Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 9999

Received: 29/07/2022

Respondent: London Square Developments Ltd

Agent: Carter Jonas LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Draft Policy HOU13 allocates Land at Gibraltar Corner for new development including a mix of residential uses, open space and a primary school. However, an area of land which is suitable and available for development has been excluded from this draft allocation without valid justification.

Site #2410 is referred to in the Council’s HELAA evidence base associated with the Draft Local Plan at Appendix 5. Whilst the site passed Stages 1 and 2 of the assessment and scores well in the sustainability criteria under stage 3, the site assessment concludes that the site is not preferred for development. The justification for this is not robust and it is the landowner’s view that this site should be more carefully considered, particularly as the wider area has a draft allocation for development.

In terms of site 2410, the landowner engaged in two rounds of pre-application discussions with Bedford Borough Council in 2018 and 2019 regarding the development potential for housing. At this time, the Council’s pre-application advice noted that this site was surplus to the Council’s housing land requirements and that the best option would be to promote the site via the Local Plan process.

In line with the above advice, representations were submitted to the Council’s call for sites in September 2020. At this stage, the site was put forward with potential capacity for 38 dwellings. Representations were also submitted to ‘The Draft Plan: Strategy Options and Draft Policies’ consultation which was held between 29 June and 3 September 2021. As part of this consultation, detailed comments were provided on the Council’s analysis of the site noting that if the site were to receive a draft allocation, the relevant surveys would be undertaken to ensure that no ecological, biodiversity or highways issues would arise as a consequence of developing the site. These representations concluded that there were no criteria leading to the site being unsuitable or undevelopable.

Following the above consultation, the landowners of Site 2410 were not contacted in respect of the site’s suitability, deliverability or the representations made. In reviewing the HELAA evidence base published as part of this Regulation 19 consultation, the site assessment states the following:

“The site is not preferred for development. The site has a constrained access. Development of the site has the potential to impact on the amenity of properties in The Chase given their close proximity to the boundary. The site is partially within flood zones 3a and 3b at its eastern edge. Alternative sites are preferred which in combination are proposed for a level of growth to support the provision of a primary school”.

This statement raises three potential concerns associated with the site’s suitability: access/highways, proximity to existing neighbours and flood risk. Each of these potential issues are dealt with in turn below. These representations are also supported by a Vision Document prepared to demonstrate the site’s deliverability.

1) Access

Appendix 5 to the HELAA also includes the following statement on highways in respect of Site 2410:

“The site is located in the village of Wootton approximately 6 miles south of Bedford town centre. Access to the site is feasible from Wootton Road, but the width is tight, around 9m. Traffic generation from the potential development could cause moderate problems to Wootton Road. The nearest bus stops are on Ridge Road approximately 220m in distance. The footway on Wootton Road is around 1.8m and is shared between pedestrians and cyclists. Given the significant scale of proposals, a road to adoptable standards is required in accordance with Bedford Borough Council's highway standard. A Transport Assessment will be required to identify the impact of traffic and provision of satisfactory facilities for both pedestrians and cyclists”

The enclosed vision document for the site demonstrates that a site access of 7.5 metres from Wootton Road is achievable. This would comprise of a 5.5 metre carriageway and a 2.0 metre footpath and is considered by transport specialists to be entirely adequate for a proposed development of 38 dwellings. The location of the access is also safely located between nos. 11 and 15 Wootton Road. The highways officer has noted that a Transport Assessment will be required to identify the impact of traffic and provision of satisfactory facilities for both pedestrians and cyclists. A Transport Assessment was not requested by the Council from the landowner to demonstrate the site’s deliverability at any stage to date. We consider that this should have been requested in order for the site to be considered unsuitable/undeliverable and this did not take place. The view of a transport specialist is that a Transport Assessment could show that elements of the access require rearranging (e.g. it could be that the pedestrian footpath into the site is better located to the south of the access) but accessing the site in this location from Wootton Road is unlikely to be an issue in principle.

2) Impact on neighbouring amenity

The vision document demonstrates that this site could be developed in a manner that would not impact the amenity or privacy of residents living in The Chase. The Concept Plan at 5.2 of the accompanying Vision Document demonstrates that adequate distances could be retained between existing dwellings on The Chase and any new development proposed on the subject site. Any proposed gardens adjoining the boundary with the Chase would have distances of between 11 and 16 metres and the existing gardens associated with properties on The Chase are also generous, therefore the building to building distances would be much greater.

3) Flood risk

In terms of flood risk, the site is almost entirely within Flood Zone 1. Only a small area in the south eastern corner of the site is within Flood Zone 2/3, the Vision Document clearly demonstrates that this area would not be built on.

Whilst we do not object to the inclusion of the sites referred to in the HELAA documents as sites #636 and #1333 as draft Policy ‘HOU13’ in the Local Plan submission version, the Council’s assessment of these sites identifies the same potential issues with regard to highways, impact on adjacent existing development and flood risk.

Appendix 5 of the HELAA document notes that sites 636 and 1333 will be required to submit a Transport Assessment to identify the impact on the local highways network. The highways officer also notes that a re-design of the Wood End Lane/Ridge Road and Ridge Road/Home Road junctions may be required if development comes forward. These comments demonstrate further work with regard to highways are necessary to demonstrate that the draft allocation is deliverable and is at least comparable with those highways comments received in respect of site 2410.

Part of the draft allocation (site 636) has elements which are located in Flood Zones 2 and 3. Like site 2410, it is considered that these parts of the site would not be built on.

In terms of impact on existing neighbouring development, Site 1333 includes a residential development plot adjacent to existing residences on Ibett Close and Home Road. This is also comparable with Site 2410 which could be designed to respect the amenity of existing neighbours on the Chase. It should also be noted that the draft allocation sites also have the potential to impact on heritage assets which is not a concern in respect of site 2410.

It is not clear why these issues are considered surmountable in respect of the draft allocation and not with regard to Site 2140. The Council’s assessment of Site 2140 concludes that “Alternative sites are preferred which in combination are proposed for a level of growth to support the provision of a primary school”. As the draft allocation HOU13 clearly seeks to bring forward a number of non-contiguous sites in Gibraltar Corner, it is considered that the Council should have actively engaged in discussions with the landowner of Site 2140 as this is suitable for development with comparable or lesser constraints to those sites which are included in the draft allocation.