Chapter 1. Introduction

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Comment

Habitats Regulations Assessment Addendum

Representation ID: 15335

Received: 05/05/2021

Respondent: Natural England

Representation Summary:

No comments to make on the HRA Addendum

A02

Full text:

See attachment

Attachments:

Comment

Habitats Regulations Assessment Addendum

Representation ID: 15607

Received: 05/05/2021

Respondent: Sundon Parish Council

Representation Summary:

There is no assessment to the impact of the Rivers and Streams including much valued Chalk Streams 75% of the worlds total are in this and the surrounding areas.

A02

Full text:

Please find below Sundon Parish Councils comments on the Local Plan Main Modifications Consultation.

The environment agency already states that the |South East of England is getting 30% less rain than normal and this means the current water supply cannot be sustained. There is no assessment that has identified just how much water will be needed from both the industrial development (including the RFI) and the residential development and there is no inclusion of reservoirs or other systems to contain and supply the increase in water demand. Water companies have already stated they cannot keep up with current demand and are having to draw water from rivers with 39 separate reports (Source: The Times) already in existence for streams and rivers in the surrounding area with only 14% reaching good ecological standards (Source: The Environment Agency) due to impacts from this activity of the water companies to supply current demand. With no assessment to the impact of the Rivers and Streams including much valued Chalk Streams 75% of the world’s total are in this and the surrounding areas ( Source: The Times)
o Sundon Parish Council would ask the inspectors to include the urgent need for a further review to include the water supply for current demand and an assessment of what further impact can be expected from the industrial and residential developments in the plan. This will ensure a sustainable water supply for all elements in the Plan including the ecology of the area in scope, its surroundings and its downstream stakeholders.

The table of available Brownfield sites mentioned states why they could or would be excluded. It states in the report that Brownfield sites must be used first.
o Sundon Parish Council ask that the inspectors to request a table of all Brownfield sites with an assessment of their suitability and non-suitability as required by the Plan.

We would like to bring to the Inspectors attention a report that was published in February 2021 and consequently not available for inclusion in your December Draft Plan review meetings.
The report on local transport on infrastructure was prepared by England’s Economic Heartland (EEH), a consortium of fourteen local transport authorities including Central Bedfordshire Council (CBC) in strategic partnership. The report focuses on decarbonising the transport system whilst continuing to ensure the needs of the freight and logistics sector are met with lowering environmental impact.

The report recognises the need for enhanced rail capacity on four strategic corridors which serve / cross the region

o Sundon Parish Council ask the Inspectors to consider that whilst (EXAM 107) came to the conclusion after examining many sites including those already rejected by the Radlett RFI studies and others on the Great Northern railway line, that Sundon was the only site that could accommodate a form of RFI the report did not include the East West route which will pass through Bedford. As the rail strategy studies state this is a valuable alternative and one which will offer better connections with considerable advantages over the Sundon RFI.

o Also, The Sundon RFI which would connect to the MML is not mentioned in this report.

Habitats Regulations Assessment Addendum
o There is no assessment to the impact of the Rivers and Streams including much valued Chalk Streams 75% of the worlds total are in this and the surrounding areas.

o Sustainability Appraisal Main Modifications Report
The HRA is nearly 3 years old and Sundon Parish Council ask the inspectors to request a more up to date appraisal

Policy SP1
o Sundon Parish Council would like to see this policy include that although green belt land may be needed to overall size of green belt should not be reduced and recovered and reclaimed land elsewhere should make up for any loss in other areas.

MM16
o Section 6.8 - 6.8.5 should be reinstated as it is already stated elsewhere that green belt boundaries may need to be changed as part of the local plan and therefore need to be reviewed as part of the delivery
of the local plan when agreed.

MM20
Table 6.3- should read 2035

Attachments: