Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 10033

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

SUPPORT

Policy DM7(S) seeks to secure a minimum 10% net environmental gain, which is consistent with the Environment Act 2021. The national 10% biodiversity net gain requirement has not become law yet, but it is likely to be mandatory within the next year or so and would apply to those draft allocations in PSBLP that are adopted.

The Southill Estate owns two parcels of land that are identified as draft allocations in PSBLP: land at Abbey Field West of Elstow site for residential development (Policy HOU 5); and land at Pear Tree Farm Elstow for a science and innovation park (Policy EMP 5). The sites are in agricultural use. The policies for both allocations include requirements that could support net environmental gains as part of the promoted developments. For example, criteria vii of Policy HOU 5 requires an assessment of ecological impacts of the promoted development, and criteria i(d) requires the promoted development to identify opportunities to include green infrastructure and to connect to existing networks. Criteria xi of Policy EMP 5 requires the submission of a wildlife and habitat survey with mitigation and enhancement measures for the promoted development, criteria vii requires the promoted development to include a green corridor, and criteria vi requires a contribution to the Forest of Marston Vale through tree planting on the site.

It is considered that the draft allocations at Abbey Field West of Elstow and at Pear Tree Farm Elstow would contribute towards the delivery of environmental net gains. Policy DM7(S) is supported and no changes are required.

Comment

Representation ID: 10034

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

olicy DM5(S) requires developments of +100 dwellings to include plots for self and custom build housing, with the amount subject to negotiation. It is agreed that the amount of self and custom build plots provided should be subject to negotiation and assessed on a site by site basis. The Southill Estate owns land for two draft allocation, one for residential development (Policy HOU 5) and the other for a science and innovation park (Policy EMP 5). There is an inter-relationship between the two developments, with the delivery of the economic benefits associated with the science and innovation park supported by the delivery of residential development. There may need to be some flexibility about the delivery of self and custom build plots in this case. These issues would be addressed at masterplan and planning application stage.

Comment

Representation ID: 10035

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Policy DM3(S) seeks to ensure that a mix of house types and sizes are delivered at developments to meet identified needs. The Southill Estate owns land at the Abbey Field West of Elstow site that is a draft allocation for residential development (Policy HOU 5). Criteria ii of Policy HOU 5 also requires that a mix of house types are sizes are provided from this allocation. The promoted development would provide a mix of house types and sizes. As set out in the Southill Estate’s representations to Policy DM1(S), there is potential for a proportion of the housing within this promoted development to be retained specifically for employees at the science and innovation park allocation at Pear Tree Farm. This approach would provide an additional type of housing not mentioned in Policy DM3(S). The housing mix for the promoted development at Abbey Fields West of Elstow would be determined at masterplan and planning application stage.

Comment

Representation ID: 10036

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Policy DM1(S) sets out the policy requirements for affordable housing. The Southill Estate owns land at the Abbey Field West of Elstow site that is a draft allocation for residential development (Policy HOU 5), and land at the Pear Tree Farm Elstow site for a science and innovation park (Policy EMP 5). The sites are adjacent to one another, and there is an inter-relationship between the two developments because of the common landownership. There may need to be some flexibility towards affordable housing in order to deliver the economic benefits associated with the science and innovation park. In addition, there is potential for a proportion of the housing to be retained specifically for employees at the science and innovation park, which could affect the overall supply of affordable housing. These issues would be addressed at masterplan and planning application stage.

Support

Representation ID: 10037

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Paragraph 4.77 sets out the Vison for the South of Bedford Area. Policy HOU 12 sets out the policy requirements for the Area. Figure 5 defines the boundary of the Area. The Southill Estate owns land at Pear Tree Farm Elstow, which is identified as a draft allocation for a science and innovation park (Policy EMP 5) and the site falls within the South of Bedford Area. The Pear Tree Farm site is identified for a high value science and innovation park, primarily research and development with elements of manufacturing, warehousing and distribution.

In summary, the South of Bedford Area is based on an environment led approach to development, and includes green infrastructure, access by sustainable modes of transport including rail, delivery of existing and proposed new settlements, and employment. The South of Bedford Area is consistent with Paragraphs 105 and 106 of the NPPF, in terms of directing significant development to locations that are or can be made sustainable, supporting the delivery of sustainable modes of transport, and providing a mix of uses including housing, employment and green infrastructure.

The draft allocation for a science and innovation park at the Pear Tree Farm site would contribute directly towards the vision for the South of Bedford Area, including by delivering employment, support for Forest of Marston Vale, and green infrastructure.
The South of Bedford Area is supported, and no changes are required to Policy HOU 12.

Object

Representation ID: 10038

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Southill Estate owns the land at Pear Tree Farm Elstow, and supports the draft allocation for a science and innovation park and agrees with the policy requirements for the promoted development. The draft allocation is on a smaller parcel of land that is allocated for the same use in the adopted Allocations & Designations Local Plan (Site Ref. AD11 – Land at Medbury Farm). The adopted allocation has already been assessed as sound, and it is proposed that the science and innovation park use is carried forward in PSBLP with a slightly smaller site area. The site is consistent with the spatial strategy and distribution strategy contained in PSBLP, and with the policy for the South of Bedford Area. The site is also consistent with national policy contained in the NPPF, in terms of supporting economic growth, meeting employment needs and the specific needs for high technology industries, the preferred location for strategic development, and accessibility by sustainable modes of transport.

Figure 10 provides the supporting site location plan for Policy EMP 5. An updated Bedford Innovation Campus Indicative Masterplan Document has been prepared for the promoted development at Pear Tree Farm (and the promoted residential development at Abbey Field West of Elstow allocation, also owned by the Southill Estate). The updated Masterplan Document includes a Concept Masterplan for the promoted development. It is requested that Figure 10 is amended to reflect the site area and Concept Masterplan in the updated Masterplan Document. It is amendments to Figure 10 that is the only basis for the Southill Estate’s objection to Policy EMP 5.

The decision to allocate the Pear Tree Farm site has been informed by the Economic Growth Ambitions Topic Paper, and the assessment of the site against selection criteria and constraints in the Employment Land Study Part 2, and the assessment of the site against sustainability objectives in the Sustainability Appraisal Report.

The Economic Growth Ambitions Topic Paper provides information on the ambitions in PSBLP to rebalance the local economy, with less reliance on Class B8 warehouse and distribution uses and an increase in higher value added jobs. The proposed allocation for a high value science and innovation park would meet the ambitions to rebalance the local economy.

The land at Pear Tree Farm (identified as land at Medbury Farm) is assessed against suitability criteria in the Employment Land Study Part 2 – see pg.41. It is recommended in the Study that the site is retained as an employment allocation.

The site was assessed against sustainability objectives in the Sustainability Appraisal Report and Appendices – see SA Appendix pg. 210 to 212. The Southill Estate’s representations to the Sustainability Appraisal comment in more detail on the findings of the assessment, and request changes to the scores for some sustainability objectives. In summary, negative effects are identified for biodiversity and habitats, historic environment, support for physical activity, and previously developed land. Policy EMP 5 includes policy requirements to address impacts on biodiversity and the historic environment and ensure that mitigation measures are provided as part of the promoted development. It is not normal for employment development to include land for recreational activities, but the promoted development would be accessible by walking and cycling and would connect with a green corridor. The identified development needs for PSBLP will require both previously developed land and greenfield sites. The medium and longer term impacts on biodiversity and habitats, and on the historic environment should be changed to neutral or positive because of the policy requirements in Policy EMP 5 for effective mitigation measures to be implemented as part of the promoted development.

A Landscape and Visual Statement has previously been prepared for the site. In summary, the site and surrounding area is a landscape where commercial and industrial buildings are a common feature. The site is visually and physically connected to the A6 junction with the A421. There is dense vegetation on the edge of settlements and around more recent developments to address landscape and visual impacts. It is recommended in the Report that buildings of a similar size and scale to those in the surrounding area could be provided at the site. It should be noted that Policy EMP 5 includes policy requirements for a masterplan and design codes to be submitted with a planning application (criteria i) and for the design of the promoted development to respect local landscape priorities including views of Elstow Abbey and separation from Elstow village (criteria iii). As such, there are policy requirements to assess landscape and visual impacts at planning application stage once more detailed information is provided on the design and layout of the promoted development.

An updated Bedford Innovation Campus Indicative Masterplan Document has been prepared for the promoted development. This confirms that the site’s developers and landowners will continue to work proactively with Bedford Borough Council to bring forward the development of the site for employment purposes. This includes a commitment to meet the emerging policy requirements set out by policy EMP5.

It is requested that Figure 10, which provides the supporting site location plan for Policy EMP 5, is amended to include additional details of the promoted development as contained in the Concept Masterplan in the updated Masterplan Document.

In conclusion, the Southill Estate supports the draft allocation for science and innovation park and agrees with the policy requirements for the promoted development. No changes are required to Policy EMP 5, but Figure 10 could be updated.

Object

Representation ID: 10039

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Southill Estate owns the land at Abbey Field West of Elstow, and supports the draft allocation for residential development and agrees with the policy requirements for the promoted development. The decision to allocate the land has been informed by the assessment of the site against selection criteria and constraints in the Housing and Employment Land Availability Assessment and Site Assessments, and in the assessment of the site against sustainability objectives in the Sustainability Appraisal Report. The site is consistent with the spatial strategy and distribution strategy contained in PSBLP. The site is also consistent with national policy contained in the NPPF, in terms of the preferred location for strategic development and accessibility by sustainable modes of transport.
A Heritage Impact Assessment has been prepared for the site to assess the impacts on heritage assets and set out mitigation and enhancement measures to address those impacts; the Assessment was submitted with the Southill Estate’s representations at Draft Local Plan stage in Summer 2021. An updated Bedford Innovation Campus Indicative Masterplan Document is submitted with these representations.

A more detailed commentary on these matters is provided below.

Policy HOU 5 identifies a number of key principles for the promoted development, which are included to ensure a high quality scheme and that the opportunities associated with the location of the site are delivered, and to ensure that significant constraints are addressed. For example, there are policy requirements relating to heritage assets, open space, green infrastructure, noise pollution, housing mix, access arrangements, pedestrian and cycle connections, education contributions, archaeology, flood risk, ecology, climate change, and water infrastructure. These policy requirements have been informed by the findings of the site assessment process.

The policy requirements in Policy HOU 5 are consistent with national policy contained in the NPPF. For example, there are sections of the NPPF that address housing (Section 5), communities (Section 8), sustainable transport (Section 9), design (Section 12), climate change and flooding (Section 14), natural environment (Section 15), and historic environment (Section 16).

The site was assessed in the Housing and Employment Land Availability Assessment and Site Assessments (Site Ref. 638). The site assessment identified potential constraints associated with nature conservation, heritage assets, and noise. The assessment identifies uncertain impacts for protected species, biodiversity net gain, agricultural land, and flood risk. The assessment includes detailed commentary on highway, transport and access matters. Policy HOU 5 include policy requirements for nature conservation (criteria vii), heritage (criteria i(a), and noise (criteria i(d). The policy requires an assessment of ecology, flood risk and drainage, and transport to support a planning application. In addition, there is a policy requirement for a masterplan and design code to be submitted with a planning application. Policy DM7 of PSBLP provides the general policy for biodiversity net gain that applies to all major developments, including the promoted development at HOU 5.

The site was assessed against sustainability objectives in the Sustainability Appraisal Report and Appendices – see SA Appendix pg. 174 to 175. The Southill Estate’s representations to the Sustainability Appraisal comment in more detail on the findings of the assessment, and request changes to the scores for some sustainability objectives. In summary, negative effects are identified for biodiversity and habitats, historic environment, previously developed land, and community services and facilities. Policy HOU 5 includes policy requirements to address impacts on biodiversity and the historic environment and ensure that mitigation measures are provided as part of the promoted development. The promoted development would provide pedestrian and cycle connections to enable residents to access the services and facilities available in the surrounding area. The identified development needs for PSBLP will require both previously developed land and greenfield sites. The medium and longer term impacts on biodiversity and habitats, historic environment, and services and facilities should be changed to neutral or positive because of the policy requirements in Policy HOU 5 for effective mitigation measures to be implemented as part of the promoted development.

A Heritage Impact Assessment has been prepared for the site to address impacts on heritage assets. In summary, it is concluded in the Assessment that the draft site allocation would change the wider rural setting of Elstow Conservation Area, the Parish Church of St Mary and St Helena, Church Tower, and the Elstow Manor House Scheduled Monument including Hillersden Mansion. This change would result in no more than a minor adverse impact to their wider rural setting and would have no impact on the immediate setting of the assets. The impact on the wider rural setting of these designated heritage assets would amount to less than substantial harm to the significance of these assets. The conclusion of the Assessment demonstrates that in terms of impacts on heritage assets it would be appropriate to allocate the site in PSBLP. In any event, there is a policy requirement to assess heritage impacts at planning application stage once more detailed information is provided on the design and layout of the promoted development.

An updated Bedford Innovation Campus Indicative Masterplan Document has been prepared for the promoted development. This confirms that the site’s developers and landowners will continue to work proactively with Bedford Borough Council to bring forward the residential development of the site. This includes a commitment to meet the emerging policy requirements set out by policy HOU5.

It is noted that Policy HOU 5 does not specify the number of dwellings that could be accommodated within the draft allocation, which is an approach that is consistent with other strategic allocations. This site is included in the housing trajectory for 200 dwellings – see Appendix 1 in Stepped Trajectory Topic Paper April 2022. It is considered that the promoted development could accommodate more dwellings (approximately 400 dwellings) by increasing the density while still meeting all of the policy requirements. This is not a requested change to Policy HOU 5, but an adjustment is required to the housing trajectory for PSBLP.

In conclusion, the Southill Estate supports the draft allocation for residential development and agrees with the policy requirements for the promoted development. No changes are required to Policy HOU 5, but site capacity referred to in the housing trajectory should be increased to approximately 400 dwellings.

Support

Representation ID: 10040

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Policy DS5(S) specifies the amount of housing and employment development directed to different locations within the plan area. The two parcels of land owned by the Southill Estate and identified as draft allocations, on land at Abbey Field West of Elstow (Policy HOU 5) and land at Pear Tree Farm Elstow (Policy EMP 5), are consistent with the proposed distribution strategy. The Abbey Field West of Elstow site falls within the urban area. The Pear Tree Farm Elstow site falls within a strategic location adjacent to the urban area. The proposed distribution is consistent with Paragraph 105 of the NPPF, which expects the planning system to actively manage patterns of growth to support the delivery of sustainable transport objectives, with significant development directed to locations that are or can be made sustainable.

As set out in the Southill Estate’s representations to Policy HOU 5, the Abbey Field West of Elstow site could accommodate more dwellings than currently indicated in the housing trajectory. It is requested that the number of dwellings proposed for the urban area within Policy DS5(S) is increased to reflect the additional dwellings that could be delivered from the Abbey Field West of Elstow site i.e. an additional approximately 200 dwellings (and a total of approximately 400 dwellings).

It is noted that the proposed science and innovation park allocation at Pear Tree Farm Elstow is excluded from the employment land figures in Policy DS5(S) on the basis that as an existing employment allocation it is categorised as a commitment. The draft allocation at the Pear Tree Farm site (Policy EMP 5) is slightly smaller than the adopted allocation at Medbury Farm (Site Ref. AD11), and it is proposed in PSBLP that Policy EMP 5 would replace Site Ref. AD11. It is suggested that, for clarity and for future monitoring purposes, the land at Pear Tree Farm should be included within the employment land figures for Policy DS5(S) i.e. within the figures for the strategic locations adjacent to the urban area.

The proposed distribution strategy in Policy DS5(S) is supported. It is requested that proposed number of dwellings for the urban area is adjusted to include additional dwellings at the Abbey Field West of Elstow site, and that the employment land figures for the strategic locations adjacent to the urban area includes the Pear Tree Farm site.

Support

Representation ID: 10041

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Policy DS4(S) seeks to deliver an additional 26,700 jobs, in order to create a high value and high skilled economy. The Economic Growth Ambitions Topic Paper provides information on the ambitions in PSBLP to rebalance the local economy, with less reliance on Class B8 warehouse and distribution uses and an increase in higher value added jobs. The Bedford Employment Land Study identifies the need and demand for employment land between 2020 and 2040, and assesses the sites that should be allocated to meet the employment land supply. The Southill Estate owns the land at Pear Tree Farm Elstow that is within a larger allocated site for a science and innovation park in the adopted Allocations & Designations Local Plan (Site Ref. AD11 – Land at Medbury Farm), and it is proposed that this site is carried forward as a smaller draft allocation in PSBLP (Policy EMP 5 – Land at Pear Tree Farm). Paragraph 9.11 of the Employment Land Study Part 1 identifies the characteristics of potential employment land allocations, including having few constraints, an ability to accommodate flexible building types, providing connections to technology and communications infrastructure, and having good market visibility and proximity to an employment cluster. The land at Pear Tree Farm (identified as land at Medbury Farm) is assessed against suitability criteria in the Employment Land Study Part 2 – see pg.41. It is recommended in the Study that the site is retained as an employment allocation.

Section 6 of the NPPF provides national planning policy for the economy. Paragraph 81 provides support for economic growth and productivity. Paragraph 82 expects planning policies for economic development to include the following: to encourage sustainable economic growth; to identify strategic sites for inward investment to meet anticipated needs; to address potential barriers to investment including inadequate infrastructure; and to be flexible to meet future needs. Paragraph 83 expects planning policies to address the specific locational requirements of different sectors, including high technology industries. Policy DS4(S) of PSBLP is consistent with national policy, in that it is based on an assessment of employment land needs and demand, it supports economic growth, it seeks to meet the needs for higher value jobs, and specifically allocates land for research and development employment uses including at the Pear Tree Farm site.

Policy DS4(S) is supported, and no changes are required.

Object

Representation ID: 10042

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The proposed housing requirement in PSBLP is a minimum of 27,100 dwellings between 2020 and 2040. A stepped trajectory is proposed with more significant growth proposed in the post-2030 period once critical infrastructure has been delivered. The Southill Estate does not object to the proposed housing requirement or the principle of applying a stepped trajectory. The Southill Estate owns the land at Abbey Field West of Elstow that is identified as a draft allocation for residential development (Policy HOU 5). This site is included in the housing trajectory for 200 dwellings and it is predicted that housing delivery would commence from 2030/31 – see Appendix 1 in Stepped Trajectory Topic Paper April 2022. As set out in the Southill Estate’s representations to Policy HOU 5, the site could accommodate more dwellings and could be delivered much earlier than currently indicated in the housing trajectory. It is requested that the housing trajectory is adjusted to include additional dwellings and an earlier delivery date from the site. This requested change would mean that additional dwellings could be delivered in the period 2025/26 to 2029/30.

Paragraph 74 of the NPPF requires a housing trajectory to be provided for development plans, setting out the expected rate of housing delivery during the plan period and if appropriate the delivery rates for specific sites. The housing trajectory for PSBLP should be included within the document, and not only shown in the Stepped Trajectory Topic Paper.