this respect it may be noted that the site comprises intensively farmed and so regularly ploughed / cultivated land and as such land generally accepted as unlikely to comprise important habitat / impact protected species.

In response to 2c and 2d, boundary landscaping is to be retained and very significant scope exists to provide wider buffers to these boundaries than currently exists as a result of the farming. There is also potential to provide links across the site as part of detailed design.

The allocation of the land could therefore deliver net biodiversity gains and enhanced linkages to the surrounding green infrastructure network.

Heritage (4a)

Criterion 4a states that “The proposal has the potential to cause harm to heritage assets” with these impacts potentially ranging from ‘low to high’.

This is a generic comment which appears in relation to most sites that have been assessed.

It is not clear what heritage assets the comments are referring to.

The nearest statutory heritage assets to the site, are 52 Green End to the north, the listed buildings at the Howbury Hall estate to the west and the Scheduled Ancient Monument and listed buildings on the southern side of the A421.

Development at the proposed site would not have any adverse impacts on the setting of any of these assets which are very clearly significantly removed from it and have no direct visual relationships in terms of setting.

It is respectfully submitted that there are no heritage constraints to the allocation of this site.

Employment (5a)

It is stated at Criterion 5a that it is unknown as to whether the proposal would be ‘likely to increase future economic and employment opportunities’.

The site is promoted as an ‘employment site’ which could provide up to 800,000 sq ft of floorspace. Accordingly, it is considered clear that it is likely that the site would provide significant economic and employment opportunities.

The site is located directly on a main junction of the A421 and economic development here would fit squarely with the emerging local plan strategy of focusing such growth at the edge of the urban area and within this corridor.

Highways (15e and 15f)

The Proforma suggests that it is not clear if the site can connect to the highway without constraint.
However, as part of the original Call for Sites submission a Highway and Access Assessment including a detailed access plan was provided by TPA consultants.

This demonstrates how the existing roundabout which adjoins the sites southern boundary could be readily improved to provide appropriate access to the site.

In terms of linkages an additional plan is also now included with this submission showing the location of the site relative to a number of existing footpaths and cycleways and existing bus services in the area. As will be noted good quality connections already existing between the site and existing foot, cycleway and public transport infrastructure.

Conclusions

The submitted site offers substantial potential for allocation for employment generating uses and roadside services including electric vehicle charging as proposed.

The emerging local plan strategy seeks to focus development within the urban area, directly adjoining the urban area and along the A421 corridor. This site lies close to the existing urban area and so benefits from excellent proximity and access to the A421 corridor. It’s allocation would fit squarely with this emerging strategy.

There are no technical constraints to the development of the land.

The site is owned and controlled by the Howbury Hall Estate. No third party land or agreements are required to facilitate the development as proposed.

Ease of deliverability can therefore be readily assumed.

Should the Council have any further questions or queries regarding this site please do not hesitate to contact us.

Object

Representation ID: 8077

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

The following clarifications and additional information is provided in response to the Call for Sites Assessment proformas.

Ecology (2b, 2c, 2d)

Criterion 2b suggests that protected species are recorded at the site. It is unclear what protected species are considered likely to exist on this land.

The land is intensively farmed and so regularly ploughed / cultivated such that it is very unlikely to support any important habitat for protected species.

Should it be considered that protected species may utilise boundary landscaping it can be noted that this is to be retained and could be enhanced as part of any redevelopment, widening buffers and so in response to comments under 2c and 2d, deliver net biodiversity gains well in excess of that possible as part of an intensively farmed unit.

Heritage (4a)

Criterion 4a states that “The proposal has the potential to cause harm to heritage assets” with these impacts potentially ranging from ‘low to high’.

This appears a very generic comment included on many of the site assessments. It is not clear what heritage assets the comments are referring to.

The nearest statutory heritage assets are located well to the south west at Great Dairy Farmhouse. The Farmhouse is separated from this site by St Neots Road and a distance of at least 150 metres.

Development at the proposed site would not have any adverse impacts on the setting of Great Dairy Farmhouse which has no direct visual relationship with the site.

It is respectfully submitted that there are no heritage constraints to the allocation of this site.

Employment (5a)

It is stated that it is unclear as to whether the proposal would be ‘likely to increase future economic and employment opportunities’.

The site is promoted as an ‘employment site’ which could provide up to 47,500 sq ft of floorspace. Accordingly, it is considered clear that it is likely that the site would provide significant economic and employment opportunities.

The site is located directly on a main junction of the A421 and economic development here would clearly fit squarely with the emerging local plan strategy of focusing such growth at the edge of the urban area and within this corridor.

Conclusions

The submitted site offers substantial potential for allocation for employment generating uses.

The emerging local plan strategy seeks to focus development in the urban area, directly adjoining the urban area and along the A421 corridor.
This site is located within excellent proximity of and with good access to the A421 corridor.

It’s allocation would fit squarely with this emerging strategy.

There are no technical constraints to the development of the land.

The site is owned and controlled by the Howbury Hall Estate. No third party land or agreements are required to facilitate the development as proposed.

Ease of deliverability can therefore be readily assumed.

As the Council is aware the site has also been promoted as part of a wider proposal (site 878) which includes a large area of land between the site and the western edge of Great Barford. Whilst the landowner is happy for this land to be included as part of that submission, it is again emphasised that the site could readily come forward as a standalone development.

Should the Council have any further questions or queries regarding this site please do not hesitate to contact us.

Object

Representation ID: 8078

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

The following clarifications and additional information is provided in response to the Call for Sites Assessment proformas.

Site Options
Firstly, as part of the original Site 765 submission, two potential options were highlighted. Option A was a housing only scheme whilst Option B proposed to accommodate a new for primary school alongside the proposed housing.

The site assessment does not appear to specifically consider both options i.e., the school is not mentioned. Having raised this matter with Policy Team Leader Kim Wilson we are advised that the Council is aware of both options and is in possession of both submissions. We query therefore whether a second assessment including the school should be included i.e., a Site 765(a) and 765(b).

Notwithstanding this and for clarity Option B including the school is offered on the basis that it is understood that Renhold Primary School is at or approaching capacity. It is included to ensure that if the site were to be favoured for residential development, education capacity should not then be seen as a constraint to allocation as a solution is available in this regard.

Clearly if education capacity in the area is such that a new school is not required then the school site would not be needed and Option A would progress rather than Option B.

Ecology (2a, 2b, 2c, 2d)
The site proforma notes at criterion 2a that the site is ‘within or adjoining a site of nature conservation importance’.

Having review DEFRA’s Magic map and the current Policies Map, it is unclear what site is being referred to as the nearest statutory designated ecological site is the SSSI at Tilwick Meadow which is over 5 kilometres away, whilst the nearest Local Nature Reserves, Putnoe Woods and Mowbury Hill are both over 2 kilometres away.

A local County Wildlife site is located to the southwest but separated from the site by St Neots Road.

Criterion 2b advises that it is unclear whether protected species may be impacted by development at the site.

In response to this query Aspect Ecology have been instructed to prepare an initial Preliminary Ecological Assessment (PEA) and have visited the site as part of this work. The Aspect report accompanies this submission.

As will be noted this confirms that the land to the north of the proposed site (the main body of the site) has little or no ecological value as it is quite intensively farmed. THE PEA noted that the boundary hedges and trees do provide reasonable ecological potential as habitat corridors but these are constrained by the tight nature of the farming up to them.

Significant scope exists to build in wider buffers to these boundaries and so enhance their ecological value.

A small portion of the promoted site comprises degraded low quality parkland. The grass species in this area is noted as poor and there are no veteran trees. The report therefore notes the potential to enhance this area as part of any development.

The final part of the site comprises the area of trees at the southern end through which the proposed access road would be taken. This is again noted as poor in ecological terms as pig rearing in this area has removed any understorey elements of interest. Again, therefore as part of any development significant scope exists to improve the biodiversity value of the area.

The report makes clear that overall, there are no ecological grounds to resist the development of the promoted site.

Heritage (4a)
Criterion 4a states that the “The proposal has the potential to cause harm to heritage assets” and goes on to identify that this harm may range from ‘low to high’.

This appears a fairly generic comment which is made in respect of the vast majority of the promoted sites. It is not clear from the assessment work available to view what heritage assets the assessment is referring to.

However, it is of course noted that there are a series of listed buildings within the Howbury Hall estate. These are all set some distance from the proposed site and separated from it visually by bands of trees.

In addition, as part of the site assessment work the Council requested that the applicant provide a Heritage Impact Assessment Report (JIA). This was prepared by Albion Archaeology and submitted to the Council in March 2021.

The HIA is not referenced within the site assessment proforma.

The HIA confirms that the development of the site as proposed would not result in any materially harmful heritage impacts and this matter should not therefore be held as a constraint to the sites allocation.

Settlement Form (8b)

Criterion 8b states that “The site is more than 0.5 miles from a defined settlement policy area or the built form of a small settlement” however it is also observed at criterion 1 that the site adjoins the urban area. It therefore appears clear that the site is adjacent to a defined settlement policy area (i.e., the urban area).

In this regard the site performs well in terms of its relationship with the favoured and most sustainable spatial strategy option (2a)

Highways (15e & 15f)

The proforma discusses highway matters at 15e and 15f and appears to indicate that the proposed access arrangement is unclear and / or could result in some capacity issues.

This is not the case.

A Highway and Access Appraisal prepared by consultants TPA was provided with the call for sites submission.
This shows two detailed potential roundabout access options at Appendix A and Appendix B of the report. The designs are also based upon transport assessment and modelling of the volume of traffic and current capacity of St Neots Road.

The submission makes clear that the favoured option is that at Appendix A which is located to the south west corner of the estate and would retain the new access away from the hall and the important parkland areas.

For clarity therefore the submitted information clearly demonstrates that an appropriate access for the site can be delivered and there are no capacity issues.

A general comment is made in the highway assessment comments that the proposed access road would be approximately 300 metres long before accessing the housing area.

As discussed above, two options for the site development have been prepared (A and B). Whilst Option A retains the housing development further north and so with a longer length of access road before houses would be developed, Option B includes housing development closer to the access with a length of approximately 80 metres from the highway to the first house.

Whilst the length of the access drive is not considered to be an issue which may be held to lessen the attractiveness of the land as a potential site allocation, should the Council hold any concerns in this regard the Option B layout addresses this matter.

An additional plan is also now included with this submission showing the location of the site relative to a number of existing footpaths and cycleways and existing bus services in the area.

A bridleway runs along the sites western boundary and so provides direct access to the east side of Bedford via Asgard Drive to Norse Road.

Bridleways also run to the south and east of the site, connecting with various adjacent public footpaths which in turn link to Renhold to the north.

There are also dedicated cycleways connecting to the Lidl, Tesco and Waitrose stores to the west without need to cycle on roads. The cycleways also provide excellent access to neighbouring employment areas and through to Bedford Station.

There are bus stops on Norse Road at the entrance to Asgard Drive within 600 metres of the site. There is a regular service (Route 5 every 15 minutes during weekdays), into Bedford and also hourly services (Route X5) between Cambridge, Milton Keynes and Buckingham.

There is also a local service connecting the area with the nearby villages (Route 27).

As will be noted therefore good quality connections already existing between the site and existing transport infrastructure.

Conclusions

The submitted site offers substantial potential for allocation as a housing site.

The emerging local plan strategy seeks to focus development within the urban area, directly adjoining the urban area and along the A421 corridor. This site directly adjoins the existing urban area and is located within excellent proximity of and with good access to the A421 corridor.
The sites allocation would fit squarely with this emerging strategy.

There are no technical constraints to the development of the land. As art of the initial call for sites submission, and now this updated representation, cumulatively the following technical documents have been supplied:

- Preliminary Ecological Appraisal
- Heritage Impact Assessment
- Highway Impact Assessment and detailed Access options
- Tree Survey & Arboriculture Assessment

In addition, two high level master plans have been prepared showing how the site could come forward as a residential only allocation (Option A), or if required to include the delivery of a new Primary School (Option B).

The site is owned and controlled by a single entity, the Howbury Hall Estate. No third party land or agreement is required to facilitate the development as proposed.

Should the Council have any further questions or queries regarding this site please do not hesitate to contact us.

Object

Representation ID: 8079

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

Site ID: 807 - Address: Land south of St Neots Road (A428)

The following clarifications and additional information is provided in response to the Call for Sites Assessment proformas.

Ecology (2a, 2c and 2d)

The assessment suggests that the site is considered to be within or adjoining a site of nature conservation importance.

DEFRA’s Magic map and the current Policies Map do not identify any sites of nature conservation within or immediately adjoining the site other than a County Wildlife site to the west.

The indicative Masterplan for the site, as previously submitted indicates that development of the site would be limited to the northern part with the southern part retained as a water meadow with public access.

This would provide very clear opportunities for ecological enhancement and net gains to biodiversity.

Heritage (4a)

It is suggested that “The proposal has the potential to cause harm to heritage assets” and goes on to identify that this harm may range from ‘low to high’. This is a generic comment which seems to apply to the majority of submitted sites.

A review of Historic England’s Heritage Map for England and the Policies Map identify no heritage assets within or adjoining the site.

The nearest heritage asset is Howbury Hall to the North and Great Dairy farmhouse across the A421 to the south. Both would be separated from the site by mature trees and a significant distance such that visually development here would not harm the setting of either.

Employment (5a)

The site is promoted as an ‘employment site’ which could provide up to 21,000 sq ft of floorspace. Accordingly, it is considered clear that it is likely that the site would provide economic and employment opportunities.

Highways(15e and 15f)

The assessment queries whether the site can be accessed from the highway without constraint.

As set out in the original submission, the site benefits from a frontage onto and would be accessed via St Neots Road.

An additional plan is also now included with this submission showing the location of the site relative to a number of existing footpaths and cycleways and existing bus services in the area. As will be noted good quality connections already existing between the site and existing walking, cycling and public transport infrastructure.



Conclusions

The submitted site offers substantial potential for allocation as a ‘Green’ employment site and deliver access to an enhanced riverside recreation area.

The emerging local plan strategy seeks to focus development along the A421 corridor. This site benefits from good access to the A421 corridor. It’s allocation would fit squarely with this emerging strategy.

There are no technical constraints to the development of the land.

The site is owned and controlled by the Howbury Hall Estate. No third party land or agreements are required to facilitate the development as proposed.

Deliverability can therefore be readily assumed.

Should the Council have any further questions or queries regarding this site please do not hesitate to contact us.

Object

Representation ID: 8080

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

Site ID: 811 - Address: Land south of the A421 at St Neots Road, Renhold

The following clarifications and additional information is provided in response to the Call for Sites Assessment proformas.

Ecology (2a, 2b, 2c, 2d)
The site proforma notes at 2a that the site is ‘within or adjoining site of nature conservation importance’.

Having review DEFRA’s Magic map and the current Policies Map, it is unclear what site is being referred to as the nearest statutory designated ecological site is the SSSI at Tilwick Meadow which is over 5 kilometres away, whilst the nearest Local Nature Reserves, Putnoe Woods and Mowbury Hill are both over 2 kilometres away. There is a County Wildlife site approximately 1kn to the west.

2b suggests protected species may have been recorded at the site. It is unclear what this refers to. However, the land is regularly cultivated such that the main body of the site is unlikely to support protected species.

In response to 2c and 2d, there is significant potential to deliver a substantial net biodiversity gain and to link to the surrounding green infrastructure network.

Heritage (4a)

It is stated at criterion 4a that the site has potential to cause very high harm to a heritage asset.

Although the site does lie close to a listed building (Great Dairy Farmhouse to the west), it has been highlighted in previous submissions that careful design and positioning of the proposed hotel would not result in an adverse impact upon this heritage asset.

For clarity there is no proposal to develop on the Great Dairy Farmhouse portion of the site, the proposed hotel would be located to the east side of the land adjacent to the A421 roundabout junction.

Substantial scope exists for separation and planting between the hotel and the retained farmhouse.

Employment (5a)

The site is promoted as holding potential to deliver a 60 bed hotel, and accordingly it is considered clear that it would result in both economic and employment opportunities.

These opportunities would not only flow from the investment into the site and jobs created during construction and when operational but also through improving opportunities for visitors to the area.

The site is excellently placed on the A421 corridor and so a perfect location for this use.

Agricultural Land Classification (9b)

The site assessment proforma suggests that all or the majority of the site is considered to be ‘best and most versatile land’.

We do not believe this is correct. The Natural England Agricultural Land Classification map indicatively indicates that the site is grade 4 (poor).

Highways (15e)

Criterion 15e suggests that it is unclear if the site can be accessed without constraint.

Whilst detailed access proposals have not been prepared at this stage the site retains frontages onto St Neots Road and so the ability to provide a new / upgraded access as required for a hotel use.

In terms of linkages whilst it is acknowledged that the site does not currently relate directly to an existing settlement an additional plan is included with this submission showing the location of the site relative to a number of existing footpaths and cycleways and existing bus services in the area.

Conclusions

The submitted site offers substantial potential for allocation as a hotel which would generate employment and provide a service for visitors to the area in a key location directly adjoining the A421.

The emerging local plan strategy seeks to focus development along the A421 corridor and so the sites allocation would fit squarely with this emerging strategy.

There are no technical constraints to the development of the land.

The site is owned and controlled by the Howbury Hall Estate. This is a single entity. No third party land or agreements are required to facilitate the development as proposed.

Ease of deliverability can therefore be readily assumed.

Should the Council have any further questions or queries regarding this site please do not hesitate to contact us.