Full text:
Comments
Section 4.2 Local Policy
Local Plan Policy HQ1 'sets the requirements for high quality design and encourages proposals that’:
Bullet Point 2:
'Make the most efficient use of the land available through careful consideration of density, whilst reflecting the character of the local area and providing appropriate landscaping.’
Comment: ‘Appropriate landscaping’ is very vague and subjective. This needs to be strengthened to convey to Developers that a few street tress and the odd piece of grass will not suffice. Landscaping suggests a means of softening the built environment, whereas the emphasis should be on providing usable and sustainable habitat.
Bullet Point 4:
‘…….. and soft landscaping that seeks to increase biodiversity.’
Comment: ’Soft Landscaping’ can mean many things to many people. It is the site as a whole that needs to be seen to increase biodiversity. I am happy that Central Beds have produced the Biodiversity Net Gain (BNG) document and have already adopted the 10% target that is expected to become legal this year. Within that document (para 2.1.1) there is a commitment to increase biodiversity across the whole authority area. The document also states (para 2.1.2) that BNG is an approach to development and/or land management that delivers measurable improvements for biodiversity by creating or enhancing habitats. For avoidance of doubt, similar phraseology should be used within the SPD. In addition, the creation or enhancement of habitats should not be restricted to within the site boundary, but any adjoining land where such creation or enhancement would benefit biodiversity.
Section 5.4 Landscape Connections
Comment: Much has been made of the landscape character of Central beds, but the danger is placing too much emphasis on these isolated pockets. There needs to be greater effort to create meaningful corridors to link them. Mere tree planting within new development will not suffice. There seems to be more importance attached to the visual aspect of tree planting, for example from 5.4.1 ‘landscape design needs to ensure development fits in visually with the character of the surrounding landscape’. Stress should be placed on development landscaping being of sufficient quality and breadth to act as a meaningful corridor for nature. Much is made of the Chiltern Area of Outstanding Natural Beauty, however, whilst it undoubtedly looks scenic, without specific habitat improvement it plays a less than meaningful contribution to biodiversity. There needs to be (if there isn’t already) a strategic plan to enhance biodiversity, as they have in hand at the South Downs National Park.
Section 7.8 Street Trees
Comment: Again too much emphasis is placed on the visual contribution of street trees. One might dispute the contention that trees slow surface water run off. Placed within a street environment dominated by impermeable surfacing the effect is likely to be negligible. In isolation street trees alone will not form long term sustainable habitats and corridors for biodiversity. They will possibly aid movement to a certain extent, but are unlikely to offer a significant contribution.
Section 8 Nature
Comment: I find this whole section weak and insufficiently challenging or adventurous.
Section 8.11.1 Biodiversity opportunity networks have been identified and mapped (BRMC - Beds and Luton LERC)
Comment: These are out of date and need to updated to be of any real use or to attach any real reliability to. Rebuilding Biodiversity in mid Beds dates back to 2008, which is 15 years old. As we all know the decline in biodiversity has not slowed down over this time and the inclusion of data from 2008 provides a false picture of the current situation. For example, Fig 2 of that document shows ‘important Farmland Species’. This will have undoubtedly changed in the last 15 years with drastic declines in all those species mentioned. Grey Partridge and Tree Sparrow, to name but two, have virtually disappeared altogether from this area. New guidance should not be based on an evidential document, which is at best out of date and at worst completely erroneous.
Comment: For a section purporting to be referencing ’Nature” there are very few positive actions proposed. Density requirements in residential developments should not deny the opportunity to increase spacing and enhance garden size. There should be an inherent requirement for Developers to provide planting schemes to benefit nature in all types of development proposals and to provide associated educational literature in marketing strategies. Community gardens and/or wild flower meadows of a useful size should be a minimum requirement of larger developments together with an on going maintenance plan.
Section 10.12 Key Design Principles for Schools
Comment: Education facilities should have built in environmental facilites to enable children to learn about nature by positive interaction. Access to nature rich habitat should be available within all school grounds and the teaching of environmental studies should feature within the normal curriculum.
Section 11 Homes and Buildings
Comment: With more focus on the maintenance of older buildings the scope for swifts to nest in small nooks and crannies has reduced in the past few years. This can be easily remedied by placing a duty on developers to provide ’swift boxes’ particularly in residential developments. Similarly, with garden fencing, suitable gaps should be left as a ’nature highway’ for hedgehogs and the like.
General Point:
The designation of arable land as Green belt is a complete misnomer. There is nothing ‘green’ about huge expanses of nature sterile farmland. This land (or a proportion of it) would be better served being released for ecologically friendly development, with an associated duty placed on the Developer to form a substantial buffer zone for nature around the edge of the development site. This would more properly act as an easily identifiable and readily defensible zone. This would provide the links necessary between the nature corridors within the development and the existing habitats outside.
4.2Local
Policy4.2.1This
Design Guide provides guidance to support many of the policies within the adopted Local Plan. Policy HQ1:
High Quality Development
is an all-encompassing policy that sets the requirements for high quality design in
Central Bedfordshire.
It encourages proposals that:►Take
account of opportunities to enhance or reinforce local distinctiveness, including the landscape
setting and character,
to create a sense of place, and relate well to existing local surroundings through size, scale, massing,
orientation, materials and appearance.►Make
the most efficient use of the land available through careful consideration of density, whilst
reflecting the
character of the local area and providing appropriate landscaping. ►Provide
safe, attractive and convenient routes which are well connected to the surrounding areas,
and the landscape
setting, encouraging travel by sustainable modes, meeting the needs of all users
and promoting healthy
lifestyles. ►Integrate
into the existing natural, built and historic environment through high quality hard and
soft landscaping
which seeks to increase biodiversity and green infrastructure and has a strong distinction between private
and public space. Bullet Point 2: .2
Lcal Policy4.2.1This
Design Guide provides guidance to support many of the policies within the adopted Local Plan. Policy HQ1:
High Quality Development
is an all-encompassing policy that sets the requirements for high quality design in
Central Bedfordshire.
It encourages proposals that:►Take
account of opportunities to enhance or reinforce local distinctiveness, including the landscape
setting and character,
to create a sense of place, and relate well to existing local surroundings through size, scale, massing,
orientation, materials and appearance.►Make
the most efficient use of the land available through careful consideration of density, whilst
reflecting the
character of the local area and providing appropriate landscaping. ►Provide
safe, attractive and convenient routes which are well connected to the surrounding areas,
and the landscape
setting, encouraging travel by sustainable modes, meeting the needs of all users
and promoting healthy
lifestyles. ►Integrate
into the existing natural, built and historic environment through high quality hard and
soft landscaping
which seeks to increase biodiversity and green infrastructure and has a strong distinction between private
and public space.
