Site Assessment Pro Formas

Support

Representation ID: 3851

Received: 26/08/2021

Respondent: Hollins Strategic Land

I am writing in regards to the Site Assessment undertaken for Site 371 – ‘Land adjacent to Wootton Upper School, Hall End Road, Wootton’.

There are various questions answered by the planning department that have not taken account of your officers’ and statutory consultees’ detailed comments on a recent planning application on the site. I attach the Officer’s Planning Committee Report which was published for a Planning Committee on 25th November 2019. This sets out many of the answers to the questions in Call for Sites site assessment section and the Council should take account of it in its site assessment work to ensure consistency in decision making.

In summary, the following points should be considered for each of the site assessment questions:

2a – the report confirms that “the site falls within a designated County Wildlife Site totalling about 13% of that total designated area…Recognition as a County Wildlife site does not confer protection on the site…The Wildlife Trust has been consulted on the application and they do not object to the development…It is therefore concluded that the scheme will result in an improvement to the biodiversity value of the site and that the benefits to be achieved and secured by the scheme outweigh the estimated loss of c.3.1 hectares of the neutral grassland at the CWS to achieve compliance with the NPPF”
2b – the report summarises that “The Habitat Survey has confirmed the presence of Great Crested Newts in the existing pond on site…and the presence of Badgers on the land, although no setts were identified…The Wildlife Trust has been consulted on the application and they do not object to the development”. A significant buffer is achievable to protect the existing pond.
2c – the report confirms that “It is therefore concluded that the scheme will result in an improvement to the biodiversity value of the site and that the benefits to be achieved and secured by the scheme outweigh the estimated loss of c.3.1 hectares of the neutral grassland at the CWS to achieve compliance with the NPPF”
2d – The report states: “The Masterplan demonstrates how a new landscaped footpath fringes the development site and connects the new
homes with built form to the edge of settlement. The proposed development will not obstruct the existing PRoW within the northern
and western site boundaries; this bridleway will be managed to ensure it remains suitable for use, with users encouraged to respect
the areas of protected Meadow land”. The site also borders a cycle route and can link into a green infrastructure opportunity network.
4a – The report states: “The application has been assessed by the Council’s Heritage Team and they have identified the development would result in a very low level of less than substantial harm which could be removed altogether with suitable siting and screening of the development. … They have advised that the site makes very limited contribution to the significance of the identified heritage assets…”
5a – The report confirms the site would provide “associated support to the local economy”
9b – The report confirms that the loss of Grade 3a agricultural land on the site would be “of a minor nature”.
15f – The site assessment references application 19/00894/MAO which confirms the Highway Authority consider 81 dwellings to be acceptable. No issues have been substantiated on highway or junction capacity.
Contaminated Land – The report confirms “The Council’s Contaminated Land Officer has raised no objections to the findings of the [desk based study] which recommends full intrusive investigation (and any required mitigation) is undertaken. Subject to a condition to require this investigation the proposal is considered acceptable in terms of contaminated land”.
Environmental Health – The report confirms “The Council’s Environmental Health Team has raised no objections to the application”.

Support

Representation ID: 8722

Received: 28/09/2021

Respondent: Hollins Strategic Land

Agent: Emery Planning

5. Land west of Hall End Road, Wootton (Site ID371)
5.1 We set out below an overview of the site HSL are promoting for residential development in
Wootton for up to 81 homes.
Site Location and Description
5.2 The site is generally rectangular shape, on the edge of the western built-up area of Wootton,
which lies south west of Bedford. The site, as identified by the red line boundary, covers
approximately 6.5 hectares (ha) or 16 acres.
5.3 The northern edge of the site is defined by Hall End Road (also National Cycle Route 51) and the
John Bunyan Trail. There is a field access gate to the northeast corner of the site. From this
direction, the settlement of Wootton has recently been expanded towards the site with the
construction of 58 dwellings (Ref: 14/02939/MAF) (Allocation AD2) and is a prominent feature. An
allocation for a school extension is also located north east of the site on the opposite side of Hall
End Road and is yet to be implemented and extends the settlement edge outwards.
5.4 The eastern boundary runs alongside an unnamed road that provides access to Wootton Upper
School and commercial/ farm premises. The southern boundary is contiguous with Wootton
Wood, an area of ancient and semi-natural woodland. The western boundary is shared with an
adjacent field, laid to pasture. These boundaries are all formed from native hedgerow with a
combination of post and rail or post and wire fencing within.
Sustainable and Suitable Location
5.5 The village centre of Wootton is located approximately 900 metres to the east of the site. The
village benefits from many amenities including local convenience stores, pubs and restaurants,
several churches, a petrol station, pharmacy, public library and football club. The wider parts of
the village contain community services such as the village hall, memorial hall, play areas, skate
park and tennis courts.
5.6 In terms of transport links, bus services serve Wootton and can be accessed within a short walk of
the site. These services provide regular daily services to destinations such as Bedford, Milton
Keynes and other local villages, providing residents with the opportunity to access a wide range
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of employment, shopping, leisure and cultural opportunities without having to rely upon the
private car. The site location therefore would accord with NPPF §109.
5.7 The Environment Agency Flood Maps show the appraisal site lies entirely within Flood Zone 1
indicating it has a low probability of flooding and is suitable for residential uses.
5.8 The village of Wootton has a historic character, with buildings and monuments dating from as
early as the 14th Century. Wootton Church End Conservation Area is located approximately 250
metres to the east of the appraisal site and encompasses the Grade I listed Church of St. Mary
and several other listed buildings. These heritage assets are separated from the site by Wootton
Upper School and so development of the site would not have a negative impact upon their
setting. The westernmost part of the site is within an Archaeological Interest Site. The LPA also
agreed in the committee report (see EP4).
The Proposed Development
5.9 This proposal submitted to the LPA sought outline planning permission for the construction of up
to 81 dwellings with access. The final layout, scale, landscaping and appearance would be the
subject of a reserved matters application. The proposed illustrative site layout and Design and
Access Statement submitted with the application shows how the dwellings could be comfortably
accommodated on the site along with open space and the conserved and managed meadow.
These are enclosed as Appendix EP2.
5.10 All of the proposed dwellings within the site would be served by a single access road which would
be taken from Hall End Road. The main internal access road is shown and the precise details
would form part of the reserved matters application. Pedestrian and cycle connectivity can be
explored at the reserved matters stage.
5.11 The TA states that the proposed site is situated approximately 950m west of Wootton village
centre, and coupled with the site’s proximity to frequently serviced bus stops, cycle routes and
viability to access the nearest rail station, accessibility from the site is considered to be of a good
standard with opportunities to promote sustainable travel from the site. A Travel Plan was also
submitted with the application to help promote more sustainable choices of travel.
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The Application and Appeal
5.12 Following their consideration of the proposal, the professional officers of the Council concluded
that planning permission should be granted and recommended this to the planning committee
on 28th October 2019. The application was deferred for a site visit and it was considered again on
the 25th November (Appendix EP3). The members of the Planning Committee voted to refuse the
application solely on highway grounds contrary to the advice of the planning and highway
officers.
5.13 The committee report sets out the detailed 22 planning considerations that were examined and
the planning officer was informed by statutory and non-statutory consultees and other
consultation letters during the determination period with the conclusion that permission should
be granted.
5.14 An appeal was submitted and determined. However, following a High Court challenge the
Inspector’s decision on the appeal dated 15 September 2020 was quashed and the Court has
ordered that the appeal be re-determined. The proposal has the following benefits:
• the delivery of open market housing to assist in boosting the supply of housing in
Bedford and can meet the 145 homes identified in the evidence base for the WNP as
well as borough housing needs;
• delivery of a medium sized site by HSL who have a proven track record of delivery
which would accord with the clear objective of the Government in paragraph 69 of
the Framework.
• the development accords with the spatial strategy as expressed in Policy 3S of the
Local Plan which identifies Wootton as a Key Service Centre which can accommodate
strategic residential development in a sustainable location.
• the proposed development helps to meet the objectives set out in the Bedford Green
Infrastructure Plan (2009) and the provision of open space to meet the needs of
existing and proposed residents and maintain a Green Corridor as required by saved
policy AD24.
• residential development at the site through the proposed scheme will result in an
improvement to the biodiversity value of the site and the net gain benefits to be
achieved and secured by the scheme outweigh the estimated loss of c. 3.1 hectares
of the neutral grassland at the CWS to achieve compliance with the paragraph 180(c)
of the Framework.
• the delivery of 30% affordable housing accords with Policy CP8 and would assist in
addressing the very significant and persistent shortfall in affordable housing delivery.
Paragraphs 4.23 to 4.30 of the Application Planning Statement confirm that there is a
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shortfall of 552 affordable homes since 2003 and the need going forward is 278
affordable homes per annum. There is also a need for 24 affordable homes as set out
in the Housing Needs Survey.
• highway works that will improve highway safety; and;
• a range of social and economic benefits and increase spending for local services and
facilities.
5.15 In the Site Assessment Pro-Formas June 2021 the subject site is Site ID 371. However the assessment
does not take account of the Officers Report to committee for the application and HSL sent an
email to the LPA on 2nd August 2021 setting out our comments which were noted in an email
dated 11th August 2021. The email exchange is Appendix EP4. The site is deliverable.
5.16 Our position is that the site can be delivered in full in the first five years of the plan period. This is
because the land is controlled by HSL, an experienced land promotion company complete with
its own housebuilding division. The site is controlled by a willing landowner, and there are no legal
or ownership issues that would prevent development. Appendix EP5 is a summary of the delivery
record of HSL in recent years. The Council can proceed in the confidence that the site is
deliverable and can be delivered in the first 5 years of the housing land supply and should be
allocated on that basis.
5.17 To conclude, with the need for further housing to meet the requirement to 2040 we request that
the site is proposed for allocation. We would welcome discussions with the LPA on what the site
can offer so that a deliverable site can be allocated to meet the housing needs in the first 5 years
of the plan period. HSL has a good track record in seeking to positively engage with communities
preparing neighbourhood plans as they have done with the Willington neighbourhood planning
group in Bedford on their land at Sandy Road. That NP is now at examination stage with HSL land
allocated for up to 50 dwellings to meet local needs alongside a range of community benefits
and HSL have a planning application pending. HSL undertook technical survey work to help
inform the NPG as they consulted with the community, which resulted in the allocation of the site
for development with the support of the local community and Parish Council.
5.18 This concludes our representations.