Central Bedfordshire Pre-submission Local Plan (January 2018)

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Comment

Central Bedfordshire Pre-submission Local Plan (January 2018)

2.6 Environment, Heritage Assets and Sustainability

Representation ID: 8522

Received: 19/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

GENERAL - text amendments

22

Full text:

In the interests of accuracy and consistency with national policy, the second sentence closing text of "...and the Forest of Marston Vale." should be expanded to read "...and the Forest of Marston Vale, one of England's Community Forests.". This minor amendment would ensure correct representation of the national status of the Forest of Marston Vale as one of England's Community Forests which receive national policy support. The change would therefore make the Local Plan sound in this regard.

Support

Central Bedfordshire Pre-submission Local Plan (January 2018)

5.2 Key Spatial Objectives

Representation ID: 8527

Received: 19/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

We strongly support the second spatial objective and the explicit support given for the ongoing creation of the Forest of Marston Vale and for the creation of a key section of the B&MK Waterway Park within the heart of the designated Forest area.

Full text:

We strongly support the second spatial objective and the explicit support given for the ongoing creation of the Forest of Marston Vale and for the creation of a key section of the B&MK Waterway Park within the heart of the designated Forest area.

Comment

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy EE9: Forest of Marston Vale

Representation ID: 8542

Received: 19/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

GREEN INFRASTRUCTURE - Strategic scale development proposals must provide strategic scale contributions to the creation of the Forest
POLICY - Wording requires strengthening

05

Full text:

The Forest of Marston Vale Trust is the charity leading on the delivery of the environmentally-led regeneration of the Marston Vale by creating the Forest of Marston Vale. The Forest is one of 12 nationally-designated Community Forests, with a Government set target to increase woodland cover to 30% by 2031. As one of England's Community Forests, the vision to create the Forest of Marston Vale benefits from both Government and national policy support. The National Planning Policy Framework states that:

"Community Forests offer valuable opportunities for improving the environment around towns, by upgrading the landscape and providing for recreation and wildlife. An approved Community Forest plan may be a material consideration in preparing development plans and in deciding planning applications." (NPPF, para. 92)

The delivery of the Forest is supported by Policy CS16 (Landscape and Woodlands) and Policy CS17 (Green Infrastructure) of the Central Bedfordshire Core Strategy 2009, which state that the Council will:
"Continue to support the creation of the Forest of Marston Vale recognising the need to regenerate the environmentally damaged landscape through woodland creation to achieve the target of 30% woodland cover in the Forest area by 2030." (CS16)
"Seek a net gain in green infrastructure through the protection and enhancement of assets and provision of new greenspaces as set out in the Strategic, Mid Bedfordshire and Parish Green Infrastructure Plans.
Take forward priority areas for the provision of new green infrastructure in the Forest of Marston Vale (including the Bedford and Milton Keynes Waterway), the Ivel Valley, the Greensand Ridge, the Flit Valley and the Chilterns.
Require new development to contribute towards the delivery of new green infrastructure and the management of a linked network of new and enhanced open spaces and corridors." (CS17)
Development sites should contribute towards the achievement of the 30% tree cover by maximising woodland or tree cover (with a 30% woodland cover target) across the development site. The trees and woodland should ideally be located within the public realm.

As an independent charity established to spearhead the creation of the Forest of Marston Vale, the Forest of Marston Vale Trust works to implement the politically and publicly endorsed Forest Plan. The Forest Plan provides the strategic framework and long-term vision for creating the Forest, setting out a range of aims, objectives and broad principles to be implemented. The Forest Plan states that:
"Land use decisions will clearly be important for the future of the Forest and such decisions will be taken by the planning authorities, in the context of the planning framework set out in the statutory development plans. No proposals in the Forest Plan can override the policies contained in these statutory plans. However the Forest Plan should be:
* a material consideration used to inform the preparation of statutory development plans;
* a material consideration in determining planning applications for development within the Forest boundary;..."
and further states that:
"The Forest Team will seek to secure meaningful on and off-site landscape gains from development schemes in the Community Forest. These should be appropriate to the scale and location of the development. This will be done by establishing good working relationships with planning officers and, where appropriate, developers and ensuring that Community Forest aims and objectives are fully understood."

The Forest Plan also clearly notes that:
"Development pressures will continue to cause controversy and impact upon communities within the Vale. An aim of the Forest Team will be to encourage landowners, developers and planning authorities to deliver Community Forest objectives and incorporate the principles of sustainability when considering further development."

In accordance with these statements in the Forest Plan, the Forest of Marston Vale Trust has a long-standing policy regarding development within the Forest area:
"While the Trust will support development that directly meets the objectives of the Forest, the Trust is neutral on individual planning applications that do not directly conflict with the aims of the Forest of Marston Vale. Where development is planned the Trust will work with developers and planners to secure a contribution to the Forest that is consistent with the Forest Plan and with the impact of the proposed development on the Vale".
(Policy on development - adopted 8th September 2005)

It is in the context of all of the above policies and guidance that the following specific comments are made on behalf of the Trust regarding the Local Plan Submission Draft.

The East-West Area proposed location for growth includes strategic development proposals within the designated Forest of Marston Vale area. Any such development in these locations that may be deemed appropriate by the Council must clearly demonstrate how they contribute to the creation of the Forest of Marston Vale as the adopted mechanism for the environmentally-led regeneration of the area. Strategic scale development proposals must provide strategic scale contributions to the creation of the Forest, so as to ensure policy compliance and delivery of the approved Forest Plan (as noted in the NPPF). The publicly and politically endorsed vision of an enriched, "forest" landscape should be the defining factor in the design of any strategic development proposals within the designated Forest of Marston Vale. The currently proposed text, whilst supportive, requires strengthening to better reflect the importance and status of the Forest of Marston Vale as one of England's Community Forests.

Comment

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy EE9: Forest of Marston Vale

Representation ID: 8550

Received: 19/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

ENVIRONMENT - any development must clearly demonstrate how they contribute to the creation of the Forest of Marston Vale

05

Full text:

The Forest of Marston Vale Trust is the charity leading on the delivery of the environmentally-led regeneration of the Marston Vale by creating the Forest of Marston Vale. The Forest is one of 12 nationally-designated Community Forests, with a Government set target to increase woodland cover to 30% by 2031. As one of England's Community Forests, the vision to create the Forest of Marston Vale benefits from both Government and national policy support. The National Planning Policy Framework states that:
"Community Forests offer valuable opportunities for improving the environment around towns, by upgrading the landscape and providing for recreation and wildlife. An approved Community Forest plan may be a material consideration in preparing development plans and in deciding planning applications." (NPPF, para. 92)
The delivery of the Forest is supported by Policy CS16 (Landscape and Woodlands) and Policy CS17 (Green Infrastructure) of the Central Bedfordshire Core Strategy 2009, which state that the Council will:
"Continue to support the creation of the Forest of Marston Vale recognising the need to regenerate the environmentally damaged landscape through woodland creation to achieve the target of 30% woodland cover in the Forest area by 2030." (CS16)
"Seek a net gain in green infrastructure through the protection and enhancement of assets and provision of new greenspaces as set out in the Strategic, Mid Bedfordshire and Parish Green Infrastructure Plans.
Take forward priority areas for the provision of new green infrastructure in the Forest of Marston Vale (including the Bedford and Milton Keynes Waterway), the Ivel Valley, the Greensand Ridge, the Flit Valley and the Chilterns.
Require new development to contribute towards the delivery of new green infrastructure and the management of a linked network of new and enhanced open spaces and corridors." (CS17)
Development sites should contribute towards the achievement of the 30% tree cover by maximising woodland or tree cover (with a 30% woodland cover target) across the development site. The trees and woodland should ideally be located within the public realm.
As an independent charity established to spearhead the creation of the Forest of Marston Vale, the Forest of Marston Vale Trust works to implement the politically and publicly endorsed Forest Plan. The Forest Plan provides the strategic framework and long-term vision for creating the Forest, setting out a range of aims, objectives and broad principles to be implemented. The Forest Plan states that:
"Land use decisions will clearly be important for the future of the Forest and such decisions will be taken by the planning authorities, in the context of the planning framework set out in the statutory development plans. No proposals in the Forest Plan can override the policies contained in these statutory plans. However the Forest Plan should be:
* a material consideration used to inform the preparation of statutory development plans;
* a material consideration in determining planning applications for development within the Forest boundary;..."
and further states that:
"The Forest Team will seek to secure meaningful on and off-site landscape gains from development schemes in the Community Forest. These should be appropriate to the scale and location of the development. This will be done by establishing good working relationships with planning officers and, where appropriate, developers and ensuring that Community Forest aims and objectives are fully understood."
The Forest Plan also clearly notes that:
"Development pressures will continue to cause controversy and impact upon communities within the Vale. An aim of the Forest Team will be to encourage landowners, developers and planning authorities to deliver Community Forest objectives and incorporate the principles of sustainability when considering further development."
In accordance with these statements in the Forest Plan, the Forest of Marston Vale Trust has a long-standing policy regarding development within the Forest area:
"While the Trust will support development that directly meets the objectives of the Forest, the Trust is neutral on individual planning applications that do not directly conflict with the aims of the Forest of Marston Vale. Where development is planned the Trust will work with developers and planners to secure a contribution to the Forest that is consistent with the Forest Plan and with the impact of the proposed development on the Vale".
(Policy on development - adopted 8th September 2005)
It is in the context of all of the above policies and guidance that the following specific comments are made on behalf of the Trust regarding the Local Plan Submission Draft.

The Marston Valley strategic allocation is within the designated Forest of Marston Vale area. Any such development must clearly demonstrate how they contribute to the creation of the Forest of Marston Vale as the adopted mechanism for the environmentally-led regeneration of the area, so as to ensure policy compliance and delivery of the approved Forest Plan (as noted in the NPPF). Strategic scale development proposals must provide strategic scale contributions to the creation of the Forest. The publicly and politically endorsed vision of an enriched, "forest" landscape should be the defining factor in the design of any proposals within the designated Forest of Marston Vale area.

Support

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy EE9: Forest of Marston Vale

Representation ID: 8554

Received: 19/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

DTC - Greater cross boundary working is advocated in relation to the Forest of Marston Vale

05

Full text:

We welcome and support the inclusion of the boundary of the designated Forest of Marston Vale area on the Key Diagram. This appropriately reflects the national landscape designation status of the Forest of Marston Vale as one of England's Community Forests.
It should be noted that this only represents the portion within Central Bedfordshire, which is approximately 50% of the total 61 square miles designated as the Forest of Marston Vale. The remaining 50% lies adjacent within Bedford Borough.
Greater cross-boundary working is strongly advocated by the Trust in pursuit of delivering the common vision for creating the Forest. Such cross-boundary working offers an excellent opportunity to demonstrate positive fulfilment of the Duty to Co-operate by both CBC and BBC.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

7.4 The Key Diagram

Representation ID: 8684

Received: 20/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

GENERAL - No opportunity to comment on the Proposed Submission Policies Map, Forest of Marston Vale should be added to the Proposed Submission Policies Map.

05

Full text:

This comment relates to the Proposed Submission Policies Map and is made here as no other opportunity was found in the document to comment on the Proposed Submission Policies Map.

Whilst the Key Diagram correctly includes the Forest of Marston Vale (hence our separate supporting representation), the Proposed Submission Policies Map does not include the Forest of Marston Vale. This oversight must be corrected to ensure that the Proposed Submission Policies Map correctly reflects the Key Diagram, correctly reflects policy EE9, and demonstrates consistency with national policy so as to ensure the soundness of this element of the Plan.

Comment

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy SP3: Generic Requirements for Strategic Sites

Representation ID: 8690

Received: 20/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

POLICY - policy should refer to a net environmental gain.

07

Full text:

The Green Infrastructure Strategy referred to should be required to demonstrate the "net environmental gain" proposed by the development. Adopting this approach and terminology would align CBC's Pre-Submission Local Plan with the Government's recently launched '25-year Environment Plan' which states a clear objective of embedding the principle of "net environmental gain" into development.

Comment

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy SA2: Marston Vale New Villages

Representation ID: 9033

Received: 21/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

POLICY - Must demonstrate how the site will benefit the Marston Vale, existing policies on environmental enhancements, proposal falls short of Marston Vale vision for a forest landscape - needs addressing
INFRASTRUCTURE - Need to invest in Green Infrastructure, must demonstrate how it will guarantee the delivery of the waterway

09

Full text:

The Forest of Marston Vale Trust is the charity leading on the delivery of the environmentally-led regeneration of the Marston Vale by creating the Forest of Marston Vale. The Forest is one of 12 nationally-designated Community Forests, with a Government set target to increase woodland cover to 30% by 2031. As one of England's Community Forests, the vision to create the Forest of Marston Vale benefits from both Government and national policy support. The National Planning Policy Framework states that:

"Community Forests offer valuable opportunities for improving the environment around towns, by upgrading the landscape and providing for recreation and wildlife. An approved Community Forest plan may be a material consideration in preparing development plans and in deciding planning applications." (NPPF, para. 92)

The delivery of the Forest is supported by Policy CS16 (Landscape and Woodlands) and Policy CS17 (Green Infrastructure) of the Central Bedfordshire Core Strategy 2009, which state that the Council will:

"Continue to support the creation of the Forest of Marston Vale recognising the need to regenerate the environmentally damaged landscape through woodland creation to achieve the target of 30% woodland cover in the Forest area by 2030." (CS16)
"Seek a net gain in green infrastructure through the protection and enhancement of assets and provision of new greenspaces as set out in the Strategic, Mid Bedfordshire and Parish Green Infrastructure Plans.
Take forward priority areas for the provision of new green infrastructure in the Forest of Marston Vale (including the Bedford and Milton Keynes Waterway), the Ivel Valley, the Greensand Ridge, the Flit Valley and the Chilterns.
Require new development to contribute towards the delivery of new green infrastructure and the management of a linked network of new and enhanced open spaces and corridors." (CS17)

Development sites should contribute towards the achievement of the 30% tree cover by maximising woodland or tree cover (with a 30% woodland cover target) across the development site. The trees and woodland should ideally be located within the public realm.

As an independent charity established to spearhead the creation of the Forest of Marston Vale, the Forest of Marston Vale Trust works to implement the politically and publicly endorsed Forest Plan. The Forest Plan provides the strategic framework and long-term vision for creating the Forest, setting out a range of aims, objectives and broad principles to be implemented. The Forest Plan states that:

"Land use decisions will clearly be important for the future of the Forest and such decisions will be taken by the planning authorities, in the context of the planning framework set out in the statutory development plans. No proposals in the Forest Plan can override the policies contained in these statutory plans. However the Forest Plan should be:
* a material consideration used to inform the preparation of statutory development plans;
* a material consideration in determining planning applications for development within the Forest boundary;..."

and further states that:

"The Forest Team will seek to secure meaningful on and off-site landscape gains from development schemes in the Community Forest. These should be appropriate to the scale and location of the development. This will be done by establishing good working relationships with planning officers and, where appropriate, developers and ensuring that Community Forest aims and objectives are fully understood."

The Forest Plan also clearly notes that:

"Development pressures will continue to cause controversy and impact upon communities within the Vale. An aim of the Forest Team will be to encourage landowners, developers and planning authorities to deliver Community Forest objectives and incorporate the principles of sustainability when considering further development."

In accordance with these statements in the Forest Plan, the Forest of Marston Vale Trust has a long-standing policy regarding development within the Forest area:

"While the Trust will support development that directly meets the objectives of the Forest, the Trust is neutral on individual planning applications that do not directly conflict with the aims of the Forest of Marston Vale. Where development is planned the Trust will work with developers and planners to secure a contribution to the Forest that is consistent with the Forest Plan and with the impact of the proposed development on the Vale".
(Policy on development - adopted 8th September 2005)

It is in the context of all of the above policies and guidance that the following specific comments are made on behalf of the Trust regarding the Draft Local Plan.

The "Marston Vale New Villages" proposed strategic allocation lies within the designated Forest of Marston Vale. Any such development in these locations that is deemed appropriate by the Council must clearly demonstrate how they contribute significantly and strategically to the creation of the Forest of Marston Vale as the adopted mechanism for the environmentally-led regeneration of the area. Strategic scale development proposals must provide strategic scale contributions to the creation of the Forest. The publicly and politically endorsed vision of a "forest" landscape should be the defining factor in the design of any strategic development proposals in the Forest. Whilst the proposed Policy SA2 positively includes the requirement for any development to provide 30% tree cover, it regrettably falls short of embedding the endorsed "forest" vision as the defining characteristic for the Marston Vale New Villages. We request that this be corrected to assert the locally and nationally sponsored vision for the Forest of Marston Vale as the defining design influence for any development.

The proposed Policy SA2 makes reference to the provision of green infrastructure, leisure facilities and access routes but fails to consider the need to invest in existing green infrastructure, leisure facilities and access routes that would serve the proposed development. The Trust's Forest Centre & Millennium Country Park lies directly adjacent to the proposed strategic allocation. It is an award-winning strategic greenspace, owned and operated by the Trust for public benefit at no cost to taxpayers. It will serve the residents of the proposed New Villages and therefore must be considered within this policy as essential supporting (green) infrastructure which will require investment in order to accommodate the proposed population growth.

The "Marston Vale New Villages" proposed strategic allocation also incorporates the proposed alignment of the Bedford & Milton Keynes Waterway Park. The Forest of Marston Vale Trust is an active member of the Consortium working to accelerate the creation of the Waterway Park, and any development in these locations must clearly demonstrate how it will guarantee delivery of a strategic section of the Waterway Park (i.e. more than just a navigable channel) as key green/blue infrastructure through the heart of the Forest of Marston Vale.

Comment

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy SE2: M1 Junction 13 - Marston Gate Expansion

Representation ID: 9054

Received: 21/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

GREEN INFRASTRUCTURE - concern regarding Forest of Marston Vale and tree cover

06

Full text:

The Forest of Marston Vale Trust is the charity leading on the delivery of the environmentally-led regeneration of the Marston Vale by creating the Forest of Marston Vale. The Forest is one of 12 nationally-designated Community Forests, with a Government set target to increase woodland cover to 30% by 2031. As one of England's Community Forests, the vision to create the Forest of Marston Vale benefits from both Government and national policy support. The National Planning Policy Framework states that:

"Community Forests offer valuable opportunities for improving the environment around towns, by upgrading the landscape and providing for recreation and wildlife. An approved Community Forest plan may be a material consideration in preparing development plans and in deciding planning applications." (NPPF, para. 92)

The delivery of the Forest is supported by Policy CS16 (Landscape and Woodlands) and Policy CS17 (Green Infrastructure) of the Central Bedfordshire Core Strategy 2009, which state that the Council will:

"Continue to support the creation of the Forest of Marston Vale recognising the need to regenerate the environmentally damaged landscape through woodland creation to achieve the target of 30% woodland cover in the Forest area by 2030." (CS16)
"Seek a net gain in green infrastructure through the protection and enhancement of assets and provision of new greenspaces as set out in the Strategic, Mid Bedfordshire and Parish Green Infrastructure Plans.
Take forward priority areas for the provision of new green infrastructure in the Forest of Marston Vale (including the Bedford and Milton Keynes Waterway), the Ivel Valley, the Greensand Ridge, the Flit Valley and the Chilterns.
Require new development to contribute towards the delivery of new green infrastructure and the management of a linked network of new and enhanced open spaces and corridors." (CS17)

Development sites should contribute towards the achievement of the 30% tree cover by maximising woodland or tree cover (with a 30% woodland cover target) across the development site. The trees and woodland should ideally be located within the public realm.

As an independent charity established to spearhead the creation of the Forest of Marston Vale, the Forest of Marston Vale Trust works to implement the politically and publicly endorsed Forest Plan. The Forest Plan provides the strategic framework and long-term vision for creating the Forest, setting out a range of aims, objectives and broad principles to be implemented. The Forest Plan states that:

"Land use decisions will clearly be important for the future of the Forest and such decisions will be taken by the planning authorities, in the context of the planning framework set out in the statutory development plans. No proposals in the Forest Plan can override the policies contained in these statutory plans. However the Forest Plan should be:
* a material consideration used to inform the preparation of statutory development plans;
* a material consideration in determining planning applications for development within the Forest boundary;..."

and further states that:

"The Forest Team will seek to secure meaningful on and off-site landscape gains from development schemes in the Community Forest. These should be appropriate to the scale and location of the development. This will be done by establishing good working relationships with planning officers and, where appropriate, developers and ensuring that Community Forest aims and objectives are fully understood."

The Forest Plan also clearly notes that:

"Development pressures will continue to cause controversy and impact upon communities within the Vale. An aim of the Forest Team will be to encourage landowners, developers and planning authorities to deliver Community Forest objectives and incorporate the principles of sustainability when considering further development."

In accordance with these statements in the Forest Plan, the Forest of Marston Vale Trust has a long-standing policy regarding development within the Forest area:

"While the Trust will support development that directly meets the objectives of the Forest, the Trust is neutral on individual planning applications that do not directly conflict with the aims of the Forest of Marston Vale. Where development is planned the Trust will work with developers and planners to secure a contribution to the Forest that is consistent with the Forest Plan and with the impact of the proposed development on the Vale".
(Policy on development - adopted 8th September 2005)

It is in the context of all of the above policies and guidance that the following specific comments are made on behalf of the Trust regarding the Pre-submission Local Plan.

The "Marston Gate Expansion" proposal lies within the designated Forest of Marston Vale. Any such development in these locations that is deemed appropriate by the Council must clearly demonstrate how they contribute significantly and strategically to the creation of the Forest of Marston Vale as the adopted mechanism for the environmentally-led regeneration of the area. Strategic scale development proposals must provide strategic scale contributions to the creation of the Forest. The publicly and politically endorsed vision of a "forest" landscape should be the defining factor in the design of any strategic development proposals in the Forest. Policy SE2 should be amended to include specific and explicit reference to the need for any development proposals to include 30% tree cover in line with the Government target for creating the Forest of Marston Vale.

Support

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy EE1: Green Infrastructure

Representation ID: 9096

Received: 21/02/2018

Respondent: Forest of Marston Vale Trust

Representation:

POLICY - support

06

Full text:

We strongly support this policy.

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