Holme Farm, Biggleswade - Planning Design Delivery Analysis Report [EXAM 108-108D]

Showing comments and forms 1 to 7 of 7

Comment

Holme Farm, Biggleswade - Planning Design Delivery Analysis Report [EXAM 108-108D]

Representation ID: 14528

Received: 12/08/2020

Respondent: BRCC

Representation:

Commenting on behalf of Beds RCC and the Biggleswade Green Wheel Development Group.
The provision of a Bridle-bridge over the A1 and bridleway links to the Green Wheel should be planning conditions.
The landscape buffer zones, the ‘potential ecological park’ and the corridors carrying the Green Wheel and PRoW should be landscaped with locally appropriate native planting. The ‘potential ecological park’ should be a planning condition and both it and the Plot 5 Proposed Ecological Mitigation Area should provide public access.
We request an opportunity to be involved in planning and implementing the woodland expansion at Holme Green (Plot 5).

A02
P02
Comments relating to Rights of Way/ Bridleway and potential Ecology Park

Full text:

I am submitting the following comments on behalf of Bedfordshire Rural Communities Charity and the Biggleswade Green Wheel Development Group.
The provision of a Bridle-bridge over the A1 and bridleway links to the Green Wheel are welcomed and should be planning conditions. Should the development be granted planning permission, we request that the Biggleswade Green Wheel Development Group and CBC's area Rights of Way Officer are involved in determining path and structure specifications
The landscape buffer zones, the ‘potential ecological park’ and the corridors carrying the Green Wheel and PRoW should be landscaped with locally appropriate native planting. The ‘potential ecological park’ should be a planning condition (ie a firm commitment and not just a 'potential' feature. This ecological park and the Plot 5 Proposed Ecological Mitigation Area should provide public access and be recognised as part of the Biggleswade Green Wheel corridor. We request that BRCC's Ecologist is invited to inform detailed plans for these habitats. Furthermore, we request that BRCC and the Friends of Biggleswade Green Wheel are involved in the creations of these habitats.

Object

Holme Farm, Biggleswade - Planning Design Delivery Analysis Report [EXAM 108-108D]

Representation ID: 14546

Received: 12/08/2020

Respondent: BRCC

Representation:

We request that ambiguous wording in relation features impacting upon the Biggleswade Green Wheel are clarified and made planning conditions.
A bridge over the A1 carrying a Public Bridleway and linking to the wider PRoW and Biggleswade Green Wheel network must be a planning condition.
Other features - as detailed in the full response - should be firm commitments/ conditions and not simply 'proposed' or 'potential'.

A02
P07
Concern over use of wording.

Change suggested by respondent:

The wording of the plan needs to change to make the above features firm commitments/ conditions and not simply 'proposed' or 'potential'.

Full text:

These comments re submitted on behalf of Bedfordshire Rural Communities Charity and the Biggleswade Green Wheel Development Group.
We are objecting to the wording of certain aspects of the proposed plans; not the plan as a whole.

The Landscape Strategy Map, Dwg No. - A249 LA01on Page 174 uses the terms 'proposed' and 'potential' and we would ask that these are committed to at this stage.
While the specific location for the proposed green wheel bridge can be determined at a later date, we ask that the provision of the bridge is not simply 'proposed' but is a planning condition. The proposed bridge over the A1 is referred to through the plan variously as a 'Green Wheel Bridge' and a 'Footbridge'. To remove any doubt, this bridge - must carry a Public Bridleway to cater for pedestrians, cyclists and horse riders - the legitimate user groups of the Green Wheel. Such a bridge in this vicinity is a key component on the CBC-Adopted Biggleswade Green Wheel Masterplan and must be provided as part of this development. A new Public Bridleway linking the bridge to the Green Wheel routes to the west of the development site should also be a planning condition.

The 'proposed minimum 40m landscape buffer zones' should also be planning conditions - both the provision of the buffer zones and the minimum 40m width.
The wording of the 'potential ecological park location' is ambiguous - is the location of the park 'potential' or is the park itself 'potential'?

Figure 1 - B10495-AEW-XX-XX-DR-A-0015 on Page 186 identifies Plot 6 as 'Proposed Ecological Mitigation Area'. Given the scale of the development and the impact upon the local landscape, the enhancement of this plot as an extension to Holme Green Woodland should be a planning condition.


There is a fear that with ambiguous wording and a lack of commitment, any/ all of the above features could be removed from future planning applications.

Object

Holme Farm, Biggleswade - Planning Design Delivery Analysis Report [EXAM 108-108D]

Representation ID: 14552

Received: 12/08/2020

Respondent: Barnack Estates

Agent: DLA Town Planning Ltd

Representation:

The Inspectors have raised significant concerns in relation to the Council’s proposed employment allocation at Holme Farm, Biggleswade. The Council has reassessed the Holme Farm site against a potential alternative on the east side of the A1. However, there are other reasonable alternatives available, such as land at Hill Farm, Biggleswade and this should be considered,
either in addition to or instead of the Holme Farm site.

The Council’s updated evidence points to a clear need for more employment space, particularly for Small and Medium-size Enterprises. The Council’s proposal to repurpose some of the land at the Holme Farm for local economic growth is not supported and the allocation of land at Hill Farm for local economic growth should be taken forward instead.

A02
P07
propose alternative site.

Change suggested by respondent:

Land at Hill Farm, Biggleswade should be included in the LocalPlan, either instead of or as well as the Council’s proposed allocations

Full text:

See attachments

Comment

Holme Farm, Biggleswade - Planning Design Delivery Analysis Report [EXAM 108-108D]

Representation ID: 14566

Received: 12/08/2020

Respondent: Historic England

Representation:

A02
P02
Previously agreed policy wording from Statement of Common Ground not included in the policy. For policy to be sound, please reinstate agreed wording.

Full text:

See attachment

Attachments:

Object

Holme Farm, Biggleswade - Planning Design Delivery Analysis Report [EXAM 108-108D]

Representation ID: 14592

Received: 12/08/2020

Respondent: Hallam Land Management

Agent: Carter Jonas LLP

Representation:

A02
P07
The PDDA and LVIA assessments are inadequate. No consideration of the impacts from expansive views across the site.

Change suggested by respondent:

The proposed allocation at Holme Farm Biggleswade would have substantial adverse landscape and visual effects. The landscape evidence that has informed the decision to allocate the site is not robust. The site is not well related to Bigglewade and strategic employment in this location would not encourage travel by sustainable modes of transport, despite the proposed, potentially undeliverable footbridge and limited shuttle bus service.

It is requested that the proposed strategic employment allocation at Holme Farm Biggleswade is deleted.

Full text:

The Inspectors raised concerns about the findings of the Sustainability Appraisal for this site in terms of accessibility by sustainable modes of transport (see Para 11 of EXAM 69) and the potential landscape impact of development and the separation of the site from Biggleswade (see Paras 68 to 72 of EXAM 69)
EXAM 108 includes a range of additional evidence that seeks to address the Inspectors concerns comprising property market analysis, an access strategy, a landscape and visual analysis, and revised masterplan. It is proposed that additional landscaping would be provided and building heights would be limited to address landscape and visual impacts. It is proposed that a pedestrian bridge over the A1 would be provided to connect to Stratton Business Park, and a shuttle bus service would be provided to connect the site with Biggleswade Town Centre and Railway Station.
It is not mentioned in EXAM 108 but Central Bedfordshire Council owns the land at the Holme Farm Biggleswade allocation and we are genuinely concerned that this may be distorting the Council’s approach to this patently unsustainable and unsuitable proposal.
Hallam Land Management has instructed FPCR to assess the additional landscape evidence. The FPCR technical note is submitted with these representations, and a summary of the findings is provided below.

Landscape Comments
EXAM 108 does not address the Inspectors concerns regarding the potential significant landscape and visual impact impacts resulting from the proposed development. FPCR have identified deficiencies and inconsistencies in the LVIA presented within EXAM 108. The landscape visuals contained in EXAM 108 are from selective viewpoints that do not provide the detail required to assess the impacts in the surrounding landscape.
In terms of the baseline analysis, the landscape character assessment lacks an understanding of the site and its relationship to the wider Ivel Valley landscape and to the adjacent settlement edge of Biggleswade. The visual appraisal does not acknowledge any aspects of the site as being notable for its visual qualities. There is no appreciation of the expansive views across the Ivel Valley afforded by this open flat low lying arable landscape. Consequently, in terms of landscape character and visual resources EXAM 108 has undervalued the role of the site and its immediate context, and the potential impacts of the proposed development.
It is unlikely that the proposed development could be assimilated within the Ivel Valley landscape without resulting in long term adverse effects upon the landscape and visual resources. FPCR’s appraisal of the EXAM 108 does not alter the conclusions of the 2018 Landscape and Visual appraisal (Land at Biggleswade, Bedfordshire Landscape Appraisal).
In addition, the proposed transport improvements to the employment allocation include a pedestrian bridge over the A1. The visual impact of the footbridge should have been included in the landscape assessment.

Transport/Accessibility Comments
The site allocation Policy SE3: A1 Corridor - Holme Farm Biggleswade is located on the western side of the A1, which means it is not currently well connected to the existing employment uses at Stratton Business Park nor the services and facilities within Biggleswade, including the railway station and public transport services. The site was assessed in the Full Strategic Employment Site Assessment (Doc Ref. F02) – see Appendix F Site Ref. NLP437. The findings of the site assessment highlight the poor relationship between the site and Biggleswade – see Assessment Topic Nos. 20 to 22. The previous assessment has not been updated for EXAM 108.
The post-examination modifications to Policy SE3 include policy requirements for a pedestrian footbridge, walking and cycling connections, and a shuttle bus service. However, it is not certain whether the footbridge is deliverable or the transport measures would be effective and overcome the isolated and extremely poorly connected locational characteristics of this proposed allocation.
It is proposed that the pedestrian footbridge over the A1 would connect with Stratton Business Park. It is not stated whether there is any landowner agreement for a pedestrian bridge to be access from the eastern side of the A1 within Stratton Business Park. The cost of the pedestrian bridge and who would pay for it is also not stated, but it is likely to be expensive and may deter potential developers and occupiers. In the absence of landowner agreement and the significant potential costs, the delivery of the pedestrian bridge is not certain. The proposed strategy to make the site accessible by walking and cycling would be undermined if the pedestrian bridge cannot be provided.
It is proposed that the development would include a shuttle bus service to connect the site with Biggleswade, including the town centre and railway station. It is proposed that the service would be delivered by one full size single deck bus with a seating capacity of 46 passengers. It is proposed that the service would operate a half hourly service, on weekdays and weekends, during the following hours: 05:30 to 09:45; 12:15 to 13:45; 13:45 to 20:00; and, 21:00 to 22:30. It appears that the proposed shuttle bus service is limited, particularly as the service is delivered by a single vehicle, and may be inadequate for the amount of employment development proposed. It is highly unlikely that the proposed shuttle bus service would encourage access by public transport or deter travel by private car.
If, as expected, the proposed strategic employment development at Holme Farm Biggleswade fails to encourage travel by sustainable modes of transport it would be inconsistent with Paragraphs 30 and 32 of the 2012 NPPF.

Comment

Holme Farm, Biggleswade - Planning Design Delivery Analysis Report [EXAM 108-108D]

Representation ID: 14775

Received: 12/08/2020

Respondent: Denison Investments Ltd

Agent: Arrow Planning

Representation:

A01
P10

LVIA does not adequately assess proposals

Full text:

Please see attached representation statement. The representations identify the following matters, which are
expanded upon within:
i. The failure of the Council to assess in the SA the option of allocating a higher amount of strategic warehousing land to meet footloose regional demand;
ii. The failure of the Council to correctly assess land east of the A1, Biggleswade, despite recognition from the Inspectors that this should take place;
iii. The failure of the SA to assess the correct site area for the land west of the A1, Biggleswade;
iv. Concerns with the proposed increase in size of the Holme Farm allocation and the resultant landscape and visual impacts which directly contradict the criticisms raised by the Inspectors in their September letter;
v. The lack of a holistic approach taken at Holme Farm with the allocation focused on land owned by the Council, but excluding additional land that is contiguous with the A1;
vi. The lack of accessibility to Holme Farm, particularly when considered against the reasonable alternatives;
vii. Whether the proposed infrastructure improvements to make the Holme Farm site accessible are viable and deliverable.
The Inspectors letter of 30th September 2019 very clearly set out a number of areas of significant concern, and that had led to the view that the Plan is not sound. Having reviewed the additional work prepared by the Council, we consider that a number of areas of concern specifically identified by the Inspectors have still not been addressed either at all, or sufficiently to overcome those concerns.
In summary, the additional work:
viii. Still fails to assess the proposed expansion of Stratton Business Park as put forward at the Regulation 19 stage (Inspectors letter para 10);
ix. Fails to test the reasonable alternative employment scenarios, as it does not test an option meeting a higher footloose regional demand for strategic warehousing in line with past trends;
x. Relies on a SA that is still incorrect in respect of Sustainable Transport for land west of the A1 (Inspectors letter para 11);
xi. Has not assessed the increased site area for land west of Biggleswade in the SA;
xii. Does not adequately address the landscape and visual impacts of the proposed allocation SE3 at Holme Farm (Inspectors letter paras 70-72);
xiii. Fails to appropriately assess the proposed shuttle bus and footbridge to serve allocation SE3;
xiv. Does not demonstrate a sustainable and suitable access strategy for Allocation SE3 and still would not be conducive to walking or cycling (Inspectors letter para
11).
The proposed allocation SE3 Holme Farm should therefore be deleted and a full assessment carried out of the land south and east of Stratton Business Park. It is likely, that this would then replace the Holme Farm allocation as a more logical and appropriate employment allocation along the A1 corridor.

Object

Holme Farm, Biggleswade - Planning Design Delivery Analysis Report [EXAM 108-108D]

Representation ID: 14809

Received: 12/08/2020

Respondent: Hallam Land Management

Agent: Carter Jonas LLP

Representation:

Object to Holme Farm

Full text:

EXAM 112 provides the Councils response to the Inspectors concerns about the strategic employment allocations, including Policy SE2: M1 Junction 13 - Marston Gate Expansion (Section 6.4) and Policy SE32: A1 Corridor – Holme Farm Biggleswade (Section 6.5). EXAM 112 includes proposed modifications to the strategic employment allocations. Paragraph 6.2.11 of EXAM 112 includes commentary on alternative strategic employment sites that have been assessed including land at Winterwoods Farm Brogborough (promoted by Hallam Land Management).
EXAM 112 highlights the demand for B8 sites in Central Bedfordshire, and it is considered that this demand should be met within the M1 Corridoir which is the preferred location for occupiers.
Section 6.4 – Policy SE2: Marston Gate Expansion
In Section 6.4 the Council seeks to respond to the Inspectors concerns with the proposed allocation Policy SE2: M1 Junction 13 - Marston Gate Expansion, and to explain the outcome of the additional evidence and proposed modifications.
The Hallam Land Management representations to EXAM 106 comment in detail on the additional evidence and proposed modifications.
In summary, EXAM 106 does not address the Inspectors concerns regarding the significant visual impact of the mass, size and type of development proposed on the surrounding network of public footpaths (including the iconic Greensand Ridge Walk and John Bunyan Trail) and local landscape character. The viewpoints included in EXAM 106 are selective and do not consider views from the north east. Therefore, the proposed site allocation Policy SE2: Marston Gate Expansion, including the proposed modifications, would still result in substantial adverse landscape and visual effects including long term harm upon the setting of the Greensand Ridge and historic villages.
EXAM 106 does not assess the long term adverse effects that the modified parameters plan would have upon the existing landscape and visual resources and there is a woeful omission of key views from the NE along and close to the named trails and footpaths. Therefore, the landscape evidence provided in EXAM 106 is not robust and does not support the proposed site allocation Policy SE2: Marston Gate Expansion, and a decision to allocate this site would not be justified or consistent with national guidance.
The proposed modifications in EXAM 106 to address heritage impacts have not removed the harmful effects on designated heritage assets about which HE has such understandable concern, given the extraordinary linear reach and spread of the Marston Gate proposal across the landscape .
Section 6.5 – Policy SE3: Holme Farm Biggleswade
In Section 6.5 the Council seeks to respond to the Inspectors concerns with the proposed allocation Policy SE3: Holme Farm Biggleswade, and to explain the outcome of the additional evidence and proposed modifications.
The Hallam Land Management representations to EXAM 108 comment in detail on the additional evidence and proposed modifications. It also voices its concern that the Council’s ownership of this site may have distorted its assessment , given that it is so patently unsustainable and unsuitable for the proposed development.
In summary, the proposed allocation at Holme Farm Biggleswade would have substantial adverse landscape and visual effects. The landscape evidence that has informed the decision to allocate the site is not robust. The site is not well related to Bigglewade and strategic employment in this location would not encourage travel by sustainable modes of transport, despite the proposed footbridge and shuttle bus service.
Section 6.2 – Supplementary Sustainability Appraisal
Paragraph 6.2.11 in Section 6.2 identifies alternative strategic employment sites that have been assessed but not allocated. Hallam Land Management has promoted land at Winterwoods Farm Brogborough at M1 Junction 13 for strategic employment; the site was assessed in the Full Strategic Employment Site Assessments - Ref. NLP178.
As set out below, the assessment and scores in the Supplementary Sustainability Appraisal are flawed for some sites, which has resulted in sites being scored incorrectly and inappropriate sites with more significant impacts from being allocated.
The Hallam Land Management representations to emerging CBLP requested amendments to the site assessment for Winterwoods Farm and that this site should be allocated as a strategic employment site; those representations relate to Section 7.7 of emerging CBLP - see Rep Id. 9807. In particular, the representations highlighted some incorrect commentary in the site assessment, including on distance to nearest railway station (Criteria 22), landscape character (Criteria 27), and heritage/archaeology (Criteria 28). The incorrect scoring of Winterwoods Farm is a recurring theme in the Supplementary Sustainability Appraisal. The representations referred to the findings of reports submitted in support of a planning application on 2016.
The representations on distance to nearest railway station, landscape character and heritage/archaeology are restated below:
• 22 (Distance to nearest train station): The site is approximately 1km from Ridgmont Station. As set out in the planning application, the proposed development would enhance the footway and cycleway connections, providing links to an existing bridleway and also to Ridgmont Station. We note that the site is one of the few Class B8 employment sites in Central Bedfordshire which benefits from close proximity to a railway station, and this fact should be acknowledged in the assessment of the site. It is requested that the score for this criteria is amended to ‘A for Amber’.
• 27 (Landscape character): A landscape and visual impact assessment of the proposed development was undertaken for the current planning application. A meeting was held to discuss the response to the application from the Council’s Landscape Officer and as a result revisions to the scheme have recently been submitted to address concerns. The site is not covered by any local or national landscape quality designations. The site and surrounding area lies within the Forest of Marston Vale and the proposed development provides an opportunity to increase woodland coverage in accordance with strategic objectives for the area. A high quality design strategy has been prepared for the proposed development. The landscape and visual effects can be minimised through the proposed comprehensive package of design and mitigation measures. The green infrastructure framework will ensure that the proposed development would be well integrated within the local landscape, and would deliver a range of environmental enhancements. An attractive ‘gateway’ entrance feature is proposed along Salford Road and designed to be sympathetic to its rural aspect. The proposed development would not result in significant adverse visual effects within the wider landscape including upon settlements such as Hulcote or Salford, or upon the public rights of way network such as the Greensand Ridge Walk or John Bunyan Trail. It is requested that the score for this criteria is changed to ‘G for Green’.
• 28 (Heritage/Archaeology): An assessment of heritage and archaeology was undertaken for the planning application to identify the significance and potential impact of the proposed development on heritage assets. The Assessment confirms that the proposed development lies outside of the setting of Brook Farm House. The Assessment acknowledges that there could be unrecorded archaeological remains present within the Application Site, and recommends that a condition is attached requiring a programme of archaeological evaluation to be undertaken. It is requested that the score for this criteria is changed to ‘G for Green’.
It is clear from the above that Winterwoods Farm is a sustainable option for strategic employment, and scores better than Martston Gate Expansion in key sustainability criteria. There are no technical constraints to development at the site. The proposed development would enhance the footway and cycleway connections, providing links to an existing bridleway and also to Ridgmont Station to encourage travel by these modes of transport. There is no reason to reject the site on landscape grounds and the proposed development includes substantial areas of green infrastructure and substantial woodland planting to address any potential landscape impacts.
Therefore, the decision to reject the land at Winterwoods Farm for strategic employment development is not justified because the evidence contained in the assessment of the site is not robust.
An alternative strategic employment site located in the vicinity of J13 is available (land at Winterwoods Farm at Brogborough) has far fewer harmful impacts on landscape and heritage assets compared with the allocation at Marston Gate Expansion.