Prologis Park, Marston Gate - Expansion Scheme Comparison Document [EXAM 106]

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Comment

Prologis Park, Marston Gate - Expansion Scheme Comparison Document [EXAM 106]

Representation ID: 14565

Received: 12/08/2020

Respondent: Historic England

Representation:

A02
P02
Continue to find Marston Gate proposal unsound.

Full text:

See attachment

Attachments:

Object

Prologis Park, Marston Gate - Expansion Scheme Comparison Document [EXAM 106]

Representation ID: 14589

Received: 12/08/2020

Respondent: Hallam Land Management

Agent: Carter Jonas LLP

Representation:

A02
P02
Object to Marston Gate expansion. Evidence does not address Inspectors concerns. Concern raised over approach to assessing landscape impact of proposal.

Change suggested by respondent:

The proposed allocation at Marston Gate Expansion would have substantial adverse landscape and visual effects. The landscape evidence that has informed the decision to allocate the site is not robust. The proposed allocation would have a harmful effect on designated heritage assets, despite the proposed additional mitigation measures.

It is requested that the proposed strategic employment allocation on land at M1 Junction 13 Marston Gate Expansion is deleted.

Full text:

The Inspectors raised concerns about the findings of the Sustainability Appraisal for the Marston Gate Expansion site in terms of landscape (see Para 12 of EXAM 69) and the potential harm to landscape character of the area (see Paras 49 to 53 of EXAM 69).
EXAM 106 seeks to redefine parameters for the development at the site to address the concerns about landscape impact and also to address concerns about the impact on heritage assets raised by Historic England.
In summary the redefined parameters relate to the following: building heights reduced by 3m; roof design amended; appropriate palette of colours used for buildings; and, additional off-site landscaping provided. These redefined parameters are included in suggested modifications to Policy SE2: M1 Junction 13 - Marston Gate Expansion – see Paras 6.4.26 and 6.4.27 of EXAM 112 for the modifications.
Hallam Land Management has instructed FPCR to assess the additional landscape evidence and Orion Heritage to assess the additional heritage evidence. The FPCR and Orion Heritage technical notes are submitted with these representations as appendices. A summary of the findings for each topic is provided below.

Landscape Comments
EXAM 106 does not address the Inspectors concerns regarding the significant visual impact of the mass, size and type of development proposed on the surrounding network of public footpaths and local landscape character. EXAM 106 provides a comparison between the modified parameters plan and the submitted parameters plan. It also compares the modified parameters plan against development on the existing Marston Gate site. EXAM 106 concludes that the reduction in building heights along with the additional mitigation measures will result in a reduction in effect from the majority of views, whilst only illustrating a small (and very selectively chosen) minority of the previously assessed viewpoints.
Such comparisons should not be used to judge the visual effects of the proposed development. The existing baseline condition for the site is a valued landscape which forms part of the attractive low lying open arable farmland at the foot of the distinctive Greensand Ridge and provides a setting to the historic settlements of Ridgmont and Husborne Crawley. EXAM 106 does not assess the long term adverse effects that the modified parameters plan would have upon the existing landscape and visual resources.
FPCR have identified deficiencies and limitations with the montages, the proposed reduction in building heights and the additional mitigation measures presented within EXAM 106:

Montages
• The montages do not provide a worst case assessment of the close range views. Compared to the longer distance views, the proposed development would be even more visible and highly prominent within close range views that would occur from the public rights of way and highways network surrounding the site. The LVIA submitted for the Marston Gate Expansion along with FPCR’s viewpoints and photomontages demonstrate that numerous other views would affected. Within such views the proposed development would result in substantial adverse visual effects.
• The majority of the photographs used for the montages were taken during weather conditions of “fair” visibility. These do not enable a proper appreciation of the impact of the proposed development upon the Greensand Ridge.
• Photographs used for some of the montages do not cover the full extent of the proposed development that would be evident within the view. Therefore these do not allow an assessment of the impact that the whole development would have upon the view.
Reduction in Building Heights
• Existing buildings within the Marston Gate Development are located on much lower lying land compared to the expansion land. Indeed much of the existing development is sited on previously developed land which used to house the Brogborough Brickworks. The so called expansion land has completely different characteristics and will intrude across a wide swathe of undeveloped countryside forming a key setting for the Greensand Ridge and will even march up the side of a hill The finished floor levels proposed within the modified parameters plan would still be at a significantly higher level than the existing buildings within the Marston Gate Development. Proposed buildings up to 15m and 18.5m tall would appear highly prominent within the landscape.

Mitigation Measures
• As shown in Appendix E2 of FPCR’s note (see Reprsentative Viewpoints 3, 4, 5, 6, 7, 8A ,8B, 10A, 10B, 11 and 14) the proposed development would be seen against the backdrop of the Greensand Ridge, and from many locations would appear above the Greensand Ridge breaking the skyline. Lighter coloured buildings would be prominent against the darker greens of the surrounding Greensand Ridge, whilst a darker colour palette consisting of browns, greens and greys would appear prominent against the sky. Consequently it is highly unlikely that an elevational treatment at Marston Gate Expansion would be effective in reducing the visual harm to an acceptable level.
• The proposed off site mitigation planting would only assist in the mitigation of one long range view from the second floor of Segenhoe Manor.
The proposed development would be highly visible across a wide landscape, from a range of sensitive locations including elevated vantage points from the public rights of way network on the Bedfordshire Greensand Ridge. The proposed development would result in adverse impacts upon views from the Mid Greensand Ridge towards the Woburn Greensand Ridge and vice versa.
A proposed development in accordance with the modified parameters plan would result in substantial adverse landscape and visual effects including long term harm upon the setting of the Greensand Ridge and historic villages, along with users of the public rights of way network including the Greensand Ridge Walk, the John Bunyan Trail and also from adjacent roads including the M1 motorway. There has been no attempt to reduce the territorial extent of the allocation, which we understand is based solely upon landownership parcels. It is for this reason, we understand, that the proposal extends awkwardly alongside the M1 for so long and then proceeds up the slope in its north-eastern corner.

Heritage Comments
Orion Heritage has assessed the impact of the proposed post-examination modifications in terms of their impact on heritage assets.
Orion Heritage conclude that the reduced height, palette, roof design and mitigation planting for the proposed allocation at Marston Gate Expansion is a positive response to Historic England’s concerns and overall does reduce the effect of the scheme. However, the allocation with the proposed mitigation measures still has a harmful effect on the eight designated assets that Historic England had raised concerns about i.e. Ringwork Scheduled Ancient Monument, Malton Spinnery Scheduled Ancient Monument, Ridgmont Conservation Area, Husbands Crawley Conservation Area, Church End Conservation Area, Woburn Registered Park & Garden, St James Church and Segenhoe Manor. Yet the commentary for historic environment states that “There are limited heritage assets in the area…”.
In summary, the proposed mitigation measures have not removed the potentially harmful effects on designated heritage assets.

Conclusions on EXAM 106
EXAM 106, despite its attempt to retrofit the evidence base, does not address the Inspectors concerns regarding the significant visual impact of the mass, size and type of development proposed on the surrounding network of public footpaths and local landscape character. Therefore, the proposed site allocation Policy SE2: Marston Gate Expansion, including the proposed modifications, would still result in substantial adverse landscape and visual effects including long term harm upon the setting of the Greensand Ridge and historic villages.
EXAM 106 does not assess the long term adverse effects that the modified parameters plan would have upon the existing landscape and visual resources. Therefore, the landscape evidence provided in EXAM 106 is not robust and does not support the proposed site allocation Policy SE2: Marston Gate Expansion, and a decision to allocate this site would not be justified or consistent with national guidance.
The proposed modifications in EXAM 106 seeking to address heritage impacts have not removed the potentially harmful effects on heritage assets.

Object

Prologis Park, Marston Gate - Expansion Scheme Comparison Document [EXAM 106]

Representation ID: 14595

Received: 12/08/2020

Respondent: Ridgmont Station Heritage Centre

Agent: BRCC

Representation:

The photomontages do not include a view from Ridgmont Station Heritage Centre, which is Grade II and only 50m from the site.

The photomontage that was submitted previously showed the Heritage Centre blighted by the size and scale of the development.

The proposed reduction of the height of the buildings by 3m does not mitigate the impact on the Heritage Centre.,

The development would also have a significant impact on the surrounding open countryside with ensuring loss of habitat, and would lead to the loss of local footpaths, one of which is being used to develop a new heritage trail.

A09
P02

Change suggested by respondent:

Significant reduction in the scale of the development and relocation away from the current site (which is largely in an area with special landscape status).

Full text:

The photomontages do not include a view from Ridgmont Station Heritage Centre, which is Grade II and only 50m from the site.

The photomontage that was submitted previously showed the Heritage Centre blighted by the size and scale of the development.

The proposed reduction of the height of the buildings by 3m does not mitigate the impact on the Heritage Centre.,

The development would also have a significant impact on the surrounding open countryside with ensuring loss of habitat, and would lead to the loss of local footpaths, one of which is being used to develop a new heritage trail.

Object

Prologis Park, Marston Gate - Expansion Scheme Comparison Document [EXAM 106]

Representation ID: 14636

Received: 12/08/2020

Respondent: Brogborough Parish Council

Representation:

A02
P07
Object to SE2, impact on Greensand Ridge and heritage assets.

Full text:

Clever use of colour on the diagrams, (in the planner’s best interests), help to create the illusion of the buildings blending into the landscape once their height has been lowered. We whole-heartedly disagree with this illusion and consider them very misleading. Blue lines on a blue sky are of course going to help the roof heights appear easier on the eye. The height reduction on its own is not enough. The buildings need to be sunk deeper into the landscape in order to be of a similar height appearance as the existing buildings, which were sunk when they were built 20 years ago. The SE2 site is on higher ground than Marston Gate is.

We are not sure how the Green sands Ridge on the exam 14, page 23, can be considered “an area of great landscape value” and yet 20 years later we can happily allow massive warehouses to be built on it. Throughout this document, it refers to protecting views of valuable heritage attributes in and around the vale and not obscuring views with trees, by careful planting. It is now considered acceptable to put massive warehouses on these sites, which will obscure the views completely, forever. Thus will be very damaging for the landscape.
Heritage England, were very keen to keep the historic views to surrounding valuable ancient monuments, and not lose them forever once these buildings are erected. We still consider this to be of extreme importance.

Object

Prologis Park, Marston Gate - Expansion Scheme Comparison Document [EXAM 106]

Representation ID: 14783

Received: 12/08/2020

Respondent: Ridgmont Parish Council

Representation:

A01
P0 ?
P03

Paras 57 onwards - object to SE2 and proposed mitigation

Full text:

This submission focusses on the related issues arising from the Hearing Sessions into Central Bedfordshire’s Local Plan and the Inspectors’ letter dated 30th September 2019. It forms the basis of Ridgmont Parish Council’s objections in relation to the soundness of Central Bedfordshire Council’s Revised Sustainability Appraisal and other documents, which are the subject of the consultation. The objection is pursuant to the allocation SE2
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