Site ID: 413

Showing comments and forms 1 to 2 of 2


Site Assessment Pro Formas

Representation ID: 4381

Received: 31/08/2021

Respondent: Mr Kulwinder Rai

Representation Summary:

The site assessment is factually correct in multiple respects. My comments address these errors.


Site Assessment Pro Formas

Representation ID: 7869

Received: 23/09/2021

Respondent: Mr Kulwinder Rai

Representation Summary:

Your preliminary assessment of site 413 contains numerous factual errors. The site assessment is misleading in multiple respects and less than thorough.

If it is indicative of the standard of accuracy that has been applied to other sites in the Assessment exercise in general, then I suggest that you probably need to go back to the drawing board and start again if the Local Plan 2040 is to maintain any credibility.

Your site 'assessment' assertions...

2c. Potentially able to achieve a net gain in biodiversity?
? Uncertain or insufficient information

Half of the proposed site is a former car park comprising inert hardcore. This does not support any known biology whatsoever so ANY development of residential dwellings here would introduce associated soft landscaping where there is currently none.

This would unquestionably result in a net gain for biodiversity. It is not remotely uncertain...

2d. Able to link into the green infrastructure opportunity network?
Nothing chosen

Actually, the site WILL link into the Green Infrastructure Opportunity network.
I refer you to page 109 of the Bedford Green Infrastructure Plan.

You will note that ‘Figure 31 - Linear access opportunities’ includes a ‘proposed cycle route’ linking Bedford and St Neots. The route runs directly past the site therefore the proposed site IS able to link into the Green Infrastructure Opportunity network.

3a. Proposing a renewable energy scheme or extra energy efficiency standards?
Nothing chosen

I am unsure whether the author of this assessment has even read the application. In my submission I wrote…

'Section 6 Climate Change states:

The council has declared a climate emergency. How the proposal will respond to climate change

All dwellings would be built to the Passivhaus standard, built using the Kingspan TEK Building System. Consequently, they will exceed all the requirements set out for energy efficiency and efficient use of water resources. Because of the low energy requirements of Passivhaus-compliant dwellings all heating requirements will be met from renewable sources (solar panels and air-source heating), as well as a high proportion of energy needs. Each dwelling would be fitted with an external EV charge point.'

Contrary to the assertion that 'nothing' has been chosen, therefore, I have actually PROPOSED a specific renewable energy scheme AND extra energy efficiency standards.

9a. On previously developed land?
x The site is not previously developed land as defined in the NPPF.

Incorrect. Approximately half the site is extant rural residential garden land which qualifies as PDL according to the NPPF. This was independently confirmed by a Planning Inspector in 2018.

9b. On best and most versatile agricultural land ie grades, 1, 2 or 3a?
x All or a majority of the site is best and most versatile agricultural land as defined in the NPPF.

Incorrect. And hilarious. NONE of the proposed site is best and most versatile agricultural land as defined in the NPPF. The Eastern half is a rural residential garden and the western half is a former car park.

Highway comments.
‘There is a bus stop on the other side of the road approximately 70m east from the site entrance.’

Incorrect. The bus stop was moved from the location you describe several years ago. It is now directly opposite the proposed site entrance. Please update your records, they are woefully out of date.

Environmental Health
would consider eastern use

I do not actually understand what this response suggests. Please illuminate me...

I realise that your barking obsession with locating development in the most sustainable locations, not to mention the planning department's long-standing personal beef with myself, means Site 413 hasn't got a cat in hell's chance of being selected, despite the fact that half of it is a car park (and still is despite the Council's frequent assertions that it was returning to nature).

However, the very least that you as a department could do is at least go through the motions in a half accurate manner...