Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 10408

Received: 29/07/2022

Respondent: The Executors of the late Nigel Alington

Agent: Code Development Planners Ltd

These representations have been prepared by CODE Development Planners on behalf of the Executors
of the late Nigel Alington in relation to the policies and evidence base of the regulation 19 Bedford
Borough Local Plan 2040 (BBLP 2040).
2 Proposals being promoted
2.1 The Alington Estate, Little Barford is proposed for allocation under Policy HOU19 of the BBLP 2040 for
a new settlement to delivery at least 4,000 new homes and in the region of 4ha of employment land.
The policy also identifies, inter alia, “walkable neighbourhoods which will enable residents to meet the
majority of their day to day needs locally” and “the new settlement will provide a range of community
services and facilities including health, education, retail, culture, community meeting spaces,
multifunctional open space and sports and leisure facilities.” However, there is no corresponding
recognition within Policy TC1(S) and paragraph 5.7 that the new settlement will create a local centre
and neighbourhood centres.
2.2 The Town Centres and Shopping Policies Topic Paper, April 2022 refers to the types of centres
(para 2.3). It states, “Local centres include a range of small shops of a local nature, serving a small
catchment. Typically, local centres might include, amongst other shops, a small supermarket, a
newsagent, a sub-post office and a pharmacy. Other facilities could include a hot-food takeaway and
launderette. In rural areas, large villages may perform the role of a local centre.” We recognise that until
a masterplan has been progressed for the new settlement at Little Barford the location and extend of
the local centre within it will not be spatially defined. However, the effective delivery of the ‘placemaking’,
‘accessible’ and ‘prosperous’ elements of Policy HOU19 would be enhanced by the inclusion of Little
Barford as a “Local Centre: Key Service Centre” within policy TC1(S) and an additional bullet point
within Policy HOU19.
Although Wixams is not a direct comparable, wording in paragraph 5.7 of the BBLP 2040 states,
“Wixams new settlement is identified as a potential Key Service Centre as, over the course of the plan
period, the planned town centre will be constructed and, once completed, will serve the settlement . . .”
It would seem reasonable that similar wording should be inserted into the policy in recognition of Little
Barford’s allocation as a new settlement.
2.4 The urban area of St Neots, Huntingdonshire is within 0.5 miles of the northern boundary of the Little
Barford New Settlement boundary. St Neots has been identified within the Huntingdonshire Local Plan
to 2036 as one of four spatial planning areas. This designation is the highest order settlement and
reflects St Neots’ status as a traditional market town and as one of the most sustainable centres for
development1.
2.5 The relative positions of St Neots and Little Barford within the settlement hierarchy, with St Neots
categorised as the equivalent of a strategic or district centre and Little Barford as a local centre: key
service centre (policy TC1(S)) recognises that whist the day to day needs of the residents of the new
settlement of Little Barford will be provided on site, residents would travel beyond the new settlement
for access to higher order facilities. The proximity of the two settlements to one another enables such
journeys to be made by sustainable and active modes of travel.

Support

Representation ID: 10409

Received: 29/07/2022

Respondent: The Executors of the late Nigel Alington

Agent: Code Development Planners Ltd

These representations have been prepared by CODE Development Planners on behalf of the Executors
of the late Nigel Alington in relation to the policies and evidence base of the regulation 19 Bedford
Borough Local Plan 2040 (BBLP 2040).
2 Proposals being promoted
2.1 The Alington Estate, Little Barford is proposed for allocation under Policy HOU19 of the BBLP 2040 for
a new settlement to delivery at least 4,000 new homes and in the region of 4ha of employment land.
The policy also identifies, inter alia, “walkable neighbourhoods which will enable residents to meet the
majority of their day to day needs locally” and “the new settlement will provide a range of community
services and facilities including health, education, retail, culture, community meeting spaces,
multifunctional open space and sports and leisure facilities.” However, there is no corresponding
recognition within Policy TC1(S) and paragraph 5.7 that the new settlement will create a local centre
and neighbourhood centres.
2.2 The Town Centres and Shopping Policies Topic Paper, April 2022 refers to the types of centres
(para 2.3). It states, “Local centres include a range of small shops of a local nature, serving a small
catchment. Typically, local centres might include, amongst other shops, a small supermarket, a
newsagent, a sub-post office and a pharmacy. Other facilities could include a hot-food takeaway and
launderette. In rural areas, large villages may perform the role of a local centre.” We recognise that until
a masterplan has been progressed for the new settlement at Little Barford the location and extend of
the local centre within it will not be spatially defined. However, the effective delivery of the ‘placemaking’,
‘accessible’ and ‘prosperous’ elements of Policy HOU19 would be enhanced by the inclusion of Little
Barford as a “Local Centre: Key Service Centre” within policy TC1(S) and an additional bullet point
within Policy HOU19.
Although Wixams is not a direct comparable, wording in paragraph 5.7 of the BBLP 2040 states,
“Wixams new settlement is identified as a potential Key Service Centre as, over the course of the plan
period, the planned town centre will be constructed and, once completed, will serve the settlement . . .”
It would seem reasonable that similar wording should be inserted into the policy in recognition of Little
Barford’s allocation as a new settlement.
2.4 The urban area of St Neots, Huntingdonshire is within 0.5 miles of the northern boundary of the Little
Barford New Settlement boundary. St Neots has been identified within the Huntingdonshire Local Plan
to 2036 as one of four spatial planning areas. This designation is the highest order settlement and
reflects St Neots’ status as a traditional market town and as one of the most sustainable centres for
development1.
2.5 The relative positions of St Neots and Little Barford within the settlement hierarchy, with St Neots
categorised as the equivalent of a strategic or district centre and Little Barford as a local centre: key
service centre (policy TC1(S)) recognises that whist the day to day needs of the residents of the new
settlement of Little Barford will be provided on site, residents would travel beyond the new settlement
for access to higher order facilities. The proximity of the two settlements to one another enables such
journeys to be made by sustainable and active modes of travel.
2.6 Identifying Little Barford within the settlement hierarchy, with St Neots designated in a higher tier of
settlement, protects St Neots from competition from Little Barford whilst recognising that there will be a
relationship between the two.

Support

Representation ID: 10410

Received: 29/07/2022

Respondent: The Executors of the late Nigel Alington

Agent: Code Development Planners Ltd

These representations and the accompanying technical documents demonstrate that land within the
control of the Alington Estate, Little Barford can deliver a new settlement of at least 4,000 new homes,
circa 4ha of employment land and associated infrastructure. Therefore, in broad terms Policy HOU19
Little Barford New Settlement is supported.
1.3 These representations are accompanied and supported by the following technical documents:
 Representations to the Regulation 19 BBLP 2040 in relation to Policy TC1(S) and associated
paragraphs, and paragraphs 4.12-4.13 and Table 2 of the BBLP 2040, and the Sustainability
Appraisal, April 2022;
 Drawing 068-001-014 Rev A: Areas available for allocation, March 2022 prepared by CODE
Development Planners;
 Drawing 60830-PP-500 B: Highway Access and Development Parcels – New Settlement (BBLP
2040 Reg 19 – HOU19);
 Preliminary Ecological Appraisal, September 2021 (issue 3) prepared by Southern Ecological
Solutions [land west of East Coast Mainline];
 Preliminary Ecological Appraisal, July 2022 prepared by Southern Ecological Solutions [land east
of East Coast Mainline line and west of A428 improvement];
 Botany Assessment of Grassland Component of Little Barford CWS, September 2021 (issue 2)
prepared by Southern Ecological Solutions;
 Botany Assessment of RWE Buffer, September 2021 (issue 3) prepared by Southern Ecological
Solutions;
 Transport Assessment, September 2021 prepared by Richard Jackson Ltd incorporating the
following:
Drawing 60830-PP-014A: Sustainable travel options plan [although this drawing is embedded
in the 2021 TA it has been superseded by drawing 60830-PP-018);
- Drawing 60830-PP-017: Proposed A428 grade separated junction location;
- Drawing 60830-S-004: Bridge at section 2 general arrangements and typical details;
- Drawing 60830-S-005: Bridge at section 9 general arrangements and typical details;
- Sustainable Transportation Technical Note, September 2021;
 Sustainable Transportation Technical Note Revision A, April 2022 prepared by Richard
Jackson Ltd
 Drawing 60830-PP-018: Little Barford Sustainable Travel Strategy, April 2022 prepared by Richard
Jackson Ltd
 Transport Technical Note, July 2022 prepared by WSP
 Site Specific Flood Risk Assessment (FRA), June 2021 (revision A) prepared by Richard
Jackson Ltd;
 Surface Water Strategy, August 2021 prepared by Richard Jackson Ltd incorporating the following:
- Drawing 60830-PP-200: Surface water strategy (sheet 1 of 5);
- Drawing 60830-PP-201: Surface water strategy (sheet 2 of 5);
- Drawing 60830-PP-202: Surface water strategy (sheet 3 of 5);
- Drawing 60830-PP-203: Surface water strategy (sheet 4 of 5);
- Drawing 60830-PP-204: Surface water strategy (sheet 5 of 5);
 Services Technical Note, September 2021 prepared by Richard Jackson Ltd incorporating the
following;
- Drawing 60830-PP-100A: Existing service records (sheet 1 of 5);
- Drawing 60830-PP-101A: Existing service records (sheet 2 of 5);
- Drawing 60830-PP-102: Existing service records (sheet 3 of 5);
- Drawing 60830-PP-103: Existing service records (sheet 4 of 5);
- Drawing 60830-PP-104: Existing service records (sheet 5 of 5);
 Tree Constraints Report, December 2021 (revision C) prepared by Southern Ecological Solutions
incorporating the following:
- Tree Survey Schedule;
- Tree Survey and Constraints Plan;
 Heritage Impact Assessment, October 2021 prepared by Bidwells’ Heritage;
 Archaeological Desk Based Assessment, December 2021 prepared by HCUK Group;
 Landscape and Visual Position Statement, October 2021 prepared by Fabrik;
 Drawing 60830-PP-502A Mineral Extraction Constraints Plan prepared by Richard Jackson Ltd;
 Noise and Vibration Constraints Technical Note, July 2022 prepared by WSP;
 Education Review, July 2022 prepared by Educational Facilities Management Partnership Limited

Proposals being promoted
2.1 The Alington Estate – Little Barford is in a single ownership and totals 453ha. It comprises 309ha that
will form site allocation HOU19, two areas of contingency land (one of 88ha and another of 28ha) and
land included as part of the A428 Black Cat to Caxton Gibbet improvement (circa 28ha). The
contingency land is available in the event that i) the route alignment chosen for East West Rail (EWR)
impacts on the delivery of elements of Policy HOU19; and/or ii) additional land is required for
biodiversity net gain, multifunctional green space or carbon off-setting. Drawing 60830-PP-500B
identifies that not all land is proposed for built development.
2.2 Based on technical assessments undertaken to date (the scope of which is considered proportionate
to this stage of the preparation of the BBLP-2040) the new settlement proposal is capable of delivering
at least 4,000 new homes and in the region of 4ha of employment land. A capacity study will be
submitted at an appropriate stage in the preparation of the BBLP 2040.
2.3 The achievement of this quantum of development has assumed the following:
 retention of listed buildings;
 settings of listed buildings to be defined to avoid ‘substantial harm’;
 no residential or employment development within fluvial flood zones 2 and 3;
 except for the area immediately south of the gas power station (required for bridge crossing the
ECM railway) retention of existing woodlands and belts of trees;
 no development within the County Wildlife Site (CWS);
 no development within easement of 100kv (or greater) high voltage overhead powerlines and
associated pylons;
 storage areas for surface water drainage detention basins currently calculated on a worst case
scenario based on desk based soil assessment;
 multifunctional recreational open space will include, inter alia, areas constrained by the high
pressure gas mains, and high voltage overhead power cables and will encourage healthy lifestyles
through the provision of safe routes to schools for walking and cycling in combination with green
corridors for wildlife;
 the definition of formal recreational open space provision is wider than the narrow definition of
playing pitches and can include trim trails etc (refer to Sport England’s Strategic Outcomes
Planning Guidance, 2019);
 an average residential density of 30-35 dwellings per hectare.
 no development within the inner and middle HSE zones of the high pressure gas main on the east
side of the ECM railway;
 education provision to serve the needs of the new settlement;
 on site provision of schools will share facilities (eg hall, playing fields etc) with the community;
 a site for a supermarket/convenience food retail store (2ha);
facilities commensurate with designation as “local centre: key service centre” and neighbourhood
centres under Policy TC1(S) of the BBLP 2040 and the Town Centres and Shopping Policies Topic
Paper, April 2022;
 subject to arboriculture constraints and livestock considerations, a continuous leisure route
adjacent to the River Great Ouse could be delivered on land within the control of the Alington Estate
(opportunities to create circular loops off this riverside leisure route to connect with St Deny’s
Church could be considered as further assessments are undertaken);
 development on the east side of the ECM railway, greater than circa 300 homes will require a
second point of access.
3 Approach to site capacity
3.1 Technical assessments have established a net developable area, with a full capacity study to be
submitted at an appropriate stage in the preparation of the BBLP 2040. However, a cautious approach
to assessing the dwelling capacity of the site has been taken. We have already netted out from the site
area the following features:
 flood zones 2 and 3;
 CWS;
 existing woodlands;
 areas constrained by high pressure gas mains;
 high voltage overhead electricity cables and associated pylons;
 surface water detention basins;
 schools; and
 a site for a convenience food store.
3.2 In addition to the above, assessments are on-going in relation to two areas to the east of the Barford
Road close to the existing settlement of Little Barford, to determine the extent of the areas within them
that could accommodate development without having an unacceptable effect on heritage assets. Again,
following a cautious approach these areas have, for the purpose of testing the capacity of the site to
deliver new homes, been excluded from the current net developable area. Subject to the conclusions
of the assessments we anticipate further areas to contribute to the provision of new homes.
3.3 Although further reductions to the net developable area are anticipated from the following, a generic
allowance has been made for these by applying a ratio for those elements that are accepted as being
included in and excluded from a ‘net site area’:
 community facilities and local services (in addition to the previously assumed food store);
 bridge structures;
 noise buffers (ECM railway, A428 improvement and gas power plant); and
 biodiversity net gain.
The Executors of the late Nigel Alington
Alington Estate, Little Barford – Representations to Regulation 19 of the BBLP 2040
29 July 2022
Page 5 of 11
3.4 Due to the ratio applied (whilst already having netted out the items in paragraph 3.1 above), it is likely
that the number of new homes achievable from the Little Barford new settlement will increase once a
capacity study and associated masterplan have been prepared. Such an approach provides confidence
at this stage in the preparation of the BBLP 2040 that allocations for at least 4,000 new homes, 4ha of
employment land and the necessary supporting social infrastructure is deliverable. Housing trajectories
will be provided at an appropriate stage in the preparation of the BBLP 2040.
4 Soundness of policy HOU19
4.1 Paragraph 35 of the National Planning Policy Framework (NPPF) states that, “Local plans and spatial
development strategies are examined to assess whether they have been prepared in accordance with
legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s
objectively assessed needs, and is informed by agreements with other authorities, so that unmet
need from neighbouring areas is accommodated where it is practical to do so and is consistent
with achieving sustainable development.
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on
proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on crossboundary
strategic matters that have been dealt with rather than deferred, as evidenced by the
statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustainable development in
accordance with the policies in this Framework.”
4.2 We contend that in broad terms the current wording of Policy HOU19 is sound, however the following
sections consider various elements of the policy wording to assess its robustness in relation to the tests
of soundness but also in relation to its ability to inform and guide a planning application.
5 East West Rail
5.1 The landowner support EWR. However, until there is an announcement on the chosen route, we
consider direct references to it within Policy HOU19 veil the sustainability credentials of the Little Barford
new settlement. Our representations to the Sustainability Appraisal, April 2022 and the Transport
Technical Note that accompany these representations, demonstrate that although the site’s proximity
to EWR was a factor in BBC’s allocation for a new settlement, there are additional reasons (which have
not currently been assessed by BBC in its SA) to justify the site’s selection. Even in the absence of
EWR the location of Little Barford and the extent of land within the ownership of the Alington Estate
means that it still out performs the reasonable alternatives against the SA objectives.
The Executors of the late Nigel Alington
Alington Estate, Little Barford – Representations to Regulation 19 of the BBLP 2040
29 July 2022
Page 6 of 11
5.2 Whilst the modifications we are seeking to Policy HOU19 remove direct reference to EWR, the
replacement wording “sustainable travel nodes” would include EWR.
6 Supplementary Planning Document (masterplan and design code)
6.1 Whilst the principle of a supplementary planning document (SPD) could be supported by the landowner,
it is not justified within BBC’s evidence base. The need for a strategic masterplan, design code and
site/development specific infrastructure delivery plan (IDP) is supported by the landowner. The site is
in a single ownership and will be delivered through the master developer model. The comprehensive
planning and delivery of the site will be achieved through other, more streamlined means that can still
be produced with stakeholder engagement and agreed ahead of or within the site wide planning
application process.
6.2 Furthermore, we contend that the process of preparing and adopting an SPD would fetter the
effectiveness of the plan to deliver the required number of new homes from the site within the plan
period. This element of the policy (and through extension the BBLP 2040) is unsound on the basis that
it does not meet the tests of “justified” or “effective”. The remedy would be for a strategic masterplan,
design code and site/development specific infrastructure delivery plan to be prepared by the master
developer through a series of stakeholder engagement sessions/events and for them to be approved
and conditioned as part of the site wide (outline except for strategic infrastructure) planning permission.
7 Strong local community based approach
7.1 There are different models for successfully managing the assets of the new settlement for the long term
benefit of the community that will be created. There is no justification provided within BBC’s evidence
base that community ownership of assets is a superior model than other examples. It is too early in the
development of the proposals to know which will be the most viable and beneficial to the new
community. This strategic policy should maintain sufficient flexibility that allows for a range of options
to come forward as the details of the proposals are established through later stages of the planning
process.
8 Conservation Area Designation
8.1 The landowner is supportive of the principle of a conservation area designation for an appropriate area
of the site and we are working with the Council in the preparation of suitable evidence to support the
process. However, the process of designating a conservation area is separate from the local plan
process and the delivery of the policy should not be intrinsically linked to the designation of a
conservation area. Development within a conservation area is controlled by the Planning (Listed
Buildings and Conservation Areas) Act 1990 and therefore it should not be necessary to include text in
the allocation policy, Gypsy and Travellers
9.1 The Gypsy and Traveller Accommodation Assessment, November 2021 only identifies the number of
pitches BBC considers are required within the plan period. However, the alternative options for the
number of pitches to be provide or options for how those pitches should be distributed does not appear
to have been assessed through the sustainability appraisal (SA) process. Although paragraph 4.12 of
the BBLP 2040 states that the identified need for additional Gypsy and Traveller pitches and additional
plots for Travelling Show People forms part of the borough’s overall housing need, it is not clear why
alternative options for the selection of allocation sites to include provision has not be subject to SA. We
therefore contend that the inclusion of reference to the provision of pitches for Gypsy and Travellers
and plots for travelling show people within Policy HOU19 is not justified and requires further
consideration by BBC to demonstrate that its strategy is appropriate.
9.2 The associated reference in paragraph 4.13 of the BBLP 2040 to Little Barford (Policy HOU19) should
also be amended to reflect the outcome of further SA.
10 Education
10.1 The landowner supports the onsite provision of new schools to support the development. Education
Facilities Management has reviewed BBC’s evidence base documents supporting the BBLP 2040
where their relate to education. The Education Review, July 2022 submitted with these representations
identifies that the detailed wording within Policy HOU19 is not justified and risks not being effective in
the delivery of the education provision that the new settlement will generate. This representation
suggests modification to the wording of Policy HOU19 to remedy our concerns.
11 Modifications required to Policy HOU19
11.1 The landowner broadly support Policy HOU19 and confirm that a new settlement at Little Barford will
deliver at least 4,000 new homes, circa 4ha of employment land and associated infrastructure to support
a new community. However, modifications are required to ensure robustness against the tests of
soundness and improve the legibility of the policy. To achieve both aspects the following modifications
are required to Policy HOU19.
[see attachment]