Site Assessment Pro Formas

Object

Representation ID: 9025

Received: 04/10/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

SITE OPPORTUNITY AND RESPONSE TO SITE ASSESSMENT PRO-FORMA
(CALL FOR SITES ID: 839/832)
Introduction to Site and Proposals
7.1 The site subject to this representation is Land off Station Road, Oakley, which extends to approximately 15.22ha. The site is ‘triangular’ in shape, and is bounded to the south by Lovell Road, on its eastern side by the Midland Main railway line, which is on an embankment along this length and hence is a strong defining feature, and properties on Lovell Road (including the land at No. 24 Lovell Road which has the benefit of planning permission for residential development), and to the west by Station Road and the built development that runs with that.
7.2 The site is wholly contained by development or built infrastructure and is very well related to the structure, form, and character of the village as it appears on the ground, making it a highly sustainable location for new development.
7.3 In the case of our client’s land, the site was considered favourably in the Council’s 2017
Consultation Paper as part of preferred options for site allocation. The northern portion of the site (c.2ha) is allocated for development under Policy HG1 of the Oakley Neighbourhood Plan, which was made and adopted on the 23rd of March 2020.
7.4 The ONP allocates two sites in accordance with the requirements of Policy 4S of the LP2030 to provide for a minimum of 25-50 dwellings up to 2030.
7.5 Promotion of our client’s wider interests East of Station Road does not impact upon the intention to bring forward those parts of the land currently identified within the Indicative New Settlement Area and in accordance with the policies and objectives of the ONP.
7.6 In order to meet to ONP level of development up to 2030 and the additional level of development that would be required to satisfy the emerging Local Plan until 2040, the wider site could deliver around an additional 200 residential dwellings. Furthermore, in accordance
with relevant development plan policies, the development proposal will include the provision of additional affordable housing and a mix of housing types.
Services and Facilities
7.7 Oakley is considered to be a sustainable location for new development on the basis of the services it currently offers and its proximity to those found in nearby Clapham (approximately 2km) and Bedford some 7km to the east. Oakley provides a good range of local employment opportunities, including land designated for these uses at Highfield Road in close proximity to the site.
7.8 Furthermore, the proposed development would offer the opportunity to complement and enhance these existing facilities by enabling the existing, well-established, and popular Lincroft Academy. This is in order to both improve to better meet the needs of its pupils and staff and increase capacity to enable the school to meet the increased demands arising from
planned growth within its catchment area; notably the level of growth currently planned at Bromham, Clapham and Oakley.
7.9 The proposal would also provide the opportunity for the school to offer its sports facilities for community use whereas now the facilities are considered unsuitable for such use.
Proposed Development Option
7.10 In addition to the above, the Borough Local Plan Review 2040 rolls the Plan forward by 10 years. However, this is insufficient given the Ox-Cam Arc looks towards 2050 but notwithstanding this, it is clear that more development needs to be found across the Plan
Area. Currently, the draft Plan focuses mainly on new settlements and rail-based growth and pays little attention to the rest of the settlement hierarchy.
7.11 The land provides an opportunity to provide for a carefully considered mixed residential development area, including new and better located sports facilities for Lincroft Academy.
7.12 The allocation of our client’s Land East of Station Road in full would also enable provision a new traffic managed through-route which would be evidenced through technical reports. This proposed through-route would not only provide for the creation of a new dedicated school entrance drive and development access road for the new housing area but would also ensure that traffic would be externalised and existing issues of school traffic, parking and associated congestion on Station Road would be removed.
7.13 These representations should be read alongside and with those prepared on behalf of the Cambridge Meridian Academies Trust (CMAT) which seek recognition within the Planmaking process of the significant increase in the pupil roll be accommodated through the expansion of Lincroft Academy.
7.14 CMAT support in principle indicative land-use proposals for a ‘one-site’ solution incorporating
land East of Station Road within the Lincroft Academy Campus through the relocation of existing sports pitches, facilitated by joint promotion of the land.
7.15 Submission of these representations reflects that negotiations between the parties are advanced, ongoing and expect an agreement that will satisfy the Education and Skills Funding Agency regarding the enhancement of facilities to be achieved, retain the support of other stakeholders (including Sport England), and recognise the wider benefits of developing the larger site.
7.16 Details of an indicative layout making provision for these improvements and wider benefits is included at Appendix 2.
7.17 The proposal would both address existing and well documented issues and deliver the following benefits:
1) The creation of a new, self-contained Lincroft Academy campus (comprising both primary and secondary schools) with the existing school sports facilities, which are separated from the school at present, being moved onto land directly opposite the school, thus increasing convenience and safety, and pre-school provision. These will be re-modelled and new, modern, all-purpose facilities will be created with an indicative scheme
comprising:
• Playing fields;
• Multi-purpose artificial sports pitches;
• Athletics track;
• Sports pavilion;
• Extensive new parking and circulation area; and
• Changing and sports teaching/admin facility.
2) The stopping up of Station Road north and south of Lincroft Academy and provision of a new road around the perimeter of the site provides positive benefits. A new, traffic managed ‘through-route’ would be created on the eastern periphery of the site, which would also provide for the creation of a new dedicated school entrance drive and would also serve as a development access road and serve the new housing area. In doing so, traffic would be externalised and existing issues of school traffic, parking and associated congestion on Station Road would be removed.
3) The site could provide around an additional 200 residential dwellings including the provision of affordable housing. New tree planting would also be provided to the site boundaries, which would provide a landscaped edge to the site, as well as within the site to break up the built development.
4) The site, as stated, is well contained on all sides and there would be no encroachment into the open countryside. Development would be defined by logical and defensible boundaries – notably the railway line to the eastern side and existing residential development on the remaining boundaries. (plans amended see Appendix 1 and 2 of full rep)
Response to Borough Council’s Site Assessment Pro-Forma and Neighbourhood Plan
Assessment
7.19 The site was submitted to the Summer 2020 Call for Sites event.
Site Assessment Pro-forma (ID:839 / ID: 832) – Objection
7.20 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). The view
of Bedford Borough Council as part of its ‘Initial Site Assessments’ (2017) was that the land East of Station Road is suitable, available and achievable for development.
7.21 The site assessment pro-forma for the site does not identify future requirements for infrastructure provision or how these might be addressed; and does not assess any relevant constraints in terms of how they might be overcome. Identification of ‘wider infrastructure
issues’ is frequently cited as informing the assessment findings, including in relation to highways capacity, without adequate reference to the associated evidence base and the potential benefits arising from development.
7.22 The site assessment also highlights that there are no protective designations restricting development upon the site.
Reasoning
Impact on designated or non-designated heritage assets or their setting
7.23 The site assessment found that the site has potential to cause harm to heritage assets. As
part of external assessments relating to bringing forward application proposals on the land allocated within the Oakley Neighbourhood Plan, we can confirm these identify that development of the land may impact on the wider rural setting of nearby designated heritage
assets, resulting in slight harm to one aspect of their setting. Noting the significance of the affected assets, including the contribution made by their wider setting the level of impact is likely to be limited or negligible. With the appropriate mitigation measures (stepping back the
building from the road frontage, careful landscaping, planting etc.) the harm would certainly represent less than substantial harm in terms of Paragraph 202 of the NPPF.
7.24 Experience with the Council’s Archaeology Officer also indicates that these matters are capable of being addressed by way of a geophysical survey and/or archaeological trial trenching evaluation ahead of submission of a planning application.
Ecology and Protected Species
7.25 In relation to ecology matters, external assessments undertaken as part of bringing forward application proposals on the land allocated within the Oakley Neighbourhood Plan demonstrate that there would be no impact on protected species or habitats that could not
be appropriately mitigated.
7.26 As part of future development of the wider site it would be appropriate to seek preparation of a further Ecological Impact Assessment comprising a Phase 1 Habitat Survey and assessment of potential site features supporting the presence of protected species.
7.27 This would be an appropriate basis to 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.
Best and Most Versatile Agricultural Land
7.28 While the Council’s site assessment pro-forma records that all or a majority of the site is best
and most versatile agricultural land as defined in the NPPF this ignores that a significant proportion of the site is in use as existing playing fields with around 2ha already subject to allocation within the adopted development plan. The land does not form part of a wider area used for forming and relates most closely to the existing built-up area. On this basis 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.
Highways
7.29 The key factor identified as an area of concern within the Council’s site assessment proforma relates to perceived highways issues. The site assessment states that the amount of extra traffic resulting from the proposed development would likely cause increased congestion, particularly on Station Road. 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.
7.30 The Council’s assessment findings ignore altogether the expected increase in pressure that will result from the immediate expansion required in the pupil roll at Lincroft Academy. Proposals for our client’s land, which are not reflected in the pro-forma, include the stopping
up of Station Road north and south of Lincroft Academy and provision of a new road around the perimeter of the site. In doing so, traffic would be externalised and existing issues of school traffic, parking and associated congestion on Station Road would be removed.
7.31 Furthermore, the scheme proposes to include an expansion of the footpath network to create a safer environment for pedestrians as well as providing improved cycle connections for access to the schools.
Suggested Alternative Site Assessment Finding
7.32 Given the findings of the assessment, Land East of Station Road appears to be suitable for development, ensuring that the appropriate assessments are conducted in terms of highways and archaeology. See main rep attached which includes District Wide Delivery Assessment.

Object

Representation ID: 9026

Received: 04/10/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

SITE OPPORTUNITY AND RESPONSE TO SITE ASSESSMENT PRO-FORMA
(CALL FOR SITES ID: 839/832)
Introduction to Site and Proposals
7.1 The site subject to this representation is Land off Station Road, Oakley, which extends to approximately 15.22ha. The site is ‘triangular’ in shape, and is bounded to the south by Lovell Road, on its eastern side by the Midland Main railway line, which is on an embankment along this length and hence is a strong defining feature, and properties on Lovell Road (including the land at No. 24 Lovell Road which has the benefit of planning permission for residential development), and to the west by Station Road and the built development that runs with that.
7.2 The site is wholly contained by development or built infrastructure and is very well related to the structure, form, and character of the village as it appears on the ground, making it a highly sustainable location for new development.
7.3 In the case of our client’s land, the site was considered favourably in the Council’s 2017
Consultation Paper as part of preferred options for site allocation. The northern portion of the site (c.2ha) is allocated for development under Policy HG1 of the Oakley Neighbourhood Plan, which was made and adopted on the 23rd of March 2020.
7.4 The ONP allocates two sites in accordance with the requirements of Policy 4S of the LP2030 to provide for a minimum of 25-50 dwellings up to 2030.
7.5 Promotion of our client’s wider interests East of Station Road does not impact upon the intention to bring forward those parts of the land currently identified within the Indicative New Settlement Area and in accordance with the policies and objectives of the ONP.
7.6 In order to meet to ONP level of development up to 2030 and the additional level of development that would be required to satisfy the emerging Local Plan until 2040, the wider site could deliver around an additional 200 residential dwellings. Furthermore, in accordance
with relevant development plan policies, the development proposal will include the provision of additional affordable housing and a mix of housing types.
Services and Facilities
7.7 Oakley is considered to be a sustainable location for new development on the basis of the services it currently offers and its proximity to those found in nearby Clapham (approximately 2km) and Bedford some 7km to the east. Oakley provides a good range of local employment opportunities, including land designated for these uses at Highfield Road in close proximity to the site.
7.8 Furthermore, the proposed development would offer the opportunity to complement and enhance these existing facilities by enabling the existing, well-established, and popular Lincroft Academy. This is in order to both improve to better meet the needs of its pupils and staff and increase capacity to enable the school to meet the increased demands arising from
planned growth within its catchment area; notably the level of growth currently planned at Bromham, Clapham and Oakley.
7.9 The proposal would also provide the opportunity for the school to offer its sports facilities for community use whereas now the facilities are considered unsuitable for such use.
Proposed Development Option
7.10 In addition to the above, the Borough Local Plan Review 2040 rolls the Plan forward by 10 years. However, this is insufficient given the Ox-Cam Arc looks towards 2050 but notwithstanding this, it is clear that more development needs to be found across the Plan
Area. Currently, the draft Plan focuses mainly on new settlements and rail-based growth and pays little attention to the rest of the settlement hierarchy.
7.11 The land provides an opportunity to provide for a carefully considered mixed residential development area, including new and better located sports facilities for Lincroft Academy.
7.12 The allocation of our client’s Land East of Station Road in full would also enable provision a new traffic managed through-route which would be evidenced through technical reports. This proposed through-route would not only provide for the creation of a new dedicated school entrance drive and development access road for the new housing area but would also ensure that traffic would be externalised and existing issues of school traffic, parking and associated congestion on Station Road would be removed.
7.13 These representations should be read alongside and with those prepared on behalf of the Cambridge Meridian Academies Trust (CMAT) which seek recognition within the Planmaking process of the significant increase in the pupil roll be accommodated through the expansion of Lincroft Academy.
7.14 CMAT support in principle indicative land-use proposals for a ‘one-site’ solution incorporating
land East of Station Road within the Lincroft Academy Campus through the relocation of existing sports pitches, facilitated by joint promotion of the land.
7.15 Submission of these representations reflects that negotiations between the parties are advanced, ongoing and expect an agreement that will satisfy the Education and Skills Funding Agency regarding the enhancement of facilities to be achieved, retain the support of other stakeholders (including Sport England), and recognise the wider benefits of developing the larger site.
7.16 Details of an indicative layout making provision for these improvements and wider benefits is included at Appendix 2.
7.17 The proposal would both address existing and well documented issues and deliver the following benefits:
1) The creation of a new, self-contained Lincroft Academy campus (comprising both primary and secondary schools) with the existing school sports facilities, which are separated from the school at present, being moved onto land directly opposite the school, thus increasing convenience and safety, and pre-school provision. These will be re-modelled and new, modern, all-purpose facilities will be created with an indicative scheme
comprising:
• Playing fields;
• Multi-purpose artificial sports pitches;
• Athletics track;
• Sports pavilion;
• Extensive new parking and circulation area; and
• Changing and sports teaching/admin facility.
2) The stopping up of Station Road north and south of Lincroft Academy and provision of a new road around the perimeter of the site provides positive benefits. A new, traffic managed ‘through-route’ would be created on the eastern periphery of the site, which would also provide for the creation of a new dedicated school entrance drive and would also serve as a development access road and serve the new housing area. In doing so, traffic would be externalised and existing issues of school traffic, parking and associated congestion on Station Road would be removed.
3) The site could provide around an additional 200 residential dwellings including the provision of affordable housing. New tree planting would also be provided to the site boundaries, which would provide a landscaped edge to the site, as well as within the site to break up the built development.
4) The site, as stated, is well contained on all sides and there would be no encroachment into the open countryside. Development would be defined by logical and defensible boundaries – notably the railway line to the eastern side and existing residential development on the remaining boundaries. (plans amended see Appendix 1 and 2 of full rep)
Response to Borough Council’s Site Assessment Pro-Forma and Neighbourhood Plan
Assessment
7.19 The site was submitted to the Summer 2020 Call for Sites event.
Site Assessment Pro-forma (ID:839 / ID: 832) – Objection
7.20 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). The view
of Bedford Borough Council as part of its ‘Initial Site Assessments’ (2017) was that the land East of Station Road is suitable, available and achievable for development.
7.21 The site assessment pro-forma for the site does not identify future requirements for infrastructure provision or how these might be addressed; and does not assess any relevant constraints in terms of how they might be overcome. Identification of ‘wider infrastructure
issues’ is frequently cited as informing the assessment findings, including in relation to highways capacity, without adequate reference to the associated evidence base and the potential benefits arising from development.
7.22 The site assessment also highlights that there are no protective designations restricting development upon the site.
Reasoning
Impact on designated or non-designated heritage assets or their setting
7.23 The site assessment found that the site has potential to cause harm to heritage assets. As
part of external assessments relating to bringing forward application proposals on the land allocated within the Oakley Neighbourhood Plan, we can confirm these identify that development of the land may impact on the wider rural setting of nearby designated heritage
assets, resulting in slight harm to one aspect of their setting. Noting the significance of the affected assets, including the contribution made by their wider setting the level of impact is likely to be limited or negligible. With the appropriate mitigation measures (stepping back the
building from the road frontage, careful landscaping, planting etc.) the harm would certainly represent less than substantial harm in terms of Paragraph 202 of the NPPF.
7.24 Experience with the Council’s Archaeology Officer also indicates that these matters are capable of being addressed by way of a geophysical survey and/or archaeological trial trenching evaluation ahead of submission of a planning application.
Ecology and Protected Species
7.25 In relation to ecology matters, external assessments undertaken as part of bringing forward application proposals on the land allocated within the Oakley Neighbourhood Plan demonstrate that there would be no impact on protected species or habitats that could not
be appropriately mitigated.
7.26 As part of future development of the wider site it would be appropriate to seek preparation of a further Ecological Impact Assessment comprising a Phase 1 Habitat Survey and assessment of potential site features supporting the presence of protected species.
7.27 This would be an appropriate basis to 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.
Best and Most Versatile Agricultural Land
7.28 While the Council’s site assessment pro-forma records that all or a majority of the site is best
and most versatile agricultural land as defined in the NPPF this ignores that a significant proportion of the site is in use as existing playing fields with around 2ha already subject to allocation within the adopted development plan. The land does not form part of a wider area used for forming and relates most closely to the existing built-up area. On this basis 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.
Highways
7.29 The key factor identified as an area of concern within the Council’s site assessment proforma relates to perceived highways issues. The site assessment states that the amount of extra traffic resulting from the proposed development would likely cause increased congestion, particularly on Station Road. 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.
7.30 The Council’s assessment findings ignore altogether the expected increase in pressure that will result from the immediate expansion required in the pupil roll at Lincroft Academy. Proposals for our client’s land, which are not reflected in the pro-forma, include the stopping
up of Station Road north and south of Lincroft Academy and provision of a new road around the perimeter of the site. In doing so, traffic would be externalised and existing issues of school traffic, parking and associated congestion on Station Road would be removed.
7.31 Furthermore, the scheme proposes to include an expansion of the footpath network to create a safer environment for pedestrians as well as providing improved cycle connections for access to the schools.
Suggested Alternative Site Assessment Finding
7.32 Given the findings of the assessment, Land East of Station Road appears to be suitable for development, ensuring that the appropriate assessments are conducted in terms of highways and archaeology. See main rep attached which includes District Wide Delivery Assessment.