Site Assessment Pro Formas

Support

Representation ID: 6195

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

3.0 RESPONSE TO SITE ASSESSMENT PRO-FORMA (CALL FOR SITES ID 1000)
Introduction to Site and Proposals
3.1 The site was previously submitted to the Council for consideration as part of the Council’s ‘call for sites’ exercise in August 2020. The land area being promoted is shown below. [Site location plan inserted.]
3.2 Land adjacent to Highfield Road, as defined in this representation, comprises circa 4.5ha of agricultural land and is considered to be suitable for employment development. The site adjoins existing development including residential development, the Midland Main Line (London – Sheffield) and the former Oakley Station and to the northeast existing employment.
3.3 Access can be achieved via an existing access point on Highfield Road west of the Highfield or at another point that may be agreed.
3.4 The site sits adjacent to the existing settlement boundary and strategic road network. It is well related to the main built up area of Oakley, is also in single ownership and there are no constraints to its development. It has sufficient land available to ensure development could be provided in a form and character that would respect its surroundings.
3.5 The site is considered suitable for a high calibre employment site (across the Class B and Class E Use Classes at a scale appropriate to the local area). The site offers an opportunity for the consolidation of the existing employment development on Highfield Road, which was purpose built and offers arrange of ‘mid-size’ units for a range of ‘B’ type uses. Policy BE1 of the Oakley Neighbourhood Plan provides support for a range of B1/B2/B8 uses (with reference to the previous Use Classes Order) within the existing Highfield Park. Policy BE1 is constrained by the timeframes and settlement hierarchy set by the strategic policies of the LP2030 and thus does not address the requirement to address needs over an appropriate Plan period as necessitated the immediate review and preparation of the Local Plan 2040.
3.6 The site is contained by existing development comprising the Midland Main Railway Line, existing housing, employment uses and the A6 Clapham Bypass. This contained setting would result in development appearing as a logical extension to Oakley and can also benefit from appropriate landscaping to mitigate impacts upon rural character and separation with Clapham to the south and east. The site has the capacity to accommodate approximately 3ha of employment development and also offers an opportunity for innovative design and job creation.
3.7 To ensure sufficient employment land is available to support housing growth, we would emphasise that when evaluating potential options for allocation and existing land use designations, consideration should be given to potential sites that could provide optimize opportunities for economic development in rural areas as well as potential infrastructure that would improve the delivery of employment sites.
3.8 The site as defined in Figure 1 is contained by the A6 Clapham by-pass, the Midland Main Railway Line, existing housing, employment uses and agricultural land that can be used to contain and enhance its setting.
3.9 The site has no known environmental, ecological, or archaeological constraints that would inhibit development.
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 773)
Site Assessment Criteria
3.10 We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Within or adjoining the urban area or a defined settlement policy area boundary
3.11 The site adjoins the urban area or a settlement policy area (SPA), it therefore should be considered for development. The site offers an opportunity for the consolidation and expansion of the existing employment development on Highfield Road, (e.g., Highfield Parc), which was purpose built and offers a range of ‘mid-size’ units for a range of Class B and E type uses. The economic performance of Highfield Road is ‘high’ according to the Employment Land Review (ELR) (2015) findings. This is repeated in Part 2 of the Council’s Employment Land Topic Paper (Site Ref: BE22) with the site recognised as providing modern, good quality space.
Impact on designated or non-designated heritage assets or their setting
3.12 The Call for Sites assessment found that the proposal has the potential to cause harm to heritage assets, which may range from low to high. This is a standard response that the Council has applied to a large number of the assessment pro-forma.
3.13 In this case our client’s land at Highfield Road there are no designated heritage assets within or adjacent the site. The land is well-related to existing road and rail infrastructure and adjacent to modern commercial premises. The nearest designated heritage assets comprise the cottages at 27-33 Station Road, west of the railway and within the built settlement at Oakley. Development of our client’s land may result in some impact upon the rural setting of the nearest designated assets although the impact on the immediate setting and contribution made towards their wider setting is likely to be negligible.
3.14 There will be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons. In the case of our client’s land further assessment will be undertaken to more fully explore impacts on significance and to ensure that any impact would represent less than substantial harm in terms of Paragraph 202 of the NPPF, which is the expected outcome given the context described above.
Impact on Highways
3.15 The site is located at the south side of Highfield Road and adjacent to the east side of property no. 8 Highfield Road, in village of Oakley, approximately 5 miles north-west of Bedford town centre. The site fronts onto Highfield Road at the most northern tip of the site and on the west side of the existing roundabout junction with A6 and also the A6 link road between the roundabout junction and the A6 dual carriageway on the east side.
3.16 The Council’s Site Assessment pro-forma does not indicate any in-principle constraints to serving access from Highfield Road or providing sustainable options for access by non-car modes. The closest bus stop is about 280m from the site, serving buses 50 and 51 to Bedford and Rushden, at 2 times per hour frequency. A Transport Assessment will be developed to assess the impact of the development on the road network, with cycle connection improvements well as improvement of the pedestrian facilities.
3.17 In terms of the highway network the Council also accept that neither Highfield Road nor the A6 are normally congested. The issues identified relate to existing congestion on Station Road, within the village, which neither the Local Plan 2030 nor Oakley Neighbourhood Plan seeks to address. These representations should be read alongside our client’s submissions promoting Land East of Station Road for development, incorporating a new dedicated access to Lincroft Academy and Oakley Primary Academy as part of a new road layout enabling the stopping-up of Station Road to through-traffic. This demonstrates a deliverable solution to address pre-existing issues raised by the Council’s pro-forma.
3.18 This solution is consistent with delivering needs for community infrastructure and Oakley’s reclassification to a Key Service Centre and would be complemented by further local employments at Highfield Road.
Groundwater Source Protection Zone
3.19 While the Council’s site assessment pro-forma notes some potential impact arising from proposed industrial uses, given its location in an area for Groundwater protection, this does not reflect its location adjacent to existing commercial uses. Development of the site would be undertaken in accordance with best practice, utilising and enhancing existing drainage measures to mitigate any potential wider impact.
Protected Species
3.20 The Council’s assessment records a potential uncertain impact but recognises that the land is not within or adjacent areas of nature conservation importance and is in-fact located between existing corridors for transport infrastructure and commercial development. As part of future development of the site it would be appropriate to seek preparation of an Ecological Impact Assessment comprising a Phase 1 Habitat Survey and assessment of potential site features supporting the presence of protected species.
3.21 This would be an appropriate basis assess the impact of the development proposal and set out mitigation measures required to ensure there is no net harm to ecological features and where possible identify any opportunities available for integrating ecological features within the development. It is anticipated that a number of ecological enhancements could be provided as part of proposals, such as habitat piles, hedgehog tunnels, bat boxes, bird boxes and native planting and that delivery of these enhancements would lead to an overall Neutral to Minor Beneficial impact

Object

Representation ID: 6508

Received: 13/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Introduction to Site and Proposals
3.1 The site was previously submitted to the Council for consideration as part of the Council’s ‘call for sites’ exercise in August 2020. The land area being promoted is shown below. [site plan inserted here]
3.2 The site, as submitted, extends to 1.4ha and is located immediately adjacent the northern edge of the built settlement.
3.3 The site comprises an active and successful existing employment use, assessed as such and identified for protection as part of the Council’s Part 2 Employment Land Topic Paper (Site BE20).
3.4 The Council’s assessment relates only to a smaller portion of the site (0.63ha) occupied by an existing industrial unit and office facility comprising for vehicle repairs and fleet logistics. Demand for uses at the site has and continues to intensify, with the Council’s own assessment noting - having regard to temporary extensions to workspace and vehicle parking – “the site may not be large enough to fully accommodate the uses, or may require built development to accommodate this.”
3.5 These representations seek to ensure that the emerging Local Plan 2040 supports the sustainable growth of the site in to maintain and increase opportunities for economic development in this location. This can be achieved through an extension in the area proposed for designation/allocation and policies to support the future expansion of floorspace at the site, in accordance with the Strategy’s settlement hierarchy and objectives for jobs growth.
3.6 The site is suitable served by an existing access from the A6 (Rushden Road). The site has no known environmental, ecological, or archaeological constraints that would inhibit development.
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 852)
Site Assessment Criteria
3.7 We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Within or adjoining the urban area or a defined settlement policy area boundary
3.8 The site adjoins the urban area or a settlement policy area (SPA), it therefore should be considered for development and predominantly comprises previously developed land in existing employment uses (or temporary uses associated with these). The land is well-related to the existing settlement and its expansion would be contained by the presence of further commercial floorspace lying to the north (at Protech Stainless Steel) beyond the existing settlement boundary. Designation of the full site area submitted in respect of our client’s interests is therefore appropriate and would proportionate to the scale of the settlement and would not extend beyond existing development.
Impact on designated or non-designated heritage assets or their setting
3.9 The Call for Site assessment found that the proposal has the potential to cause harm to heritage assets, which may range from low to high. This is a standard response that the Council has applied to a large number of the assessment pro-forma.
3.10 In this case our client’s land at Rushden Road there are no designated heritage assets within or in close proximity to the site.
3.11 There will be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons. In the case of our client’s land further assessment will be undertaken to more fully explore impacts on significance (including the contribution made by the setting of any affected assets) and to ensure that any impact would represent less than substantial harm in terms of Paragraph 202 of the NPPF, which is the expected outcome given the context described above.
Impact on Highways
3.12 No access or capacity issues are identified, reflective of the site’s location and existing use. The findings of the site assessment proforma are endorsed, including the potential to extend pedestrian footway connections, if required.
Protected Species and Ecological Value
3.13 The Council’s assessment records a potential uncertain impact but recognises that the land is not within or adjacent areas of nature conservation importance. The proforma does not reflect that the majority of the site area comprises previously developed land.
3.14 As part of future development of the site it would be appropriate to seek preparation of an Ecological Impact Assessment comprising a Phase 1 Habitat Survey and assessment of potential site features supporting the presence of protected species.
3.15 This would be an appropriate basis assess the impact of the development proposal and set out mitigation measures required to ensure there is no net harm to ecological features and where possible identify any opportunities available for integrating ecological features within the development. It is anticipated that a number of ecological enhancements could be provided as part of proposals, such as habitat piles, hedgehog tunnels, bat boxes, bird boxes and native planting and that delivery of these enhancements would lead to an overall Neutral to Minor Beneficial impact.
[Site plan inserted here]

Object

Representation ID: 8395

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Bedfordia land ownership extends to approximately 2.06ha in size and lies within the built-up area of Felmersham adjacent to Memorial Lane and south of The Old Road.
site location plan see appendix
The site is largely undeveloped. It has no relevant planning history, although there is currently a children’s playground located on the northernmost parcel or land fronting on to The Old Road. This falls outside of the land put forward within these submissions but is within Bedfordia’s ownership and is currently let to the local community and is proposed to be retained as part of any development proposals.
3.3 The western boundary of the site adjoins the defined settlement envelope. The north of the site is adjacent to developments on The Old Road. The southern and eastern extents of the site are bounded by countryside.
3.4 Existing bus stops are located on The High Road, which is within close proximity of the site. The site also has connections to the A6 via Memorial Lane and Radwell Road. There are no constraints to accessing the site and no ransom strips as the land is within the single ownership of Bedfordia.
3.5 To the north of the site is The Manor, a Grade II Listed Building. In addition, the Felmersham Conservation Area is adjacent to the site, with boundaries on Memorial Lane and The Old Road.
3.6 The site is approximately 300m from the River Great Ouse and the Environment Agency shows low risk of fluvial or surface water flooding. No contamination or pollution has been indicated on site. No hedgerows are present and there is only one tree on site and this tree is not subject to a Tree Preservation Order. There are no designated Public Rights of Way on site, although there is an undesignated pathway from Memorial Lane to the Pinchmill Primary School along the northern boundary of the site. The site is not located within any statutory designated areas, AONB, Local Nature Reserve, SSSI or Green Belt.
3.7 The site represents a sustainable location and is well located to local services, including Pinchmill Primary School and the play area which are adjacent to the site. The site is within walking distance of two bus stops, the village church (St Mary’s Church) and the local public house (The Sun). The site also has excellent connectivity, being less than two miles from the A6 and within approximately 15-minute drive time to Bedford.
Proposed Development
3.8 The site provides an opportunity to deliver a carefully considered and sustainably located residential development, which is well located relative to the core of the village and existing services. This proposed site provides a sustainable location and is a natural extension to the village, which is well related to the existing pattern of built form as seen elsewhere in the village.
3.9 Whilst Felmersham is not identified for any housing growth in the emerging Local Plan, the Neighbourhood Plan which is being developed has an identified need of 13 dwellings. Having taken on board the feedback received from both the NP Group and local community during public consultation exercises for the Neighbourhood Plan and Local Plan, Bedfordia recognises that development of the western portion of their land holding, to deliver in the region of 10-12 dwellings which are a mix of sizes and tenures, plus overflow car parking for Pinchmill Primary School, is a pragmatic and proportionate option to help meet local needs up to 2030, and this is set out below in Figure 2 (Appendix 2 see attachment).
Preparation of the Local Plan 2040 provides a further opportunity to consider the ability of these proposals to contribute towards needs in the period to 2030 or beyond.
The proposed site would in principle be capable of accommodating one, or a combination of the following uses:
• Market housing;
• Affordable housing;
• Starter homes;
• Self/custom build plots;
• Additional car parking to serve Pinchmill Primary School;
• Potential new meeting hall for the village.
3.12 Any development would be designed to respect and strengthen the structure, form, and character of the village, integrating seamlessly into the existing settlement. In particular, special attention will be paid to design and construction materials to ensure the development respects the setting of nearby listed buildings and reflects and enhances the character of the Conservation Area.
3.13 A suitable dedicated vehicle access to the site could be achieved off Memorial Lane, with additional pedestrian access through to Pinchmill Primary School via the retention and enhanced of the existing footpath located along the northern boundary of the site. This would have the potential to greatly ease the congestion as it currently exists in The Old Road at school drop-off and pick-up times. To further mitigate congestion around pick-up times any future development on the site would offer the potential for overflow parking for Pinchmill Primary School.
3.14 Allocation for self or custom build plots would allow the site to come forward at a pace that meets local need in the area, with the flexibility of price and design to suit local circumstances.
3.15 It is important to reiterate that the development proposals will retain and not impact upon the existing play area located to the on the northern portion of the site in the wider ownership of Bedfordia.
3.16 As a part of the development proposals there will be additional planting and the implementation of a landscaping buffer along the southern, western, and part of the eastern boundary.
3.17 However, in addition to the above the site put forward as part of the submissions to the Local Plan 2040 contains land to the east of the Layout Plan (Figure 2) as shown in Figure 1 at the beginning of this Report. The wider site could deliver up to 30 dwellings across the increased land area. This would not only meet the needs of Felmersham to 2030, but also assist in meeting the local housing needs up to 2040.

We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Impact on designated or non-designated heritage assets or their setting
3.19 The Council’s site assessment proforma finds that the proposal has the potential to cause harm to heritage assets, which may range from low to high. There will be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation.
3.20 Potential constraints relating to the historic environment are widely relevant to most site options in Felmersham and are considered relatively less significant in the context of our client’s land. There are no designated heritage assets within the site itself and the site is located outside of the Conservation Area. A sensitively designed scheme, subject to suitably worded policy criteria, would form the basis to secure acceptable outcomes, and could require suitable technical documentation to be submitted alongside development proposals on the site. The historic environment has been considered in the description of the proposals provided above.
Protected Species
3.21 The Council’s assessment records a potential uncertain impact but recognises that the land is not within or adjacent areas of nature conservation importance.
3.22 As part of future development of the site it would be appropriate to seek preparation of an Ecological Impact Assessment comprising a Phase 1 Habitat Survey and assessment of potential site features supporting the presence of protected species.
3.23 This would be an appropriate basis assess the impact of the development proposal and set out mitigation measures required to ensure there is no net harm to ecological features and where possible identify any opportunities available for integrating ecological features within the development. It is anticipated that a number of ecological enhancements could be
BE1752-5P – Felmersham
Bedfordia Developments Ltd
Bedford Local Plan 2040 Representation
September 2021
16
provided as part of proposals, such as habitat piles, hedgehog tunnels, bat boxes, bird boxes and native planting and that delivery of these enhancements would lead to an overall Neutral to Minor Beneficial impact
Impact on Highways
3.24 The assessment identifies that the “Access point to the site is feasible from Memorial Lane” and “No significant traffic issues in the vicinity and a development of this size is unlikely to cause significant impacts.” This assessment then moves to suggest that access should be directly off Radwell Road, which could be achieved, but the Site Assessment appears confused on the suitability of the access and where this should be located. This could be clarified as part of additional technical work which could explore the suitability of both accesses directly onto Memorial Lane and Radwell Road, which would in turn support identification of a preferred option amongst the various suitable alternatives.

Support

Representation ID: 8646

Received: 28/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

3.1 The site was previously submitted to the Council for consideration as part of the Council’s ‘call for sites’ exercise in August 2020. The land area being promoted is shown below.
SEE APPENDIX 1 OF ATTACHMENT FOR SITE PLAN
Site Context and Description
3.2 The site extends to approximately 0.4 hectares and lies at the edge of the present built form for the village of Souldrop, adjacent to Stocking Lane.
3.3 The western boundary of the site abuts the defined Settlement Policy Area Boundary under Policy 5S of the adopted Local Plan 2030. There are no known designations or constraints on the site that would inhibit development being brought forward on the site.
3.4 The site is accessed via an agricultural access off Stocking Lane, to the north-east.
3.5 To the west of the site, albeit some distance from it, there are two Grade II Listed Buildings and a Grade II* Listed Church, but there is built form and boundary treatments between the site and these assets, such that there would be little if any impact on their significance (including the contribution made by their setting). Furthermore, to the north of the site there is a Grade II Listed Building, but views of this from the site are obscured by dense vegetation.
3.6 The site, historically, was in agricultural use but is no longer fit for modern farming practices. There is a Dutch barn and a large area of hard standing present on the site.
3.7 The site is within a short walk of the centre of the village of Souldrop and within reach of local amenities, facilities, and services such as the village green and the Bedford Arms, a public house, and the Crossweir Farmyard business area. A bus route connects Souldrop to Bedford, Rushden, and surrounding villages such as Riseley and Sharnbrook. Sharnbrook is a main rural service centre and is some 2 km from the village. Residents of the village are also able to utilise the services available in Sharnbrook.
Proposed Development Options
3.8 The land provides an opportunity to provide for either a carefully considered residential development of up to 10 dwellings, well located relative to the core of the village, village green and existing services, or be fully used for business purposes.
3.9 This site provides a sustainable location and natural extension to the village of Souldrop, which is well related to the existing pattern of development along Sharnbrook Road. Similar development has been seen elsewhere in the village, such as at the High Street – Green intersection.
3.10 The proposed site would be developed to provide a potential mix of dwelling types that will respect and strengthen the structure, form, and character of the village. The site would, in principle, be capable of accommodating either one, or a combination of the following uses:
• Market housing.
• Affordable housing.
• Starter homes.
• Self / custom build plots.
3.11 Special attention will be paid to selected design and construction materials, to ensure the development respects the setting of the nearby Listed Buildings and reflects the traditional, rural character of the village. Appropriate landscaping and screening will ensure the residential amenity of neighbouring properties is maintained. This will ensure the development integrates seamlessly into the existing settlement.
3.12 Allocation for self or custom build plots would allow the site to come forward at a pace that meets local need in the area, with the flexibility of price and design to suit local circumstances. It also accords with the Government’s commitment to promoting self-build and custom build opportunities, as set out in the UK Housing Strategy.
3.13 The site could also accommodate a small office (Class E) or storage or distribution (B8) development, with associated landscaping and parking, or be developed as an additional business location fully utilising the land. Special attention would again be paid to design and construction materials and landscaping and screening would be appropriate to ensure the residential amenity is maintained and the development is compatible with the surrounding area.
3.14 The site is in single ownership and is available for development and should therefore be considered deliverable with a realistic prospect some housing or employment use could be delivered within 5 years.
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 1245)
Site Assessment Criteria
3.15 We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Impact on Highways
3.16 No access or capacity issues are identified, reflective of the site’s location and existing use. The findings of the site assessment proforma are endorsed, including the potential to extend pedestrian/cycle footway connections, if required.
Agricultural Land Classification
3.17 The assessment notes that the site consists of the best and most versatile land, but the proforma fails to reflect that the submitted site does not farm part of a larger agricultural field. The land instead provides existing agricultural buildings in a location well-related to the built settlement that would result in no greater spread of built development southwards or eastwards. The characteristics of our client’s small site, and its existing condition (providing mainly scrub and boundary vegetation), do not indicate that any adverse effects would be likely in terms of impacts upon the supply of best and most versatile agricultural land.
Previously Developed Land (PDL)
3.18 The Council’s assessment of the site notes that it is not PDL. Whilst the use of the site is agricultural, it is important to highlight that there is a substantial building on the northern boundary of the stie and a significant area of hardstanding. This reflects the prospects for redevelopment of the land in a manner that would be sympathetic to the existing character and condition of the site and its relationship with the village.
Impact on designated or non-designated heritage assets or their setting
3.19 The assessment proforma found that the proposal has the potential to cause harm to heritage assets, which may range from low to high. This is a standard response that the Council has applied to a large number of the assessment pro-forma.
3.20 In this case our client’s land at Town Farm, Souldrop there are no designated heritage assets within the site itself or in close proximity to the site. To the west of the site there is two Grade II Listed Buildings and a Grade II* Listed Church, but there is built form and boundary treatments between the site and these assets, mitigating the impact of development on their significance (including the contribution made by their setting). Furthermore, to the north of the site there is a Grade II Listed Building, but views of this from the site are obscured by dense vegetation.
3.21 There will be options to avoid, reduce or mitigate this harm where sites have not been ruled out altogether for other reasons. In the case of our client’s land further assessment will be undertaken to more fully explore impacts on significance (including the contribution made by the setting of any affected assets) and to ensure that any impact would represent less than substantial harm in terms of Paragraph 202 of the NPPF, which is the expected outcome given the context described above.
3.22 A sensitively designed scheme for redevelopment, subject to suitably worded policy criteria, would form the basis to secure acceptable outcomes with the requirement for suitable technical evidence.
Protected Species and Ecological Value
3.23 The Council’s assessment records a potential uncertain impact but recognises that the land is not within or adjacent areas of nature conservation importance. The proforma does not reflect that the majority of the site area comprises land occupied by hardstanding or existing agricultural buildings. The Council’s assessment states that protected species have been recorded on the site.
3.24 As part of future development of the site it would be appropriate to seek preparation of an Ecological Impact Assessment comprising a Phase 1 Habitat Survey and assessment of potential site features supporting the presence of protected species.
3.25 This would be an appropriate basis assess the impact of the development proposal and set out mitigation measures required to ensure there is no net harm to ecological features and where possible identify any opportunities available for integrating ecological features within the development.

Support

Representation ID: 8741

Received: 29/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

3.1 Our client’s interests at Land off Marsh Lane have previously been promoted at each consultation stage of the adopted Bedford Local Plan 2030 and throughout the preparation of the Milton Ernest Neighbourhood Plan.

3.2 As part of the Bedford Borough Councils previous ‘Call for Sites’ our client’s land was assigned site reference 518 (‘Land off Rushden Road’). This site forms the current proposed MENP housing allocation (Policy ME H1). The adjacent site, also in our client’s ownership (ref: 162), adjoining the southern eastern boundary, was assigned to ‘Land at Marsh Lane’. The site is now collectively referred to as Site Ref 910 in the Local Plan 2040 supporting Site Assessment Proforma June 2021.

3.3 The site forms an opportunity for comprehensive, sustainable development in the longer term. The larger part of the site previously referred to as Site 518 has been comprehensively analysed within the Borough Council’s ‘Site Assessments and Potential Options for Allocation’ Report (April 2017) where it was identified as a potential allocation option for Milton Ernest considered to be able to make a “significant contribution both alone and in conjunction with adjoining site 162 towards the strategy target of up to 50 dwellings for this village”. As illustrated at Table 2.1.1 of the AECOM Masterplanning Report (prepared as evidence to support the Neighbourhood Plan) sites 518 and 162 were both listed for consideration.

3.4 As part of the MENP evidence base a Site Assessment, was undertaken by Troy Planning and Design (TPD) which included Site 518 in the list of four site options flagged as having scope for further consideration. The TPD Assessment again also included Site 162 as a potentially suitable option. Within the TPD Assessment, Site 162 achieves a favourable Green/Amber assessment reflecting the potential opportunities associated with enhancements to Green Infrastructure and links to the countryside. The TPD Assessment also acknowledges that these benefits would likely be achieved through development in conjunction with the adjoining land under Site Ref 518, in terms of facilitating access and links to the A6.

3.5 In terms of TPD’s view on site capacities, utilising their density calculation method, TPD


recorded a potential site capacity of 75 dwellings for site 518, if 50% of the site is developable at a density of 30dph. Adjacent site 162 is recorded in the TPD’s Assessment as having a potential site capacity of 11 dwellings, at 30dph assuming a developable area of 70%.

3.6 Whilst several suggested amendments were taken forward by the Parish Council in the production of the submission version of the MENP, our client continued to highlight the potential benefits of incorporating a wider site boundary (including further green infrastructure
/ SUDS opportunities, improved links to the countryside and ecological / biodiversity enhancements), which could be further realised by joining site 162 to the allocation area.

3.7 The MENP Examiner’s report published 28 July 2021, which recommended the Plan proceed to referendum subject to modifications, included removing the reference to a maximum of 25 dwellings (amending to minimum) reflecting policy and supporting acknowledgement that this site could support the delivery of further dwellings to address housing need.

Land off Marsh Lane

3.8 The site is located to the north of the village of Milton Ernest and covers an area of approximately 4.99 hectares, currently in agricultural use. The site is located outside of the current Settlement Policy Area (SPA). However, Policy ME C1, seeks to amend this boundary to include that part of the proposed housing allocation at Land off Marsh Lane (Policy ME H1) identified as the ‘Development Area’.

3.9 For the avoidance of doubt our client intends to bring the scheme forward for residential development within the amended SPA as set out in the MENP policy ME H1. However, this should not preclude the potential to provide additional capacity for suitable residential development as part of preparation of the Local Plan 2040.

3.10 The site is positioned to the north of Bedford. The A6, one of the main routes into Bedford, runs through the settlement. As set out in the highways comments supporting TPD’s Assessments, a safe and suitable access should be deliverable from Rushden Road (A6), at multiple points along the site frontage. This is also confirmed within the Borough Councils Site Assessment Proformas (June 2021) where it is stated “A new access would have to be created onto the A6 however the proposed access location is fine. No significant traffic congestion in the area, and the development is unlikely to have more than a moderate impact”.


3.11 The site is bound by Rushden Road to the south-west, private residential properties to the north-west and south-east, and countryside to the north-east. A tall hedgerow screens the south-western edge from Rushden Road and the back of private properties south of the road, and the northern edge runs along an open field boundary. The gradient of the land rises north eastward through the site and as is shown on the supporting Constraints and Opportunities map at Appendix 2. There is little subdivision within the site.

3.12 The surrounding built environment consists of mainly lower density detached and semi- detached one and two-storey residential buildings, in various architectural styles. There are no flats, commercial or industrial buildings in the immediate vicinity of the site. The two Listed Buildings near the south-east are screened by walls and vegetation, but partly visible from the site. Mitigation for these assets in terms of any impact on their significance (including the contribution made by their setting) has been considered as part of the preparation and Examination of the MENP. The MENP Policy H1 criteria includes a requirement to maintain an appropriate buffer with between the development area and heritage assets, which our emerging proposals will accord with. Our client is also in the process of commissioning a detailed heritage assessment to inform future design proposals and requirements in terms of mitigation.

3.13 The site has good access to a range of local facilities. As confirmed through TPD’s and Bedford’s Local Plan Assessments, it is recorded as Green (less than 400m) in terms of access to village centre services including access to a primary school and access to public transport. The site is within close proximity to the village centre and a short walking distance (2 minutes) to nearest bus stop on Rushden Road with public transport connections to Bedford.

3.14 The site is defined by the Environment Agency as Flood Zone 1, which indicates that flooding from nearby rivers is unlikely. A small section of the south-eastern edge of the site can be prone to surface water flooding but this area of land would also form a suitable landscaped area that can incorporate flood attenuation and sustainable drainage features. A mature hedgerow runs along the western boundary of the site parallel to Rushden Road which largely defines the existing view from Rushden Road.

3.15 The site is not located within any statutory area, AONB, Local Nature Reserve, SSSI or Green Belt.


3.16 The land has no outstanding planning permissions and no planning history of note.

Potential Development Scheme

3.17 These representations have been prepared in the context of the submission version MENP and the proposed ‘development area’ indicated under Policies ME C1 and ME H1 of the MENP. While appropriate modifications were suggested (including those acknowledged by the Examiner in terms of capacity and links with the adjacent site), there were no overriding objections to the approach proposed in the MENP.

3.18 Equally, however, the evidence for the site itself reflects that there is no in-principle constraint to extending the area proposed for built development beyond the MENP’s suggested extension to the SPA boundary. Achieving further built and non-built uses beyond the proposed SPA boundary could be achieved together with potential benefits towards the requirements for sustainable development within the wider boundary of site refs 518 and 162.

3.19 As stated, the site as allocated is considered suitable, available, and achievable to meet the dwelling requirement set out in the MENP and policy 4S of the Local Plan. The site is capable of delivering a carefully considered residential development, which can help achieve the objectives of the proposed development strategy, in a sustainable location. The location of the site provides a natural extension to Milton Ernest and is well-related to and capable of enhancing the existing pattern of development along Rushden Road.

3.20 The site would allow for the development of a mix of dwelling types and sizes to complement and enhance the existing housing stock and to meet and address the specific local needs of the area. The site could be developed to respect and complement the established pattern, form, and character of the village, be sympathetic to the settings of the adjacent Listed Buildings and provide a congruous extension to the existing settlement form.

3.21 This site additionally provides opportunities to unify the western and eastern portions of the village along Rushden Road, together with providing a new active frontage facing the A6. The allocation of this site would reduce the linear spread of development to the south-west of Rushden Road, away from the existing village centre, instead facilitating the centralisation of development closer to the heart of Milton Ernest.


3.22 Whilst the allocation of this site has some potential to affect the local landscape character, this can be limited through comprehensive master planning and a careful consideration of green infrastructure. As highlighted in the AECOM Masterplanning document this can be achieved through the integration of landscaping buffering which delineates the new edge of the built-up area from the countryside to the north and “ensures a sympathetic village edge transition”.

3.23 To support these representations a Constraints and Opportunities Plan has been prepared (see Appendix 2).

3.24 The proposed approach in the MENP is broadly consistent with this Plan, in terms of initially focusing built residential development within the ‘development area’ proposed together with opportunities to deliver open space, recreation and ecological enhancement outside of the proposed amendment to the SPA boundary.

3.25 The Constraints and Opportunities Plan illustrates the ability to test further layout options considering the wider area, identifying scope for flexibility in terms of the extent of residential development and future opportunities for extension of the built area. This demonstrates scope for the delivery of increased dwelling numbers both within and beyond the proposed amendments to the SPA boundary as set out in the emerging MENP.

3.26 To support the progression of development in this location in accordance with Policy ME H1 our client is in the process of commissioning a series of technical assessments covering highways, heritage and archelogy and drainage options. Layout considerations and Masterplanning work has also been undertaken.

3.27 Emerging proposals for the site as proposed for allocation within the emerging MENP Policy ME H1 indicate that the site can sustainably facilitate options for site capacity that would sit comfortably across the range of 25-50 dwellings indicated in Policy 4S of the Bedford Local Plan 2030. These representations demonstrate the scope to assess the potential to support higher levels of growth based on the potential benefits to be provided such as the delivery of additional open space.

3.28 As part of preparation of the Local Plan 2040 it is important to safeguard acceptable parameters for future proposals in this location whilst avoiding the unnecessary prescription and limitations on opportunities to secure the achievement of sustainable development. This


would facilitate the Council identifying Milton Ernest to make a modest further contribution towards the additional needs for development in the period to 2030 and beyond, consistent with the Plan’s overall requirements and objectives.

APPENDIX 1 OF ATTACHMENT IS SITE LOCATION PLAN
APPENDIX 2 OF ATTACHMENT IS CONSTRAINTS AND OPPORTUNITIES PLAN

Support

Representation ID: 8877

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

3.0 RESPONSE TO SITE ASSESSMENT PRO-FORMA
Introduction to Site and Proposals
3.1 The site was previously submitted to the Council for consideration as part of the Council’s ‘call for sites’ exercise in August 2020. The land area being promoted is shown below.
Figure 1: Land at Green End, Kempston
3.2 The site, extending to circa 7 ha, comprises an area of grass land and lies on the western side of Kempston. To the north the site is bounded by Cemetery Road, to the east by the A428 Branston Way and the Kempston urban extension, to the south by Kempston nurseries and residential development on Ibbett Close, and to the west by Green End Road and housing within Green End.
3.3 Access can be achieved via Cemetery Road or Green End Road.
3.4 The site is well related to the urban area of Kempston, and the extensive range of services
and facilities provided there and within the urban extension development area. This includes a broad range of retail facilities including supermarkets, doctors/dentist surgeries, schooling (primary and secondary) and a range of leisure. There is also access to public transport providing services to Bedford and the surrounding towns and villages.
3.5 The site is sustainably located relative to the wider highway network and surrounding settlements but is detached and capable of substantial development for a range of uses without impacting upon neighbouring uses and without resulting in physical coalescence with the main urban area.
3.6 There are no known physical, environmental, ecological, or archaeological constraints that would prevent development from coming forward.
3.7 Although a substantial site, the land has the potential to accommodate a variety of scales and types of development subject to design. For the purposes of these representations further site analysis has been undertaken on behalf of our client by BE1 Architects with input from Transport Consultants SDD. A copy of this work is included at Appendix 2 and has been used to respond to comments in the Council’s Site Assessment proforma.
3.8 The analysis undertaken takes account of current and historic land use designations affecting the site area, including its previous allocation as part of the Land West of Kempston expansion (Policy H7). However, our client’s land is not included within the specific land use proposals associated with this expansion. The areas assessed for development sit beyond the Bedford to Milton Keynes Green Infrastructure Opportunity Zone (Policy AD24) and are not subject to proposals for further planting as part of creation of the Forest of Marston Vale (Policy 36S) but could make a valuable contribution towards both of these policy aims.
3.9 The Site Analysis concludes on the ability to identify a developable area of approximately 3.5 hectares across those parts of the land with the greatest capacity to accommodate new development and with feasible access options.
Figure 2: Land at Green End, Kempston – Development Opportunity Diagram
3.10 The developable area identified is comparable to the requirements for the delivery of specialist accommodation for older people as part of a Retirement Village model focusing on the provision of Extra Care facilities. This option should be subject to further testing by the Council for the purposes of site selection.
3.11 The developable area within the wider site would also be compatible with providing for general needs housing where the level of development proposed would be proportionate to the size of the settlement and the site’s setting and context.
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 1247)
Site Assessment Criteria
3.12 We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Within or adjoining the urban area or a defined settlement policy area boundary
3.13 The Council’s assessment pro-forma records the location as adjacent to the Urban Area Boundary, which correctly reflects the sustainability of the location and its proximity to services and facilities. However, despite this physical and functional relationship with the urban area the developable parts of the site would remain separate from the main urban area as a result of the existing green infrastructure corridor west of Kempston. This enables the opportunity to deliver growth commensurate to the built settlement at Green End and in-keeping with its local character and settlement pattern and without impacting on the important gap between the site and the urban area (Policy AD42).
3.14 It should be noted that this site would maintain sustainable patterns of development in this regard. The Council has on multiple occasions previously accepted the A428 bypass does not comprise a fundamental barrier to the extension of development west of Bedford. The bypass has been breached by various developments, including new employment west of the A428 encroaching into the Green Infrastructure corridor. Our client’s land would avoid any further harmful impacts in this regard while continuing to represent a sustainable location for growth accessible to the main urban area.
Impact on designated or non-designated heritage assets or their setting
3.15 The Council’s site assessment proforma finds that the proposal has the potential to cause harm to heritage assets, which may range from low to high. There are no designated heritage assets within the site itself and the nearest assets are located north of Green End Road within the existing settlement (3no. Grade II Listed properties).
3.16 Development of our client’s land may result in some impact upon one aspect of their setting resulting from their relationship with the surrounding rural area. There will be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons. In the case of our client’s land further assessment will be undertaken to more fully
explore impacts on significance and to ensure that any impact would represent less than substantial harm in terms of Paragraph 202 of the NPPF, which is the expected outcome given the context described above.
Protected Species and Ecological Value
3.17 The Council’s assessment notes that the site is not located within an area of importance for nature conservation but states that protected species have been recorded on the site. This could be addressed through an ecology survey and protected species surveys, if appropriate, and the recommendations and mitigation strategy could be incorporated into any development scheme.
3.18 Site Analysis undertaken by our client demonstrates that the proposed developable areas would be focused upon areas of existing paddock and grassland. This indicates that those areas of greatest habitat value are likely to be unaffected, including trees towards the site boundaries the may provide habitats for protected species such as bats and badgers. These areas of the site could be subject to appropriate measures for protection and enhancement of their biodiversity value as part of the wider scheme proposals.
Green Infrastructure Opportunity Network
3.19 The Council’s own site assessment proforma fails to recognise the location of the northernmost and eastern portions of the site within the Bedford Milton Keynes Opportunity Area. The Site Analysis undertaken on behalf of our client seeks to keep areas with this area free from the development while the wider scheme proposals on unconstrained land would offer opportunities for further enhancement and access for recreation and leisure.
Access, Highways and Sustainable Transport
3.20 The Council’s assessment pro-forma notes no in-principle access constraints but would seek improvements in pedestrian and cycle connectivity from the site to surrounding services and facilities. This has been reflected in the Site Analysis and development opportunities identified on behalf of our client, including the excellent opportunities that the site provides in terms of connections to the existing Public Rights of Way network. In-particular:
• Vehicular access off (northernmost) part of Green End Road, located within a 30mph speed limit with street lighting and an existing footway on the opposite side of the carriageway, is considered a suitable location (for accessing residential development) and would require connecting into the existing footways.
• If no vehicular access is proposed along Cemetery Road, it nevertheless feasible that a pedestrian / cyclist access is proposed in this location, to connect into the existing infrastructure.
• From an access at Cemetery Road, there is an opportunity to extend the existing shared footway / cycleway facility from the A428 / Cemetery Road roundabout towards the site along the northern edge of the carriageway. This would be the key desire line for future residents travelling to Kempston Town Centre. Alternatively, there appears to be adequate verge width along the southern side of Cemetery Road to provide a new footway along the site frontage with would extend east towards the A428 roundabout.
• The closest bus stops are also located on Cemetery Rd to the southeast, approximately 400m from a potential access at Cemetery Rd, or circa 700m from the centre of the site. The stops are served by Route 24, operating at an hourly frequency, between Great Denham and Bedford.
• Public footpath ‘A6’ and ‘39’ are located within the site, noting that footpath A6 extends beyond the site northeast towards the A428 roundabout. There could be an opportunity to improve this PROW so that it is more attractive for future residents, as it provides a shorter route for residents within the southern parcel of the land to the bus stops and Kempston Town Centre, linking to local facilities such as schools, small retail facilities, churches, pub, and employment areas. Footpath 19/A6 enters the site from the southwest and forms part of an important rural pedestrian link between Green End and Kempston, and footpath 15/39 provides further permeability, offering a potential for enhance connectivity to further north to Box End.
For figures and appendices see attachment

Support

Representation ID: 8907

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

RESPONSE TO SITE ASSESSMENT PRO-FORMA (CALL FOR SITES ID 663)
Introduction to Site and Proposals
3.1 The site was previously submitted to the Council for consideration as part of the Council’s ‘call for sites’ exercise in August 2020, this following on from discussions about the future of the buildings some years previously. The land area being promoted is shown below.
Figure 1: Manor Farm, Knotting
3.2 The site forms part of a larger farm holding and for these purposes extends to approximately 1ha and fronts onto Melchbourne Road and comprises a number of former farm buildings and extensive hardstandings.
3.3 The site is located on the east side of Melchbourne Road in the village of Knotting approximately 10 miles north of Bedford town centre. The access point is feasible via Melchbourne Road, which is a 40mph road. There is no traffic congestion in the area.
3.4 The site currently falls outside of a defined Settlement Policy Area, however, permitted development rights would enable the change of use of the buildings. An allocation of the land for development of the site would enable a more imaginative and beneficial scheme to be
realised, having regard to the site’s setting and opportunities for outstanding design that it represents.
3.5 The site, due to its size and location, is capable of delivering a carefully considered residential development in accord with the existing character of the area, and at a level that may be achieved through the change of use and conversion of the buildings. Given the permitted development rights that apply, the site’s allocation would enhance the scope for a fully contextual development in keeping with the structure, form and character of the area, and its surrounds.
3.6 The site offers small scale, considered growth that will benefit the existing amenities, facilities and services of the settlement and its neighbouring villages. This will ensure the village and the surrounding wider rural area continue to thrive.
3.7 The site has no known environmental, ecological, or archaeological constraints that would inhibit development.
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 663)
Site Assessment Criteria
3.8 We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Within or adjoining the urban area or a defined settlement policy area boundary
3.9 The site falls outside of a defined settlement policy area (SPA); however, it should be considered for development. The site forms part of a larger farm holding extends to approximately 1ha. The site offers the opportunity for delivering a carefully considered residential development in accordance with the existing character of the area, and at a level that may be achieved through the change of use of the buildings.
Impact on designated or non-designated heritage assets or their setting
3.10 The Council’s site assessment proforma finds that the proposal has the potential to cause harm to heritage assets, which may range from low to high. The existing buildings are substantial and utilitarian in appearance, and as such there will be options to avoid, reduce
or mitigate this harm, and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation.
3.11 There are no designated heritage assets within the site itself. A sensitively designed scheme for conversion and redevelopment, subject to suitably worded policy criteria, would form the basis to secure acceptable outcomes and would offer the Council greater control than any change of use under rights for permitted development.
Protected Species
3.12 The Council’s assessment states that protected species have been recorded on the site. This could be addressed through an ecology survey and protected species surveys, if appropriate, and the recommendations and mitigation strategy could be incorporated into any development scheme.
See attachment for appendix

Support

Representation ID: 8912

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The site was previously submitted to the Council for consideration as part of the Council’s ‘call for sites’ exercise in August 2020. The land area being promoted is shown below.
Figure 1: Land off Moor End Lane, Radwell (Radwell Lakes)
3.2 Land off Moor End Lane, Radwell extends to approximately 135 hectares and comprises, in addition to farmland, substantial areas of former gravel workings that over time have become lakes that are currently used for fishing and other open-air, informal leisure uses (see figure 1 below). There is a crescent of lakes west of the A6 and the River Great Ouse. There is also a small lake on the southwest corner of the site. A designated cycle route runs parallel to the A6. Moor End Lane lies to the north of the site forming the boundary along its northern tip.
There is a railway line which is located on the western side of the site.
3.3 The village of Radwell is located circa 230 metres to the west of the railway line. The eastern part of the site is in flood zone (3b) (functional floodplain) and there is a small pocket of land in flood zone (3a) to the northwest. Access to the site is provided via a private road that is owned and controlled by parties related to Bedfordia Developments Ltd. There are two existing access points onto into the public highway in the vicinity of Radwell. The site forms part of the Upper Great Ouse River Valley.
3.4 Owned entirely by one party, the site offers an opportunity to provide for an expansion of tourism and leisure use, including, but not limited to, water sports and water-based recreation; ancillary restaurants, cafes and/or public houses; recreational based retail outlets; and accommodation - lodges, eco camping; camping pods or glamping.
3.5 Similar examples of such development have been seen elsewhere in the region at Stanwick Lakes (East Northants) and on a smaller scale and linked with a specific pastime at Box End Aqua Park (Bedford Borough).
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 703)
Site Assessment Criteria
3.6 We have reviewed the Council’s assessment of the site and wish to make a number of comments below. In terms of the assessment proforma more generally the Council has failed to take account of the potential net benefits associated with the proposed leisure and tourism uses, referring incorrectly to (for example) proposed industrial development in assessing potential impact on groundwater and indicating the potential to generate congestion.
Within or adjoining the urban area or a defined settlement policy area boundary
3.7 The proposed nature of uses at the site indicates that its location in the rural area outside of existing settlements does not represent a constraint to leisure and tourism uses. The site offers significant potential to provide mixed use leisure development including pub/restaurant/hotel and holiday homes in an attractive location. As part of the details submitted for our client’s site at Radwell Lakes we confirm that this location is free from overriding constraints to availability or suitability and that access can be provided.
Habitats and Protected Species
3.8 While the Council’s proforma notes the presence of protected species and uncertain impacts on habitats given the site’s importance for nature conservation this fails to take account of the extensive land area (over 145ha) or existing uses within the site. Subject to further consideration by the Council it would be appropriate to ensure that areas of greatest potential impact are avoided and opportunities for mitigation and enhancement can be provided based initially on the findings of a Preliminary Ecological Appraisal including Phase 1 Habitat Survey and protected species surveys including reptiles and bats.
Impact on designated or non-designated heritage assets or their setting
3.9 The Call for Site’s assessment found that the proposal has the potential to cause harm to heritage assets, which may range from low to high. This is a finding applied to the majority of the Council’s assessment pro-forma.
3.10 In relation to the proposed leisure and recreation uses at the site, and given the substantial land area, these would not represent any significant change to the contribution that the site makes to the setting of any designated or non-designated heritage assets. There will be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation.
Impact on highways
3.11 The Council’s assessment notes that the site is located east of Radwell village approximately 7.5 miles north of Bedford town centre. The closest bus stop located west in Radwell village approximately 750m of the site. The Council’s assessment takes no detailed account of the proposed leisure and tourism uses at the site nor its existing function including the provision of fishing lakes and open air leisure. Assessment for the intensification of these uses would result in materially less impact on the highways network than development of the whole site (as implied by the suggestions in the Council’s pro-forma).
3.12 A Transport Assessment will be developed to assess the impact of the development on the highway network, particularly along the Moor End Lane, together with an assessment of feasibility of the numerous options available to improve access, if required. Appropriate policy criteria could also be provided to support development of a Travel Plan taking account of existing walking routes within and adjoining the site.
See attachment for plans.

Object

Representation ID: 9010

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Together, the sites represent an area of circa 52 ha, 47 ha of which lies to the east of Odell
Road (Site A) with the remaining 5 ha off School Approach (Site B), both on the southwestern
side of Sharnbrook.
(Figure in attachment)
Both sites maintain a strong relationship with the village and are well related to the existing
built-up area. Taken together they can provide a full range of housing types and tenures and
substantial community infrastructure including provision of land for a new one or two form
entry primary school. The indicative site masterplan (Figure 2 below) illustrates how the sites
could be developed to include around 20ha of multifunctional open space/riverside parkland,
enhancing the recreation, open space, and green infrastructure provision in the village The sites currently comprise arable fields and are identified as Grade 3 ‘Good to Moderate’
Agricultural Land.

Odell Road forms the western extent of Site A, lying behind the established residential
dwellings to the east and north. To the south and south-east, the site is bound by a series of
lakes and water courses within the Felmersham Gravel Pits SSSI, with the River Great Ouse
beyond. Site B is bounded by residential development to the east, beyond School Approach,
with Sharnbrook Academy to the north, and agricultural land to the south/ west. Adjacent to
the site’s southern boundary is an access track that leads onto Odell Road, adjacent to Site
A.

Access to the sites is to be achieved from Odell Road (Site A) and School Approach (Site B)
respectively, both of which are adopted highways, facilitating direct connections to the
principle thoroughfares of Sharnbrook.

There are no listed buildings within the immediate vicinity of the sites, nor are they within a
Conservation Area (the northern boundary of Site A partially adjoins). Both sites include a
portion of land subject to land designation, with sites A and B including a small area of land
identified as ‘Village Open Space / View’ under Policy AD40 of the Site Allocations and
Designations Local Plan (2013). The potential impact on this designation was considered as
part of a Comparative Landscape Assessment undertaken on behalf of our client, illustrating
that the Stoneyfields site compares favourably to the proposed allocation at Hill Farm (see
Appendix 4).

Neither site falls within any Area of Outstanding Natural Beauty (AONB), Local Nature
Reserve, or Site of Specific Scientific Interest (SSSI) (Site A adjoins). The sites themselves
are also unconstrained in terms of ecology.

Site B remains unconstrained by flooding, with only the eastern margin of Site A lying in
Flood Zone 2 / 3. This is however proposed to be retained as open space / green
infrastructure and would therefore not impact on the development capacity of the site.

These sites are therefore considered to be relatively unconstrained and well related to the
existing built-up area making them suitable development allocations, contributing towards
the growth needs of Sharnbrook and the wider authority area whilst providing substantial
community infrastructure.

Services and Facilities
The settlement of Sharnbrook provides a good range of local services and facilities and
includes a post office, convenience store, a pharmacy, restaurants, cafes, public houses,
and Sharnbrook Upper School, hence its designation as a Key Service Centre.

Sharnbrook is also served by several bus routes, including bus route 50 (Bedford/Kettering)
and bus route 25/26 (Bedford-Rushden) with the nearest rail links provided at Bedford.

Proposed Development Scheme - Stoneyfields
An indicative Masterplan (see Figure 2 below - see attachment) illustrates how the sites could be developed
for the land known as ‘Stoneyfields’.
Stoneyfields presents significant development opportunities, not only to accommodate
between 450-500 dwellings but also by facilitating the development of multifunctional
countryside parkland, enhancing the recreation, open space, and green infrastructure
provision in the village. The creation of this area, adjacent to the River Ouse Corridor, not
only optimises the use of land within Flood Zones 2 / 3, but also serves to enhance the village
and the open countryside beyond. This riverside park would additionally introduce a series
of new footpath connections, linking to those currently within the area and providing greater
linkages for existing residents to the open countryside.

The proximity of the Stoneyfields site to the Felmersham Gravel Pits SSSI has been
considered throughout its promotion. Previous site assessment undertaken by Bedford
Borough Council has indicated scope for mitigation, subject to investigations. Our client has
undertaken engagement with Natural England as part of its Discretionary Advice process. A
scheme of works for the necessary hydrological, drainage and water quality investigations is
to be agreed.

The Concept Masterplan has been informed by ongoing engagement with Natural England.
The latest correspondence (14/10/2020) further highlights no showstopper constraints to
development in this location. Here Natural England again welcome the provision of a Country
Park, stating this “acts as a physical buffer between the SSSI and the proposed development,
and conforms to Natural England’s NE265 'Nature Nearby' Accessible Natural Greenspace
Guidance”. A copy of this correspondence has previously been provided to Officers at the
Council.

Initial transport assessments dictate that a suitable and safe vehicular access to the
development area could be delivered in principle. This would be achieved as part of provision
of a new distributor road within Site A, enabling a traffic calming and an improvement on the
existing highways arrangement on Odell Road. The proposed arrangement provides
significant potential to improve existing pressure on the highway network associated with
Sharnbrook Academy and the School Approach roundabout. The indicative Masterplan also
includes provision of a drop-off facility for Sharnbrook Academy in order to relieve existing
pressure associated with car parking and access to buses via School Approach.
A Review of the Sharnbrook Transport Study Review (SDD Consultants) (prepared to
support representations to the emerging Neighbourhood Plan and illustrate the comparative
advantages of the site in terms of access to services and facilities in the village) is included
at Appendix 3.

This site provides a unique opportunity to create a unified educational campus with the
potential for a new one or two form entry primary school supporting the educational needs of
the community and enhancing the continuity of educational facilities within the Sharnbrook
catchment area.

The Masterplan dedicates land for provision of a local centre including the potential for
relocation of the existing GP facility and new convenience retail floorspace. The facilities
would be well-related to the site and the existing village for access by non-car modes for
current and future residents. Additional retail floorspace would assist in potentially reducing
pressure on the High Street in a sustainable location.

In conclusion, development of Land at Stoneyfields could contribute towards the needs for
development identified in the Bedford Local Plan 2040 in one comprehensively planned site,
accommodating a mixture of dwelling types in addition to providing a new primary school and
other community benefits. Both sites have a strong relationship to the existing built form of
the village, immediately adjoining the settlement boundary of Sharnbrook. As such, it is
considered that the development of these sites appears a logical extension to the village,
continuing the established settlement form in a southerly direction and rounding off
development with a new strong and defensible boundary.

Both sites A and B are within the control of one party, are available now and can be brought
forward without any need for agreement with other parties. This means development can be
phased to link with the delivery of essential infrastructure, e.g., education provision, open
space etc.

In the context of the points discussed above, the sites are unconstrained in terms of
deliverability and therefore could come forward in a timely manner. They would deliver a welldesigned
and spacious scheme, incorporating a mix of sizes and tenures as well as extra
care/care accommodation for the elderly and the potential for a new single form primary
school, all of which are required with the village.

Land at School Approach
Land at School Approach has been included in these representations as a potential smaller
scale opportunity to address risks of non-delivery or delays associated with the proposed
allocation of Hill Farm or to provide a more limited contribution towards future needs in the
Local Plan 2040 from the KSC at Sharnbrook. A boundary plan showing the site in the context
of Sharnbrook is available below.
This site has previously been submitted to the Council as part of their Call for Sites and was
suggested as a proposed ‘Reserve Site’ as part of representations to the emerging
Sharnbrook Neighbourhood Plan.

Land west of School Drive was also comprehensively analysed as part of the Borough
Council’s ‘Site Assessments and Potential Options for Allocation’ Report (April 2017), where
it was identified as part of a suitable allocation option for Sharnbrook. Details of the site were
resubmitted as part of the ‘Call for Sites’ exercise undertaken to inform the Review of the
Bedford Local Plan 2030.

The Site Assessment exercise undertaken by AECOM to support preparation of the
Sharnbrook Neighbourhood Plan identified the site as considered suitable for between 60 to
74 dwellings and considered deliverable within the next 5 years.
The site as recognised is unconstrained and well connected to the existing settlement and is
available, suitable, and achievable within the first five years of the plan period.
Copies of a Preliminary Ecological Appraisal undertaken for the site and the response from
Natural England’s Discretionary Advice Service have previously been provided to the
Council.

Additional information is provided relating to our client’s work to promote the site as part of
the Sharnbrook Neighbourhood Plan, which was produced to illustrate the benefits of the site
in comparison to objections of the proposed allocation at Hill Farm. A copy of our client’s
Vison Document for the Stoneyfields site is also provided at Appendix 8.

The following plans and documents are appended:
Appendix Drawing / Document
Ref.
Description
Appendix 1 BE5229-6-D01 Location Plan
Appendix 2 5229-SK02 Stoneyfields Indicative Masterplan
Appendix 3 BE5229-16PD Sharnbrook Transport Study Review (SDD
Consultants)
Appendix 4 SES 17005-LS02 Sharnbrook NP Comparative Landscape
Assessment
Appendix 8 N/A Stoneyfields Vision Document
Response to Borough Council’s Site Assessment Pro-Forma and Neighbourhood Plan
Assessment

These sites were submitted as part of Summer 2020 Call for Sites event.
Site Assessment Criteria (Site ID 932) – Object

The resulting assessments do not provide a robust justification for the approach taken to site
selection and supporting growth. The assessments do not provide a criteria-based
assessment of relevant factors (including suitability, availability, and achievability).
Reasoning

The site assessment found that the site has potential to cause highway and congestion
issues, however, initial transport assessments dictate that a suitable and safe vehicular
access to the development area could be delivered in principle. This would be achieved as
part of provision of a new distributor road within Site A, enabling a traffic calming and an
improvement on the existing highways arrangement on Odell Road. The proposed
arrangement provides significant potential to improve existing pressure on the highway
network associated with Sharnbrook Academy and the School Approach roundabout. The
indicative Masterplan also includes provision of a drop-off facility for Sharnbrook Academy
in order to relieve existing pressure associated with car parking and access to buses via
School Approach.

Furthermore, the site assessment has noted a ‘high risk allocation’ with regard to Natural
England Risks Opportunities, however, our client has undertaken various engagement with
Natural England as part of its Discretionary Advice process and, as a result, a scheme of
works for the necessary hydrological, drainage and water quality investigations is to be
agreed. Moreover, the Concept Masterplan has been informed by ongoing engagement with
Natural England.

In relation to the potential presence of protected species on site our client confirms that a
Preliminary Ecological Appraisal (PEA) has been undertaken. A copy has previously been
provided to Officers at the Council. This comprises a desk study, Phase 1 Habitat Survey,
and an assessment of the potential of site features to support bats, together with an
assessment of impacts at Stoneyfields. This report indicates positive findings in terms of the
suitability of the site for development, subject to further survey requirements that will be
undertaken and reported during relevant seasonal periods, taking full account of the existing
biodiversity evidence base. The report identifies that the Felmersham Gravel Pits SSSI is a
predominantly aquatic habitat and that associated requirements can be acceptably
accommodated as part of the Masterplan process.

In the absence of mitigation, the development may be considered to give rise to minor
adverse impacts on habitats for reptiles and breeding birds. The PEA further notes mitigation
has been proposed including careful lighting design for nocturnal wildlife and removal of
vegetation outside the nesting bird season. This mitigation would reduce the impacts of the
development proposals upon the habitats and species present, to give rise to an overall
Neutral to Minor Beneficial impact.

The Report also notes that “A number of ecological enhancements have been proposed,
which would improve the quality of the site for native flora and fauna, including habitat piles,
hedgehog tunnels, otter holts, bat boxes, bird boxes and native planting. Delivery of these
enhancements would lead to an overall Moderate to Major Beneficial impact.” Delivery of the
Riverside Park would be associated with further specific ecological benefits in terms of
attenuation, addressing increased recreational pressure and mitigating construction impacts
through separation from the main development areas within the site.

Any noise impacts from Santa Pod would be capable of appropriate mitigation. However, our
client notes that the Stoneyfields site falls outside of the contours for areas most likely to be
impacted by the raceway and sits on lower-lying land south of the existing built settlement.
In contrast, the Council’s assessment for the Hill Farm site (ID: 814) (which does
acknowledge noise impacts from the A6 and rail line) makes no reference to Santa Pod
despite the site’s proximity and higher elevation.
Suggested Alternative Site Assessment Finding

Given the findings of the assessment, the allocated appears to be suitable for development,
ensuring that the appropriate tests are conducted in terms of highways, ecology (including
hydrology), noise, and archaeology.

Object

Representation ID: 9013

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Reasoning
Firstly, the site assessment noted that the agricultural land classification of the site is not
known or it not clear whether it is classified as grade 3a or 3b. However, the site in isolation
would provide for smaller-scale development well-related to existing built development,
where the impact on the supply of best of most versatile agricultural land should not be seen
as significant in the context of overall development needs.

Similarly, to site ID 932, the site assessment found that the site has potential to cause
highway and congestion issues, however, initial transport assessments dictate that a suitable
and safe vehicular access to the development area could be delivered in principle. This would
likewise be achieved as part of provision of a new distributor road within Site A, enabling a
traffic calming and an improvement on the existing highways arrangement on Odell Road.
The proposed arrangement provides significant potential to improve existing pressure on the
highway network associated with Sharnbrook Academy and the School Approach
roundabout. The indicative Masterplan also includes provision of a drop-off facility for
Sharnbrook Academy in order to relieve existing pressure associated with car parking and
access to buses via School Approach.

Any noise impacts from Santa Pod would be capable of appropriate mitigation. However, our
client notes that the Stoneyfields site falls outside of the contours for areas most likely to be
impacted by the raceway and sits on lower-lying land than the majority of the built settlement.

In relation to the potential presence of protected species on site our client confirms that a
Preliminary Ecological Appraisal (PEA) has been undertaken. This report indicates positive
findings in terms of the suitability of the site for development, subject to further survey
requirements that will be undertaken and reported during relevant seasonal periods, taking
full account of the existing biodiversity evidence base. This takes account of the distance
between the School Approach site and the predominantly aquatic habitat within the
Felmersham Gravel Pits SSSI, significantly reducing the potential impacts upon protected
species.

The site assessment pro-forma findings (which are identical across most site options) take
no account of the significant distance between the site and any designated heritage asset
(including Sharnbrook Conservation Area) with the land located immediately west of recent new-build development.
Suggested Alternative Site Assessment Finding

Given the findings of the assessment, the allocated appears to be suitable for development,
ensuring that the appropriate tests are conducted in terms of highways, ecology, noise, and
archaeology.