Site Assessment Pro Formas

Object

Representation ID: 6507

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Paragraph 4.4 of the Strategy Options and Draft Policies document invites comments in respect of the interim conclusions presented as part of the Council’s ongoing assessment of sites. Whilst no significant issues in respect of availability, deliverability or overall suitability have been raised in respect of our client’s site at Salph End (ID 822) it appears that some of the evidence provided as part of our Call for Sites submissions dated 14th August 2020 and 6th January 2021 has been overlooked. In addition, there are some helpful concluding remarks on a number of technical and environmental matters provided by the Inspector who presided over the recent appeal. We wish to make the following comments in respect of the Council’s review of our client’s land referencing the various subheadings comprising the assessment proforma:
2a. Within or adjoining a site of nature conservation importance.
2b. In an area where protected species are known or likely to exist.
2c. Potentially able to achieve a net gain in biodiversity.
The Preliminary Ecological Assessment (PEA) submitted as part of the initial Call for Sites package in August 2020 considers the site in the context of surrounding habitats and designations. In respect of point 2a the maps included as appendices to this document confirm that the site, whilst in relatively close proximity to two Local Nature Reserves (Putnoe Wood and Mowsbury Hill) it does not adjoin them.
The Council’s assessment currently concludes that protected species could be affected by the development of the site (point 2b). The PEA disproves this in concluding that “the habitats within the site provide few opportunities for faunal species, being dominated largely by open, intensively managed arable land, albeit the field boundary vegetation and associated features provide some potential for use by common nesting birds, Badger and bats in particular. Accordingly, a number of recommendations and measures are set out with regard to protected species, (with compensatory and enhancement measures proposed where appropriate), in order to ensure that they are fully safeguarded, and the conservation status of local populations is maintained under the proposals, following which the proposals are unlikely to adversely affect any such species”.
In any event, and in response to point 2c, the PEA also concludes that the development of the site could lead to ecological enhancements and an improvement in respect of the local network of habitats. Due to the significant amount of open space that is capable of being secured as part of any development, along with the creation of a linear area of more natural open space along the route of the brook which dissects the parcel, numerous opportunities exist to secure biodiversity enhancements and a strengthening of the local Green Infrastructure network. A Biodiversity Impact Calculator (BIC), prepared in August 2020 by Aspect Ecology and made available to the Inspector and the Council as part of the recent appeal, concludes that a significant level of biodiversity gain can be secured on site – approximately 25% so significantly in excess of the current DEFRA target of 10%. A copy of the BIC is enclosed with this submission (Enclosure 1).
2d. Able to link into the green infrastructure opportunity network.
In response to this point the Council’s conclusions to date state that no position has been provided by our client in respect to green infrastructure. In which case it is worth noting that the Proposals Map supporting the current Local Plan 2030 shows that the southern portion of the site (that to the south of the brook) comprises part of the green infrastructure opportunity network, specifically as part of the Bedford Northern Fringes network. An extract of the map showing the extent of our client’s land is shown below with the green infrastructure network hatched in green: [map inserted here]
On this basis, and referring to the objectives for the Bedford Northern Fringes green infrastructure network set out in the current Allocations and Designations Local Plan (Policy AD24), there is a clear opportunity for the delivery of the site to help the Council to achieve the following in particular:
• Delivering the north west section of the Bedford Green Wheel project to create a green access route around and into the town; and
• Creating walking, cycling and horse riding routes linking villages to the north of Bedford with the northern section of the Bedford Green Wheel.
In addition, the proposed development, as demonstrated by the Parameter Plan submitted as part of the August 2020 Call for Sites package, would both enhance access to the green infrastructure network more generally, opening up the parcel on the site as public open space. In fact the recreational value of this land would increase through the inclusion of more formal types of open space including sports pitches and informal semi-natural picnic areas.
4a Likely to impact on designated and non-designated heritage assets or their settings?
The Council’s review of the site in respect of heritage assets currently concludes with what we understand to be generic text attributed to all sites in the immediate vicinity of listed buildings such as our client’s land. It concludes that further assessment of the potential impact of development on the site “may ultimately lead to the conclusion that the site should not be allocated”. This matter was, however, considered in significant detail during the course of the recent appeal and of course the application that preceded it. Our client’s case was supported by a comprehensive Heritage Statement and Addendum (copies of which were submitted towards the Call for Sites exercise in August 2020) which allowed the Inspector to conclude on this point as follows:
“From its highest point, the topography of the site dips down to meet the older part of Salph End, which lies along Ravensden Road, outside the Settlement Policy Area defined in the Local Plan. This older part comprises a few large houses in extensive grounds on the west side of Ravensden Road, including Salph End Farm house and Abbey Farm house, both listed buildings and, on the east side of Ravensden Road, development more in depth in Brook Lane and Brookside, either side of Renhold Brook3, including a group of listed cottages on Ravensden Road itself (numbers 27-31 and 33-35, Abbey Croft and Moon Cottage). These help this part of the settlement to retain the character of a rural village.
Abbey Farm house was once closely associated with the site but, as the appellant’s Heritage Statement demonstrates, that connection was severed in the 1990s by the demolition of the associated farm buildings, their replacement with a new detached property, Carlton House, lying between Abbey Farm house and the site and the definition of a new residential curtilage to Abbey Farm house itself.
For that reason, together with the topography of the land, existing tree and shrub planting and fencing which screens Abbey Farm house, Salph End Farm house, Abbey Croft and Moon Cottage, I concur with the findings of the appellant’s Heritage Statement, that these listed buildings are not experienced in conjunction with the site and so the site makes no appreciable contribution to their setting. It follows that the development of the site would cause no harm to the setting or significance of these listed buildings.”
On this basis and following rigorous independent review of the potential impact of the site on the setting of nearby heritage assets, it is evident that the Council can conclude with confidence that the presence of listed buildings adjacent to the site should not present a constraint to its allocation.
All other assessment criteria
Otherwise, the Council’s site assessment proforma does not identify any other criteria where either the suitability of the site for development is questioned or further information is sought from our client. On this basis we concur with the findings of the site review.
Conclusions
On review of the latest draft of the emerging Local Plan 2040 we are firstly pleased to note that the Council is now clearly taking a more ‘real world’ approach to the delivery of significant strategic levels of growth across the Borough to meet a need that has been mounting since before the beginning of the current adopted Local Plan period. However, grasping the much-increased level of annual housing need on an annual basis and tackling it through a significant escalation in housing delivery is essential from the first year of the plan period following its adoption. Stepped trajectories should be avoided and a strategy which embraces the allocation of sustainable and immediately deliverable sites must form the central pillar of the updated plan.
On this basis the allocation of strategic scale sites on the edge of the Bedford and Kempston urban area must form the foundation to this strategy. Such sites are likely to be easily deliverable, served by existing road, rail, social and utilities infrastructure meaning they can be developed with minimal delays or risk and well related in character to the Borough’s main urban area.
In which case it is important to re-emphasise the deliverability and suitability of our client’s land to plug into this strategy. As demonstrated by the significant level of technical evidence provided to the Council during the previous Call for Sites period, and now updated within this response, there are no technical or legal constraints that would prevent our client’s land from delivering within the first five years of the plan period following adoption. Indeed, the credentials and suitability of the site for the delivery of a strategic scale residential development supported by on-site infrastructure including a new primary school site was clearly stated by the Inspector presiding over the recent appeal. Additionally, we have reviewed the site against the updated NPPF (July 2021) and note the enhanced importance it now attributes to good design. We are pleased to confirm that our client’s site provides ample flexibility to deliver a development where density, design and extensive tree planting reflective of its urban edge location can be achieved.