Question 12

It is not considered that existing planning polices fail to cover important national or local issues on the protection and enhancement of the natural environment.

It is not considered that existing planning polices fail to cover important national or local issues on the protection and enhancement of the natural environment.

It is not considered that existing planning polices fail to cover important national or local issues on the protection and enhancement of the natural environment.

It is not considered that existing planning polices fail to cover important national or local issues on the protection and enhancement of the natural environment.

It is not considered that existing planning polices fail to cover important national or local issues on the protection and enhancement of the natural environment.

BBC should consider the use of strategic multifunctional green infrastructure sites that other development could contribute towards. Each strategic Suitable Alternative Natural Greenspace (SANGs) would have a carrying capacity in relation to the quantum of development it could support. The land to the west of sites AL1, AL2 and AL3 has been included as part of Lower Great Ouse River Valley, Zone 3 of Policy AD24 Green Infrastructure Opportunity Zones in the Allocations Land Designations Local Plan (2013). However, there is currently limited public access. Opportunities to secure this through the allocation of AL3 would be considered by the Executors of the late Nigel Alington.

We must continue to pursue carbon reduction with better recycling (which does not mean burning it!) and promotion of renewables. Current policy totally fails the natural environment as BBC is too often led by the nose by developers and their short and long term financial gain. More consideration should be made to promoting emotional health and wellbeing by protecting and enhancing our natural environment-the River Ouse and the green open spaces and by avoiding high density low cost housing. Small settlements should be excluded from development as most are neither ‘Key’ nor ‘Rural’ service centres. Most will also be very rural and adjacent to countryside. Locally valued landscapes should be protected and enhanced-not built on.

12.1 Our client welcomes updates to the technical work relating to environmental policies. Each site being promoted through the Local Plan will be subject to a planning application where more detailed assessments will be possible when the exact proposals are known. It is therefore vital that technical and environmental constraints are considered on a site by site basis, with any environmental evidence produced in support of the Local Plan forming the background to the research that is undertaken as part of the planning application process. 12.2 The existing policies that seek to protect and enhance the natural environment are considered adequate to guide development away from the most sensitive areas and are therefore considered appropriate.

13.1 Our client welcomes updates to the technical work relating to environmental policies. Each site being promoted through the Local Plan will be subject to a planning application where more detailed assessments will be possible when the exact proposals are known. It is therefore vital that technical and environmental constraints are considered on a site by site basis, with any environmental evidence produced in support of the Local Plan forming the background to the research that is undertaken as part of the planning application process. 13.2 The existing policies that seek to protect and enhance the natural environment are considered adequate to guide development away from the most sensitive areas and are therefore considered appropriate.

No

Street-lighting is too bright and could also be turned off after a certain time in the night. Larger gardens in any new developments.

13.1 The Council’s stated intention to update its evidence base in relation to environmental sustainability, open space and Green Infrastructure is supported. It was noted during the Examination of the Local Plan 2030 that neither the Council’s evidence base nor the strategy to defer site allocations to Neighbourhood Plans would ensure that these objectives would be met in full. There are various examples of sites previously assessed as part of the plan-making process that were identified as preferred allocation options and would contribute towards the Plan’s objectives for the natural environment but have not since been supported as allocations through the development plan (i.e. through the Local Plan 2030 or subsequent Neighbourhood Plans). 13.2 In updating its evidence base the Council should seek to ensure that the development plan brings forward allocations that satisfy future requirements for growth e.g. additional opportunities for sport and recreation. This is not achieved through the Local Plan 2030 where requirements are identified but meeting these is deferred to Neighbourhood Plans. There is a strong prospect that some Neighbourhood Plans will not deliver the type and location of sites that would secure optimum Green Infrastructure enhancements. 13.3 Where any requirements remain unmet, solutions should be clearly set out via the policies and allocations of the Local Plan Review. Specific allocations should be supported, particularly where this align with the Council’s spatial strategy and objectives for sustainable development and would provide for the additional requirement for housing growth in the period to 2030 and beyond. In this context, allocations to meet housing needs in full and deliver other priorities (such as Green Infrastructure) should not be deferred to the review of Neighbourhood Plans. 13.4 It is essential that the Council’s Infrastructure Delivery Plan (most recent version dated December 2018) is updated to reflect the requirements of further evidence, once available. This would address issues with the evidence for the Local Plan 2030 where the range of projects identified are typically non-specific with uncertainty over future funding to be provided by CIL/S106, given that allocations are not yet provided through the development plan. The lack of specific projects in rural areas does not reflect the overall priorities for development in the spatial strategy and demonstrates that aspects of the evidence base in relation to Green Infrastructure do not fully reflect the contents of the submission Local Plan. i) Land South of Odell Road, Sharnbrook and Land at Station Road, Oakley 13.5 Updates to the Council’s evidence base, including that relating to open space and playing pitches, would be welcomed as part of the Review of the Local Plan 2030. It was noted during the Examination of the Local Plan 2030 that the 2007 Open Space, Sports and Recreation Study (2007) was substantially dated and insufficient to fully assess requirements to be met as a result of future growth. 13.6 In relation to our client’s interests on Land East of Station Road, Oakley, the settlement is noted as being located in the ‘North Rural West’ parishes. The Lovell Road Sports Pitches are recorded as site ‘Oak8’ and acknowledged as ‘education playing fields’. Figure 4.19 records the surplus/deficit of supply and demand for pitches excluding school pitches and shows a substantial shortfall for the North Rural West parishes. However, one recommendation of the study is the future development and S106 obligations secure community use for facilities, citing Lincroft School as one example of this. 13.7 The existing use and management of the sports pitches available to specific groups and local teams on request therefore makes an important contribution to the deficit in supply identified in the OSSRS. However, this must be interpreted within the overall requirements of the BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 35 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission school itself, including increased pupil numbers and demand for the facilities. 13.8 Our client would therefore support a review of the current position to reassess the ongoing deficit in provision and seek to address this as part of the Review of the Local Plan 2030. This can be achieved as part of allocation of the Land East of Station Road for development to facilitate the relocation and enhancement of the existing Lincroft Academy Sports Pitches in order to support opportunities to deliver wide community benefits. 13.9 The Council has been provided with further evidence of our client’s land at Sharnbrook (School Approach / east of Odell Road), supported by a Landscape and Green Infrastructure Strategy. This demonstrates the availability of a suitable opportunity for delivery of relevant policy objectives through provision of a minimum 25ha of land to be managed for ecology and riverside park as well as opportunities to provide formal open space and playing pitch facilities. The proposed approach provides the ability to secure net gains in biodiversity and management of the relationship with the Felmersham Gravel Pits Site of Special Scientific Interest and areas of Flood Risk to the south of the site.

13.1 The Council’s stated intention to update its evidence base in relation to environmental sustainability, open space and Green Infrastructure is supported. It was noted during the Examination of the Local Plan 2030 that neither the Council’s evidence base nor the strategy to defer site allocations to Neighbourhood Plans would ensure that these objectives would be met in full. There are various examples of sites previously assessed as part of the plan-making process that were identified as preferred allocation options and would contribute towards the Plan’s objectives for the natural environment but have not since been supported as allocations through the development plan (i.e. through the Local Plan 2030 or subsequent Neighbourhood Plans. 13.2 In updating its evidence base the Council should seek to ensure that the development plan brings forward allocations that satisfy future requirements for growth e.g. additional opportunities for sport and recreation. This is not achieved through the Local Plan 2030 where requirements are identified but meeting these is deferred to Neighbourhood Plans. There is a strong prospect that some Neighbourhood Plans will not deliver the type and location of sites that would secure optimum Green Infrastructure enhancements. 13.3 Where any requirements remain unmet, solutions should be clearly set out via the policies and allocations of the Local Plan Review. Specific allocations should be supported, particularly where this align with the Council’s spatial strategy and objectives for sustainable development and would provide for the additional requirement for housing growth in the period to 2030 and beyond. In this context, allocations to meet housing needs in full and deliver other priorities (such as Green Infrastructure) should not be deferred to the review of Neighbourhood Plans. 13.4 It is essential that the Council’s Infrastructure Delivery Plan (most recent version dated December 2018) is updated to reflect the requirements of further evidence, once available. This would address issues with the evidence for the Local Plan 2030 where the range of projects identified are typically non-specific with uncertainty over future funding to be provided by CIL/S106, given that allocations are not yet provided through the development plan. The lack of specific projects in rural areas does not reflect the overall priorities for development in the spatial strategy and demonstrates that aspects of the evidence base in relation to Green Infrastructure do not fully reflect the contents of the submission Local Plan. i) Land at Willoughby Park, Great Barford 13.5 One such example is our client’s interests at Great Barford, which comprise land in single ownership supported by a comprehensive Masterplan, where allocation as part of the Local Plan Review would ensure delivery of opportunities towards the Plan’s objectives. The Masterplan proposals reflect a landscape-led approach to accommodating development within the site. The context for assessment has evolved since the Council’s previous 2017 Assessment of Site Options. 13.6 The Masterplan proposals for the Willoughby Park site and by extension the reduced 100-unit option are both supported by a landscape assessment that reflects key features within the site. Specifically, the proposed 24ha Countryside Park would address the Council’s previous site assessment conclusions regarding how a defensible northern boundary might be established for the site, with this area incorporating substantial opportunities for landscaping, open space and recreation and ecological enhancement. This extends to the layout of the site’s frontage with Roxton Road, incorporating areas for a community orchard and green infrastructure enhancement together with areas for attenuation as informed by a drainage assessment prepare to inform the Masterplan. BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 32 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 13.7 The Council’s identified A421 Corridor spatial option recognises opportunities to enhance Green Infrastructure in this location (specifically referencing the Marston Vale Community Forest). We believe this should be emphasised by a review of the Council’s 2009 Green Infrastructure Study. 13.8 Of particular relevance in terms of the 2009 Study are opportunities to extend the ‘Green Wheel’ north and east of Bedford to connect Great Barford and Roxton. Green infrastructure improvements in this area would also enable an extension of the Bedford River Valley Park and might be associated with delivery of community greenspace in the village. The Council’s Sustainability Appraisal Scoping Report also notes the Lower Great Ouse Valley Green Infrastructure Opportunity Zone as relevant to the Plan’s objectives. 13.9 Comprehensive development of our client’s land north of Roxton Road 500 dwellings and open space would ensure that the objectives of the submission Local Plan are achieved. This comprehensive development would deliver areas of open space, play space and amenity areas; and support delivery of areas for habitat and landscape improvements/creation alongside the delivery of 500 dwellings in the plan period. 13.10 Material prepared as part of undertaking community consultation with local residents in April 2019 reiterates the ability to make provision for a Countryside Park (approximately 24ha) and other wildlife and green space enhancements funded by the development. Evidence for the concept scheme illustrates that this will be provided on the northern edge of the village. This will incorporate the public bridleway and existing footpaths within the site, providing connections to the countryside beyond the A421. 13.11 The Countryside Park itself would follow the existing public bridleway (BW24) and provide an attractive area for recreation; exercising, dog walking etc. It would also provide an extensive area for biodiversity habitat creation and woodland planting. North of the proposed Countryside Park, existing Rights of Way also link to countryside beyond the A421 and represent opportunities for wider landscape connections and links to further green infrastructure corridors east of Renhold. 13.12 Connectivity to the new development and wider Great Barford village could be provided by footpath 20 which follows the route of the brook. Additional green infrastructure and footpath links are shown through the proposed developed area itself, adding important connections to the countryside and a green lung for the development.

We must continue to pursue carbon reduction with better recycling (which does not mean burning it!) and promotion of renewables. Current policy totally fails the natural environment as BBC is too often led by the nose by developers and their short and long term financial gain. More consideration should be made to promoting emotional health and wellbeing by protecting and enhancing our natural environment-the River Ouse and the green open spaces and by avoiding high density low cost housing. Small settlements should be excluded from development as most are neither ‘Key’ nor ‘Rural’ service centres. Most will also be very rural and adjacent to countryside. Locally valued landscapes should be protected and enhanced-not built on.

See answer to question one on 10% net biodiversity gain.

We note that you are planning to update the Landscape Character Assessment as part of the evidence base which is welcomed. Please ensure that your Historic Landscape Characterisation is up-to-date.

Currently, policy inhibits any housing growth beyond in the rural area which is not planned for as part of Neighbourhood Plans. Together, the implementation of a Settlement Policy Area which restricts rural growth and the increasingly limited options for growth within the Bedford and Kempston urban area lead to situation wherein currently adopted policies, unintentionally or otherwise, fail to sufficiently accommodate growth in a manner that is commensurate with Paragraph 170 of the NPPF. Paragraph 170(a) states that Planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils. Paragraph 170(b) requires that those policies and decisions recognize the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland. The terminology used above is very clear in that non-valued landscapes should not be protected and instead be recognized. A number of policies across the country which have come into conflict with the NPPF for blanket protection of the countryside have been ruled inconsistent with Paragraph 170(b) for this reason. Whilst this many not be the case here, it is evident nonetheless, that the scope within which one can bring forward development to enhance the vitality and wellbeing of local communities is extremely limited despite the sustainability credential of some of the more major rural settlements in the Borough. Certainly, windfall sites should they come forward never intend to compete with allocated / Neighbourhood Plan sites. They provide housing growth in addition the minimum levels of growth that the Borough must deliver and, where they constitute sustainable development, they often fall foul of very technical considerations such as Settlement Policy Area. Whilst relevant for considering when specific policies (such as Policy 7S) may come in to play for applications and proposals, it has had the inadvertent consequence of severely restricting levels of growth that may be in line with Paragraph 170(b), but will fail to completely account for other policies, to include that of Paragraphs 77 and 78 on rural growth which do not specify that an identified need (as set out in Policy 7S0 is required to ensure rural vitality. This is particularly so when this Council must duly take account the planned levels of growth for the Borough due to revisions in Standard Methodology; issues with affordability; the Ox-Cam Arc; and even the specific context within with this Government views proposals that boost the supply of housing even when authorities demonstrate a 5YHLS. These are all matters expanded on below.

1.45. It is not considered that current policies are failing in this regard.

Currently, policy inhibits any housing growth beyond in the rural area which is not planned for as part of Neighbourhood Plans. Together, the implementation of a Settlement Policy Area which restricts rural growth and the increasingly limited options for growth within the Bedford and Kempston urban area lead to situation wherein currently adopted policies, unintentionally or otherwise, fail to sufficiently accommodate growth in a manner that is commensurate with Paragraph 170 of the NPPF. Paragraph 170(a) states that Planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils. Paragraph 170(b) requires that those policies and decisions recognize the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland. The terminology used above is very clear in that non-valued landscapes should not be protected and instead be recognized. A number of policies across the country which have come into conflict with the NPPF for blanket protection of the countryside have been ruled inconsistent with Paragraph 170(b) for this reason. Whilst this many not be the case here, it is evident nonetheless, that the scope within which one can bring forward development to enhance the vitality and wellbeing of local communities is extremely limited despite the sustainability credential of some of the more major rural settlements in the Borough. Certainly, windfall sites should they come forward never intend to compete with allocated / Neighbourhood Plan sites. They provide housing growth in addition the minimum levels of growth that the Borough must deliver and, where they constitute sustainable development, they often fall foul of very technical considerations such as Settlement Policy Area. Whilst relevant for considering when specific policies (such as Policy 7S) may come in to play for applications and proposals, it has had the inadvertent consequence of severely restricting levels of growth that may be in line with Paragraph 170(b), but will fail to completely account for other policies, to include that of Paragraphs 77 and 78 on rural growth which do not specify that an identified need (as set out in Policy 7S0 is required to ensure rural vitality. This is particularly so when this Council must duly take account the planned levels of growth for the Borough due to revisions in Standard Methodology; issues with affordability; the Ox-Cam Arc; and even the specific context within with this Government views proposals that boost the supply of housing even when authorities demonstrate a 5YHLS. These are all matters expanded on below.

1.43. It is not considered that current policies are failing in this regard.

1.32. It is not considered that current policies are failing in this regard.

1.32. It is respectfully submitted that there are some policies within the current plan such as AD43 ‘Open Space Gaps’ that are no longer consistent with National Policies and are not required in the review plan.

2.21 MGH understands the importance of protecting the natural environment and recognises that any updated Local Plan policies will need to take account of the enacted requirements being proposed in the Environment Bill. Notwithstanding this, the costs of any policy requirements need to be fully considered in the Council’s viability study to ensure that development across the Borough remains deliverable.

12.1 O&H have no comment.

The 2014 Landscape Character Assessment is too generalised to allow proper assessment of the impact of development on sensitive landscapes. More finely grained assessment (through landscape sensitivity studies) is required across the Borough, and the outputs should be reflected in policy so as to allow locally valued landscapes to be protected and enhanced. Green Infrastructure Studies should be encouraged (mandated?) for Neighbourhood Plans in order to capture local priorities and to fully understand local traditions and historical context.

13.1 Our client welcomes updates to the technical work relating to environmental policies. Each site being promoted through the Local Plan will be subject to a planning application where more detailed assessments will be possible when the exact proposals are known. It is therefore vital that technical and environmental constraints are considered on a site by site basis, with any environmental evidence produced in support of the Local Plan forming the background to the research that is undertaken as part of the planning application process. 13.2 The existing policies that seek to protect and enhance the natural environment are considered adequate to guide development away from the most sensitive areas and are therefore considered appropriate.

12.1 Our client welcomes updates to the technical work relating to environmental policies. Each site being promoted through the Local Plan will be subject to a planning application where more detailed assessments will be possible when the exact proposals are known. It is therefore vital that technical and environmental constraints are considered on a site by site basis, with any environmental evidence produced in support of the Local Plan forming the background to the research that is undertaken as part of the planning application process. 12.2 The existing policies that seek to protect and enhance the natural environment are considered adequate to guide development away from the most sensitive areas and are therefore considered appropriate.

Choice of building materials appears to be fairly loose, with new housing developments typically standing out very starkly against the environment rather than blending in, eg use of synthetic slate or nontraditional (to the locality) brick colours.

The approach to the natural environment in any updated local plan will clearly need to take account of the enacted requirements being proposed in the Environment Bill. It will be important that the costs of any requirements are fully considered in the Council’s viability study to ensure that development across the Borough remains deliverable. Some more general comments on regarding whole plan viability studies are outlined below. Viability The 2019 National Planning Policy Framework (NPPF) requires development viability to be resolved through the local plan and not at the planning application stage. The aim of this approach is to ensure that, as outlined in paragraph 57 of the NPPF, decision makers can assume that development which is in conformity with the local plan is viable and to, ultimately, reduce the amount of site by site negotiation that takes place. As such it will be important that the Council’s approach to its viability assessment and the costs it places on development are cautious to take account of the variability in delivering the range of sites that will come forward through the local plan. To support local planning authorities in preparing their viability evidence the HBF has prepared a briefing note, attached to this response, which sets out some common concerns with viability testing of local plans under the latest guidance and how these should be addressed. Whilst this note focuses on all aspects of the viability testing of the residential development and should be taken into account, we would like to highlight four particular issues with whole plan viability assessments. The first issue is with regard to the approach taken to abnormal infrastructure costs. These are the costs above base construction and external costs that are required to ensure the site is deliverable. Prior to the 2019 NPPF viability assessments have taken the approach that these cannot be quantified and were addressed through the site by site negotiation. However, this option is now significantly restricted by paragraph 57 of the 2019 NPPF. As such these abnormal costs must be factored into whole plan viability assessments. We recognise that the very nature of an abnormal costs is difficult to quantify, but it is a fact that they are often substantial and can have a significant impact on viability. Where and how these costs arise is also variable. They can occur in site preparation but can also arise with regard to the increasing costs of delivering infrastructure, such as upgrades to increase the capacity of utilities. It is also the case that abnormal costs are higher on brownfield sites where there can be a higher degree of uncertainty as to the nature of the site and the work required to make it developable. Whilst we recognise that abnormal costs are expected to come off the land value, we are concerned that if abnormal costs are high then it will result in sites not being developed as the land value will be insufficient to incentivise the landowner to sell. It is therefore important that a significant buffer is included within the viability assessment to take account of these costs if the Council are to state with certainty that those sites allocated in the plan will come forward without negotiation. Secondly, we would encourage the Council to use the upper end of any of the ranges suggested with regards to fees and profit margins. Again, these will vary from developer to developer but given that the Government want to minimise negotiation on planning obligations it would make sense to use the highest point of any range. The changing landscape with regard to viability assessment could lead to development slowing significantly if the correct variables are not taken into account. Thirdly, the council must ensure that all the policy costs associated with the local plan are included within the viability assessment. Whilst affordable housing and infrastructure contributions for the majority of the additional costs that are placed on developers by the Council it is important that the cumulative impact of all policies are tested. With regard to the local plan review the Council will need to consider the impact of its proposed policies on self-build, open space, bio-diversity net gains, electric vehicle charging, sustainable design and construction; and renewable energy. Finally, the approach to land values needs to be a balanced approach and one that recognises that there will be a point at which land will just not come forward if values are too low to take account of policy and infrastructure costs. There are a variety of reasons why a landowner is looking to sell their land and it cannot be assumed that they will absorb significant reductions in land values to meet policy costs. Land is a long-term investment and the returns being offered must take account of this. Conclusion We hope these representations are of assistance in taking the plan forward. Should you require any further clarification on the issues raised in this representation please contact me.

Pavenham Parish Council is content with the current policies in the Local Plan designed to protect the natural environment – provided, as noted in the Parish Council’s answers to a number of earlier questions in this Consultation Paper, the Council actually observes them. There is ever increasing pressure on our natural environment and the Parish Council will be very interested to see how the Borough Council intends to respond to the White Paper – Planning for the Future, bearing in mind its proposals for “zoning” and the introduction of “Growth”, “Renewal”, and “Protected” areas -effectively designed to act as a fast track to planning permission. That said, the Parish Council does think that the Council should be a little more flexible in supporting Parish Councils which in their Neighbourhood Plans, wish to protect open green spaces which may not necessarily align with the strict thresholds detailed in the NPPF.