Site Assessment Pro Formas

Object

Representation ID: 6562

Received: 13/09/2021

Respondent: FCC Environment UK Ltd

Agent: Axis PED Ltd

1.1.1 On behalf of our client, FCC Environment (UK) Ltd (FCC), we set out our comments to the Bedford Local Plan 2040 Site Assessment Proformas document. Where necessary, these representations draw on the comments previously made to the 2020 Local Plan Issues and Options and Call for Sites submissions.
1.1.2 These comments relate to the Council’s Site Assessment of FCC’s site at land west of Wilstead Road Elstow, Site ID 947. For consistency, we have used the Council’s numbering below where relevant.
Background, Timescales and Delivery
1.1.3 The Site is covered by planning permissions granted in 1949 and 1980 for mineral extraction and restoration. Both the 1949 and 1980 permissions provide the opportunity for delivering a number of restoration options, including full or partial infilling.
1.1.4 FCC are now preparing a comprehensive application pursuant to the above permissions for the approval of a final restoration scheme which includes dewatering the void and the creation of a development platform suitable for built development. The approach to infilling the voids has been discussed and in principle agreed with the Council through pre-application discussions. The voids are being dewatered with EA and IDB consents and site investigations and design work are completed to inform the technical specification for infilling and an Environmental Permit application. It is anticipated that the discharge of condition application will be submitted this calendar year. Reference below is made to the restoration proposals which will create a level restored site with an interim restoration and drainage scheme which would be suitable for future development.
1.1.5 Whilst it is acknowledged that any further development will be subject to a separate planning application, once restored, built development can be brought forward on the site, to complement and enhance the strategic and employment development surrounding the site.
1.1.6 FCC intend to submit the discharge of condition application for the restoration of the site in 2021. The dewatering of the site has already commenced and will take approximately 2 years. The site will be infilled and ready for development by 2030. Employment development can be brought forward on the site to meet the identified economic requirements during the plan period.
Site Selection Criteria
1a. Within or adjoining UAB (Urban Area Boundary) SPA (Settlement Policy Area) or built form of a small settlement.
1.1.7 The site scores negatively against this criterion with the additional text stating: “The site is not within or adjoining the urban area or defined settlement policy area, or within the built form of a small settlement”.
1.1.8 This statement is incorrect, the site adjoins the Urban Area Boundary at its most northern point. This part of the site is promoted for retail, offices and / or commercial uses. The site also adjoins the Settlement Policy Area to the south west and south east. We have prepared Figure 1 which shows the site in relation to the UAB and SPA. The UAB is approximately 60m from the north-eastern corner of the site and the southern boundary of the site clearly adjoins the SPA. As illustrated on Figure 1, the site is located within an area which has and will continue to experience considerable economic development. To the south and east of the site is safeguarded employment land and to the west is the proposed Bedford Business Park.
1.1.9 Clearly the site should score favourably in this category. The site is sustainably located on the edge of the urban area. It is bordered by deciduous tree belts to the east, south and west and by the Council owned landfill to the north. The A6 trunk road runs close by to the east. Recently built residential properties at Wixams are located to the southeast. Figure 1 shows the site context. There is an extensive industrial estate to the south east of the site. A large area south-west of the Site is being developed for further employment development. The Elstow Aggregate Railhead facility is located to the west of the Site, with access through the FCC land. Further west beyond the railway line is a large site known as Bedford Business Park. A planning application is pending for the development of 233,360m2 of B2 and B8 floorspace.
1.1.10 Figure 1 demonstrates that whilst the site sits currently outside of the UAB and SPA it is closely connected to both areas. The proximity of the site to other industrial uses, the UAB and SPA weighs heavily in the site’s favour for allocation.
2a. Within or adjoining a site of nature conservation importance.
1.1.11 The site itself is identified as Elstow Pit County Wildlife Site (CWS) recognised for its waterbodies and mosaic of grassland, scrub and swamp. The CWS citation described the site from a survey in 1998 (now deemed historic) with the lakes noted as having abundant aquatic vegetation in the shallows. The edges of the lakes contained areas of swamp consisting of common reed Phragmites australis, reedmace Typha spp. and bulrush Scripus lacustris. Neutral grassland with scattered scrub and trees, and in places disturbed with bare ground, surrounded both lakes. This habitat has now largely succeeded to dense scrub, with a central area of scattered scrub and neutral/ calcareous grassland.
1.1.12 Consideration should be given to the fact that planning permission exists to restore the site which will require the entire dewatering of the site and the infilling with suitable material, resulting in the removal of the majority of the existing habitats (aquatic and terrestrial).
1.1.13 On completion of the infilling phases, restoration planting and habitat creation will provide new habitat over the entirety of the CWS, predominantly woodland and grassland. Habitats created across the restored site will be maintained over the long term as planting and habitat creation becomes established to provide a permanent area of open space with woodland, scrub, grassland and pond habitat. This will however be a change to the constituent habitats within the current CWS designation, with a permanent loss of open water and reedbed habitat.
1.1.14 It is noted that the CWS has already undergone some alteration from its original condition when designated, with significant expansion of scrub cover and loss of some swamp habitat and open ground/mosaic features.
1.1.15 Given that the site survey relating to the CWS citation is over 20 years old and more recent surveys have confirmed that natural succession over time has changed some of the original elements noted in the original citation with scrub replacing much of the ‘Open Mosaic Habitat’ areas and that permission exists to restore the site, the current CWS designation should not preclude the allocation of the site.
2b. In an area where protected species are known or likely to exist.
1.1.16 Several protected species surveys have been undertaken at the site to support the EIA submission to be made in 2021 including:
• Breeding and Wintering Bird
• Bat
• Otter
• Watervole
• Great Crested Newt
• Invertebrates
1.1.17 The results of the surveys have shown that whilst there are some protected species using the site, such as birds and reptiles, suitable mitigation methods can be implemented as part of the restoration works to ensure no harm to the conservation status of the protected species. This will therefore allow further built development to take place on the site without significant ecological constraints.
4a. Likely to impact on designated or non-designated heritage assets or their settings.
1.1.18 The site scores negatively against this criterion. The text provided within the assessment states: “The proposal has the potential to cause harm to heritage assets. This may range from low to high. There may be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation. This further assessment may ultimately lead to the conclusion that the site should not be allocated.”
1.1.19 An Archaeological and Cultural Heritage Assessment has been prepared to accompany the application to discharge the conditions associated with the restoration of the site. There are no World Heritage Sites, Scheduled Monuments, Registered Battlefields, Registered Parks and Gardens, or Conservation Areas recorded within the 1km study area. There are three Grade II Listed Buildings just under 1km to the north west of the Site. These Grade II Listed Buildings largely include
the 17th century timber framed Lynn Farmhouse; a pair of 18th century estate cottages; and a 19th century barn. The assessment has concluded that there would be no direct effects upon designated heritage assets as a result of the restoration proposals. It also confirms that due to intervening distance and vegetation no intervisibility was observed between the Listed Buildings and the site. Given the surrounding nature of the site, occupied by large warehouse and distribution buildings, and based on the assessment work undertaken at the site, there are no archaeological or cultural heritage constrains to the delivery of built development on the site.
1.1.20 The Assessment also found no potential for archaeological remains to survive in the previous extraction areas, which cover the majority of the site. During the scoping exercise for the restoration proposals, the Archaeological Officer stated that settlement remains from the late Iron Age and Romano-British periods onwards were recorded in the wider area and suggested that an archaeological evaluation may be required to be undertaken in the areas of the site unaffected by the extraction works, namely the southern corner of the Site, to assess the presence or absence of archaeological remains on the Site, and to characterise any such remains that may be present.
1.1.21 An archaeological evaluation will be undertaken in the southern area of the site should this area be disturbed as a result of the development proposals. This would enable the identification, assessment and recording of any surviving remains in advance of development at the site.
1.1.22 There was found to be no appreciable intervisibility between the Site and designated heritage assets within 1 km of the site. Due to intervening vegetation and the built environment, no intervisibility was found between Elstow Conservation Area, including the Scheduled Elstow Abbey. As such no impacts and no harm upon the setting of these designated assets is expected. FCC will be happy to provide further information from their archaeological and cultural heritage assessment.
1.1.23 It is therefore considered that the site should not be scored negatively against this criterion.
15e. Connect highway without constraint?
1.1.24 The site does not score positively or negatively for this criterion, the supporting text states: “? Potential access requiring mitigation.’”
1.1.25 Vehicular access to the proposed development will be provided either via the existing access from Wilstead Road which is located on the south-east boundary of the site or, as shown on Figure 1 via a new access to the north east of the site.
1.1.26 Wilstead Road extends from the A6 / Wilstead Road Roundabout to the north-west of the site access before continuing south-east to the Bedford Road / The Causeway roundabout.
1.1.27 To the south-east of the existing site access at Wilstead Road is a bus gate which restricts movements such that only buses are permitted to route to and from the south. Consequently, Wilstead Road effectively forms a cul-de-sac for other vehicles which terminates to the south-east of the proposed site access junction.
1.1.28 The road is subject to a mandatory 40mph speed limit to the north-west of the site access, changing to a 30mph limit to the south-east of the access at the bus gate.
1.1.29 Approximately 500m to the north of the site access Wilstead Road joins a five-arm roundabout junction with the primary route of the A6 and access into the Renewi Waste Management Facility.
1.1.30 There is a circa 3.5m wide shared cycle/footway on the northern-eastern side of Wilstead Road which connects the Wixams Retirement Village to the south-east of the site. The number of pedestrian/cycle trips expected on this route are minimal, primarily comprising local staff of the Shank Waste Management Facility and pedestrians/cyclists passing between Wixams and Elstow. Wilstead Road provides direct access to one other development at Wixams Retirement Village.
1.1.31 It is therefore considered that there are no existing access constraints and the site should score positively against this criterion.
15f. Highway or junction capacity issues
1.1.32 The site does not score positively or negatively for this criterion, the supporting text states: “? The Assessment Potential capacity problem requiring mitigation.”
1.1.33 A Transport Statement has been prepared as part of the restoration proposals. Baseline weekday survey has been obtained in order to determine the impact of the restoration operations on the surrounding highway network.
1.1.34 A review of the anticipated future operational road conditions with reference to appropriate guidance has been undertaken. This has concluded that the restoration proposals would not result in a significant impact on operational or environmental conditions over the local transport network and there is no requirement for off-site transport improvement / mitigation works. It is envisaged that the proposed employment development would generate a similar level of trips per day to the proposed restoration scheme.
1.1.35 The impact of trips generated by the proposed infilling scheme have been assessed and it is concluded that in all scenarios, the effects are considered to be negligible or minor adverse in nature. FCC will be happy to provide this information to the Council.
1.1.36 There are therefore no highway or junction capacity issues which should preclude the site’s allocation.