Design Guide SPD - Nature - Chapter 8

Response from South Bedfordshire Friends of the Earth to the Design Guide Consultation.


This has been a very difficult consulation for community groups. There is a lot repetition making it a very long document and very unwieldy to comment on.

This design guide contains some really exciting work in chapter 12 on Sustainability and biodiversity. However this does not seem to clearly run through the guide. This chapter with the case studies should be at the start of the document and then there could be further details after this.
The design guide is severely hampered by the objectives of the Local Plan which are really out of date in relation to the sixth carbon budget and the latest work which shows how depleted the UK is in terms of Nature using the 2019 State of Nature report which highlights that 44 million pairs of breeding birds have been lost since 1967, 97% of wildflower meadows lost since the 1960’s, huge declines in hedgehogs and butterflies.

There need to be targets for Biodiversity creation as a whole in Bedfordshire and then these need to feed through into the design of green spaces and landscape. There needs to be much more emphasis on flowering shrubs both native and non native, ivy, spring bulbs that support pollinators, areas of long grass, wildflower meadows with management plans, areas of rotting logs, winding paths through trees and shrubs etc, areas of ponds that are kept filled up in the summer, untidy areas with brambles where birds can shelter from the huge danger of cats, areas of dead leaves and areas for hedgehodgs to hibernate and bare areas of earth on banks where solitary bees can create nests. The photos show very sterile areas for the most part.
As well as this there need to be corridors of flowering shrubs both native and non native for children to play with winding paths and big logs etc to encourage natural play. There need to be many informal play areas with old logs, shrubs etc and mounds and space for kicking a football for children to play out.

Health and co benefits of carbon cutting and sustainability need to run through this, opening up pathways for extra external funding to help with sustainability of the development.

In light of the Committee on Climate Change’s recent announcement on the slow pace of decarbonising the electricity grid, it is really important to include wind turbines/ farms going to a direct wire to a new estates, along with heat pumps etc and linking this in to landspace.

There needs to be far more in town centres to support artists who in turn create regeneration, and covered and indoor spaces. Solar panels on car parks and building and translucent solar rooves. Health and culture and local businesses and education on green skills need to be key to the town centre. Culture, heritage and the arts need to be key to supporting health, wellbeing and building community in town centres
There need to be much strong targets for cycling and walking .
Pollution into watercourses from microplastics in car tyres needs to be mitigated and prevented.
Response from South Bedfordshire Friends of the Earth.
This has been a very difficult consulation for community groups. There is a lot repetition making it a very long document and very unwieldy to comment on.

This design guide contains some really exciting work in chapter 12 on Sustainability and biodiversity. However this does not seem to clearly run through the guide. This chapter with the case studies should be at the start of the document and then there could be further details after this.
The design guide is severely hampered by the objectives of the Local Plan which are really out of date in relation to the sixth carbon budget and the latest work which shows how depleted the UK is in terms of Nature using the 2019 State of Nature report which highlights that 44 million pairs of breeding birds have been lost since 1967, 97% of wildflower meadows lost since the 1960’s, huge declines in hedgehogs and butterflies.

There need to be targets for Biodiversity creation as a whole in Bedfordshire and then these need to feed through into the design of green spaces and landscape. There needs to be much more emphasis on flowering shrubs both native and non native, ivy, spring bulbs that support pollinators, areas of long grass, wildflower meadows with management plans, areas of rotting logs, winding paths through trees and shrubs etc, areas of ponds that are kept filled up in the summer, untidy areas with brambles where birds can shelter from the huge danger of cats, areas of dead leaves and areas for hedgehodgs to hibernate and bare areas of earth on banks where solitary bees can create nests. The photos show very sterile areas for the most part.
As well as this there need to be corridors of flowering shrubs both native and non native for children to play with winding paths and big logs etc to encourage natural play. There need to be many informal play areas with old logs, shrubs etc and mounds and space for kicking a football for children to play out.

Health and co benefits of carbon cutting and sustainability need to run through this, opening up pathways for extra external funding to help with sustainability of the development.

In light of the Committee on Climate Change’s recent announcement on the slow pace of decarbonising the electricity grid, it is really important to include wind turbines/ farms going to a direct wire to a new estates, along with heat pumps etc and linking this in to landspace.

There needs to be far more in town centres to support artists who in turn create regeneration, and covered and indoor spaces. Solar panels on car parks and building and translucent solar rooves. Health and culture and local businesses and education on green skills need to be key to the town centre. Culture, heritage and the arts need to be key to supporting health, wellbeing and building community in town centres
There need to be much strong targets for cycling and walking .
Pollution into watercourses from microplastics in car tyres needs to be mitigated and prevented.

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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.

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As a member I would like the following comments to be considered:

New properties should be in the style specified by Neighbourhood Plan not just meeting the quality of the worst previous local developments.
Public transport within 100m.
Cycle routes within 100m
Garden size at least as big as the footprint of the house.
Extensions which overlook not to be built within 15 metres of the applicant's boundary.
Preserve a 5m gap between properties.
Custom build should mean it not just 'pick one from a list of 3 ugly houses the developer offers'
All developments have to be adopted.
Keep all established trees/hedges and add to them
Not more planning by condition. Make sure the design guide covers off all that has been conditioned in recent years.
minimum of 2 off street parking spaces and 1 parking space per bedroom.
Materials to match those used in the long-established local area not just modern brick. See the Cotswolds.
Better drainage
Broad streets with traffic able to pass other vehicles if traffic is parked down one side.
Front gardens for all houses. No doors opening onto the pavement.
Social housing not to built more cheaply than the rest of the development.
Reduce density - 12/hectare (p.40)
Variation of design - not just one of 3 designs
Let people walk before paths are constructed. See where people go.
Bat/swift boxes for all houses.
Ability for all houses to have EV points.
Annual review of the plan
Bin storage off the pavement. No shadows cast over windows from adjacent properties.