Design Guide SPD - Contents and Introduction - Chapters 1 to 4.

It is really difficult to know whether to support or oppose for reasons attached.

A01

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.

Thank you for your letter to Exolum Pipeline System Ltd regarding the above. Please find attached a plan of our client’s apparatus. We would ask that you contact us if any works are in the vicinity of the Exolum pipeline or alternatively go to www.lsbud.co.uk, our free online enquiry service.

4.2 "Local Policy". Noted that "convenient routes ... well connected to surrounding area.. encouraging travel by sustainable modes". Too many recent developments have totally ignored "permeability". Walking and cycling routes may be fine within a new development but there is often no way to get out of that development by walking or cycling. This needs to be forced upon developers.

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We have reviewed the draft Design Guide SPD document and have a few comments and observation to make.
1) The photo on the front of the document is from a development in Bedford Borough Council Area. If you are trying to push for good design do you not think a CBC example should be used?
2) We feel the general tenure of the document looks too much historically backwards and only reuses examples from previous versions.
3) There are new dwelling types and configuration that have not been included within the documentation I.e. Extra care at Dunstable & Houghton Regis, single storey courtyard dwellings and higher density back to back dwellings with first floor amenity spaces.
4) Can you include within the document useful Architectural examples of recent award winning designs or links where further information could be cross referenced. To assist we have collated residential design example document with examples for your consideration.

The objectives of the Local Plan referred to in 4.1.2 are weak objectives and not strong enough to implement the needs of the sixth Carbon budget under 2008 Climate Change Act and CBC's Sustainablity plan. of net zero by 2030. There needs to be a at least a 7% modal shift in transport according to the sixth carbon budget and as well as this the congestion in the area and the recent report by CBC public health on excess weight and the importance of active travel makes the transport ambitions not in keeping with making Central Bedfordshire a great Place to work. The levels of ambition for reducing carbon are very weak.

The chapter on resources that has very good information on Passivhaus and low carbon design should be at the start and should be a much stronger thread running through

IN the introduction policies HQ1, T1 and T2 and EE1 and net gain of 10% are much stronger than the objectives and should be quoted.

Chapter 12 and case studies should be at the start of the design guide and the golden thread of sustainablity and biodiversity and meeting carbon targets should run through the whole document. It is very confusing having this last and there is a huge amount of repetition in the document making it very long and inaccessible. Chapter 12 builds on some of the excellent work that officers in green infrastructure and sustainability are doing. There is not nearly enough on health benefits throughout and there is no metric for working out co benefits that could lead to accessing further funding

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Thank you for consulting on the Planning Design Guide SPD.

I am responding on behalf of the Chiltern Society, a local charity campaigning for the protection and enhancement of the Chilterns countryside, including the Chilterns AONB and parts of the London Green Belt.

An area of concern to the Society is about incentivising the incorporation of Sustainable and Renewable technology. Central Beds do have a section in the Development Briefs and Design Codes for Environmental Requirements and the Local Plan includes sections on Renewable Energy and Sustainability but you have to look hard to find it all. We would wish to see these matters featured more prominently in the Design Guide with clear guidance as to how these matters can be incorporated into the decision-making process.

Section 5.1.4 of the Design Guide - (Key documents & resources that should be referenced) should include a requirement to achieve 3* or above Home Quality Mark (or similar) rating, or BREEAM Very Good/Excellent grades for commercial properties. If requirement is too strong a word, then something on the lines of additional consideration or weighting should be given to projects that achieve recognised Home Quality Mark/BREEAM classifications. Guides such as this really should be championing and incentivising green technology. It exists and needs to become mainstream.

We are also pleased to see reference to the Chilterns Design Guide in Section 5.2.6. This guide is an important part of protecting the special qualities of the AONB and it is likely that when it is revised it will contain further guidance on sustainability principles and sustainable design.

We support the inclusion of detailed guidance on green and blue infrastructure and biodiversity. Getting the latter right is key with the introduction of Biodiversity Net Gain following the Environment Act 2021 and with the current nature crisis. In order to conserve the character of the countryside, including the Chilterns, it is essential that design gives full consideration to conserving and enhancing local distinctiveness in both the natural and built environment.

The Guide should also include clear guidance on reducing and managing water usage. Measures should be included to encourage the use of no more than 110 litres per person per day to reduce the needs for water abstraction from local watercourses.

The Society has no comments to make on the Housing Policy Technical Guidance SPD.