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 RNPSG seem to think that there is.
Dear Riseley Parish Council
11/10/21
Riseley Neighbourhood Plan
Policy AD40, Village Open Space, AECOM and Site 512, The Paddock.
The Village Open Space Policy, AD40, has been presented by AECOM, in its Site Suitability Assessments, as a blanket ban on development. This is not the case. We have gone back to 2013 in Bedford Borough Council records and found 24 planning applications where Policy AD40 has been an issue, but where it did not prevent development.
Policy AD40 is a policy, and just like building outside of the SPA, given the right circumstances and subject to consultation with Bedford Borough Council, development is possible.
We note that AECOM declare that 11 sites are potentially suitable for allocation in the Riseley Neighbourhood Plan and every one of them includes the phrase “subject to consultation with BBC” and four of them also require consultation with the Highways Authority.
The only reason that Site 512 was not allocated for development was its designation as a Village Open Space, Policy AD40.
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 is not 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.
The allocation of Site 512 is supported by the following analysis:
Village Open Space, Policy AD40 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.”
Site 512 in the Riseley Neighbourhood Plan, which includes Riseley site G, on the Bedford Borough Council Policies Map is designated against two criteria:
- The gap provides visual relief in an otherwise built up area punctuating the street scene;
- The open space assists the transition between village and countryside providing a soft edge to the village which is pleasing visually.
Precedents where the designation ‘Village Open Space’ has not prevented appropriate development.
In Appendix 1 (attached) are detailed 24 planning applications in which Village Open Space was an issue but in which officers felt that Policy AD40 need not be compromised by the proposed development. Four of those cases are detailed below:
Planning Application 14/02687/FUL Cotton End (Case 2 in the appendix) the Officer notes: “in support of the application.”
“The application site forms part of a Village Open Space. The Village Open Space includes the application site and a parcel of land to the south west of the site bounded by the Bell Inn pub car park to the north west, Wood Lane to the south west and dwellings to the south.
The boundary of the Village Open Space with Wood Lane consists of a dense, mature hedge which was approximately 3 metres in height at the time of the officer site visit. This restricts views into the site, but in the event that the hedge is removed the proposed dwelling will be sited approximately 60 metres from the road and the gap provided by the open space will be maintained. There are no views into the site and the site has a limited role in its function, character and identify of the village. The report further states that the site would have a limited role as a gap being that the development would not be visible from the street scene of Wood Lane or Bell Lane. A Landscape and Visual Appraisal has been submitted.”
Comparison to Site 512. With the retained mature trees and hedges on all sides of Site 512 this same analysis should apply. For comparison the bungalows, on site 512, are 60m from the High Street on the Northern side and 40m from the High Street on the South side.
Planning Application 20/00061/FUL , Bromham, is also relevant. (Case 3 in the appendix) The Officer report states: “The application site is designated as a Village Open Space on the council’s policies map. The proposed buildings would not be readily visible from public views within Denyvor Close. The northern boundary of the site is landscaped with dense tree and hedge planting. The proposal seeks to retain and enhance the boundary planting which could be secured by condition if planning permission was to be forthcoming. The proposed dwellings would be viewed against the existing built from of Denyvor Close from public. The majority of the site is to be retained as open space with views through the site still being achievable between the proposed buildings. The proposed development is not therefore considered to compromise the reasons that the site was designated as a village open space. Making the space publically accessible again would also contribute positively to its designation. The proposal is not therefore considered to conflict with saved policy AD40 of the Allocations and Designations Local Plan 2013.”
Comparison to Site 512. The proposed bungalows would not be readily visible from public views from the High Street as the boundary of the site with the High Street retains untouched dense trees and hedge except for a 5m addition to the gateway to allow the bin lorry access. New hedges will be planted across the site to screen the view through the gateway. The street scene remains essentially untouched. With the retained mature trees and boundary hedging on all sides of Site 512, this same analysis should apply.
Planning Application 18/00433 by Bloor Homes South Midlands for the erection of up to 65 dwellings is also relevant. Wilstead Case 20 in the appendix) The Officers Report states: “The front of the site is designated as a Village View. The indicative plan submitted with the application shows that the front of the site, including the part of the site containing the designated Village View will be set aside for public amenity space with the first dwelling set back approximately 30 metres from Cotton End Road. Therefore it is considered that the development can be designed to respect the reason for the designation and the development is not contrary to Policy AD40.”
Comparison to Site 512. In the proposed layout, the front of site 512 is set out as an open space and allotments and has public access for the first time becoming a public amenity space with the first bungalow is set back approximately 60m from the High Street on the Northern side and 40m from the High Street on the South side. This application also brings into play consulting with Bedford Borough Council to design the development to respect the reasons for designation.
Planning Application Number 18/02517 Stagsden is very relevant- Case 1 in the appendix “The site is currently designated as agricultural land which consists of grass. It is outside of the Settlement Policy Area (SPA) boundary of Stagsden and is therefore considered to be within the open countryside. However, the site adjoins the SPA boundary and is also designated within the Policies Map 2014 as Village Open Space and allocated for a small scale housing development (6 houses)Comparison to Site 512. The Stagsden site is a Village Open Space but also has been allocated for a small development of 6 houses and it has many similarities to Site 512 and shows that development on a Village Open Space is achievable.
It would be very helpful if you could send me an email, which I can pass on to Riseley Parish Council and the Riseley Neighbourhood Planning Group, clarifying the AD40 Policy issues and confirming that Policy AD40 does not prohibit a site being potentially allocated to the Riseley Neighbourhood Plan 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 Policy AD40.
Many thanks for your help with this.
George and Sue Davies
160B High Street
Riseley