Comment

Representation ID: 16235

Received: 15/03/2023

Respondent: Greensand Trust

8.1 – We welcome the statement that “nature must take a stronghold in the design process from the outset” but this needs clearer explanation of what is meant/required.
• Additionally, this sentiment expressed in 8.1 is not followed through in this section. Better reference should be made to:
o Priority habitats within Central Bedfordshire and their distribution
o The importance of integrating natural habitats within development, enhancing them and improving connectivity between the.
o The importance of providing opportunities for people to engage with nature close to where they live, contributing to health and wellbeing.
o The forthcoming Local Nature Recovery Strategies and the principles behind Nature Recovery (e.g. Bigger, Better, More and Joined-Up – Lawton 2010)
• 8.1.3 should also reference resources available via the Greensand Country website (www.greensandcountry.com/resources), and the Natural Capital Planning documents available via the Bedfordshire LNP website (https://bedfordshirenaturally.com/downloads/)
• 8.2.5 makes reference to the Central Bedfordshire Green and Blue Infrastructure Strategy, but as this has not been published yet it is impossible to comment on this section. If the G&B Infrastructure Plan is not published at the time of this Design Guide being adopted then reference should be made to the existing suite of GI Plans covering the area as interim guidance. Text from 8.2.6 should be used here. As a stand alone paragraph, 8.2.6 has the potential to create confusion with 8.2.5 and reference to the G&B Infrastructure Strategy.
• Where reference to the Bedfordshire LNP website is made a link needs to be included (www.bedfordshirenaturally.com)
• Additionally, reference should be made to the Natural England GI Framework, and to ‘parish level’ GI Plans, especially where these have been produced as part of a Neighbourhood Plan.
• 8.6.6 – sandstone boundary walls can also be a suitable boundary treatment where appropriate. This paragraph/section needs clarifying, as it lists hedging as preferential to fencing, but does not explain walling despite picturing it.
• Reinforcing Local Distinctiveness (8.6.10 onwards) should make reference to the work on sense of place and local distinctiveness carried out by the Greensand Country Landscape Partnership through its Landscape Character Assessment and Historic Environment Characterisation, available via www.greensandcountry.com/resources.
• 8.6.7 (Planting) should also reinforce the principle of ‘Right Tree Right Place’ to ensure inappropriate species are not used, and to ensure that trees/woodland are not planted where other habitat types may be a priority. This principle also needs to be embedded in 8.9.4
• 8.8.1 – Management and Maintenance – it is essential that the need to establish sustainable natural habitat management is conveyed so that interest is not lost over time.
• 8.9.2 – reference to Central Bedfordshire being ‘lightly wooded’ (<10%) does not reflect the fact that the Greensand Ridge contains a significant proportion of its woodland (especially ancient woodland). This must be highlighted to ensure opportunities to better buffer and connect ancient woodland are optimized and not lost. Historically development has been allowed, through poor design, too close to ancient woodlands, harming them and permanently losing opportunities for enhancement. The Greensand Country website (www.greensandcountry.com/resources) includes guidance around key habitat types (woodland, grassland and heathland) in Central Bedfordshire.
• 8.9.5 – The statement that CBC’s Heritage Trees are “mostly confined to ancient oak” is completely incorrect. The Greensand Country Landscape Partnership has created a ‘Heritage Tree Trail’ across the area, in association with the National Tree Register, which highlights and interprets a range of different heritage trees of several different species across Central Bedfordshire (and beyond). It is recommended that (a) this paragraph is updated with the National Tree Register, and (b) that imagery from the Heritage Tree Trail is included within the photographs (please contact daniel@greensandcountry.com).
• Figure 221 (LCAs) displays the county boundary, not the C Beds boundary, as noted above.
• 8.11.7 (Design Principles) – While we agree with the sentiment, we feel that the wording here is clumsy. This paragraph should set out that we should seek to enhance the biodiversity value of all green spaces in and around developments, including more formal greenspaces.
• 8.11.12 – We welcome reference to Biodiversity Opportunity Networks. This should include reference to ‘Re-building Bedfordshire’s Biodiversity’, the forthcoming Local Nature Recovery Strategy and Greensand Ridge NIA Policy (EE8).
• 8.11.14 should reference LP Policy EE8 (Greensand Ridge NIA) alongside Policy EE2.
• 8.11.14 – We welcome reference to the Greensand Trust in the context of stakeholder involvement and future management. Reference should also be made here to the Greensand Ridge NIA (Local Plan Policy EE8) and Greensand Country.

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