Site Assessment Pro Formas

Support

Representation ID: 8401

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

The site details and summary of the findings of Bedford Borough Council during the site
assessment process can be seen below.
Site Details
Address Land to the east and west Home Road, to the north of Wood End Lane
and Ibbett Close, Gibraltar Corner, Bedford. The land consists of two
parcels either side of Home Road.
ID
Reference
1333
Proposed
Use
Housing
Dwelling
No
Up to 425
Size (ha) 21.80

In 2020, the site at Gibraltar Corner (ID 1333) was submitted as part of the Call for Sites
exercise, proposed for residential development of up to 425 dwellings, with associated
open space, landscaping and access. A total of 430 sites were submitted through the Call
for Sites process, they have been assessed using a ranking system; the system is as
follows.
 ++ Major Positive;
 + Positive;
 0 Neutral;
 Insufficient information;
 x Negative; and
 xx Major Negative.

As a result of this process of evaluation, the Site received 3 ?, 1xx, 2x and 6 +’s. From
these results it is clear that the site has development potential and has far more benefits
than drawbacks, however, it is considered that some of the rankings should be reassessed
to more accurately reflect the site opportunities and the further supporting
information submitted with this representation.
Reassessment of Site ID 1333

The site selection criteria have been revaluated and should be updated accordingly.
1a. Within or adjoining UAB SPA or built form of a small settlement?
The Site does adjoin the small settlement of Gibraltar Corner.
1e. Outside, adjoining or within the air quality management area?
The Site is not located within an air quality management area.

2a. Within or adjoining site of nature conservation importance
According to the Bedford Borough Policies Map (2020), the Site is not within or adjacent
to an area designated for nature and conservation importance. Further to this, the
Preliminary Ecological Appraisal states that “the site is not covered by any statutory
wildlife site designation and does not support any ancient woodland”.
2b. In an area where protected species are known or likely to exist?
In support of the Site being allocated in the emerging Local Plan, Applied Ecology have
prepared a Preliminary Ecological Appraisal. In addition to this, an extended Phase 1
habitat survey was undertaken on the 12th August 2021.
It was found that regarding protected species, there is potential for barn owls, skylark,
song thrush and yellowhammer birds to be on site. Potential for badgers, otters and
hedgehogs was also identified. The potential for great crested newts was identified,
however, the closest body of water is 85m east of the site. Potential for grass snakes and
moths was also identified (see the full Preliminary Ecological Appraisal for details).
Although the Appraisal has found that the potential for the presence of protected species
on the Site, recommendations including further investigation have been suggested in
order to minimise any associated adverse impact of development on the protected
species.
Precise development mitigation and compensation requirements will be dependent on
design detail and the results of ongoing ecological survey work.
Mitigation measures suggested are listed below.
• Existing trees and boundary hedgerows should be retained, protected and
enhanced, where feasible.
• Consider opportunities for incorporating ecological enhancements alongside
proposed drainage, access and landscape design provisions.
• Artificial lighting should be avoided / minimised in proximity to retained boundary
habitats, particularly with respect to the watercourse along the eastern boundary,
and any other proposed green corridors, in order to minimise disturbance to bats
and other nocturnal species.
• Incorporate bat and bird boxes into new buildings.
In conclusion, the site is not considered to be highly ecologically sensitive and has similar
characteristics to other greenfield sites. With appropriate mitigation as suggested above,
development of the site can be carried out without any adverse ecological impacts.
2c. Potentially able to achieve a net gain in biodiversity?
Included in the Preliminary Ecological Appraisal is a Biodiversity Net Gain Assessment, a
calculation that compares the ecological value of pre-development habitats with proposed
post-development habitats.

The site has a total pre-development biodiversity value of 59.90, once developed the
biodiversity value of the site will increase to 65.41. This provisional assessment based on
the proposed layout returns an overall potential net gain of + 5.51 habitat units. While this
will be further refined via the detailed soft landscaping proposals for the development, it
indicates that the development is capable of delivering considerable biodiversity net gain.
2d. Able to link into the green infrastructure opportunity network?
The south-east area of the Site is designated as a Bedford to Milton Keynes Marston Vale,
Green Infrastructure Opportunity Zone. The opportunity zones reflect those areas in the
Borough where there is the greatest potential to maintain and enhance the multi -functional
nature of green infrastructure across the five themes of landscape, historic environment,
biodiversity, accessible green space and access routes. The Site provides the opportunity
to expand the regenerated woodlands of Buttons Ramsey immediately adjacent to the
west of the site and to enhance the long distance walking and cycling route of the John
Bunyan Trail which passes directly through the north-western corner of the Site.
4a. Likely to impact on designated or non-designated heritage assets or their settings?
This submission is supported by a Heritage Appraisal carried out by JB Heritage
Consulting Ltd. As part of this appraisal, the Historic England Methodology has been
followed in order to maximise enhancement and avoid harm to heritage assets.
The appraisal identifies that 8 of the 10 Listed Buildings are located to the north and northeast
of the site, with the remaining 2 located to the south and south-west. A Certificate of
Immunity Asset is also located to the north-east of the site. The appraisal has, however,
only identified 3 listed buildings as being at potential risk of experiencing an impact as a
result of the potential development of the Site. These are summarised as:
Kempston House, NHLE 1114285, Grade II
The setting of Kempston House has limited prominence and visual interaction with the
land beyond its boundary, it is therefore less sensitive to development outside of its
curtilage. It is proposed that an area of open green space along the northern edge
between Kempston House and the Site will be retained. This will sustain an area of
open space, maintaining an understanding and appreciation of the listed building. In
order to maintain the rural character of Home Road, development will be located behind
landscaping, reducing impacts associated with the built form.
It is concluded that whilst there will be a change to the character of the wider setting,
taking into account the proposed offset, the private nature of its immediate setting and
the mitigation measures along the site boundaries, the impact on its setting can be
significantly reduced with potential for this to be avoided altogether through the detailed
design stages.
Ramsay Cottage, NHLE 1321547, Grade II
As an agricultural labourer’s dwelling, Ramsay Cottage has a special appreciation in
the character of the area. In order to preserve this character, open space to the north of the site boundary will be maintained, sustaining an experience of the asset in a rural
setting. Therefore, the development can be accommodated with minimal impacts on
the landscape setting and character.
The Cottage, Kempston House, NHLE 1114284, Grade II
In order to preserve the rural setting, the parcel of land south of The Cottage and to the
west of the plant nursery is proposed to be retained as open space. The retention of a
green, open space spanning across both the eastern and western sides of Home Road
will combine to create a landscape buffer to mitigate impacts of development. With the
proposed mitigation, any adverse impacts on the special interest of the area will be
minimised, and reduced to a low level of less than substantial harm.
Considering the proposed mitigation recommended above and included in the concept
plan contained within the Ramsey Green Vison Document the Heritage Appraisal
demonstrates that appropriate mitigation measures are capable of minimising any harm
to the setting of nearby heritage assets.
5a. Likely to increase future economic and employment opportunities?
The provision of new housing, both market and affordable in a sustainable location near
the Bedford urban area will support economic growth in the area.
6a. Proposing a main town centre use in, on the edge or outside of a town centre?
None proposed.
8b. Within the existing settlement form?
The site adjoins a defined settlement policy area. The proposed site adjoins the existing
small settlement of Gibraltar Corner which is located in-between the larger settlements of
Kempston and Wootton. The site is close enough to the Bedford urban area and service
centres to allow active travel modes and the use of public transport to be a realistic
alternative to private motor vehicles.
9a. On previously developed land?
The site is not previously developed land as defined in the NPPF, however, for the new
local plan to deliver it’s housing requirements greenfield sites will have to be allocated .
9b. On best and most versatile agricultural land ie grades, 1, 2 or 3a?
The site is on land classified as Grade 3, Good to Moderate, it does not fall with the higher
grades of 1 or 2. Again as referred to above, for the new local plan to deliver its housing
requirements greenfield sites will have to be allocated and the majority of the agricultural
land within the Bedford Borough area is Grade 2 or 3.

10a. Within a groundwater source protection zone?
The site is not located in a source protection zone.
11a. At risk of flooding?
The site is within Flood Zone 1 (areas that have been shown to be at less than 0.1%
chance of flooding in any year), and not located within proximity to an area prone to
flooding.
15e. Connect highway without constraint?
In support of this representation a High Level Transport Strategy has been prepared by
Stantec to provide additional detail of the transport and access elements of the site
proposal.
In summary, the Site benefits from good connectivity to Bedford, Kempston and Wootton,
by foot, bicycle and public transport. At present, the site is accessed off Home Road and
Wood End Lane. Home Road is a single carriageway road with no segregated footway
or cycleway along the site frontage, however, as part of the development proposals one
can be provided.
To provide safe and accessible access to the Site, two T-junctions are proposed on Home
Road and a single T-junction on Wood End Lane, these would form the primary vehicular,
pedestrian and cycle access to the site. Further to this, the proposal seeks to construct
2m wide footways with informal pedestrian crossings to link the development with existing
footways in order to provide pedestrian access, public transport opportunities and local
amenities. The junctions will be developed further at the design stage. In line with the
comments submitted by Bedford Borough Council Highways, a pedestrian / cycle only
access is proposed off Ibbet Close.
15f. Highway or junction capacity issues
As set out in the accompanying Transport Strategy, development of the site would
increase vehicle trips in Home Road, Green End Road and Ridge Road and a transport
assessment may be required. However, the emphasis of the transport strategy is to
reduce the need to travel, before then prioritising non-car modes of travel, focussing on
opportunities for access by walking, cycling and public transport. The development offers
good opportunities to enhance the pedestrian and cycle accessibility of the site, through
footway improvements along Wood End Lane and Home Road to connect with the existing
footway network in Gibraltar Corner and link with National Cycle Route 51 and the Bedford
Green Wheel cycle route via Ridge Road. These improvements will mean the centre of
Bedford will be within a reasonable five mile cycle ride of the site via high quality cycle
infrastructure, and local pedestrian accessibility will enhance walking connections with
Gibraltar Corner and the existing bus stops along Ridge Road. It is not considered that
there are any nearby junction capacity issues which cannot be appropriately mitigated.

With the implementation of the strategy set out in the Transport Strategy, it is considered
that the site is deliverable, the proposal positively contributes to the character of the
existing settlement and accords with national and local transport policy guidance.
Summary
Following the above re-valuation of the Site, taking into account the additional evidence
submitted along with this representation, it is considered that the original ranking should
be amended as set out below. As is evident from this reassessment, the site scores
extremely well with the only negative score being that it is not a brownfield site. As referred
to above, for the new local plan to meet its housing requirements greenfield sites will have
to be allocated. The Site at Gibraltar Corner is in a highly sustainable location, it is
available, deliverable and developable and as such would make an ideal location for a
housing allocation in the emerging plan.
(see table in attachment)