Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9935

Received: 28/07/2022

Respondent: Trakbak Racing Limited

Agent: WSP

lease see supporting covering letter which sets out amendments required in order for the plan to be made sound.

This cover letter sets out that Trakbak Racing LTD agree with the council’s assessment that the following six sites, 1002, 529, 531, 527, 519 and 532, are not suitable for a housing allocation. Trakbak Racing LTD object to the allocation of these six sites because their allocation would be contrary to paragraph 35 of the NPPF which explains that in order for local plans to be found sound, they must be in accordance with policies of the NPPF.

These representations also explain that the ‘Spatial strategy and Site allocations’ chapter of the emerging local plan be amended, with Santa Pod Raceway (SPR) allocated under a specific policy allocation which reflects the primacy of the venue and looks to support its future growth. Further to this, to protect SPR from the effects of inappropriate housing development proposals on its business, it is explained that an exclusion buffer zone for residential development around SPR should be outlined in policy. This would represent a positive response to the issue of housing around SPR and would ensure that paragraph 187 (‘agent of change’) of the NPPF is complied with, and therefore ensure the soundness of the emerging Bedford Local Plan 2040.

Comment

Representation ID: 10089

Received: 28/07/2022

Respondent: Trakbak Racing Limited

Agent: WSP

Need for SPR to be allocated as a key employment/sports arena to support its continued growth and development
SPR is a sporting facility of national significance which makes a valuable cultural and economic contribution to the local area, as set out earlier in these (and previous) representations. Despite this, there is no policy allocation in the emerging or adopted local plan which reflects the primacy of the venue and which looks to support its future growth. This is the despite SPR continuing to look for opportunities to expand its operations, to the benefit of the local area, owing to its continued success as a venue.

The lack of an allocation of SPR appears to be an oversight in the emerging local plan, Trakbak Racing LTD therefore would like to put forward the site for a specific allocation which looks to support the upgrading and expansion of this key employment area and sports arena. A red line boundary is attached at Appendix A of this letter which shows the site area proposed to be put forward for this allocation. This red line boundary encompasses the whole site as well as some land to the west of it that SPR may consider expanding into in the future.
The red line boundary outlined should be allocated under a specific policy entitled ‘Santa Pod Raceway’. This allocation should then explain the significant cultural and economic contribution of SPR before stating that any proposals for development at the raceway, which are related to and build upon its existing operations, will be permitted as long as it is considered sustainable development in accordance with paragraph 11 of the NPPF.
The addition of this policy allocation in the emerging plan would be in accordance with paragraph 81 of the NPPF as it would help create conditions for this key local business (of national significance) to invest, expand and adapt, increasing the number of people it can employ and benefitting the economy.
Need for a noise buffer zone around SPR
When the Council previously withdrew the garden village settlement at Colworth (nearby to SPD) which was put forward as an allocation in the previously emerging Bedford Local Plan 2030, they recognised that the development of housing in close proximity to SPR is inappropriate. Despite this, there is nothing in the ‘Spatial strategy and Site allocations’ chapter, on pages 22-84 of the emerging Local Plan 2040, to reflect that or to protect SPR from the effects of alternative development proposals on its business.
Trakbak Racing LTD has concerns about this, and in particular if the Council fall into a position of failing to demonstrate a five-year supply of housing land during the emerging plan period which could result in speculative housing applications being submitted nearby to SPR. At paragraph 3.9 of the document ‘Trakbak Racing LTD Regulation 19 Representations to the Bedford Borough Local Plan (October 2018)’ it is explained that there is a known noise issue in connection with SPR. In consequence, there is a risk of unreasonable restrictions being placed on SPR because of new development.
In relation to this, paragraph 187 of the NPPF that “existing businesses should not have unreasonable restrictions placed on them as a result of development permitted after they were established” needs to be complied with to ensure that the emerging local plan is in accordance with policies of the NPPF (as required by paragraph 35 of the NPPF). The agent of change (the housing development) should be required to provide suitable mitigation where the operation of an existing business could have a significant adverse effect on new development.
Appendix 23 of Trakbak Racing LTD Regulation 19 Representations to the Bedford Borough Local Plan 2030 (October 2018) contains a letter from MAS Environmental dated 25th October 2018. This
3 Reference to this can be found on page 3 of the Appendix 2 which outlines a composite list of noise assessments undertaken by MAS Environmental

letter explains that any development within the previously proposed Colworth garden village development area (site reference 1002) would carry significant risks regarding noise impact. Development in the area indicated as the inner buffer zone (within a 1.4km area of SPR, highlighted in red on figure 1) would be subject to noise from the raceway for the majority of events and there is no evidence to suggest that mitigation could adequately resolve the issue.
Trakbak Racing has been advised that any housing development approved within this area would indicate substantial changes needed at SPR and potential demise of the business due to noise complaints or severe restrictions on the operation and use of the raceway. Housing therefore should not be allocated, or approved, in this inner zone.
The outer buffer zone (within a 2.4 km area of SPR, highlighted in blue on figure 1) corresponds with the distance from the raceway to the nearest residential housing in Podington and Souldrop, where there has historically been a campaign of noise monitoring. Within this area, Trakbak Racing have been advised that, any proposed housing would require significant and substantial mitigation both at the development site and at the raceway.
In this outer buffer zone it should be essential for the Council to be satisfied, before supporting the allocation of any sites, that it would be possible for mitigation within the proposed development to provide an acceptable noise environment. This would need to be supported by robust evidence and the Council should provide guidance in the Local Plan as to what standard should be required.
Figure 1: Proposed noise buffer zones for residential housing within 1.4km (outlined in red) and 2.4km (outlined in blue) of Santa Pod

Adoption of the MAS recommended exclusion buffer zone would represent a positive response to the issue of housing around SPR and would ensure that paragraph 187 (‘agent of change’) of the NPPF is complied with. The restriction will need to be in a strategic policy to ensure that it guides the neighbourhood planning process adequately.
It is significant that in the case of SPR there is no restriction on noise levels. The distance selected for the buffer zone has been identified based on the measured noise levels experienced in the relevant areas and so is based on a sound evidence base.
The introduction of housing into the inner buffer zone would represent a serious threat to the continuation of the business at SPR. It would not accord with paragraph 187 of the NPPF and so would render the plan unsound. Any housing within the outer buffer zone would need to be subject to robust mitigation measures to provide a specified satisfactory indoor and outdoor noise environment and sites should not be allocated unless that can clearly be demonstrated. In this case the plan does not, in the absence of policy guidance in relation to the location of housing to avoid noise issues from SPR, provide a clear and adequate strategic framework and that omission goes to the soundness of the plan.