Comment

Representation ID: 16233

Received: 15/03/2023

Respondent: Greensand Trust

5.1.4: We welcome reference to Greensand Country but suggest this also references the ‘Greensand Ridge NIA’.
• 5.2 (Landscape Context) – we welcome reference to the Greensand Ridge and Greensand Country. However, this section should be accompanied by a map illustrating the location and extent of the various areas in the context of Central Bedfordshire, reinforcing the significance to Central Bedfordshire of the Greensand Country area. The map on the page below does not serve this purpose.
• 5.2.4 recognises the number of Registered Parks and Gardens in Central Bedfordshire. It should be noted that, for historical reasons, many of these are located within the Greensand Country area, which has a distinct sense of place in no small part as a result of this. It should be noted that, for historical reasons, many of these are located within the Greensand Country area. These Registered Parks and Gardens, along with other non-designated historic landscapes, strongly contribute to the area’s distinct sense of place.
• We welcome reference to Greensand Country and the Greensand Ridge in 5.28 onwards, but the text is dated and does not reflect the current picture (we recognize that it is difficult to keep anything like this ‘current’). Reference should be made to:
o The fact that a 5 year programme of National Lottery Heritage Fund supported activity has completed, but a strong partnership continues to operate, led by the Greensand Trust (no longer led by BRCC and the Greensand Trust). The Partnership is working to a ‘Forward Plan’, guiding our work over the next 5 years and including themes relating to the landscape, habitats, built heritage and the rural economy. The emphasis in the text should be on the Forward Plan, area focus and long-established partnership working (pre-dating the Lottery funding), rather than on the Lottery-funded programme. It is this desire to work in partnership to protect and enhance the area that is important, and has continued over a long period.
o The area is the same as that of both the Greensand Ridge NIA and NCA90 (National Character Area 90 – Wooded Greensand Ridge).
o Significant research has been carried out, including more detailed Landscape Character Assessment, Historic Environment Characterization, a Parkland Audit and assessment and a Sandstone Structures Audit. All of these reports are available at www.greensandcountry.com and provide a significant resource to help inform sensitive development.
• The boundary illustrated as the “Authority Boundary” in Figure 4 (LCAs) is incorrect – it shows the Bedfordshire boundary, not the Central Bedfordshire boundary.
• 5.4.2 references the Central Bedfordshire Green and Blue Infrastructure Strategy. It is difficult to comment on the interface between this and the Design Guide because the G&B Infrastructure Strategy has not been published.
• 5.4.2 (and 4.1.1 in the introduction) should also reference the Natural England Green Infrastructure Framework (2023) and ensure that the principles within it are adopted within the relevant sections of this document.
• 5.21.1 – consideration should be brought to include the non-listed features that contribute to the historic setting of the building (e.g. sandstone boundary walls).
• 5.30.1 – 5.30.4 – this section needs to mirror 5.34.7, linking the presence and significance of historic designed landscapes back to overall landscape character (significantly contributing to the sense of place in Central Bedfordshire, not just Greensand Country, and as highlighted through the Greensand Country LCA and Parkland Audit), rather than just mentioning that they are numerous.
• 5.39 – Appraising a Site and its Setting – Table 1 (Natural Environment Appraisal) asks the question of whether watercourses are to be retained and incorporated (in development). This is not an option, and the culverting or diversion of watercourses should be avoided in all instances as this results in the loss of natural form and function, negatively impacts biodiversity and can increase flood risk. The question should be about how the form, function, aesthetic and biodiversity value of any watercourse will be enhanced through development, including its wider setting.
• 5.9.5 should be altered to include sandstone walls as a key boundary feature
• Figures 9 and 10 need to include coursed and uncoursed sandstone as well as coping.
• 5.35.2 – a less desk-based approach to encourage heritage statements to include some experience of the site itself should be pursued, allowing the appreciation of views, vistas and the wider setting.

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