Dear Planning Policy Team
Re Riseley Neighbourhood Plan Regulation 16 Consultation
It is difficult to respond to this Regulation 16 Consultation for Riseley because so much of what has gone before it has been done so poorly. My attempt to complete the response form is attached. Can you please confirm that you have received my material.
All the literature on Neighbourhood Planning emphasises the need for consultation and engagement and there has been minimal consultation and engagement in Riseley. It has been a top down process.
As a landowner, as well as a resident, (I have lived in Riseley for 53 years) in the 5 years of the Neighbourhood Plan I have had only 15 minutes of face to face interaction with the Riseley Neighbourhood Plan Steering Group (RNPSG) despite endless requests on my part.
The fact that the RNPSG had to abandon the allocation of potential development sites is tragic for the village and testament to the total lack of engagement and proper consultation. The implosion of the site allocation process has hollowed out the plan and crippled its worth. The reasons for this collapse should be looked into by the Examiner.
There have been 50 RNPSG meetings and to date only 2 sets of minutes have been published despite many requests to have them published.
The Terms of Reference of the Riseley Neighbourhood Plan Steering Group (RNPSG) have not been published.
No agendas for RNPSG meetings have been published.
No RNPSG Accounts have been published.
Errors in the AECOM Site Suitability Assessments have not been corrected. Please see Appendix 3
Publishing bland monthly reports is not consultation.
No details of what was gleaned from the Regulation 15 Consultation have been published
No dedicated Riseley Neighbourhood Plan website has been published.
The public consultation questionnaire should have been published ahead of the consultation not on the day of the public exhibition and asking people to respond to the questionnaire as the left the Village Hall Exhibition in October 21 is not engagement or proper consultation.
Describing land incorrectly as equivalent to Green Belt in the October 21 Exhibition in Riseley Village Hall was a serious error which should have been corrected and wasn’t. Please see Appendix 1
It should be noted there is not a single sq inch of Green Belt Land in Bedford Borough.
The very short time for the September 21 Public Consultation just 6 days, with no workshops or engagement steps, no route to address errors- it was a rubber stamp exercise.
Thoughout the entire Neighbourhood Planning process the RNPSG have beed confused by and in turn have confused the residents over the differences between Green Space, Local Green Space and Village Open Space, Village View, open spaces, green vistas.-this compromises the validity of the Plan.
The October 21 Public Consultation Questionnaire was not fit for purpose.
The golden rule of questionnaire design is only ask one question at a time. This rule is broken frequently. The responses you get to a multipart question are meaningless. This is why respondents used so much free text outside of the defined comments boxes.
Here is one example:
Objective GS1 Retain Open Spaces, Views and Local Green Spaces as identified on the Bedford Borough Council Policies Map insert 28 Riseley 2020 and protect them from development. Agree Disagree
How does a respondent answer if they agree with no development on Local Green Spaces but disagree with no development on Open Spaces? How do respondents know what they are Agreeing or Disagreeing to, when the Policies Map is not included in the questionnaire? A respondent may not want development on the Local Green Spaces, Ross Meadow and the Playing Field but does want to see the village given the choice to accept appropriate development on Open Spaces, when the reasons for designation are not compromised or a material benefit outweighs the need to keep the land undeveloped. The questionnaire generated meaningless answers.
Another example:
Objective NE1 "The natural environment, including landscape features, biodiversity, green spaces and views and public rights of way will be protected and enhanced." Agree Disagree
This is a four component question. Green spaces and views are conflated. Landscapes, biodiversity and public rights of way are lumped together. How on earth can you make sense of an agree or disagree response?
The flawed statistical analysis in the site suitability assessments undermined the credibility of the RNPSG
Why would you attempt to reconcile two different sets of opinions, one based on the views of people who live in Riseley and have nothing but good intentions for the village and the views of a planning consultancy, AECOM, who have never spent a full 24 hours in Riseley and who have no long term commitment to Riseley and its future. The way to reconcile the different views is not to run a complex statistical analysis but to go back to the people of Riseley, in a proper public consultation and ask them what they think, what would they prefer.
I find it surprising and inappropriate that statistical analysis has found its way into the Riseley Neighbourhood Planning process and I disagree with the conclusions drawn from the analysis. It would be helpful to know how many other Neighbourhood Plans have used Spearman's rank correlation.
There may be a statistical correlation between the Riseley Neighbourhood Planning Group rankings and the AECOM rankings, of site suitability. However, the Spearman's rank correlation of 0.71, 0.73 or 0.67 depending on which data set is used, does not mean that the interpretation is correct for all sites . Some sites, in statistical terms are "outliers". They don't fit the pattern and they should be evaluated differently. The statistical analysis appears objective but is actually very subjective.
No details of what was gleaned from the Regulation 15 Consultation have been published
No dedicated Riseley Neighbourhood Plan website has been published.
The front cover of the draft plan, dated October 2022, is marked as 2022 to 2040. The submission plan, the subject of this consultation, dated March 2023, is marked on the front cover 2022 to 2030. It this a typo? If not when and why was the decision taken to reduce the life of the plan by 10 years?
Please see the attached response form for the rest of my detailed response.
I wish to take part in an oral examination please
The entire Neighbourhood Planning process in Riseley has been dominated by exclusion and top down imposition. . Engagement and effective consultation have been minimal. This is the last chance to rectify the situation and seek ways to build a Neighbourhood Plan that will help Riseley develop and prosper.
Regards
George Davies
160B High Street
Riseley
Bedford
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Reg 16 response. update 1.docx Size : 4415.54 Kb Type : docx |
RISELEY PARISH COUNCIL NEIGHBOURHOOD PLAN
PUBLIC CONSULTATION (REGULATION 14) ON THE DRAFT NEIGHBOURHOOD PLAN
21st NOVEMBER 2022 TO 16TH JANUARY 2023
Comments from.
George Davies
160B High Street, Riseley, Bedford, MK441DR
Further to my meeting with the Riseley Neighbourhood Plan Group at 14.00 on Sunday 8 January. You asked me to submit my response in writing which this document is.
The response form states: “Your views on the content of the draft NP are being sought.”
To submit a comment using the on-line form, you have to link your comment to a page, a paragraph and a Policy reference All three are required fields or the system does not let you submit the form.
This means for example that you can’t submit a comment on the “Vision” because it is not a policy! Is this level of constraint intentional or accidental? If accidental can it be rectified please. If intentional, it is unacceptable. You have made it extremely difficult to respond.
Page 1 of the draft report should have a full and detailed list of who contributed to it. Please look at the Aecom Riseley Design Guidance and Codes Final Report and the AECOM Site Assessment. You will see that in both Aecom documents, a full list of all those involved in the preparation of the report are listed. It is common practice to provide a full list of all those involved in the preparation of a report, as part of the report. A full list of all those involved in the preparation of all 5 versions of the Riseley Neighbourhood Plan 30 Oct 22 v5 should be have been included in the published Plan document.
Page 8 Paragraph 3.13 Mention should be made of the fact that the Melchbourne Estate in Riseley was home to 756 and 763 Chemical Depots of the US 8th Air Force Service Command. The main munition being incendiary bombs but the site also was a “Forward Filling Depot” for Mustard Gas, a weapon of mass destruction. 1500 tonnes of Mustard Gas was stored in three underground tanks. There are still parts of the estate fenced off because of lingering contamination.
Page 10 Vision and Objectives
Paragraph 5.2. The detailed expansion of the vision statement needs rigorous testing and review by the people of Riseley otherwise the whims of a few RNPSG members are being foisted upon the village. There is too much emphasis on “Open Spaces”.
The draft report mentions:
Green vistas -page 10 para 5.2
Open Spaces (intro 1.1) 23 mentions
Green Open Spaces (3.3 on page 6) 3 mentions
Amenity spaces (Aims 8 page 13) 2 mentions
Local Green Spaces (Aims 8 page 13) 7 mentions
Village Open Spaces (13.7 page 33) 4 mentions
Green belt (page 54) only listed in glossary of terms -never mentioned in the draft report so why in the glossary?
But, Bedford Borough Council Policy AD40 Village Open Spaces and Views– not a single mention in the draft plan.
Sloppy drafting should be eliminated and care must be taken to carefully and precisely use the recognised terms for Village Open Spaces as per Bedford Borough Council Policy AD40 and Local Green Spaces – Bedford Borough Council Policy 45, accurately and appropriately. The over emphasis on “open spaces” in the draft plan is exemplified by mentioning that the vision splays at road junctions should not be built on. This is just silly.
The Vision Statement of “Small Scale Developments” is torpedoed on page 11 by “Exceptionally, a larger development > 10 dwellings is acceptable”. The Vision and the clearly expressed views of the village is for “small scale development”. The plan is now open to 500 homes, as per Sharnbrook. Are the RNPSG pandering to the Bedford Borough Council’s desire to develop the Old Maggie B site for 37 or more dwellings.
“Respects the linear structure”- only the High Street has a linear structure, not the rest of the Village, eg College Drive, Bean Field, Kings Close, Dodds Close etc The draft report over emphasises Linear.
“Respects the landscape setting of the Parish.” Can this be justified? The issue of “The village remains inconspicuous from the surrounding countryside or when entering via road” is irrelevant and does not matter. Who really is concerned that when walking the fields around the village you can’t see the village. This is a fantasy constraint on future developments.
Policy D2: Sustainable design of homes and buildings page 23
Any new development should incorporate on-site energy generation from renewable sources such as solar panels where appropriate.
Delete the words “such as”. All new developments should have solar panels and storage batteries. The co-location of storage batteries with PV generation is not mentioned at all and should be.
Policy HE1: Conservation Areas and their settings
Development in the Conservation Areas and their settings shall achieve high quality design, set in a clear context in terms of materials, scale, setting and layout. The following criteria apply:
• The contrast of spaciousness of the green spaces with the intimacy of the rows of buildings set on the road frontage will be retained; development that would fill in historic gaps will be resisted.
Can you justify the use of the word “historic”? The gaps exist for no other reason than they have not been developed, they have no historic significance. If they did, they would be designated as such.
Housing Provision and Mix page 30 Policy H1
The draft report goes to great lengths to try and convince the people of Riseley that they do not deserve to have retirement bungalows. Is this wilful prejudice against Site 512? It flies in the face of the HNS and the responses to the September 2021 Public Consultation and The RNPSG should read https://www.gov.uk/guidance/housing-for-older-and-disabled-people -extracts below.
Specialist housing for older people
Age-restricted general market housing: This type of housing is generally for people aged 55 and over and the active elderly. It may include some shared amenities such as communal gardens, but does not include support or care services.
What factors should decision makers consider when assessing planning applications for specialist housing for older people?
Decision makers should consider the location and viability of a development when assessing planning applications for specialist housing for older people. Local planning authorities can encourage the development of more affordable models and make use of products like shared ownership. Where there is an identified unmet need for specialist housing, local authorities should take a positive approach to schemes that propose to address this need.
Paragraph: 016 Reference ID: 63-016-20190626
Revision date: 26 June 2019
How can plan-making authorities (eg Bedford Borough Council) plan for senior co-housing communities?
Senior co-housing communities are created and run by residents, based on the intention to live with a group of people of a similar age. The sites often consist of self-contained private homes as well as shared community space. Some communities offer an additional option for informal care. Local planning authorities can plan for senior co-housing communities through their implementation of the Self-build and custom-build legislation 2015, as some communities will be looking to build the development themselves. Plan-making authorities can also identify sites suitable for senior co-housing communities as part of their overall assessment of land available for housing over the plan period.
Paragraph: 011 Reference ID: 63-011-20190626
Revision date: 26 June 2019
Riseley needs more retiment
In the 2021 Public consultation, despite not being a preferred site and being lumped into a catch all box, at the very end of the questionnaire, labelled “Comments on other sites”, Site 512, “The Paddock,” retirement bungalows for local people, scored the second highest number of positive comments of all the sites with 21. The top scoring site, with 38 positive comments and 29 negative comments, was the Old Maggie B site, which pretends to be a brown field site but is only 25% brownfield and is 75% school playing field. With at least 37 dwellings proposed, the Old Maggie B site should fall at the first hurdle of not being a small scale development.
2021 Public Consultation Questionnaire
268 questionnaires were returned and a summary of positive and negative comments for the 18 residential sites is below:
Site +ve -ve
Old Maggie B * 38 29
512 The Paddock 21 13
614 Town Farm * 17 12
217 White Horse * 10 39
214 Keysoe Rd * 7 17
215 Keysoe Rd * 6 25
218 Adj 2 High St 6 12
457 Cedar Brook 6 7
211 Rotten Row 5 15
213 Dag Lane 3 25
219 Riseley Lodge 3 13
220 Butts 3 9
405 Forge 1 9
458 Keysoe Rd 1 27
459 Five Bells 1 27
694 Church Ln 1 22
LOTL 1 7
Riseley Lodge 0 2
*Preferred
Site 512 – Land adjacent to 156 High Street. The Paddock, retirement homes for local people, should have been a preferred site for residential development from the start. The RNPSG who originally stated in their Riseley Site assessments: “Site 512, The site currently is Village Open Space. The site would fill in a green space but this is not visible from the road due to tall trees bordering the road. The proposed number of dwellings is 7. The Housing Needs Survey recommended that around 20 dwellings would be needed over the next 5/10 years. This site is commensurate with those needs.”
“Page 34 Village Open Spaces – Location and Attributes
G Field off High Street, Bottom End
This field, in private ownership, provides a break between the
frontages of dwellings in Bottom End and contributes to its rural
feel. It also contributes to the setting of two listed buildings, one of
which, 135 High Street, is probably the oldest house in North
Bedfordshire.”
You should not shy away from identifying the other Listed Building, 133 High Street, Mr Middleton’s house, one of the prettiest listed buildings in Riseley??
Equally, it is relevant to point out that Hunter’s yard, a modern development of 4 bedroom houses, fills the entire space between the two listed buildings, apparently without detriment to the setting of either listed building.
Policy CF2: Open Spaces and Recreation page 35
The draft report frequently conflates Open Spaces and Recreation. This is unhelpful. Site 512, The Paddock, retirement bungalows for local people, is designated as a Village Open Space by Bedford Borough Council Policy AD40 . It makes no recreational contribution to Riseley whatsoever.
Recreation should be a separate policy area.
Existing designated open spaces as shown on the Policies Map will be protected from development.
This wording should reference the Bedford Borough Council Policy AD40 and should use the same words as used in the Bedford Borough Council Policy AD40 which states:
“Development will not be permitted on land designated as a village open space or view unless it can be demonstrated that the reasons for designation are not compromised or that other material considerations outweigh the need to retain the Village Open Space or View undeveloped.”
In the first public consultation on 20th October 2018 in Riseley Village Hall “Keep Ross Meadow” received 26 ticks. “Keep fields designated on old village plans open spaces” received 4 ticks. How do you justify the excessive focus on Village Open Spaces? The poorly designed public consultation questionnaire in September 2021 asked:
“Objective GS1 Retain Open Spaces, Views and Local Green Spaces as identified on the Bedford Borough Council Policies Map insert 28 Riseley 2020 and protect them from development. Agree Disagree”
How was a Riseley resident supposed to answer if they agree with no development on Local Green Spaces but disagree with no development on Open Spaces? How do respondents know what they are Agreeing or Disagreeing to, when the Policies Map was not included in the questionnaire? A respondent may not want development on the Local Green Spaces, Ross Meadow and the Playing Field but does want to see the village given the choice to accept appropriate development on Village Open Spaces, when the reasons for designation are not compromised or a material benefit outweighs the need to keep the land undeveloped.
The over emphasis on “open spaces” in the draft report reflets the bias of some members of the RNPSG and not the views of the people of Riseley. The draft Plan should be amended to give a more realistic and justifiable position on open spaces and development.
17. Implementation and Monitoring page 42
Working in partnership.
Partnership and joint working will be key elements in the successful implementation of the plan.
Site owners and developers will need to liaise with the Parish Council as well as the other relevant agencies involved in any development.
It is tragic that the RNPSG gave site owners 15 minutes of meaningful dialogue in the four years since work on the plan started. It makes a mockery of “working in partnership.” The total absence of engagement is why the plan is a shadow of what it should be.
The draft Neighbourhood Plan dwells in the past, maintaining things as they are and has little by way of helping Riseley develop. There is a need for small, well designed, starter houses for young people and retirement bungalows for older people.
What the draft plan doesn’t do is provide a pathway or series of proposed actions to take the village from the past to the future. The idea of the NP process is to capture the views of the villagers as to how the village should develop and meet the needs of its current and future inhabitants. Riseley is not a museum and we cannot just live in the past, ignoring the requirements of the future.
The draft Plan is very detailed in what can’t happen and where housing developments cannot be approved. Yet if the needs of the residents are to be met then common sense has to prevail and compromises must be made, to allow the construction of the required housing.
This document should clearly identify the future needs of the people of Riseley and set in place a series of steps to achieve them. It should be a RISELEY plan complied from RISELEY people’s views to meet the needs of RISELEY people. Unfortunately draft plan does not do that.
To
Sally Chapman
Riseley Neighbourhood Plan Consultant
2 March 2022
Dear Sally
Riseley Parish Council and its sub-committee, the Riseley Neighbourhood Plan Steering Group (RNPSG) seem to direct all Neighbourhood Plan queries to you, so I am contacting you directly.
This is a request to you to please facilitate meaningful dialogue between the Riseley Neighbourhood Plan Steering Group, Riseley Parish Council and the landowners and other stakeholders, before the draft Riseley Neighbourhood Plan is published.
It is unacceptable for the RNPSG and AECOM to make things up or get things wrong and not correct them and simply push on regardless.
These serious issues, first raised last year, need addressing now, before the draft Riseley Neighbourhood Plan is published. There must be a pause between the anonymised and aggregated results of the September 2021 public consultation being available and the draft Riseley Neighbourhood Plan being published. It is unacceptable after four years of work on the Riseley Neighbourhood Plan for there to have been absolutely no meaningful dialogue with the landowners.
Therefore I am formally listing the topics that need meaningful dialogue regarding Site 512.
All the evidence supporting these issues can be found on www.thepaddockriseley.co.uk
The Background
Extract from an email from the Chair of Riseley Parish Council, to me dated 19 November 2021
“I and I'm sure the majority of councillors support your site 100%. I would like the long emails to cease and let's concentrate on opening a meaningful dialogue with the NPG. I will make sure this happens.
The short term priority for our Neighbourhood Plan steering group is to collate and analyse the results from the village consultation questionnaires, a very time consuming undertaking for the small team of dedicated volunteers. Following the analysis and having the data to hand, I will recommend a consultation takes place with landowners and developers on a one to one basis to explain the rating system for their site and the rationale in the decision process."
Extract of email from me to Riseley Parish Council, dated 13 December 2021
“The RNPSG is working hard in isolation, but as a landowner I am keen to help them get their information right. This must be the case for other landowners and the village - please can we start the meaningful dialogue.”
I made this request in the Riseley Parish Council Open Forum on December 17 2021
"In the interest of fairness and accuracy I request that meaningful discussions take place between the RNPG and village stakeholders including landowners before any output from the public consultation is published."
At the Parish Council Meeting on 20 January, Mark Chamberlain confirmed that the RNPSG have no intention of talking to landowners,
The Issues with the Riseley Neighbourhood Plan and Site 512
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Site 512, and Site 459, were misrepresented as Green Belt Land in the information displayed at the Neighbourhood Plan Public Consultation. This is a very serious error.
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Bedford Borough Council have confirmed that Policy AD40, Village Open space does not prevent a site from being allocated in a Neighbourhood Plan but RNPSG think it does.
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The public consultation questionnaire was not fit for purpose.
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Because of the poor design of the public consultation questionnaire, respondents put free text outside of the defined comments boxes. The decision by RNPSG not to include comments written outside the defined comments boxes in the questionnaires is unacceptable.
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The statistical analysis used to combine the Riseley and AECOM rankings is flawed.
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The AECOM Site Suitability Assessment for Site 512 has factual errors
More detail on the issues is below and full details and all the background evidence is available on; www.thepaddockriseley.co.uk
Issue 1 Bedford Borough Council have confirmed a serious error in the information displayed at the Riseley Neighbourhood Plan Public Consultation
Sonia Gallaher, Senior Planner, Planning Policy, Bedford Borough Council has confirmed that there was a serious error in the information displayed at the Riseley Neighbourhood Plan Public Consultation last September regarding Green Belt Land. This incorrect information was very misleading and may well have caused visitors to the public consultation to have competed the questionnaire believing that sites 512 and 459, which both have in part AD40 designation, were Green Belt, when they are not. This undermines the validity of the public consultation with regard to sites 512 and 459. For more information please visit Issue 1 Not Green Belt Land
Issue 2 Bedford Borough Council have confirmed that there is no blanket ban on potentially allocating a site in a Neighbourhood Plan designated Policy AD40 Village Open Space.
It does appear that Site 512 has been assessed on the basis of a misunderstanding of Bedford Borough Council's policies and should be ranked higher and added to the sites with the potential to be allocated in the Riseley Neighbourhood Plan. There is no policy reason why Site 512 can’t be allocated in the Riseley Neighbourhood Plan, but AECOM and RNPSG seem to think that there is a blanket ban. For more information please visit Issue 2 Policy AD40 not a ban
Issue 3 The Public Consultation Questionnaire was not fit for purpose.
The golden rule of questionnaire design is only ask one question at a time. This rule is broken frequently. The responses you get to a multipart question are meaningless as you can’t tell which part of the question the response refers to. This is why respondents have used so much free text outside of the defined comments boxes. For more formation please visit Issue 3 The questionnaire is poor
Issue 4 Because of the poor quality of the design of the questionnaire respondents put free text outside of the defined comments boxes. The decision not to include comments written outside the defined comments boxes in the questionnaires is unacceptable. For more information please visit Issue 4 The comments boxes
Issue 5 The statistical analysis of the Riseley and AECOM rankings is flawed.
You may not realise that 24 pages of statistical analysis were used to identify the 6 preferred sites. Spearman's rank correlation results do not mean that the interpretation of the statistical analysis is correct for all sites. Some sites, in statistical terms are "outliers". They don't fit the correlation pattern and they should be evaluated differently. There is a common statistical convention to determine an outlier. Values beyond 1.5 times the interquartile range, IQR, are usually considered outliers. If you apply the IQR convention to the Riseley and AECOM rankings, Site 512 is indeed an “outlier” and should have been assessed differently and should be allocated for development in the Riseley Neighbourhood Plan. For more information please visit Issue 5 The Statistical Analysis is flawed
Issue 6 The AECOM Site Suitability Assessment for Site 512 has factual errors
Question 5 Is the land classified as the best and most versatile agricultural land (Grades 1,2, or 3a)? Yes-Grade 3 (no specification between 3a and 3b)
Site 512 is listed as Grade 3 land. This is incorrect. You can’t just dream up the Agricultural Land Classification, you must use the best possible data source. Site 512 is identified on the 1969 MAFF Agricultural Land classification map as "Land predominantly in urban use" and on the Defra 2004 Predictive Best and Most Valuable Land Assesement map, Site 512 is classified as " Urban/Industrial" . In the absence of an Agricultural Land Classification survey of the site this is the best data available and should have been used by AECOM and the RNPSG. It is not acceptable to just make it up, the response to question 5 should be green.
Question 6 Does the site contain local wildlife-rich habitats?
A preliminary ecological survey (PES) including GCN eDNA and a reptile survey found no wildlife-rich habitats. The full PES is available on www.thepaddockriseley.co.uk The ecologist commented that because of its proximity to houses on three sides, Site 512 is clearly patrolled by domestic cats who suppress any wildlife. The response to question 6 should be green.
Question 15 Are there any significant trees within or adjacent to the site?
There are no significant trees within or adjacent to the site and the response should be green.
Question 18 Would development of the site cause loss of social, amenity or communal value?
In reality there is no loss of social, amenity or communal value by developing the site as proposed. The next question 19 re loss of visual amenity is correctly answered No. The answer to question 18 should be no - green
Question 19 Is the site low, medium or high in terms of landscape?
The answer is low and should be green.
For more information on these errors please visit Issue 6 AECOM Site Assessment errors
The full detail and the supporting evidence behind the issues with the Riseley Neighbourhood Plan and Site 512 can be found at:
Issue 3 The questionnaire is poor
Issue 5 The Statistical Analysis is flawed
Issue 6 AECOM Site Assessment errors
George and Sue Davies
The Riseley Eco Cottage
160B High Street
Riseley
Bedford
MK441DR