Site Assessment Pro Formas

Object

Representation ID: 7748

Received: 22/09/2021

Respondent: Colmworth Parish Council

I do not support the proposal for a new “garden village” settlement at Dennybrook (site ID 977) included in three of the four options within the draft Local Plan 2040
(LP40).
I believe the Dennybrook proposal should be rejected for a number of reasons:
- Dennybrook delivers very few houses in the all important 0-5 year period, it is
the worst choice among the major sites.
- Dennybrook’s claims of housing delivery beyond year 5 at a rate of 500 per annum (10 sales per week, every week, for 20 years) seem highly optimistic,
way beyond the expectations of the other major developments. This creates a far higher risk of under-delivery than with other proposals. Even though BBC
is not relying on this delivery rate it highlights an unacceptable concentration of power in the hands of a single developer.
- The submission shows that the developer expects construction traffic on the site for over 25 years, that is an unacceptable burden on neighbouring communities.
- Dennybrook has comparatively poor access to Bedford, many people will favour St Neots which adds further economic damage to Bedford town centre which is in serious decline.
- Apart from the far end of the Dennybrook site near St Neots, the only exits from the site are unclassified roads incapable of handling the traffic volume.
The central road is a single-track road. Wilden Road is one of several local roads classified as “Unsuitable for HGVs” presenting a clear risk of unsuitable
traffic using local access privileges elevating accident risk. Neither the Dennybrook submission nor the Transport Model include any proposals for road widening or enhancement of the local minor roads that will be
overwhelmed.
- There is no shortage of high quality development opportunities for inclusion in the plan. The call-for-sites returned over 430 responses totalling in excess of
70,000 plots against a need of around 12,500 plots for completion of the plan.
There is no need to consider something as large and destructive as the Dennybrook proposal.
I recognise that the principal advantage of including a garden village settlement is that it creates the potential for a community of a size that can be largely self sufficient
and thus less reliant on neighbouring communities for services and facilities over time.
When the (originally much smaller) Wyboston site was assessed as part of LP35 BBC concluded that “the site is on the edge of the Bedford housing market area and
therefore the Council consider that if the garden village were to be allocated, it would contribute to meeting Bedford’s economy and housing need. However, the site lies very close to St Neots and it is likely that pressure would be placed on services and facilities in St Neots. This impact has not been assessed by the site promoter.” I believe this under-estimates the relative convenience and attractiveness of St Neots and thus overstates the likely contribution to Bedford’s economy and housing needs.
The site lies in the northeast corner of Bedford Borough and is significantly closer to the town of St Neots. It is likely that most new residents, in common with existing
residents in the area, will focus on that community for shopping and entertainment needs and to some degree employment. This presents a problem for BBC as the
site will be relatively unattractive to residents whose lives currently focus on Bedford, many purchasers are likely to be drawn from the St Neots area and thus the site may
not adequately address anticipated growth in housing demand from Bedford.
Moreover, Bedford will receive comparatively little economic benefit from the site’s residents and it is even possible that Bedford may see a negative impact from some of its wealthier residents who currently commute to London from the Midland station who choose to relocate to this site to benefit from the proposed Little Barford rail
station. Thus the site will likely fail to support Bedford housing needs and fail to provide economic growth to Bedford in proportion to the scale of the development.
In terms of delivery of the site the program is heavily dependent on road access arising from the planned improvement works around the Black Cat roundabout A421/A1 junction, the timetable for which remains unassured and the necessary capacity improvements are not guaranteed. The DCO has not yet been granted and a delay to the completion of the Highways England’s scheme could have a significant impact
on both the delivery of housing and local traffic flow generally. No work has been done within the Dennybrook proposal to evaluate the mitigation that would be
required to the Black Cat Roundabout should the Highways England scheme not progress or be delayed.
The Dennybrook site lies in a very rural situation where there are exceptionally few existing facilities in the immediate vicinity. There is minimal employment, little public transport, no retail outlets and no educational resources locally at present. The proposal allocates some land towards the provision of such facilities but the
scheduled build-out rate for the site is unlikely to provide self-sufficiency in these facilities for more than a decade leading to significant reliance on neighbouring
communities, particularly in the St Neots area, placing a substantial burden on those communities. Once the development is complete there will be inadequate gaps
remaining between the development and the communities of Colmworth, Wyboston and others to prevent coalescence with the existing settlements, effectively erasing the identity of historic settlements dating back to medieval and earlier periods.
The location of the site means that, for employment purposes in particular, many residents will be commuting above-average distances and will be almost wholly
reliant on private cars. The distances for most would not encourage walking and cycling and while there is a new railway station planned for the area, possibly around
Little Barford, this will best suit London commuters for the most part. Residents working in and around Bedford Borough are unlikely to find it either efficient or
economic to travel away from Bedford to the new station in order to take a train back to Bedford Midland station for a connecting train, bus or taxi onto their employment
destination.
In the LP35 assessment of the site BBC concluded that “the existing walking and cycling provision near the site is generally good, however some of the surrounding
infrastructure requires improvement (e.g. subway under Northfield road, footbridge over the A1).” However, the proposed is site is three miles in length and two miles
from the midpoint to Eaton Socon. Accordingly it seems unlikely that walking will be feasible outside the site boundaries. BBC noted “The site is located in a relatively
convenient location for vehicle journeys on the strategic road network, which may be a deterrent to non-motorised travel.“
There is no doubt that residents would be almost wholly dependent upon the private car, that is simply an established characteristic of rural life and nothing in this
proposal contributes to an effective solution to this issue. As a result, the proposal cannot be considered to be the most environmentally sound or sustainable solution
to Bedford’s housing needs. While the site will be inconvenient and unattractive to many in Bedford, there is likely to be increasing demand from residents working in the Cambridge area, looking to benefit from the new East West Rail service when available. However, these housing needs could in all likelihood be accommodated within a much smaller development such as site ID 907 at Little Barford, very close to the proposed East West Rail
station. It is difficult to see how the Dennybrook development in its current form could deliver the most appropriate strategy for expanding Bedford.
Within the analysis for LP35 the Council’s view was that the timing was not right to take forward a garden village in Wyboston. The Council wanted to have more
certainty on the timing of delivery of the Black Cat scheme, the A428/Caxton Gibbet scheme and the possibility of the A1 realignment. In particular, the Black Cat and A428 projects were considered crucial pre-requisites to a major Wyboston development and while plans and surveying for these road schemes have moved
forward, there is still no certainty as to the timing of completion. On present scheduling, construction traffic for Dennybrook would be heaviest at a time when the
Black Cat, the A1, the A421 and the A428 are all subject to partial and temporary closures adding to the current congestion.
There are multiple points of access to the Dennybrook site but currently there is no direct access to classified roads. The primary access point will be at the eastern end of the site via the A4280 onto the A1 and A421 at the Black Cat junction. There are no other A or B class roads near the site. The main access point on the western side
is Mill Road, a single-track road that runs through the site. Thus road access, particularly in the direction of Bedford, can only be described as inadequate for such
a large development.
When the site was assessed as part of the LP35 analysis, the Council stated that “the existing road widths, visibility and constraints are inappropriate to accommodate the proposed levels of development” “Access to the A1 via rural roads is currently
considered to be inadequate and unacceptable, with no proposals for improvement identified.” That conclusion related to a site of only 4,000 homes compared to the
current proposal for 10,150 homes. Despite being aware of the problem for several years now the promoters have not been able to incorporate any suggested solution
within the proposal.
The commercial value of the Dennybrook project would exceed £3 billion. Despite this, the site promoters have provided extremely little information about, or
commitment to, infrastructure improvements that would need to be delivered. There is no material information showing new roads, road widening schemes, road junction redesign, footpaths and cycle paths, public transport support, public services, leisure
facilities etc. The promoters are seeking permission to build a new town the size of
Biggleswade but are focused almost solely on the sale of houses and have given no commitment to providing the key components that comprise a successful and
desirable town environment. While there is a long way to go before the site has formal planning permission, the inclusion of the site within the LP40 would give
effective commitment to the project, essentially a commercial decision would have been made without most of the crucial facts, specification and evidence that a project of this magnitude would ordinarily provide as a prerequisite. That process introduces an unacceptable degree of project risk that is so easily avoidable. This proposal places too much control in the hands of the site promoter at the expense of BBC.
A key concern is that this single site would be selected to address almost half of all housing need in Bedford Borough for an entire generation. It seems extremely
unlikely that this scale of development in what is probably the most rural part of the Borough, largely detached from Bedford by distance and transport accessibility, can
be achieved at the rate suggested by the promoter of 500 units annually for two decades. There is a material risk that development will be moderated to support
prices meaning the site will not deliver housing at the rate promised affecting this and future Local Plans. That would also lead to a connected concern about
extension of the development schedule from the current 25 years to much longer meaning that local communities may be affected by construction traffic for 30 years
or more. That seems wholly unreasonable when there are so many other site alternatives that will not have such a destructive effect on existing residents’ lives.
Although not directly relevant to a decision on housing allocation it is worth noting that BBC made a very strong presentation to attract the East West Rail link into
Bedford town centre because of a marginal economic gain. It makes no strategic sense therefore to promote a housing scheme that is the most economically
disadvantageous to the Borough of all the proposals arising from the call-for-sites.

Object

Representation ID: 9066

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

9.1. CPC considers the Dennybrook to be sited in an unsustainable location located a very considerable distance from any existing infrastructure. The amount of infrastructure required to make such a location a sustainable and resilient location to deliver a new settlement has not been quantified by BBC or the site promoter (that we are aware of) and has clearly not been costed or critically assessed in terms of its viability. Whilst the Draft Local Plan assumes the Dennybrook for 2,500 dwellings, the site promoter’s Vision document states 7,500 – 10,000 dwellings and clearly the parcels of land they have submitted are also on the basis of a scheme of that magnitude and not 2,500. However BBC has not clarified this in its Draft Local Plan or in its supporting evidence base which is most unhelpful and disingenuous to the local community.

INCLUDES FIGURE 9.1 DISTANCE FROM DENNYBROOK TO TOWN CENTRES 'AS THE CROW FLIES'

9.2. As our map demonstrates the centre of the Dennybrook site is very isolated and located a considerable distance from any town centre. Our measurements estimate the following distances from the centre of the site to the three nearest town centres: Bedford, St Neots and Sandy:
• Dennybrook – Bedford Town Centre: 11.85 km (7.4 miles)
• Dennybrook – Sandy: 9.45 km (5.87 miles)
• Dennybrook – St Neots: 5.25 km (3.26 miles)
9.3. These measurements are ‘as the crow flies’ so they do not take account of the route one would need to take in order to access these town centres now (and in the future without the appropriate infrastructure in place).
9.4. We have also prepared a map which calculates the distances using the actual road network currently in place which is likely more accurate which demonstrates even further the isolated location of the site in terms of accessing existing services and facilities of the order of a town centre. This illustrates 14.4 km (8.9 miles) into Bedford, 11.7km (7.2miles) into Sandy and 8.17 km (5 miles) into St Neots.
9.5. The remoteness of this proposed site will clearly lead to unsustainable travel patterns and behaviour.

INCLUDES FIGURE 9.2: DISTANCE FROM DENNYBROOK TO TOWN CENTRES USING ROAD NETWORK

Infrastructure
9.6. CPC consider the Dennybrook Garden Village to not have sufficient levels of supporting infrastructure in terms of both existing and potential future infrastructure. As we have already demonstrated Dennybrook is in a remote location, so any infrastructure to serve the development needs to be built.
9.7. As noted within the associated Call for Sites Form, the proposed use of the site is for housing, retail and employment”. This is clarified by stating that “as a new settlement the site would provide a range of retail opportunities including supermarkets to meet weekly shopping needs and local centres as part of mixed-use hubs”. However, no further information regarding infrastructure has been provided by the developer and nor has BBC provided any further information regarding infrastructure. This is apart from BBC stating:
“By 2030 the Black Cat Junction improvements will be complete, the East West Rail section through Bedford Borough will be complete (including new and re-modelled stations) and sufficient lead-in time will have been available for strategic projects to be planned in detail, enabling these higher numbers to be achieved. The forward planning will include arrangements for new sustainable travel links, with the intention that these are available from day one in order to embed and promote sustainable travel choices”
9.8. However BBC also confirms that the Arc Spatial Strategy will not be finalised in time to inform BBC’s Local Plan which does lead to a great deal of confusion as to what infrastructure is confirmed for delivery or not:
“the Arc spatial strategy will not be finalised in time to inform the preparation of this plan and the Council must focus on meeting its own growth requirements”
9.9. Whilst the site promoter seeks to convey that their site has opportunities to integrate with the new East-West Rail and new station we consider that such opportunities are entirely unrealistic and poorly considered. The promoter’s map provided in its Vision (see below) shows a number of these potential improvements which only demonstrates how poorly integrated the site would actually be with the rail and road improvements. We take these in turn below.

INCLUDES FIGURE 9.3 DENNYBROOK VISION DOCUMENT -RAIL INTEGRATION OPPORTUNITIES

1. Upgraded Black Cat Roundabout:
The Black Cat Roundabout proposals are currently at the examination stage for a Development Consent Order (DCO) so the proposals are not yet approved. As we set out elsewhere in this section the transport assumptions that are used in the BBTM appear to be unjustified and therefore the modelling outputs in relation the Black Cat Roundabout upgrades cannot be relied upon. The site promoter should not assume that the upgrades to the Black Cat Roundabout will necessarily benefit its scheme as the capacity may well already be taken up by planned developments within and outside of Bedford Borough by the time the Dennybrook were to deliver any significant level of housing.
2. New Black Cat Roundabout to Caxton Gibbet Dual Carriageway: See above
3. New local link road with Roundabout on Roxton Road:
The drawing does not provide any clarity on how this road would actually function on the ground or how it even links into the proposed site. The proposed new link road onto the Roxton Road roundabout would cause widespread disruption within the local area. As shown below, the link road threatens to divide Chawston into two (east/west divide). Given that Chawston Lane is an existing direct link road, providing access northbound onto the A1, it is deemed highly inappropriate for a new link road to be situated close the the A1 junction. In the absence of any further details on this transport scheme, it is not possible to establish what the implications for this local area are, however there is no doubt that the existing Chawston Lane is not a suitable road for increased usage due to its rural nature. As such, it is clear that this issue conflicts with paragraph 104a) of the NPPF, as it is clear that the potential transport impacts have not been fully addressed.
4. New service road to access Great North Road / PFS & neighbouring properties: This service road is on the opposite side of the A1 to the proposed site. We question how this road is relevant to the Dennybrook proposals and why it is being shown.
5. New station – St Neots / Sandy area:
The promoters show one potential location of the potential new railway station which is the one option that is closest to the Dennybrook site. We have prepared our own mapping to calculate the distance and cycling times from the Dennybrook site to the railway station options (see below) which demonstrates that the development and its population will be far too remote from the station for any prospect of the station acting as a realistic sustainable transport hub for the residents at Dennybrook if it were ever to come to fruition.
6. Potential East / West Rail Line Alignment:
The East-West Rail line alignment shown by the site promoters is only one of an number of options being considered by Government. We have prepared a map to show the actual options being considered.
7. Cycle Link to New Station:
The site promoter’s very rough drawing of a dotted line for a cycle link which would link the southern end of the site with one of the railway station options is void of any technical assessment whether such an idea is feasible and it is therefore a theoretical idea and should not be relied upon. We have undertaken mapping analysis of the distance and cycle times between Dennybrook and the potential stations below.

INCLUDES FIGURE 9.4: DISTANCE BETWEEN DENNYBROOK AND POTENTIAL NEW RAILWAY STATION

As one can see the distances based on our calculations are as follows:
• Dennybrook – Option 1: 7.07 km (4.4 miles)
• Dennybrook – Option 2: 7.28 km (4.5 miles)
• Dennybrook – Option 3: 7.62 km (4.7 miles)
• Dennybrook – Option 4: 7.81 km (4.8 miles)

These distances are clearly the ‘best case scenario’ even though they are calculated from the furthest distance of the site. This is because the distances are calculated ‘as the crow flies’ whereas the road or cycle network to access these stations would be considerably further.
Without any detailed proposals for road and cycling infrastructure from the site promoters we have made some technical assumptions in order to arrive at a more accurate idea of the likely distance and cycling times to the potential new railway stations. To do this we have used the shortest route from the centre of the site along a network composed of the existing network and a straight line extension to the proposed station where no other access route was built. We used Google Maps API to determine the shortest route distances combined with a GIS calculator to determine the length and time for cycling speeds of 13.8km/h.
• Dennybrook – Option 1: 9.87 km (6.13 miles) 43 minutes
• Dennybrook – Option 2: 8.86 km (5.50 miles) 39 minutes
• Dennybrook – Option 3: 8.69 km (5.40 miles) 38 minutes
• Dennybrook – Option 4: 8.63 km (5.36 miles) 38 minutes

INCLUDES FIGURE 9.5: CYCLING DISTANCE AND TIME ESTIMATES FROM DENNYBROOK SITE TO POTENTIAL NEW RAILWAY STATIONS

Any suggestion that the Dennybrook site can be considered as ‘integrated’ with the potential new railway station is clearly unfounded by the distance between locations of the site and the potential station locations. There is no clear proposed road link that could link the site to any of the potential railways station option so it is not possible to justify public transportation linking with a railway station. Cycling will clearly not be possible as a legitimate option for residents as clearly the distance of approximately 5 miles is not something an ordinary person could endure for regular or even occasional use of a railway station.
Clearly CPC is supportive of walking and cycling as the most sustainable forms of travel and that any new settlement proposals in the borough would need to deliver walking and cycling infrastructure to the public transport network, however such plans need to be realistic and these are not.
BBC’s Transport Evidence
9.10. BBC has published 4 transport evidence base documents with the consultation:
• Bedford Borough Transport Model – Draft Local Plan Assessment Report and Summary (2021)
• Bedford Borough Transport Model - New Settlement West of Wyboston (2021)
• Bedford Borough Transport Model - New Settlements and the A6 (2021)
• Bedford Borough Transport Model - New Settlements and the Black Cat Junction (2021)
9.11. BBC does not explain its reasoning for preparing a separate report for Dennybrook but
not a separate report for the other new settlements being promoted.
9.12. We consider the transport evidence to be lacking in detail about the growth assumptions that have been input into the model and seek clarification on this. As BBC will be aware ‘a model is only as good as its assumptions’ and as it currently stands the transport evidence cannot be relied upon as sound evidence base due to the questionable growth assumptions and ‘highway infrastructure schemes’ assumed to be delivered. We explain this in more detail below.
9.13. At the start of all three reports the consultants explain that BBC has commissioned them to develop a multi-modal transport model (BBTM) covering the borough and areas adjacent to the borough in neighbouring authorities. We have a number of questions about this as it is not clear from the evidence documents and the plans and assumptions about growth in neighbouring areas is clearly a key consideration for the modelling. We note there are some maps provided showing the assumptions however these are difficult to read and interpret and we would be grateful for clarity on this matter.
• Did BBC work with its neighbouring authorities in preparing the model? If so, where is the evidence of this joint working?
• What exact ‘areas adjacent to the borough’ were included in the model?
• What growth assumptions were assumed for growth in neighbouring authority areas in the 2030, 2040 and 2050 scenarios?
9.14. No employment is assumed to be proposed with the Dennybrook development. The site promoter’s Vision document explains that central to the appeal of the promoted new village is the potential for a new science and technology hub saying it will have direct access to the new and improved infrastructure corridors to the south. Clearly this is growth that the transport evidence should be addressing.
9.15. It is unclear from the evidence what has been assumed (if anything) in terms of other uses including retail. The reasoning for this is not explained in the evidence. This is despite the site promoter’s Call for Site form stating that they intend to use of the site is for “housing, retail and employment” “as a new settlement the site would provide a range of retail opportunities including supermarkets to meet weekly shopping needs and local centres as part of mixed-use hubs”.
9.16. The transport evidence appears to randomly select site access locations due to the fact that “detailed information on the site access locations and any internal development network is not available at the present time”. Due to this lack of information it states that “the development has been assumed to connect to the existing highway network at various points along Staploe Road to the west of Wyboston as shown in Figure 2.3” at that the development has been split equally between five development zones. The consultants provide no justification or reasoning for selecting Staploe Road as the means to connect thousands of new homes to the highway network using a country lane in the middle of the countryside. There is no explanation as to how the development zones were selected which seems random as well.

INCLUDES FIGURE 9.6: ASSUMED DEVELOPMENT ZONES AT DENNYBROOK

9.17. We understand that the consultants have assumed in their ‘reference case’ that the following transport schemes within the borough and in neighbouring authority areas, will be implemented by the dates indicated. The report explains that these projects were provided by BBC to the consulant so there does not seem to have been a critical assessment of the validity of these projects and their assumed ‘opening dates’. As we highlight elsewhere in our representations, BBC has not prepared an Infrastructure Delivery Plan (IDP) to support its Draft Local Plan which makes the job of getting a comprehensive understanding of the likely infrastructure to be delivered very difficult. The schemes list in Table 2.2 and Table 2.3 (see below) whilst helpful to see in one place, do not provide much detailed information for the reader and no maps are provided to communicate the location of these schemes. We request that BBC and its consultants provide mapping and scheme details so that consultees and stakeholders can have meaningful input into these important assumptions.

INCLUDES FIGURE 9.6: HIGHWAYS INFRASTRUCTURE SCHEME ASSUMPTIONS

9.18. The report includes a number of proposed mitigation measures which were also provided by BBC to the consultants. One would have assumed the consultants would have worked with BBC to objectively determine mitigation measures based on the model’s outputs however the mitigation measures seem to be soley defined by BBC in the first instance and it is unclear what these mitigation measures are based on, their feasibility or deliverability and therefore whether they can be relied upon in the model.

INCLUDES FIGURE 9.7: HIGHWAYS INFRASTRUCTURE SCHEMES ASSUMPTIONS

9.19. The BBTM Local Plan Assessment Summary includes a number of ‘suggested additional Mitigation Measures for Proposed Dennybrook and Little Barford Developments (see table below) which the consultant consider would be required to mitigate the impacts of the two potential developments.
9.20. There does not seem to be any explanation or details of the suggested additional measures in the report as far as we can see so it is difficult to comment on these measures. We question the accuracy of the estimated costs which seem to underestimate the costs to deliver new and improved infrastructure provision to mitigate the significant amount of development that would be delivered in these locations.

INCLUDES FIGURE 9.8: TABLES A.5 BBTM LOCAL PLAN ASSESSMENT SUMMARY

9.21. As highlighted within the Bedford Borough Transport Model – New Settlement West of Wyboston (2021), traffic forecasts revealed that under the 2050 scenario without the proposed mitigation measures, “traffic is to increase within the borough by 29.5% in both the AM peak and PM peak hours compared with the 2018 base year, with growth between 14.5% in the AM peak hour and 14.8% in the PM peak hour forecast to occur from the base year to the 2030 reference case”. This increase is unacceptable and would undoubtedly lead to widespread congestion throughout Bedford Borough.
Water Supply
9.22. CPC is also concerned that there is no evidence to demonstrate how water supply will be safeguarded. This issue was also raised by the Environment Agency (stated within the Draft Sustainability Appraisal Report, 2021, stating that:
“water companies are only expected to meet increased demands from development by the means of new strategic schemes and the timings of these schemes will be crucial in the phasing of growth. It is important that the Sustainability Assessment evaluates the need to prevent deterioration in Water Framework Directive targets which will prevent water companies from using headroom to increase supply to new developments. Considering that current levels of abstraction are causing environmental damage, we recommend that that the Local Plan considers water resources as a key issue and your Authority recognises the damage of long term increases in abstraction due to growth. We also recommend any new development takes into account the combined effect of growth across the region, including in neighbouring authorities, and therefore the overall increase in demand for water”
9.23. In response to the above comment, BBC stated that the point is “to be considered in the preparation of local plan policies”. The Regulation 18 Local Plan adds that
“a large part of combating climate change is in the pattern of development that will occur in the borough going forward and this will be directly influenced by the spatial strategy that the Council adopts. By choosing a spatial strategy which will encourage fewer greenhouse gas emissions, the Council can work towards adapting development to reduce climate change risk and mitigate against the causes of climate change”.
9.24. However, despite this claim, there is currently no policy to address water supplies, or climate change, nor is there any evidence produced on this matter. This is a clear oversight by BBC, as, in the absence of evidence to state otherwise, it is possible that the Dennybrook scheme could adversely impact existing and future water supplies within the local area. As such, it is considered that this omission conflicts with paragraph 154a) of the NPPF, as it is clear that any added strains to the existing water resources would “increase vulnerability to the range of impacts arising from climate change”.
Wastewater
9.25. With a site being promoted for between 7,500 – 10,000 dwellings one would expect more information about the proposals for supporting wastewater infrastructure. This can often be a significant hurdle to the delivery of new settlement proposals and needs much further investigation as to its feasibility and viability. We notclimate change, nor is there any evidence produced on this matter. This is a clear oversight by BBC, as, in the absence of evidence to state otherwise, it is possible that the Dennybrook scheme could adversely impact existing and future water supplies within the local area. As such, it is considered that this omission conflicts with paragraph 154a) of the NPPF, as it is clear that any added strains to the existing water resources would “increase vulnerability to the range of impacts arising from climate change”. e from our own research that the Tempsford wastewater treatment facility is the nearest to the Dennybrook site however further information is needed regarding its capacity, required upgrades and pressure on its capacity from other proposed schemes in the area.
as Pipeline
9.26. There are two gas pipes which run north and south through the Dennybrook site. One is located in the eastern part of the site and the other in the western part as illustrated in the map below.
9.27. The site promoter for Dennybrook does not include information about the gas pipelines running across the site and their Vision document only mentions the pipeline in the east of the site where it says they will create a ‘wildflower corridor’ utilising the easement of the gas mains pipe.
9.28. Much more detailed assessment of the gas pipes and their constraints on the site needs to be undertaken by BBC and the site promoter. Has there been any engagement and discussion with National Grid and the Health and Safety Executive regarding this? If so, what are the details and outcomes of the discussions?

INCLUDES FIGURE 9.9 UTILITIES MAP AND DENNYBROOK

10. Heritage
10.1. The Council’s evidence base in relation to Heritage is unsound and severely lacking particularly in relation to the fact that BBC has not prepared Heritage Impact Assessments on its options to comply with the NPPF and Historic England’s Advice Notes.

10.2. Chapter 16 of the NPPF places an emphasis on the need to conserve and enhance the historic environment. In the context of Bedford Borough, this sentiment is mirrored in the Bedford Borough Landscape Character Assessment (2020), which states that “it is important that the many opportunities for the enhancement of the borough’s historic environment, including its historic landscape character, are realised. Any adverse impacts on the historic environment arising from development should be minimised to avoid degradation. The historic environment provides character and identity to places, and a positive template for new development. It can play a key role in creating a ‘sense of place’ and identities as new communities are created and existing ones enhanced”. Despite this, the Draft Local Plan and its evidence base provide very little information relating to the historic environment. CPC is therefore concerned that the absence of historic information could result in the degradation of heritage assets.
10.3. The Bedford Borough Landscape Character Assessment refers to the Church of St Denys, Colmworth, as is states that “the spires of stone-built churches (such as St Denys at Colmworth) are landmarks in this fairly level, open plateaux landscape”. It is worth noting that the Church of St Denys is a Grade I listed church dating back to 1430.
10.4. The Figures below highlight the view from Honeydon Road to the Church of St Denys in relation to the site plan of the proposed Dennybrook scheme. As shown below, the western boundary of the proposed development would sit within the historic setting of the Church of St Denys. With this in mind, it is clear that the Regulation 18 Local Plan does not align with paragraph 195 of the NPPF, as the local planning authority has failed to assess the significance of the Church of St Deny that how it (and its surroundings) would be affected by a proposal.

INCLUDES FIGURE 10.1: VIEW CONE OF PHOTO AND PHOTO OF VIEW ON HONEYDON ROAD WITH THE DENNYBROOK SITE HIGHLIGHTED

10.5. In relation to the Dennybrook site and the impact on the Church of St Deny’s, the Wyboston Garden Village Heritage Impact Assessment (2021) states that “there are views to the Grade I listed Parish Church of St Denys at Colmworth from the western area of the Site (Plate 2), and distant views to the tower from parts of the central area of the Site. The use of open space in the western area of the Site as indicated in the Concept Masterplan would put built form over 1.5km east of the church. It would also avoid built form within the church’s historic parish (Colmworth). While there might be some loss of views to the spire from the wider area, it is not anticipated that this in itself would be sufficient to adversely impact the significance of the listed building.” This argument cannot be justified, as, in acknowledgement that key views to and from the Church of St Denys would be lost, the Wyboston Garden Village is in conflict with paragraph 130c) and d) of the NPPF, as it is clear that the Wyboston Garden Village proposal is not sympathetic to the surrounding built environment and will in fact erode the local area’s sense of place.
10.6. It is also worth noting that a recent appeal regarding 49 dwellings in a Suffolk village was partly dismissed on the grounds that the inspector deemed there to be a high impact on a manor house and two barns and a medium impact on a grade II* church. The Inspector felt that the public benefits of the development did not outweigh the harm to heritage assets and therefore this provided a clear reason for refusal in accordance with paragraph 11d) of the NPPF. Similar to the above, the Wyboston Garden Village Heritage Impact Assessment (2021) notes that the following Grade II listed buildings are within or immediately adjacent to the proposed site: “Dairy Farmhouse (1114114), at the northern edge of the Site, west of Honeydon; Chestnuts Farmhouse(4321615), at the northern edge of the Site on the southern side of Honeydon; Sudbury Farmhouse (1146461), within the central area of the Site; Eaton Tithe Farmhouse (1157864), within the eastern area of the Site; Moat Cottage (1146457)”. By applying clause b ii) of paragraph 11 of the NPPF, it is clear that the adverse impacts of the Wyboston Garden Village proposal would significantly and demonstrably outweigh the benefits of the proposal, and on that basis this site should not be considered for development.
10.7. Historic England has prepared a number of Advice Notes with its guidance on how authorities should approach heritage in the Local Plan and in their selection of potential sites including the potential impacts on heritage that might result from the proposals. There are two of these Advice Notes we would like to bring to the attention of BBC:
• The Historic Environment and Site Allocations in Local Plans (Historic England Advice Note 3) October 201543.
• Statements of Heritage Significance: Analysing Significance in Heritage Assets (Historic England Advice Note 12) October 2019
10.8. There is no evidence available in the Local Plan or its supporting documents that sets out how the Local Plan process has complied with the NPPF (and the Historic England guidance) in respect of heritage (including archaeological, architectural, artistic or historic, or a combination of these) in terms of considering which development options to select and then the need to assess the heritage impact from these proposals. At a minimum the Council should have undertaken the following staged approach as set out in Advice Note 12 (see paragraph 6):
1. Understand the form, materials and history of the affected heritage asset(s), and / or the nature and extent of the archaeological deposits
2. Understand the significance of the assets
3. Understand the impact of the proposal on that significance
4. Avoid, minimise, and mitigate negative impact, in a way that meets the objectives of the NPPF
5. Look for opportunities to better reveal or enhance significance

11. Landscape
11.1. Paragraph 130c of the NPPF emphasises the importance of ensuring landscapes are retained, by stating that “planning policies and decisions should ensure that developments are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities)”. Given the scale of development proposed at Dennybrook, it is expected that this site would be subject to independent assessment, to be summarised by an associated Landscape and Visual Impact Assessment (LVIA). At current, there is no published LVIA for the Dennybrook Garden Village scheme. With this in mind, this site should not be taken forward within the plan-making process, as it is clear that the development of this site would cause adverse impacts to the local landscape character and setting.
11.2. The Bedford Borough Landscape Character Assessment (2020) states that the Thurleigh Clay Farmland (the landscape character area in which the Dennybrook Garden Village site sits), is characterised as “dominated by arable farmland generally with large irregular fields plus smaller fields around settlements”, with “hedgerow trees are prominent in the level of landscape, many of them mature, including remnant trees within fields plus substantial recent plantings lining some rural roads”. With regard to future management of the Thurleigh Clay Farmland Character Area, the Landscape Character Assessment states that a key guideline is to “conserve the character of the rural roads and limit urbanising influences – widening/kerbing to ensure that traffic management measures are sympathetic to the rural character”, with another stating to “resist any development that will result in further loss/fragmentation of hedgerows and hedgerows trees. Ensure that development works with the existing framework as far as possible”.
11.3. The proposals at Dennybrook would undoubtedly conflict with the above future management guidelines, as the scheme itself would pose as an urbanising influence on the landscape character area and, as highlighted in our transport section would result in the degradation of the existing local road network. Furthermore, there is no evidence provided by the developer to demonstrate how existing hedgerows will be retained. In the absence of this information, it is impossible to quantify the adverse landscape and environmental impacts posed by the proposed scheme.

12. Biodiversity
Policy NE1 (Environmental Net Gain)
12.1. CPC is concerned that the policy wording of Policy NE1 (Environmental Net Gain) falls hort of what is required to achieve environmental net gain. As stated in best practice guidance published by CIRIA (2019), environmental net gain is defined as (our emphasis added) “development that leaves biodiversity in a better state than before, and an approach where developers work with local governments, wildlife groups, landowners and other stakeholders in order to support their priorities for nature conservation”. However, Policy NE1 (Environmental Net Gain) merely states that “proposals for major development should provide an environmental net gain (in accordance with government policy), which incorporates biodiversity net gain, through the following:
i) enhancement of the existing features of the site, particularly where these deliver significant levels of ecosystem services; or
ii) the creation of additional habitats on the site; or
iii) the linking of existing habitats to create links between ecological networks and where possible, with adjoining features”
12.2. The above policy (NE1) demonstrates a clear disregard and divergence from best practice guidance, as the built-in flexibility effectively allows developers to disregard the quality and innate importance of existing habitats on-site, in replacement for new habitats where there is no criteria to ensure that new habitats are of good-quality or are well-integrated and sensitively sited in respect of the local landscape and surrounding ecological networks. This omission could in practice lead to the degradation of local landscapes, where new developments lead to the continued fragmentation of local habitats. As such, Policy NE1 (Environmental Net Gain) does not comply with paragraph 174d) of the NPPF, as it cannot be demonstrated that Policy NE1 “contribute[s] to and enhance[s] the natural and local environment by […] minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures”.

Dennybrook
12.3. Chapter 15 of the NPPF stipulates that decisions should contribute to and enhance the natural and local environment. Whilst it is recognised that mitigatory measures such as a designated ‘area for ecological enhancements’ in the west and a wildlife and habitat corridor in the north have been proposed on-site by the site promoter, it is considered that they have an overall lack of appreciation for and understanding of the significance of the ecology on the site. The site promoter has failed to apply the findings of the Ecology Strategy (2021) to the overall design of the scheme, thus resulting in insufficient mitigatory measures across the site. As such, it is evident that there are a considerable number of important and rare bird species on the site, which require targeted and individual conservation approaches. In the absence of a detailed conservation strategy (which covers each individual species), it is considered that the applicant fails to achieve the policies set out in Chapter 15 of the NPPF.
12.4. We raise serious concerns that the Ecology Strategy notes that “no detailed mapping or survey was undertaken”. This broad approach is deemed wholly inadequate, as it is not possible to establish whether there are rare species across the site. In the absence of this information, it is possible that the development of this proposal would result in the destruction of habitats and ecological networks.
12.5. In relation to local bird populations, the Ecology Strategy (2021) states the following:
“Records pertaining to the Site alone are more typical species of rural landscapes but do include a range of notable farmland species corn bunting, skylark, yellow wagtail, grey partridge. Other notable species include red kite, kingfisher (associated with riparian habitat), hobby, merlin, winter thrushes (redwing and fieldfare), common crossbill (from pine plantation on southern boundary) and barn owl.
For within the Site boundary, a number of birds listed under Schedule 1 of the Wildlife & Countryside Act (1981) as amended have been recorded. Schedule 1 birds in the local area also include quail, stone curlew, whimbrel, marsh harrier, whooper swan, peregrine and osprey. However, with the exception of barn owl and quail, the likelihood of these species being present on-site is very limited”.
12.6. In relation to the proposed effects of the development proposal on bird species, the cology Strategy (2021) concluded that “development would result in the fundamental of change of habitats within the Site, displacing many of those species associated with arable landscapes, and encouraging common garden bird species. As such, large-scale habitat creation proposed above to the west of the Site should include equivalent habitat opportunities to mitigate for the loss of farmland bird species, including some larger open areas of short, species rich grassland for ground nesting species. Overall however, it is anticipated that the abundance and diversity of avian populations would increase through the cessation of intensive agricultural and the large scale restoration of habitats.” Whilst it is acknowledged that mitigation measures such as ‘large-scale habitat creation’ are proposed, it is considered that these measures do not acknowledge or reflect the conservation status of each species.
12.7. With regards to bird species recorded on-site (as listed above), the latest ‘Birds of Conservation Concern 4’ publication, skylark, yellow wagtail, grey partridge, merlin, redwing thrush and fieldfare thrush are classified as ‘Red Status’ (status of most concern) and quails and kingfishers are classified as ‘Amber Status’ (status of second most concern). This evidence draws on the latest monitoring information from the UK and elsewhere in their ranges and is reflective of their “historical decline, trends in population and range, population size, localisation and international importance as well as their global and European threat status”. Eaton et al. (2015) therefore recommend that the latest publication of the Birds of Conservation Concern (4) is used “to draw distinctions between the differing status of races of the same species, enabling better targeted conservation action”.
12.8. With the above in mind, it is evident that the mitigation and compensatory measures proposed by the site promoter are wholly insufficient and highlight a lack of due care and appreciation for local wildlife populations. The Vision Document (2021) submitted as part of the Call for Sites process merely mentions that an “area for ecological enhancements” will be provided. This falls woefully short of the guidance within the Birds of Conservations Concern (4) document, as there is no evidence to suggest that conservation efforts will target and stabilise specific bird species populations. Indeed, the Ecology Strategy (2021) readily acknowledges that farmland bird species will be lost, as the Strategy states that “the Site should include equivalent habitat opportunities to mitigate for the loss of farmland bird species”. As such, it is considered that the development proposal is in contravention of paragraph 174 (d), which states that “decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures (our emphasis added)”. It is evident that the development proposal would significantly undermine the resilience of ecological networks, which would undoubtedly lead to the disturbance and potential decline of local bird populations.

Other
12.9. To date, no thorough assessment has been undertaken on-site to establish whether there are populations of bats, small mammals, reptiles, amphibians, fish or invertebrates. As such, it is not possible to justify whether the proposal is in a suitable location. This omission conflicts with paragraph 179b) of the NPPF, as it cannot be confirmed that the Regulation 18 Local Plan has “promoted the conservation, restoration and enhancement of priority habitats and ecological networks”.

13. The Best and Most Versatile Agricultural Land
13.1. The NPPF states (our emphasis):
“Planning policies and decisions should contribute to and enhance the natural and local environment by:
b) recognising the intrinsic character and beauty of the countryside, the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland”
13.2. A Green Future: Our 25 Year Plan to Improve the Environment46 sets out the government’s 25-year plan to improve the health of the environment by using natural resources more sustainably and efficiently. It plans to:
- protect the best agricultural land
- put a value on soils as part of our natural capital
- manage soils in a sustainable way by 2030
- restore and protect peatland
Paragraphs 001 and 002: Planning Practice Guidance for the Natural Environment explain why planning decisions should take account of the value of soils and agricultural land classification (ALC) to enable informed choices on the future use of agricultural land within the planning system.
13.3. Planning Practice Guidance (PPG) states that following about assessing agricultural land to enable informed choices about its future”
"How can planning take account of the quality of agricultural land?
The Agricultural Land Classification assess the quality of farmland to enable informed choices to be made about its future use within the planning system.
there are five grades of agricultural land, with Grade 3 subdivided into 3a and 3b. The best and most versatile land is defined as Grades 1, 2 and 3a. Planning Policies and decisions should take account of the economic and other benefits of the best and most versatile agricultural land.
In the circumstances set out in Schedule 4 paragraph (y) of the Development Management Procedure Order 2015, Natural England is a statutory consultee: a local planning authority must consult Natural England before granting planning permission for large-scale non-agricultural development on best and most versatile land that is not in accord with the development plan. Natural England has published guidance on development on agricultural land.
13.4. The Dennybrook site is comprised mostly of Grade 2 Agricultural Land and some Grade 1 as evidenced by the map prepared below which means that if developed the borough would lose some of its best agricultural land and would be lost to future generations at a time when climate change is having immediate impacts.
13.5. Of all the promoted new settlements Dennybrook has the best agricultural land and it should clearly be protected. Whereas Twinwoods has a considerable amount of previously developed land as does Little Barford. The whole of the Colworth site is comprised of Grade 3 and further assessment would be needed to determine if this is 3a or 3b.
13.6. We also note that most of the Dennybrook site promoter’s off-site transport improvements are proposed in the area to the south east of their site on land that is Grade 1 Agricultural Land which would also be lost as a result of their proposals.
13.7. One of BBC’s Draft Local Plan Themes is Theme 1: Greener with one of its stated objectives being to protect and enhance natural resources which includes soil (our emphasis):
“Protect and enhance our natural resources including air, soil, minerals and water to minimise the impacts of flooding, climate change and pollution”.

INCLUDES FIGURE 13.1: PROVISIONAL AGRICULTURAL LAND CLASSIFICATION MAP

14. Minerals and Waste
14.1. There are a number of designations in the Minerals and Waste Local Plan within and near the Dennybrook site which were not addressed in the site assessment form prepared by the site promoter. The site promoter appears to propose development on the location of the Minerals Safeguarding Area in its Vision document.
14.2. We have georeferenced the Minerals and Waste Policies Map with the Dennybrook
site to demonstrate this (see below). Within the site itself is the River Valley / Glacial Sand and Gravel Mineral Safeguarding Area (MSA) and additional MSAs located to the east and south of the site.

INCLUDES FIGURE 14.1: MINERALS AND WASTE LOCAL PLAN POLICIES MAP LOCATION PLAN

INCLUDES FIGURE 14.2: MINERALS AND WASTE POLICIES MAP OVERLAID WITH THE DENNYBROOK BOUNDARY MAP

14.3. The most relevant policy in relation to the MSA is MSP12 (see below).

INCLUDES FIGURE 14.3: MINERALS AND WASTE LOCAL PLAN, MINERAL STRATEGIC POLICY MSP 12

14.4. Strategic mineral sites for the supply of aggregate sand and gravels are allocated at
Site 5: Black Cat
Site 6: Blunham / Roxton

14.5. One of BBC’s Draft Local Plan Themes is Theme 1: Greener with one of its stated objectives being to protect and enhance natural resources which includes minerals (our emphasis):
“Protect and enhance our natural resources including air, soil, minerals and water to minimise the impacts of flooding, climate change and pollution”.
14.6. BBC has not mentioned the Minerals and Waste Local Plan (2014) in its Draft Local Plan despite it forming part of the Development Plan for the borough. The need to safeguard and / or extract minerals from these sites near to Dennybrook and the potential road and rail proposals could result in serious limitations to development opportunities and their timing in the east of the borough and within neighbouring authority areas. We request that BBC addresses this matter in relation to the Local Plan as soon as possible.

15. Garden City Principles
15.1. It is unclear as to whether the potential new settlements considered in the Draft Local Plan including Dennybrook are classified or described as ‘New Garden Settlement” and whether the Local Plan will be applying ‘Garden City Principles’. There is not currently any reference to this in the Local Plan however we note in the Call for Sites information that the ‘Dennybrook Garden Village’ site promoter is promoting the site as such.
15.2. The NPPF states that local authorities should “set clear expectations for the quality of the development and how this can be maintained (such as following Garden City principles) and ensure that a variety of homes to meet the needs of the different groups in the community will be provided”
5.3. Whilst we clearly would like to see the quality development that would result from planning and delivering development in line with Garden City principles we would expect BBC to carefully consider this in more detail and how deliverable they are.
15.4. The Inspectors of the Uttlesford Local Plan – which proposed multiple new garden settlements and stated that the new settlements would need to be developed in line with ‘garden city principles’ found that there were no mechanisms in place to ensure that the garden city principles could and would actually be delivered by the developers. They stated in their letter: “Without assurances that the necessary mechanisms outside the plan would be put in place, we cannot be content in principle that the new proposed settlements would be true Garden Communities, or that the plan’s stated vision for these new settlements would be met. This is a serious concern.”49. We have the same concerns for the BBC Local Plan in respect of the purported application of ‘Garden City Principles’ with no concrete mechanisms for actually delivering development in this way and no evidence to justify it.

16. Viability & Deliverability
Viability
16.1. Viability of the Local Plan and particularly proposals regarding potential new ettlements will need to be fully tested and it is disappointing that BBC has not prepared any local plan viability evidence for its final Local Plan consultation before its Regulation 19 Local Plan as confirmed in the Draft Local Plan50 This does not provide consultees any opportunity to comment on the potential viability of the Local Plan whilst the plan is still being formulating.
16.2. It is troubling to learn that BBC has selected its ‘emerging preferred options’ without understanding whether any of these options are even viable. This is despite the requirement of the NPPF to do so:
“Strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”
16.3. The scale of infrastructure required to support new settlements will need to be justified in terms of viability and there must be absolute clarity on the phasing and timing of such infrastructure, the amount of funding that will need to be in place when, who will be responsible for the delivery of the infrastructure and contingency plans. There is no Infrastructure Delivery Plan even in draft form to consider and respond to in relation to viability.
16.4. Given the above, the Local Plan viability study should take a ‘worst case scenario’ view on viability – there are countless examples across the country where viability matters for strategic proposals have not been scrutinised closely enough which has resulted in stalled sites and a lack of sufficient infrastructure to support the communities being planned.

Deliverability
16.5. The NPPF requires that local plans are “shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
16.6. Given the lack of supporting Infrastructure Delivery Plan (IDP), it is not possible to establish whether or not the Dennybrook scheme is deliverable. As highlighted in paragraph 34 of the NPPF, “Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan”.