Issue 1
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 completed 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
Misleading information on display board at the public consultation.
email to RNPSG dated 27 January 2022 Mark's reply was "Noted"!
Dear Mark
Further to my email to Alison dated 21 January 2022, you can that the email below from Sonia Gallaher, Senior Planner, Planning Policy, Bedford Borough Council dated 26 January 2022, confirms that there was a serious error in the information you 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.
Sonia Gallaher goes on to confirm that there is no blanket ban on potentially allocating a site in a Neighbourhood Plan designated Policy AD40 Village Open Space, which is what the Riseley Neighbourhood Plan Group have done. In the AECOM “summary of justification for the red overall rating” for Site 512, it is stated “therefore, it is unlikely the site could be developed without compromising the (policy AD40) designation.” “Unlikely” is not “can’t”. AECOM have confirmed that it is not up them to make the final decision , it is up to Riseley Parish Council who have already formally supported the development of Site 512, and please note the Parish Council used the word "support" not "no objection" see www.riseleyvillage.co.uk/minutes-september-2019, as did 70 residents of Riseley, in the recent planning applications and Sonia confirms that it is possible to allocate Site 512, subject to consultation with Bedford Borough Council, to see if a layout/design can be developed that does not compromise the two reasons the site was designated as a 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.
Sue and I look forward to hearing from you.
Regards
George
From: Sonia Gallaher <sonia.gallaher@bedford.gov.uk>
Date: 26/01/2022 15:09:43
Subject: RE: [External] Policy AD40 and Neighbourhood Plans
To: George Davies <georgedavies160@gmail.com>
Bedford BC - OFFICIAL-Unsecure
Dear George,
Thank you for your email.
I can confirm that the information in the photo that you supplied about Village Open Spaces and green belt is incorrect. Village open spaces and view designations do not have equivalent protection to green belt. This is only for designated Local Green Spaces.
Allocations and Designations Local Plan Policy AD40 allows development on a site designated as a Village Open Space where it can be shown that the reasons for the designation (which differ from site to site) are not compromised, or where there are other material considerations that outweigh the need to retain the open space or view undeveloped. In some circumstances that may mean that development can be justified but in others it may be that development would not be appropriate. The background paper that was produced for the Allocations and Designations Local Plan 2013 outlining these reasons for the designations and the methodology is on our website here. In terms of plan making, it is for the plan maker to weigh up the evidence and justify the selection of sites.
I trust this is of help. I would suggest that you contact the Riseley Parish Council Clerk if you have any further queries about the Riseley Neighbourhood Plan production.
Many thanks
Sonia Gallaher, Senior Planner, Planning Policy, Bedford Borough Council
From: George Davies <georgedavies160@gmail.com>
Sent: 26 January 2022 10:43
To: Sonia Gallaher <Sonia.Gallaher@bedford.gov.uk>
Subject: [External] Policy AD40 and Neighbourhood Plans
Hi Sonia
Thank you for your helpful reply. It is so nice to get a quick response.
By way of background:
On one of the display boards at the RNPG public consultation event in the Riseley Village Hall last September the RNPG confused Local Green Spaces, Policy 45, which are not Green Belt but as you told me can be considered as akin to Green Belt with Village Open Space, Policy AD 40 which, again as you told me, are a lower tier of designation and not Green Belt nor akin Green Belt.
The photo below of the display board, shows that the RNPG stated that Village Open Space protection is equivalent to Green Belt land. This is incorrect, 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.
Even AECOM confirm Village Open Space is not Green Belt. The item in the AECOM Site Suitability Assesment for sites 512 and 459 entitled "Is the site in the Green Belt" have the answer "No" for both sites.
We have just two Local Green Spaces in Riseley, Ross Meadow and the Playing Field. It is very unhelpful to mention Green Belt land at all here, as you have confirmed, there is no land designated as Green Belt, in the whole of Bedford Borough.
The rest of the Village Open Space comments, on the display board, do not conform with the wording of Policy AD40 and again are misleading and demonstrate that the RNPG does not understand Policy AD40 , Village Open Spaces and Views.
As you can see in the photo they stated: "These are also identified to protect the land for important reasons.....The land has protection equivalent to green belt land. Building causing loss of all or part of the space or of its significant local features will not be permitted unless special circumstances can be demonstrated"
The wording on the display board should have used the official AD40 policy wording and stated: "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".
This then takes us on to the AECOM Site Suitabilty Report for Site 512 where it is overall rated as: The site is not currently suitable, and available.
Summary of justification for rating
This greenfield site is adjacent to the settlement policy area boundary and is partially designated as Village Open Space in Policy AD40. The whole site is within the Conservation Area. A Grade II Listed Building (135 High Street) and its listed outbuilding are directly opposite and development on the site would likely require a mitigation strategy. The site would be in conformity with Policy 7S if allocated in the Neighbourhood Plan. However, consultation with BBC would be required to discuss the potential extension of the settlement boundary to include the site. However, the majority of the site has been designated as Village Open Space (as designated in Allocation and Designations Local Plan 2013, Policy AD40) as it provides a gap in the frontage and acts as a transition point from village to countryside. Therefore, it is unlikely the site could be developed without compromising the designation. The site is not suitable for allocation in the Neighbourhood Plan.
If my understanding is correct from your email, there is no blanket ban on potentially allocating a site with AD40 on it, which is what the Riseley Neighbourhood Plan Group have done.
In the AECOM “summary of justification for the red overall rating” for Site 512, it is stated “therefore, it is unlikely the site could be developed without compromising the (policy AD40) designation.” “Unlikely” is not “can’t”. This should not prevent the people of Riseley having their voice heard on Site 512. It should not be up to AECOM to decide. Riseley Parish Council has voiced support for the development of Site 512, as per the recent planning applications and it should be possible to allocate Site 512 subject to consultation with Bedford Borough Council to see if a layout/design can be developed that does not compromise the two reasons the site was designated as a Village Open Space
It is important to note that all the 11 sites in Riseley which have been found to be potentially suitable for allocation are outside of the SPA or have Highways or other issues requiring mitigation and all of them require consultation with Bedford Borough Council. Please see extract from AECOM report below.
Site Suitability Report Prepared for: Riseley Neighbourhood Plan Group on behalf of Riseley Parish Council AECOM
- Conclusions
Site suitability assessment conclusions.
7.2 The following 11 sites are potentially suitable for allocation in the Neighbourhood Plan subject to the
mitigation of various constraints and/or consultation with BBC.
- Site 1, Former Margaret Beaufort Middle School: The site is potentially suitable for
allocation in the Neighbourhood Plan subject to consultation with BBC.
- Site 211, 20 Rotten Row: The part of the site within the settlement area policy boundary is
suitable for allocation in the Neighbourhood Plan and the area outside of this is potentially
suitable subject to securing suitable pedestrian links with the village and consultation with BBC.
- Site 214, Land at Hill View Farm: The western half of the site is in conformity with Policy 5S as
it is within the settlement policy area boundary and therefore suitable for allocation in the
Neighbourhood Plan and the eastern half of the site is potentially suitable subject to consultation with BBC, mitigation of surface water flooding and any impact on the Conservation
Area.
- Site 215, Land at Keysoe Road (small): The site would be in conformity with Policy 7S if
allocated in the Neighbourhood Plan. However, consultation with BBC would be required to
discuss the potential extension of the settlement boundary to include the site. Therefore, the site
is potentially suitable for allocation in the Neighbourhood Plan.
- Site 216, Land at Riseley Lodge Farm: The smaller section of the site to the east of Bowers
Lane, close to the existing development, may be suitable for limited development subject to
consultation with the Highways Authority and consultation with BBC.
- Site 217, Land at Top End, High Street: The site is potentially suitable for allocation in the
Neighbourhood Plan subject to mitigating surface water flood risk and consultation with BBC.
- Site 218, Land south east of High Street:Development on the site would require the removal
of several trees and may require an ecology survey to establish the ecological impact of
developing the site. Therefore, the site is potentially suitable subject to mitigation of tree
removal, consultation with BBC and a potential ecological survey.
- Site 219, Riseley Lodge Farm: The site is potentially suitable for allocation in the
Neighbourhood Plan subject to consultation with the Highways Authority and BBC and
mitigation for heritage assets.
- Site 220, The Butts Rotten Row: The site is potentially suitable for allocation in the
Neighbourhood Plan subject to consultation with the Highways Authority and BBC and
mitigating flood risk.
- Site 458, Land at Keysoe Road (large): It is likely that the whole site would not be appropriate
for development as this would impact the character of the village, however a smaller
developable area along the north west boundary of the site for approximately 15 dwellings or an
integrated scheme with Site 215 might be a potential strategy, subject to consultation with BBC.
- Site 614, Land at Town Farm, Lowsdon Lane:A smaller section of this wider site located
within the existing development footprint of the village are potentially suitable for allocation in
the Neighbourhood Plan subject to consultation with the Highways Authority and BBC and
mitigating any habitat loss.
https://www.riseleyvillage.co.uk/aecom-site-assessment/
AECOM Site suitability report page 39
I have done some research on Policy AD40, which I sent to Riseley Parish council on 11 October 2021