Site Assessment Pro Formas

Support

Representation ID: 8520

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

Introduction to Site and Proposals
Our client’s land interests were submitted to Bedford Borough Council as part of the ‘Call for Sites’ exercise undertaken to inform preparation of the emerging Local Plan 2030.
Two ‘Call for Sites’ references exist for our client’s site, recorded under LPA ID 604 and 645. It is also noted that a third Proforma exists for the site LPA ID ref. 355, however, this was not submitted by our client (nor by DLP) and therefore we will not be providing any response on this particular assessment.
In commencing an immediate Review in accordance with Policy 1 of the adopted Plan, the Council is, as required, seeking to ensure that future needs for growth are provided for in line with government policy i.e., local housing need calculated using the standard method. The review of the Local Plan is an important opportunity to address issues regarding flexibility and choice in a variety of locations for growth, as well as ensuring a balanced allocation of land for development sufficient to meet future needs, and to ensure planning policy is up to date.
Whilst two development options have been considered for this site (100- and 500-units respectively), it is recognised that in light of the extensive scope for the review of the Local Plan 2030, an appropriate strategy will require a combination of multiple spatial options over the plan period. In the case of our client’s land at Willoughby Park (ID: 645), this would represent a logical spatial option for consideration as the Site is located at the heart of the A421 corridor spatial Option 2d. We believe the site offers substantial opportunities to meet the Borough’s increased requirements for growth without significant constraints to development or barriers to infrastructure.
As a Key Service Centre, Great Barford can contribute to this option through an increased contribution towards the Borough’s housing requirement in the period to 2030 and beyond.
In the case of our client’s land the site has the potential to deliver approximately 500 units. The site, in part, was considered favourably in the Council’s 2017 Consultation Paper as part of preferred options for site allocation, and the Council’s 2018 HELAA records it as suitable, available, and achievable for development.
Furthermore, in its 2017 Assessment of Site Options the Council identified scope in elements of the site for a positive contribution towards several plan-making objectives. These conclusions remain entirely valid in the context of Great Barford’s role as a Key Service Centre and specific planning considerations regarding our client’s land.
In addition to the wider site, the Client has also explored utilising a smaller parcel of land for the development of 100-units. This has been assessed by the LPA under site ID 604. A response to this assessment is set out below, followed by a formal response made to the assessment for site ID: 645 which relates to the 500-unit option.

Site ID: 604 – Land off Roxton Road, Great Barford
The site extends to some 9.94 hectares of land and is proposed as a residential development site for up to 100 residential dwellings (Class C3).
The site will make provision for a new footpath link between the existing rights of way and the proposed development, create a large area of publicly accessible open space and introduce structural landscaping in key view areas, introduce children’s play facilities. The site will guarantee and coordinate delivery of infrastructure and community facilities where relevant, a mix and range of housing and contributions to upgrading existing educational facilities in the area.
The site would be accessed via a single point off Roxton Road (designed to the Council’s standards) and will seek to minimise disruption to the village core, avoiding the narrow historic streets.
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 604)
We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Protected Species
Whilst a site-specific ecological assessment has not been undertaken which is directly linked To this parcel, a preliminary assessment and ecological surveys have been undertaken for a much larger parcel of land identified by site ref 645.
The outcome of those reports is discussed in greater detail in paragraph’s 7.26 – 7.33 below, however, subject to mitigation measures it is considered that there will be no impacts on protected species. A biodiversity net gain calculation could also support any potential planning application, but it is considered that there is sufficient public open space to achieve a net gain.
Opportunities to link into the Green Infrastructure Opportunity Network
The Council have advised that no answers were chosen in respect of this particular matter, however, as the Council will be aware, as part of the ongoing Neighbourhood Plan examination, Great Barford Parish Council have produced a Green Infrastructure Plan (2019). This identifies two areas within our client’s site for green infrastructure improvements. It is considered that the proposed masterplan for our client’s site (see Appendix 3) is reflective Of the aspirations of the Green Infrastructure Plan and will seek to enhance the network through the provision of additional public open space within the site.
Best and most versatile agricultural land
Whilst all of the site potentially comprises of best and most versatile agricultural land according to the Natural England’s Agricultural Land Classification map for the Eastern Region, all of the land surrounding Great Barford comprises of best and most versatile land and therefore any residential proposal in this location would require some loss. This does not represent an overriding constraint to development given the highly sustainable location of Great Barford within the A421 corridor and should be considered in the wider balance as part of the Council’s assessment of site options. Any planning application could be supported by a detailed assessment as required.


APPENDICES CONTAIN SITE PLANS AND INDICATIVE MASTER PLANS. APPENDIX 6 IS A REVIEW OF DRAFT SA

Support

Representation ID: 8521

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

Introduction to Site and Proposals
Our client’s land interests were submitted to Bedford Borough Council as part of the ‘Call for Sites’ exercise undertaken to inform preparation of the emerging Local Plan 2030.
Two ‘Call for Sites’ references exist for our client’s site, recorded under LPA ID 604 and 645. It is also noted that a third Proforma exists for the site LPA ID ref. 355, however, this was not submitted by our client (nor by DLP) and therefore we will not be providing any response on this particular assessment.
In commencing an immediate Review in accordance with Policy 1 of the adopted Plan, the Council is, as required, seeking to ensure that future needs for growth are provided for in line with government policy i.e., local housing need calculated using the standard method. The review of the Local Plan is an important opportunity to address issues regarding flexibility and choice in a variety of locations for growth, as well as ensuring a balanced allocation of land for development sufficient to meet future needs, and to ensure planning policy is up to date.
Whilst two development options have been considered for this site (100- and 500-units respectively), it is recognised that in light of the extensive scope for the review of the Local Plan 2030, an appropriate strategy will require a combination of multiple spatial options over the plan period. In the case of our client’s land at Willoughby Park (ID: 645), this would represent a logical spatial option for consideration as the Site is located at the heart of the A421 corridor spatial Option 2d. We believe the site offers substantial opportunities to meet the Borough’s increased requirements for growth without significant constraints to development or barriers to infrastructure.
As a Key Service Centre, Great Barford can contribute to this option through an increased contribution towards the Borough’s housing requirement in the period to 2030 and beyond.
In the case of our client’s land the site has the potential to deliver approximately 500 units. The site, in part, was considered favourably in the Council’s 2017 Consultation Paper as part of preferred options for site allocation, and the Council’s 2018 HELAA records it as suitable, available, and achievable for development.
Furthermore, in its 2017 Assessment of Site Options the Council identified scope in elements of the site for a positive contribution towards several plan-making objectives. These conclusions remain entirely valid in the context of Great Barford’s role as a Key Service Centre and specific planning considerations regarding our client’s land.
In addition to the wider site, the Client has also explored utilising a smaller parcel of land for the development of 100-units. This has been assessed by the LPA under site ID 604. A response to this assessment is set out below, followed by a formal response made to the assessment for site ID: 645 which relates to the 500-unit option.
Site ID: 645 – Willoughby Park, Great Barford
The site, which is in a single ownership, extends to some 48.3 hectares and is proposed as a mixed-use development comprising of up to 500 residential dwellings (Class C3), a 24 hectare (59 acre) Countryside Park; a community hub (including a new developer funded medical centre) centred on the existing Village Hall and extending the range of local recreation facilities; substantial new tree planting enhancing the village edge along Roxton Road; and, a mix of open and green spaces that can be used for multiple purposes including local play, sports areas and informal amenity areas.
A copy of our client’s proposed Masterplan for the Willoughby Park site is enclosed at Appendix 4.
The site would be accessed via Roxton Road (designed to the Council’s standards) and would seek to minimise disruption to the village core, avoiding the narrow historic streets. Emergency site access can also be achieved off Birchfield Road.
The site is bound by residential properties to the east, south and west whilst to the north the boundary of the site adjoins the A421 bypass. To the west also lies the existing community facilities including the Village Hall and its associated playing fields.
The site offers substantial benefits and is sustainably located within the heart of the village close to existing local services and facilities which are easily accessible by foot and cycle. The enhancement and creation of additional foot and cycle paths within the scheme design further improves the permeability of the site and connections to the surrounding area.
in terms of master planning, and the consideration of key facilities, we draw attention to the Great Barford Parish Council response relating to the delivery of a medical centre as part of the Great Barford West allocation within the emerging Neighbourhood Plan. Rather than clarifying the matter, this response raises further uncertainty in terms of its deliverability and where this would be located:
“We understand from Bedford Borough Council that increased lower/primary schooling provision and a new medical centre is expected to be located in the existing village with funding being provided by the new development through CIL/S106 contributions. However, the allocation site has ample capacity to deliver a primary/lower school and a new medical centre if required”.
Our client’s site is located central to the village and has the potential to deliver a medical
centre at the heart of the community and without the uncertainty regarding the approach and potential location of provision resulting from the Neighbourhood Plan. This should be recognised within the site assessment proforma alongside additional facilities that could be achieved including a new community hub and recreational space.
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 645)
Site Assessment Criteria
We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Protected Species
The Council’s assessment states that they are uncertain, or insufficient information has been
provided to determine whether protect species are known or likely to exist on the site.
Our client has undertaken both a preliminary ecological assessment (PEA) for the site and a subsequent Ecological Appraisal. These reports identify that there are no sites of international or European importance within the search area nor are there any sites of national importance. Seven County Wildlife Sites (CWS) were present in the search area, however on the basis that over half of the proposed development site is being set aside as a new Countryside Park and areas of public open space, the report concludes that this would likely encourage residents of the new development and existing residents to use the new Countryside Park as opposed to CWS that are a further distance from the site.
Furthermore, the CWS sites within the local area are either not publicly accessible by Public Rights of Way or the Public Rights of Way run adjacent to the CWS and not through them.
The Ecological Appraisal further identifies that there are no veteran trees, no rare and/or priority plants, or any rare and/or priority invertebrates at the site. Although the site offers some suitable habitat for amphibians including Great Crested Newts (GCN), no records of GCN were returned from within 500m of the site and there is a lack of ponds within the local area suitable for breeding.
The site is therefore considered to be of negligible value to GCN. No reptile species were recorded during the reptile survey and the site is therefore considered to be negligible value for reptiles.
The site is likely to be used by common breeding bird species, however it is considered that the value of the site to breeding birds is lower at the parish scale. The introduction of the Countryside Park is also considered to provide a minor beneficial impact on breeding birds. The site provides limited habitat for wintering birds and is considered of negligible value for this group.
Further surveys have been recommended in respect of water vole and bats; however, these would be at reserved matters stage once the design of the proposal is known. A pre-commencement badger survey is also recommended.
A number of mitigation measures are also recommended, and the report concludes that the adoption of these would give rise to a moderate to major beneficial impact.
In respect of biodiversity net gain, a calculation could be prepared to support any application, however it is considered that the introduction of a new Countryside Park would provide a considerable enhancement to both the site and surrounding area.
Opportunities to link into the Green Infrastructure Opportunity Network
The Council have advised that no answers were chosen in respect of this particular matter, however, as the Council will be aware, as part of the ongoing Neighbourhood Plan examination, Great Barford have produced a Green Infrastructure Plan (2019). This identifies three areas within our client’s site for green infrastructure improvements. It is considered that the proposed masterplan for our client’s site (see appendix 4) is reflective of the aspirations of the Green Infrastructure Plan and will seek to enhance the network through the provision of a new Countryside Park which will incorporate the existing Bridleways and Rights of Way that run through and across the site as well as the protected views as identified.
Impact on designated or non-designated heritage assets and their settings
The Council’s assessment has identified that the proposal has the potential to cause harm to heritage assets and this harm may range from low to high. This could be addressed through a heritage impact assessment submitted as part of any planning application.
Best and most versatile agricultural land
Whilst all of the site comprises of best and most versatile agricultural land, according to the Natural England’s Agricultural Land Classification map for the Eastern Region, all of the land surrounding Great Barford comprises of best and most versatile land and therefore any residential proposal in this location would require its loss. Any future planning application could be supported by an appropriate assessment as required.
Flood Risk
The Council advise that the majority of the site lies within Flood Zone 2, however this is Incorrect, and we are surprised that the proforma suggests that the majority of the site has drainage constraints. According to the Environment Agency Flood Map (extract below), the site lies predominantly within Flood Zone 1 (lower flood risk and acceptable for vulnerable uses including residential) with a small portion adjacent to existing residential properties on Green End Road within Flood Zone 2 and an area of Flood Zone 3 contained only to the unnamed watercourse that runs through the site.
SEE PARA 7.37 OF ATTACHMENT
Product 4 flood level information has been obtained from the Environment Agency and this has been overlaid onto our client’s topographical survey to define the flood zones in further detail than that available on the Flood Maps. This has defined the built form area as indicated on the submitted masterplan (appendix 4), with no development proposed to be located within Flood Zone 2. This obviates the requirement for undertaking a sequential test. Appropriate buffers to the brook have also been incorporated providing a landscape corridor either side.
The proposed drainage strategy for the site is based on an attenuated strategy where surface water run-off is held on site in the form of 3 large detention basins and discharged to the unnamed water course that runs through the site. The catchment for the basins has been split into three separate areas each with their own network including basin and hydro brake (discharge control point) and have been located based on the topography and best strategy to serve the likely form of development. A robust position has been taken to impermeable areas and run off rates which we believe will be required by the LLFA; the discharge rate will be controlled at or lower than greenfield run off rate. The basins will be combined with an overall SuDS strategy including use of swales.
The location of the proposed attenuation areas has also been positioned and developed to tie directly back into the enhancements to Green Infrastructure, specifically the Green Infrastructure Plan prepared as part of the Great Barford Neighbourhood Plan.
Highways
The enclosed masterplan shows how vehicular access would be taken from Roxton Road utilising two proposed points, the primary site access and a secondary site access which would serve a potential bus route. A potential emergency access can be taken onto Birchfield Road. Any planning application would be supported by detailed Transport Assessment that would consider the mitigation requirements in further detail.
Noise
It is of note that Environmental Health have raised concern surrounding noise from the bypass, however, this element of the site is reserved for a new Countryside Park and any future planning application could be supported by an appropriate noise assessment as necessary. Having regard to the details of proposals for our client’s land noise does not represent a constraint to development of the land.

APPENDICES CONTAIN SITE PLANS AND INDICATIVE MASTER PLANS. APPENDIX 6 IS A REVIEW OF DRAFT SA

Support

Representation ID: 8720

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

Introduction to Site and Proposals
7.1 Our client’s land interests were submitted to Bedford Borough Council as part of the ‘Call for Sites’ exercise undertaken to inform preparation of the emerging Local Plan 2030.

7.2 Two ‘Call for Sites’ references exist for our client’s site, recorded under LPA ID 604 and 645. It is also noted that a third Proforma exists for the site LPA ID ref. 355, however, this was not submitted by our client (nor by DLP) and therefore we will not be providing any response on this particular assessment.

7.3 In commencing an immediate Review in accordance with Policy 1 of the adopted Plan, the Council is, as required, seeking to ensure that future needs for growth are provided for in line with government policy i.e., local housing need calculated using the standard method. The review of the Local Plan is an important opportunity to address issues regarding flexibility and choice in a variety of locations for growth, as well as ensuring a balanced allocation of land for development sufficient to meet future needs, and to ensure planning policy is up to date.

7.4 Whilst two development options have been considered for this site (100- and 500-units respectively), it is recognised that in light of the extensive scope for the review of the Local Plan 2030, an appropriate strategy will require a combination of multiple spatial options over the plan period. In the case of our client’s land at Willoughby Park (ID: 645), this would represent a logical spatial option for consideration as the Site is located at the heart of the A421 corridor spatial Option 2d. We believe the site offers substantial opportunities to meet the Borough’s increased requirements for growth without significant constraints to development or barriers to infrastructure.

7.5 As a Key Service Centre, Great Barford can contribute to this option through an increased contribution towards the Borough’s housing requirement in the period to 2030 and beyond.

7.6 In the case of our client’s land the site has the potential to deliver approximately 500 units. The site, in part, was considered favourably in the Council’s 2017 Consultation Paper as part of preferred options for site allocation, and the Council’s 2018 HELAA records it as suitable, available, and achievable for development.


7.7 Furthermore, in its 2017 Assessment of Site Options the Council identified scope in elements of the site for a positive contribution towards several plan-making objectives. These conclusions remain entirely valid in the context of Great Barford’s role as a Key Service Centre and specific planning considerations regarding our client’s land.

7.8 In addition to the wider site, the Client has also explored utilising a smaller parcel of land for the development of 100-units. This has been assessed by the LPA under site ID 604. A response to this assessment is set out below, followed by a formal response made to the assessment for site ID: 645 which relates to the 500-unit option.

Site ID: 604 – Land off Roxton Road, Great Barford
7.9 The site extends to some 9.94 hectares of land and is proposed as a residential development site for up to 100 residential dwellings (Class C3).

7.10 The site will make provision for a new footpath link between the existing rights of way and the proposed development, create a large area of publicly accessible open space and introduce structural landscaping in key view areas, introduce children’s play facilities. The site will guarantee and coordinate delivery of infrastructure and community facilities where relevant, a mix and range of housing and contributions to upgrading existing educational facilities in the area.

7.11 The site would be accessed via a single point off Roxton Road (designed to the Council’s standards) and will seek to minimise disruption to the village core, avoiding the narrow historic streets.

Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 604)
7.12 We have reviewed the Council’s assessment of the site and wish to make a number of comments below.

Protected Species
7.13 Whilst a site-specific ecological assessment has not been undertaken which is directly linked to this parcel, a preliminary assessment and ecological surveys have been undertaken for a much larger parcel of land identified by site ref 645.

7.14 The outcome of those reports is discussed in greater detail in paragraph’s 7.26 – 7.33 below, however, subject to mitigation measures it is considered that there will be no impacts on protected species. A biodiversity net gain calculation could also support any potential planning application, but it is considered that there is sufficient public open space to achieve a net gain.

Opportunities to link into the Green Infrastructure Opportunity Network
7.15 The Council have advised that no answers were chosen in respect of this particular matter, however, as the Council will be aware, as part of the ongoing Neighbourhood Plan examination, Great Barford Parish Council have produced a Green Infrastructure Plan (2019). This identifies two areas within our client’s site for green infrastructure improvements. It is considered that the proposed masterplan for our client’s site (see Appendix 3) is reflective


of the aspirations of the Green Infrastructure Plan and will seek to enhance the network through the provision of additional public open space within the site.

Best and most versatile agricultural land
7.16 Whilst all of the site potentially comprises of best and most versatile agricultural land according to the Natural England’s Agricultural Land Classification map for the Eastern Region, all of the land surrounding Great Barford comprises of best and most versatile land and therefore any residential proposal in this location would require some loss. This does not represent an overriding constraint to development given the highly sustainable location of Great Barford within the A421 corridor and should be considered in the wider balance as part of the Council’s assessment of site options. Any planning application could be supported by a detailed assessment as required.

SEE APPENDIX 1 OF ATTACHMENT FOR SITE PLAN
SEE APPENDIX 3 OF ATTACHMENT FOR INDICATIVE MASTER PLAN AND LAND USE BUDGET
SEE APPENDIX 5 FOR LOCAL PLAN 2030 DELIVERY ASSESSMENT
SEE APPENDIX 6 FOR REVIEW OF SA FINDINGS

Support

Representation ID: 8721

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

Introduction to Site and Proposals
7.1 Our client’s land interests were submitted to Bedford Borough Council as part of the ‘Call for Sites’ exercise undertaken to inform preparation of the emerging Local Plan 2030.

7.2 Two ‘Call for Sites’ references exist for our client’s site, recorded under LPA ID 604 and 645. It is also noted that a third Proforma exists for the site LPA ID ref. 355, however, this was not submitted by our client (nor by DLP) and therefore we will not be providing any response on this particular assessment.

7.3 In commencing an immediate Review in accordance with Policy 1 of the adopted Plan, the Council is, as required, seeking to ensure that future needs for growth are provided for in line with government policy i.e., local housing need calculated using the standard method. The review of the Local Plan is an important opportunity to address issues regarding flexibility and choice in a variety of locations for growth, as well as ensuring a balanced allocation of land for development sufficient to meet future needs, and to ensure planning policy is up to date.

7.4 Whilst two development options have been considered for this site (100- and 500-units respectively), it is recognised that in light of the extensive scope for the review of the Local Plan 2030, an appropriate strategy will require a combination of multiple spatial options over the plan period. In the case of our client’s land at Willoughby Park (ID: 645), this would represent a logical spatial option for consideration as the Site is located at the heart of the A421 corridor spatial Option 2d. We believe the site offers substantial opportunities to meet the Borough’s increased requirements for growth without significant constraints to development or barriers to infrastructure.

7.5 As a Key Service Centre, Great Barford can contribute to this option through an increased contribution towards the Borough’s housing requirement in the period to 2030 and beyond.

7.6 In the case of our client’s land the site has the potential to deliver approximately 500 units. The site, in part, was considered favourably in the Council’s 2017 Consultation Paper as part of preferred options for site allocation, and the Council’s 2018 HELAA records it as suitable, available, and achievable for development.


7.7 Furthermore, in its 2017 Assessment of Site Options the Council identified scope in elements of the site for a positive contribution towards several plan-making objectives. These conclusions remain entirely valid in the context of Great Barford’s role as a Key Service Centre and specific planning considerations regarding our client’s land.

7.8 In addition to the wider site, the Client has also explored utilising a smaller parcel of land for the development of 100-units. This has been assessed by the LPA under site ID 604. A response to this assessment is set out below, followed by a formal response made to the assessment for site ID: 645 which relates to the 500-unit option.

Site ID: 645 – Willoughby Park, Great Barford
7.17 The site, which is in a single ownership, extends to some 48.3 hectares and is proposed as a mixed-use development comprising of up to 500 residential dwellings (Class C3), a 24 hectare (59 acre) Countryside Park; a community hub (including a new developer funded medical centre) centred on the existing Village Hall and extending the range of local recreation facilities; substantial new tree planting enhancing the village edge along Roxton Road; and, a mix of open and green spaces that can be used for multiple purposes including local play, sports areas and informal amenity areas.

7.18 A copy of our client’s proposed Masterplan for the Willoughby Park site is enclosed at Appendix 4.

7.19 The site would be accessed via Roxton Road (designed to the Council’s standards) and would seek to minimise disruption to the village core, avoiding the narrow historic streets. Emergency site access can also be achieved off Birchfield Road.

7.20 The site is bound by residential properties to the east, south and west whilst to the north the boundary of the site adjoins the A421 bypass. To the west also lies the existing community facilities including the Village Hall and its associated playing fields.

7.21 The site offers substantial benefits and is sustainably located within the heart of the village close to existing local services and facilities which are easily accessible by foot and cycle. The enhancement and creation of additional foot and cycle paths within the scheme design further improves the permeability of the site and connections to the surrounding area.

7.22 In terms of master planning, and the consideration of key facilities, we draw attention to the Great Barford Parish Council response relating to the delivery of a medical centre as part of the Great Barford West allocation within the emerging Neighbourhood Plan. Rather than clarifying the matter, this response raises further uncertainty in terms of its deliverability and where this would be located:

“We understand from Bedford Borough Council that increased lower/primary schooling provision and a new medical centre is expected to be located in the existing village with funding being provided by the new development through CIL/S106 contributions. However, the allocation site has ample capacity to deliver a primary/lower school and a new medical centre if required”.


7.23 Our client’s site is located central to the village and has the potential to deliver a medical centre at the heart of the community and without the uncertainty regarding the approach and potential location of provision resulting from the Neighbourhood Plan. This should be recognised within the site assessment proforma alongside additional facilities that could be achieved including a new community hub and recreational space.

Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 645)
SiteAssessmentCriteria
7.24 We have reviewed the Council’s assessment of the site and wish to make a number of comments below.

Protected Species
7.25 The Council’s assessment states that they are uncertain, or insufficient information has been provided to determine whether protect species are known or likely to exist on the site.

7.26 Our client has undertaken both a preliminary ecological assessment (PEA) for the site and a subsequent Ecological Appraisal. These reports identify that there are no sites of international or European importance within the search area nor are there any sites of national importance. Seven County Wildlife Sites (CWS) were present in the search area, however on the basis that over half of the proposed development site is being set aside as a new Countryside Park and areas of public open space, the report concludes that this would likely encourage residents of the new development and existing residents to use the new Countryside Park as opposed to CWS that are a further distance from the site.

7.27 Furthermore, the CWS sites within the local area are either not publicly accessible by Public Rights of Way or the Public Rights of Way run adjacent to the CWS and not through them.

7.28 The Ecological Appraisal further identifies that there are no veteran trees, no rare and/or priority plants, or any rare and/or priority invertebrates at the site. Although the site offers some suitable habitat for amphibians including Great Crested Newts (GCN), no records of GCN were returned from within 500m of the site and there is a lack of ponds within the local area suitable for breeding.

7.29 The site is therefore considered to be of negligible value to GCN. No reptile species were recorded during the reptile survey and the site is therefore considered to be negligible value for reptiles.


7.30 The site is likely to be used by common breeding bird species, however it is considered that the value of the site to breeding birds is lower at the parish scale. The introduction of the Countryside Park is also considered to provide a minor beneficial impact on breeding birds. The site provides limited habitat for wintering birds and is considered of negligible value for this group.

7.31 Further surveys have been recommended in respect of water vole and bats; however, these would be at reserved matters stage once the design of the proposal is known. A pre- commencement badger survey is also recommended.

7.32 A number of mitigation measures are also recommended, and the report concludes that the adoption of these would give rise to a moderate to major beneficial impact.

7.33 In respect of biodiversity net gain, a calculation could be prepared to support any application, however it is considered that the introduction of a new Countryside Park would provide a considerable enhancement to both the site and surrounding area.

Opportunities to link into the Green Infrastructure Opportunity Network
7.34 The Council have advised that no answers were chosen in respect of this particular matter, however, as the Council will be aware, as part of the ongoing Neighbourhood Plan examination, Great Barford have produced a Green Infrastructure Plan (2019). This identifies three areas within our client’s site for green infrastructure improvements. It is considered that the proposed masterplan for our client’s site (see appendix 4) is reflective of the aspirations of the Green Infrastructure Plan and will seek to enhance the network through the provision of a new Countryside Park which will incorporate the existing Bridleways and Rights of Way that run through and across the site as well as the protected views as identified.

Impact on designated or non-designated heritage assets and their settings
7.35 The Council’s assessment has identified that the proposal has the potential to cause harm to heritage assets and this harm may range from low to high. This could be addressed through a heritage impact assessment submitted as part of any planning application.


Best and most versatile agricultural land
7.36 Whilst all of the site comprises of best and most versatile agricultural land, according to the Natural England’s Agricultural Land Classification map for the Eastern Region, all of the land surrounding Great Barford comprises of best and most versatile land and therefore any residential proposal in this location would require its loss. Any future planning application could be supported by an appropriate assessment as required.

Flood Risk
7.37 The Council advise that the majority of the site lies within Flood Zone 2, however this is incorrect, and we are surprised that the proforma suggests that the majority of the site has drainage constraints. According to the Environment Agency Flood Map (extract below), the site lies predominantly within Flood Zone 1 (lower flood risk and acceptable for vulnerable uses including residential) with a small portion adjacent to existing residential properties on Green End Road within Flood Zone 2 and an area of Flood Zone 3 contained only to the unnamed watercourse that runs through the site.

SEE ATTACHMENT FOR FLOOD RISK PLAN

7.38 Product 4 flood level information has been obtained from the Environment Agency and this has been overlaid onto our client’s topographical survey to define the flood zones in further detail than that available on the Flood Maps. This has defined the built form area as indicated on the submitted masterplan (appendix 4), with no development proposed to be located within Flood Zone 2. This obviates the requirement for undertaking a sequential test. Appropriate buffers to the brook have also been incorporated providing a landscape corridor either side.

7.39 The proposed drainage strategy for the site is based on an attenuated strategy where surface water run-off is held on site in the form of 3 large detention basins and discharged to the unnamed water course that runs through the site. The catchment for the basins has been split into three separate areas each with their own network including basin and hydro brake (discharge control point) and have been located based on the topography and best strategy to serve the likely form of development. A robust position has been taken to impermeable areas and run off rates which we believe will be required by the LLFA; the discharge rate will be controlled at or lower than greenfield run off rate. The basins will be combined with an overall SuDS strategy including use of swales.

7.40 The location of the proposed attenuation areas has also been positioned and developed to tie directly back into the enhancements to Green Infrastructure, specifically the Green Infrastructure Plan prepared as part of the Great Barford Neighbourhood Plan.

Highways
7.41 The enclosed masterplan shows how vehicular access would be taken from Roxton Road utilising two proposed points, the primary site access and a secondary site access which would serve a potential bus route. A potential emergency access can be taken onto Birchfield Road. Any planning application would be supported by detailed Transport Assessment that would consider the mitigation requirements in further detail.

Noise
7.42 It is of note that Environmental Health have raised concern surrounding noise from the bypass, however, this element of the site is reserved for a new Countryside Park and any future planning application could be supported by an appropriate noise assessment as necessary. Having regard to the details of proposals for our client’s land noise does not represent a constraint to development of the land.

SEE APPENDIX 2 OF ATTACHMENT FOR SITE PLAN
SEE APPENDIX 4 OF ATTACHMENT FOR INDICATIVE MASTER PLAN AND LAND USE BUDGET
SEE APPENDIX 5 FOR LOCAL PLAN 2030 DELIVERY ASSESSMENT
SEE APPENDIX 6 FOR REVIEW OF SA FINDINGS