Presentation to the Parish Council Meeting on 15 December 2022
The draft Plan response form states: Your views on the content of the draft NP are being sought.
But are you aware that 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, 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 it is intentional, then it is not acceptable – it is not consultation
The draft Neighbourhood Plan dwells in the past, maintaining things as they are, and does little by way of helping, Riseley develop. There is a need for small, well designed, starter houses for young people and well designed, retirement bungalows for older people.
Riseley is not a museum and we cannot 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 Riseley residents are to be met then common sense has to prevail and compromises must be made, to allow the construction of the required houses and bungalows.
The draft plan should identify the needs of the Riseley community and set down a series of steps to achieve them.
The draft Plan is dated through to 2040 and is full of opinions not facts. The authors of these opinions must be identified in the plan. Who put this plan together?
Anonymity is not acceptable. Hence my FOI request.
It should be a RISELEY plan compiled from RISELEY people’s views, to meet the needs of RISELEY people. Unfortunately this document does not do that and therefore cannot be supported it in its current form.
Dear Riseley Parish Council 8 December 22
When people are proud of something they are usually keen to have their names associated with it. Conversely when people are not proud of something they disassociate themselves from it.
This is a FOI request, please publish on the Village Website, without delay, a full list of all the members of the Riseley Neighbourhood Plan Steering Group including the date they joined and the date they left.
Many thanks
George
Dear Riseley Parish Councillors 11 October 22
When you discuss the Draft Riseley Neighbourhood Plan next Tuesday evening, 11 September 22, please keep in mind that:
Issues relating to the entire Riseley Neighbourhood Planning process.
The Terms of Reference of the Riseley Neighbourhood Plan Steering Group (RNPSG) have not been published.
No agendas for RNPSG meetings have been published.
The minutes of only two RNPSG meetings have been published.
No RNPSG Accounts have been published.
No meaningful discussions with Riseley stakeholders have ever taken place.
Errors in the AECOM Site Suitability Assessments have not been corrected.
There has been no appeal process for the AECOM reports.
Errors in the dubious statistical analysis carried out by Mark Chamberlain -Chair of RNPSG, ignoring the statistical significance of outlier sites in a distribution, not acknowledged or corrected.
As a result of the statistical correlation analysis, six sites were put forward for allocation by RNPSG and identified in the public consultation questionnaire but it is impossible to understand the logic to get to six. For the detail please see https://www.riseleyvillage.co.uk/analysis-of-the-site-suitability-assessments-conducted-by-riseley-and-aecom/
RNPSG should have let the people of Riseley vote on all 19 sites not just on six.
The public consultation questionnaire should have been published ahead of the consultation not on the day of the public consultation exhibition.
Asking for the questionnaire to be completed before residents left the Village Hall Exhibition was rushed and inappropriate.
The poor design of the public consultation questionnaire made it very difficult to analyse.
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.
The total absence of meaningful dialogue between RNPSG or RPC with stakeholders at any time.
The bland and meaningless monthly reports from the RNPSG to the Parish Council have not helped.
The absence of a Riseley Neighbourhood Plan website – although promised in 2018 has compromised the ability of Riseley people to engage with the process.
The decision by RNPSG not to allocate any sites for development is a great loss to the people of Riseley and testament to the failure of the RNPSG to do their job properly.
Issues that relate to Site 512, The Paddock, adjacent to 156 High Street Riseley.
Errors in the AECOM Site Suitability Assessments meant that Site 512, The Paddock, was not allocated for development when it should have been. The main reason for not allocating Site 512 seems to have been Policy AD40. If Policy AD40 is a blanket ban on allocation in a Neighbourhood Plan then this should be stated clearly, all the evidence says that this is not the case. We have gone back to 2013, when Policy AD40 was adopted by Bedford Borough Council and found 24 planning applications where Policy AD40 has been an issue, but where it did not prevent development. These are detailed in pages 17 to 59 in the attached document.
The incorrect statement, on a display board, in the September 2021, Village Hall Exhibition, that Site 512 was effectively “Green Belt Land” was very prejudicial to Site 512. This error was confirmed by Sonia Gallaher in her email to me dated 26/01/2022 Please see page 17 in the attached document. When pointed out to RNPSG the Chair's response was "Noted".
Analysis of the Site Suitability Assessments Conducted by RISELEY AND AECOM: VERSION 5 states:
The rank order of the sites from the Riseley assessment was different from the AECOM rank order but there was a degree of correlation between the two ranks as shown by the graph in Table 8. The chart provides a visual display of the correlation between the two sets of data. Visual inspection of the data suggests a degree of correlation between the datasets because there is minimum displacement from the line of unity (the diagonal line connecting the origin [lower left] with the 20:20 position [upper right]. However, visual inspection is insufficient to provide a convincing argument for correlation and so a statistical method was used. To determine the degree of correlation, Spearman’s rank correlation was used. This is a non-parametric measure of rank correlation.
This means that just looking at the two rankings does not help you figure out an overall ranking. The use then, of a statistical analysis is inappropriate in this context. The statistical analysis is extremely difficult for people to understand, including the RNPSG and to make matters worse it was not used correctly.
There is a common statistical convention to determine an outlier. Values beyond 1.5 times the interquartile range, IQR, are usually considered outliers. Using this convention and looking at Table 8 in the Analysis of Site Suitability assessments conducted by Riseley and AECOM, four sites can be considered as outliers, Site 211, 20 Rotten Row, Site 219, Riseley Lodge Farm, Site 614 Land at Town Farm, Lowsdon Lane and Site 512, The Paddock. It should be noted that Sites, 211, 219 and 614 have all been listed as potentially suitable for inclusion in the Neighbourhood Plan, subject to the mitigation of identified constraints and/or consultation with Bedford Borough Council, only Site 512, The Paddock has not. So of the four sites that don't quite fit the pattern in Table 8, three are potentially allocated and one is not. If you look at Tables 9 and 10 , Site 512 is always an outlier, not fitting the pattern. This is reason to reevaluate Site 512, The Paddock.
Riseley Parish Council shouldn’t judge site 512 just by the incorrect statistical correlation between the local Riseley assessment, where it came 4th and the AECOM assessment where it came 12th (Table 8). There should be a specific decision-making scheme to take into account other factors and Site 512 should have been allocated for development in the Riseley Neighbourhood Plan subject to consultation with Bedford Borough Council.
www.riseleyvillage.co.uk/analysis-of-the-site-suitability-assessments-conducted-by-riseley-and-aecom/
If the AECOM Site Suitability Assessment for Site 512 is not corrected it should be removed from the draft Neighbourhood Plan, as it is based on incorrect data and gives a misleading impression of Site 512. This may well apply to other sites.
A full analysis of the issues is in the attached document-Email to Sonia Gallaher
Best regards
George and Sue Davies
160B High Street
Riseley
Email to Sonia Gallaher, Senior Planner, Planning Policy, Bedford Borough Council 25 September 2022
|
Email to Sonia Gallaher 25 Sept 22.pdf Size : 1327.479 Kb Type : pdf |
Dear Riseley Parish Council 25 July 2022
As you are aware, the “Nolan Principles for Conduct in Public Office” apply to Riseley Parish Councillors and to the members of the Riseley Neighbourhood Plan Steering Group (RNPSG).
The relationship between the RNPSG and the Parish Council must be transparent to the wider public, with the RNPSG publishing its Terms of Reference, Meeting Agendas, Minutes of all meetings together with all other relevant documents, on the Village website without further delay.
As it seems likely that the Chair and Secretary may be moving away from Riseley, the publication of the Terms of Reference, all Meeting Agendas and Minutes, is essential.
All members of the RNPSG need to be aware that they are there to represent the community. The Localism Act 2011 gives statutory effect to the Nolan Principles which are: selflessness, integrity, objectivity, accountability, honesty, openness and leadership. Therefore, all members of the steering group need to have regard to these (the Nolan Principles can be found at the end of this email).
The decisions made by the steering group should be taken solely in terms of the public interest, and it is important that personal factors do not affect decisions. If it is found that members of the RNPSG have acted inappropriately it could jeopardise the whole neighbourhood plan.
The steering group should take all steps necessary to ensure no biased decisions have been made. It is generally agreed that the test for bias is ‘a fair-minded and informed observer is neither unduly suspicious, nor complacent’. The Localism Act 2011 also adds clarification in s25, subsection (2) (b) it is relevant to that issue whether the decision-maker, or any of the decision-makers, had or appeared to have had a closed mind (to any extent) when making the decision.
If any member of the steering group does not have a genuinely open mind, this could potentially lead to the rejection of a Neighbourhood Plan or to a successful judicial review.
Therefore, it is in the RNPSG and the Parish Council's best interest that there is transparency, the proper procedures are followed, and that any conflicts of interests are dealt with as soon as they arise. When undertaking a task associated with the production of the Neighbourhood Plan, the RNPSG should ask themselves: Would a fair minded and informed observer find there to be bias? If the answer is yes, the RNPSG should stop the task until the bias has been addressed.
We look forward to the publication of the Riseley Neighbourhood Plan, Terms of Reference, Meeting Agendas, Minutes of all meetings together with all other relevant documents, on the Village website without further delay.
Kind regards
George and Sue Davies
Nolan Principles
1. Selflessness – Holders of public office should act solely in terms of the public interest.
2. Integrity – Holders of public office must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships.
3. Objectivity – Holders of public office must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias.
4. Accountability – Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.
5. Openness – Holders of public office should act and take decisions in an open and transparent manner. Information should not be withheld from there public unless there are clear and lawful reasons for so doing.
6. Honesty – Holders of public office should be truthful.
7. Leadership – Holders of public office should exhibit these principles in their own behaviour. They should actively promote and robustly support the principles and be willing to challenge poor behaviour wherever it occurs.
To Riseley Parish Council
08 august 2022
Dear Riseley Parish Council
I note in the draft Minutes of the July 2022 RPC Meeting you state: KS spoke of her findings of the NP questionnaire after deep diving into find there was no cause for concern and it not being fit for purpose because there was only one official complaint. There is no reason to think that the good people of Riseley would know about the design issues for questionnaires but there is a substantial body of knowledge available on-line. Looking at the number of complaints is not the way to do it. A better course of action would have been to Google "best practice for questionnaire design." The couple of extracts below clearly demonstrate that the Riseley NP questionnaire was very poorly designed and was not fit for purpose.
Best practice for creating items (questions) Imperial College London
Avoid 'agree-disagree' responses
Agree-disagree response options may introduce acquiescence bias, which is the tendency to agree with an item regardless of its content (Wright, 1975).
Asking respondents to rate their level of agreement to different statements can be cognitively demanding, which increases respondent error and reduces respondent effort (Fowler, 2009).
Instead, use verbally labelled response options that reinforce the underlying topic (e.g., the responses for “How happy are you?” would be not at all happy, slightly happy, somewhat happy, quite happy, extremely happy).
Empirical evidence demonstrates that agree-disagree response options diminish item quality and are among the “worst ways to present items”(Saris, Revilla, Krosnick, Schaeffer, & Shaeffer, 2010) and (Gehlbach & Artino Jr., 2018, p. 361).
Use at least five response options per scale
Use at least five response options per scale to capture a wider range of perceptions. Research indicates that the “sweet spot” of the number of response anchors is about five (Weng, 2004; Nielsen, Makransky, Vang, & Danmeyer, 2017).
A five-item scale that assesses a representative cross-section of a respondents experience should improve measurement (Gehlbach & Artino Jr., 2018).
Ask about one idea at a time
Ask about one idea at a time rather than using double-barrelled items, which ask about two or more ideas in the same question (e.g., instead of asking, “How happy and engaged are you?” ask two questions, one about happiness and one about engagement). If you use double-barrelled items, you risk respondents responding to only one part of that item (Dillman, Smyth, & Christian, 2014)
https://www.imperial.ac.uk/education-research/evaluation/tools-and-resources-for-evaluation/questionnaires/best-practice-in-questionnaire-design/
Survey Monkey The go-to guide for crafting better questions
Don’t use double-barrelled questions
Although it might be tempting to combine two questions into one, resist the urge or risk the reliability of your survey data. Take, for example, the following market research question: “Do you like our brand new ice lolly flavour and would you buy it more frequently than the original flavour?”
Since there are two questions embedded within, it’s difficult to gauge what respondents feel about each of the statements.
https://www.surveymonkey.co.uk/mp/online-questionnaires/
Stay away from asking double-barreled questions.
Double-barreled questions are when you ask for feedback on two separate things within a single question.
Here’s an example:
“How would you rate the quality of our product and support?”
How would the respondent answer this question? Would they address the quality of the product? The quality of support? Maybe they’d skip the question or (worse) leave your survey altogether.
You can fix a double-barreled question by either choosing one thing to ask or by breaking the question up into 2 separate ones.
https://www.surveymonkey.co.uk/mp/survey-guidelines/
Kind regards
George.
To Riseley Parish Council
June 19 2022
I noted you made a point of asking Ron if he had completed the Riseley Neighbourhood Plan Consultation Questionnaire and sent it in and you said he should wait for the output from the analysis of those questionnaires. This does not help us as we are very unhappy with the quality of the design of the questionnaire, it was not fit for purpose. So, waiting for the output fills us with dread. We would like access to the anonymised work in progress so that we can understand how they are handing the ambiguity from the poor design.
The golden rule of questionnaire design is only ask one question at a time. This rule was broken frequently in the Riseley Neighbourhood Plan Consultation Questionnaire. The responses you get to a multipart question are meaningless. This is why respondents have used so much free text outside of the defined comments boxes and, in part, why the analysis is taking so long.
Please see the following examples of poor design from the Riseley questionnaire:
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 of which Riseley has two, 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.
Objective D4 Development is preferred on sites with previous development.
Agree Disagree.
There may be other sites which have not been previously developed but have a greater benefit to Riseley - how do respondents answer with only Agree or Disagree as the response?
Objective D5 "Design of housing should be in keeping with the surrounding properties and the village".
Agree Disagree
What does this mean? It depends what is meant by " in keeping". As written, it means that only medieval dwellings can be built within sight of Philip Strickland's house! How do you interpret the replies to this question?
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 and there may be sites where development would give a greater benefit to the village. Unanswerable in its current form.
Objective NE3 "Retain existing trees"
Agree Disagree
Does this mean never cut down another tree in Riseley? Not an absolute, can't answer agree or disagree, there may well be exceptions.
Objective NE5 " Previously developed sites are preferred for development to minimise the risk of flooding"
Agree Disagree
This has two issues in one item and is impossible to answer with agree or disagree. Do 40 dwellings on the Maggie B site represent a bigger or lesser flood risk than 7 bungalows on The Paddock Site 512?
Objective NE6 "Retain the open aspect and views of the brook and the wildlife habitats"
Agree Disagree
Again two concepts in one question, one about the views of the brook and one about wildlife habitats. Impossible to answer with agree or disagree.
Objective NE7 "Protect and enhance biodiversity within the Parish"
Agree Disagree
What does this mean in practice? Unanswerable in its current form.
Objective BE2 " The historic character and heritage assets should be preserved and enhanced"
Agree Disagree
Two things in one broad brush question and neither adequately defined. Unanswerable question
Objective BE3 " High quality design will be secured in all new developments reflecting the distinctive character of Riseley"
Agree Disagree
Amazingly subjective. What is the distinctive character of Riseley and who decides it? How can anyone answer this question without knowing what it means.
Objective BE4 "Rooflines (heights) of new developments should be compatible with surrounding dwellings".
Agree Disagree
What does "compatible" mean? Does it mean one can not build a house if surrounded by bungalows or bungalows adjacent to houses?
The questionnaire asked for responses differently in the on-line version and in the hard copy version.
In the on-line version, respondents were asked to mark "Agree" or "Disagree" as the response. In the hard copy version, respondents were asked "Do you agree?" then mark "Yes" or "No" as the response. The on-line version should have been identical to the hard copy version. Using a different response format can introduce ambiguity into the meaning of the responses.
Free text
Because of the poor quality of the design of the questionnaire respondents put free text outside of the defined comments boxes, please see example below. The RNPSG decision, as stated in their minutes dated November 21, not to include comments written outside the defined comments boxes in the questionnaires is unacceptable.
The need for meaningful dialogue between those of us who are unhappy and the Parish Council and their sub-committee, the Riseley Neighbourhood Planning Group is greater than ever.
Best regards
George
Example of free text outside of the comments box which the RNPSG say they are going to ignore.
From: George Davies <georgedavies160@gmail.com>
Date: 24/05/2022 10:52:16
Subject: Re: Response email
To: Sam Langley <riseleyparishclerk@outlook.com>
Dear Sam
Thank you for your email dated 20/05/2022.
Responding to the statement in your email:
"Neither the RPC or the RNPSG have received notification of any further errors or inaccuracies with the AECOM report that are considered to be factual and/or verifiable at this point in time."
Please find attached a detailed list of errors / inaccuracies with the AECOM report and the Analysis of the Site Suitability Assessments conducted by Riseley and AECOM report, that I consider to be factual and/or verifiable at this point in time and need correcting. If not corrected then the AECOM report and the Analysis of the Site Suitability Assessments conducted by Riseley and AECOM report, for Site 512 should not be included in the draft Riseley Neighbourhood Plan and should also be removed from the village website.
My document is 57 pages long, detailed and evidence based, unlike the AECOM report.
It would have been much better to have been able to have meaningful dialogue with the Parish Council / RNPSG rather than enter into email ping pong.
I refer you to Duncan's email, as Chair of the Riseley Parish Council, to me, dated 19 November 2021 where he stated "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." This never happened.
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 dialogue takes 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,
As you can see in the emails in the attached document, I raised many issues regarding the AECOM report, with Mark and Riseley Parish Council back in August 2021 before the September public consultation.
I look forward to hearing from you.
Best regards
George
On 20/05/2022 09:17:08, Sam Langley Clerk to RPC <riseleyparishclerk@outlook.com> wrote:
Dear Mr Davies,
With reference to your email of 30th March.
You questioned the following statement in the decision paper.
‘Currently no housing development is likely to receive planning permission outside the SPA.’
We do not agree with your claim that this statement is incorrect. The quoted 7S is an exceptions policy and the key term here is ‘is likely’. The response to the planning application for site 512 in December 2020 states that “it is possible for development to be supported outside the SPA…” These are not mutually exclusive statements and can therefore both be viewed as correct.
The information provided for the Regulation 14 consultation will publish the information you have requested. Please wait for this to be published.
With reference to your email of 25th April.
Clearly, it is necessary for drafts of documents, in part or in whole, to be circulated amongst RNPSG committee members as part of the preparation of any document, including the Draft Riseley Neighbourhood Plan. This is ongoing and the final draft will be published in due course.
Concerning inaccuracies in the AECOM report. You reported an error to RNPSG about the AECOM reports. The OS map showed a track running across site 512. This was not a PROW. AECOM corrected their report, and all adjustments were made to the information presented by RNPSG. All this has been communicated to you previously.
Neither the RPC or the RNPSG have received notification of any further errors or inaccuracies with the AECOM report that are considered to be factual and/or verifiable at this point in time.
When making applications for planning approval to Bedford Borough Council, landowners will be able to present very detailed information. Within this they can address any issues they may have with either the AECOM or RNPSG reports, and the Borough Planning Committee will give their decision at that time. We do not see any reason why the AECOM report as it currently stands should be corrected or removed from the public domain.
Regards
Sam Langley
Clerk & RFO to The Riseley Parish Council
130 High Street
Riseley
Beds
MK44 1DJ
07977828153
Email: RiseleyParishClerk@outlook.com
|
|
Dear Sam.pdf Size : 1249.12 Kb Type : pdf |
April 2022
Dear Riseley Parish Council
Thank you for publishing the Neighbourhood Plan Steering Group Decision Paper on the village website. The Decision Paper is a significant public document which unfortunately contains an error. Rather than reading out documents at the Parish Council Meeting it would be very helpful if they were attached to the agenda and published on the village website ahead of the meeting.
If it had been published with the agenda, the error could have been identified and fixed before it was discussed by the Parish Council.
In the Decision Paper option B, no sites to be allocated, it states: "Currently, no housing development is likely to receive planning permission outside the Settlement Policy Area."
This statement is incorrect.
Bedford Borough Council Policy 7S deals with development outside the Settlement Policy Area (SPA). Development proposals will be supported on sites, outside of the SPA, where there is identifiable community support and the proposal is made or supported by the parish council and all of the criteria in Policy 7S are met. Please see the email below from Kim Wilson, Team Leader – Planning Policy, Bedford Borough Council. So outside of the neighbourhood plan process it is possible for development to be supported outside of the SPA where all of the criteria in Policy 7S are met. The Decision Paper implies the opposite.
It is also worth noting that Planning Application 21/00744/FUL, for the erection of 7 new dwellings on land outside the SPA, in Little Staughton, was recently approved by Bedford Borough Council using Policy 7S, not withstanding objections from the Parish Council. Little Staughton does not have a Neighbourhood Plan.
Even without allocating sites in the Riseley Neighbourhood Plan, Riseley Parish Council has considerable power and influence at their disposal, to enable Riseley to develop in ways that the people of Riseley want. This has not been recognised or made clear in the Decision Paper.
As the decision has been taken not to allocate any sites, there are no longer any conflicts of interest or financial implications and a much more open approach by Riseley Parish Council and RNPSG is both desirable and possible. This opens the door to a far more inclusive and less secretive and controlling approach being adopted by the Neighbourhood Planning Steering Group and Riseley Parish Council.
We ask that you please publish, without delay, all the information the Neighbourhood Plan Steering Group currently has, marked work in progress if necessary. Let's get more inclusion going, let's really make this a Riseley project not just just the work of a few behind closed doors. As an indicator of the opaque style used to date, we don't know what information the NPSG have. If there is a design guide please publish it without delay. If there is aggregated anonymised data available from the public consultation, including comments not in the comments boxes, please publish it without delay. If there is anything relating to addressing the climate change crisis, please publish it.
Please do not publish a draft plan until the sources underpinning the draft plan have been examined by the people of Riseley. Serious errors in the material published to date does not bode well for future publications.
The secretive and controlling style has not helped the people of Riseley. It is not too late to adopt a much more inclusive style. As part of this new approach and as a fresh start, you could consider appointing a new planning consultant. Put it all out in the open and let the people of Riseley identify and fix any errors and together we can build our own plan rather than have a plan imposed upon us.
Kind regards
George
160B High Street
Riseley
Bedford
MK441DR
07768 197549
On 28/03/2022 15:52:26, Planning Policy <planning.policy@bedford.gov.uk> wrote:
Good afternoon Mr Davies,
Policy 7S is an exceptions policy – exceptionally development proposals will be supported on sites… ….where there is identifiable community support AND the proposal is made or supported by the parish council. So outside of the neighbourhood plan process it is possible in principle for development to be supported outside of the settlement policy area where all of the criteria in the policy are met.
I hope this helps.
Kind regards,
Kim Wilson
Team Leader – Planning Policy
Bedford Borough Council
Dear Riseley Parish Councillors
January 2022
A period of review and a restart of the Neighbourhood Plan is needed.
As preparation for the Riseley Neighbourhood Plan Agenda item at the next meeting, on January 20th, I have put together some notes to help you review where we are and to consider the best way to move forward and build on the work done to date.
“We can either sit back and get what we’re given or we can say what we want and what’s important to us. This is our village and we should have a say in it’s future; a Neighbourhood Plan enables us to do that.” Mark Chamberlain, Chair of the Riseley Neighbourhood Planning Group, Sept 2021 Village Newsletter.
I don’t think that it has been done intentionally but the public consultation, last September, felt much more like a process to confirm an existing plan rather than an attempt to consult with the village. It was flawed and no matter how much hard work is put into analysing it, it remains flawed and only limited confidence can be given to the output.
It should be the people of Riseley who say which sites they think should be allocated to the Neighbourhood plan not a third party consultancy, AECOM, not Bedford Borough Council and definitely not a statistical analysis.
A key element of a public consultation is that the information is correct and as much information as possible is put into the public domain at an early stage to give people time to understand it. This was not the case in Riseley. A mountain of information, containing inaccuracies was dropped on the people of Riseley, in one hit, and they were then asked to complete a 20 page questionnaire as they left the village hall.
For all public consultations it is important that the content of the consultation does not come out of the blue, and the local community should be kept informed of developments as the plan is formulated.
On Sunday morning, 19 September 2021, Riseley Neighbourhood Planning Group published on the Parish Council website, 177 pages of AECOM report, 30 pages of Riseley report, a complex 20 page questionnaire and 18 display boards of information were put up in the Village Hall.
On 21 September -after being chased, 24 pages of statistical analysis of the site suitability assessments conducted by Riseley and AECOM were put on the website.
Once a Neighbourhood Planning Group has gathered all the relevant data, that information should be published using all the usual avenues, website, social media, hard copies, workshops etc the Neighbourhood Planning Group should then be available to answer questions, provide clarification, correct any errors. The AECOM report was passed to the RNPG in February 2021 giving 6 months for it to be checked for accuracy with stakeholders and then shared with the people of Riseley before the public consultation village hall event in September. This was not done. There were and still are errors in the AECOM site suitability assessment reports.
There was a significant error on one of the display boards in the village hall wrongly describing land designated as Village Open Space as being Green Belt. This is incorrect, there is no Green Belt land in Bedford Borough, Local Green Spaces, Ross Meadow and The Playing Field can be described as akin to Green Belt land and Bedford borough Council have confirmed that Village Open Spaces are not Green Belt.
The use of statistical analysis is inappropriate for a Neighbourhood Plan. It is difficult for many people to understand and almost impossible from most people to be able to question it.
After a reasonable period, when people have had time to assimilate the information, it is normal to hold forums and or exhibitions for the wider public where information is presented, and people involved in its preparation are available to provide clarification and answer questions Open days on the 19 proposed sites and organised village walks would have been good to help people understand the pros and cons of each of the 19 sites.
It is following this consultation period that the general feedback from simple questionnaires can be collected and taken into account with all the other feedback.
In the case of neighbourhood plans the group should keep the community informed and engaged as they then move forward.
Locality, the Government sponsored Neighbourhood Planning consultancy and provider of the grant money, have a paper entitled:
Engaging with your community in a meaningful way, which states:
“These are the key steps you will need to follow in carrying out community engagement in your neighbourhood plan:
1)Publicise the proposal to produce a neighbourhood plan.
2) Identify key local partners and stakeholders and develop working arrangements to gain their involvement and support.
3)Formulate a programme of community engagement.
4) Carry out initial community engagement and analysis to identify issues and themes.
5) Undertake on-going community engagement to support the development of policy and content of the plan.
6) Provide feedback at all stages.
7) Consult on the draft plan.
Stakeholder groups will differ hugely from community to community. The important thing is that you identify the people and groups who will be affected by your plan and influence its success. These people will range from councillors to landowners to representatives of hard-to-reach and minority communities.”
Riseley Neighbourhood Planning Group have not followed this guidance, they have not spoken to, let alone formed a relationship, with local partners and stakeholders. No programme of community engagement has been published. No feedback provided. Just lots of things going on behind closed doors.
Community Engagement
There has been no substantive feedback from the Riseley Neighbourhood Planning Group, no minutes of any of their meetings just bland reports to the Parish Council, no engagement with landowners or any other stakeholders. No attempt to talk to stakeholders and others, about the accuracy of the information to be consulted on. Only the most basic attempt at community engagement with a page in the Village Newsletter. Way back in December 2018, in the Village Newsletter, we were promised and I quote:
“A summary of the comments and all of the original comments received will be posted on a specific Neighbourhood Plan website that will be released in the New Year” .
This never happened and represents a lost opportunity for community engagement.
No minutes are available for any of the Riseley Neighbourhood Plan Group Meetings. It has been and continues to be a totally opaque process.
The Riseley Neighbourhood Plan Public Consultation Questionnaire
The Riseley Neighbourhood Plan Consultation Questionnaire was poorly designed and not fit for purpose. It frequently asked respondents to give a yes no or agree or disagree response, to complex multifaceted questions.
The questionnaire asked for responses differently in the on-line version and in the hard copy version.
In the on-line version, respondents were asked to mark "Agree" or "Disagree" as the response.
In the hard copy version, respondents were asked "Do you agree?" then mark "Yes" or "No" as the response. The on-line version should have been identical to the hard copy version. Using a different response format can introduce ambiguity into the meaning of the responses.
Questionnaire design
The golden rule of questionnaire design is only ask one question at a time in each item. This rule is broken frequently. Please see the following examples:
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.
Objective D4 Development is preferred on sites with previous development.
Agree Disagree.
There may be other sites which have not been previously developed but have a greater benefit to Riseley - how do respondents answer with only Agree or Disagree as the response?
Objective D5 "Design of housing should be in keeping with the surrounding properties and the village".
Agree Disagree
What does this mean? It depends what is meant by " in keeping". As written, it means that only medieval dwellings can be built within sight of Philip Strickland's house! How do you interpret the replies to this question?
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 and there may be sites where development would give a greater benefit to the village. This question can't be answered in its current form.
Objective NE3 "Retain existing trees"
Agree Disagree
Does this mean never cut down another tree in Riseley? Not an absolute, can't answer yes/no, there may well be exceptions.
Objective NE5 " Previously developed sites are preferred for development to minimise the risk of flooding"
Agree Disagree
This has two issues in one item and is impossible to answer with agree or disagree. Do 40 dwellings on the Maggie B site represent a bigger or lesser flood risk than 7 bungalows on The Paddock Site 512?
Objective NE6 "Retain the open aspect and views of the brook and the wildlife habitats"
Agree Disagree
Again two concepts in one question, one about the views of the brook and one about wildlife habitats. Impossible to answer with agree or disagree.
Objective NE7 "Protect and enhance biodiversity within the Parish"
Agree Disagree
What does this mean in practice? Unanswerable in its current form.
Objective BE2 " The historic character and heritage assets should be preserved and enhanced"
Agree Disagree
Two things in one broad brush question and neither adequately defined. Unanswerable question.
Objective BE3 " High quality design will be secured in all new developments reflecting the distinctive character of Riseley"
Agree Disagree
Amazingly subjective. What is the distinctive character of Riseley and who decides it? How can anyone answer this question without knowing what it means.
Objective BE4 "Rooflines (heights) of new developments should be compatible with surrounding dwellings".
Agree Disagree
What does "compatible" mean? Does it mean one can not build a house if surrounded by bungalows or bungalows adjacent to houses?
Climate Change
Locality are clear that Neighbourhood Plans must have Climate Change at their heart. They state:
“Climate change is single biggest threat to the future of our society and dealing with its implications has to be at the heart of all Neighbourhood plans. The growing and severe impacts of climate change mean that any plan made now that does not consider radical reductions in carbon and help build our resilience to things like flooding will simply not be fit for purpose. Despite their popularity, recent research has shown that the overwhelming majority of plans already adopted simply do not consider these issues in any meaningful sense. Neighbourhood plans will be in force for 15-20 years. If they are to successfully help communities deal with the future we will actually experience, they must move away from the narrow focus on accommodating housing that has blighted local planning in general, and move to an approach that plans for resilient, sustainable communities.
Has the Riseley Neighbourhood Plan paid any/enough attention to the Climate Change?
December 17 2021
Morning Duncan
As you know I made a request in the Open Forum last evening. .
"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."
Alison replied that such meetings are part of the NP process but they will not take place for months. Is there anything the Parish Council can do to enable meaningful discussions to take place sooner rather than later?
Thank you
George
From: Duncan <duncnik.steward@btinternet.com>
Date: 19/11/2021 08:39:49
Subject: Policy AD40, Village Open Space, AECOM and site 512.
To: George <georgedavies160@gmail.com>
Cc: Sam Langley <
riseleyparishclerk@outlook.com
Without Prejudice
Dear George
Firstly please accept my apologies for the delay in responding to your email addressed to the Parish Council. I’m sure you will appreciate that I had to scrutinise the points you raised and seek suitable advice and guidance - also where the heck does the time go when you’re retired?
I acknowledge your frustration of your perceived role of AECOM in the planning process which I am assured, was to provide professional assessments for each of the sites along with some guidance - which was contained within their report. It is/was not for AECOM to allocate or reject any site for development as this is outside of their remit and they have not attempted to do so. Following the recent Village consultation there are now several further stages to draft a plan and consult again with both the local community and Bedford Borough Council. The allocation of sites for development in the final plan will be just one of the outcomes of this process.
Although your main point of Policy AD40 being the main stumbling block, we have to be cognisant that this is not the sole negative criterion for site 512, this forms one of several benchmarks that received a red assessment.
The examples you provide, from the Bedford Borough Council Planning Committee, some of which mirror your site, demonstrates consent to planning applications that have not complied with Policy AD40. It is likely that further searches could provide examples where Policy AD40 has been upheld and planning permission refused - proof the application of the system is working.
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.
Our Neighbourhood Plan will continue to follow the prescribed procedures and when ready the draft plan will be available for scrutinisation by the local community, Bedford Borough Council and placed in the wider public domain for comment. It will be examined by an independent examiner and subjected to a full referendum in our community, then and only then can it be adopted by the Parish Council.
I hope the above answers the salient points of your email, if it doesn’t please do not hesitate to contact me.
Kindest regards
Duncan
DUNCAN STEWARD
Chairman, Riseley Parish Council
Dear Riseley Parish Council
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. These are detailed in the Appendix attached.
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.
Proposal to allocate
Based on the analysis above we request that Site 512 is added to the current 11 sites allocated sites which are also subject to consultation with Bedford Borough Council.
George and Sue Davies
Dear Duncan
Riseley Neighbourhood Plan Site 512 The Paddock
I have been in contact with AECOM and they tell me that no decisions on site allocations are taken by AECOM. Decisions are the responsibility of the Parish Council in consultation with the local community and key stakeholders. AECOM also told me that their reports are intended to assist in this process and that they make it clear to Qualifying Bodies that they should continue to engage with landowners and other interested parties when selecting sites for allocation. They said this includes consideration of any evidence which may affect the conclusions in the AECOM site assessment reports, which are intended to be a snapshot in time based on the information available to them at the time of assessment. They also told me that their technical support to Riseley Parish Council formally concluded in February 2021 when they delivered their final report.
An examination of the Site Suitabilty Assessment carried out by the local Riseley Neighbourhood Plan Group shows that Site 512, based on this local assessment, gets a high score of 4, and should be allocated for development in the Riseley Neighbourhood Plan. The one red score, in the local Riseley Assessment very sensibly states: "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." It should also be noted that the land rises sharply from the High Street and then very gently slopes to the back of the site. The initial sharp rise means that even without the trees you can't see into the site from the High street except through the gateway.
Table 8 in the Analysis of the Site Suitability Asessments conducted by Riseley and AECOM, confirms the local Riseley Assessment score for Site 512 is 4 while the AECOM assessment gives it a score of 12, which pushes it out of the sites to be allocated. The Neighbourhood Plan Group then use a statistical correlation exercise to try and convince themselves and others that what AECOM have done fits with the local view which it clearly does not.
This means that Site 512 has not been allocated on the basis of Spearman’s rank correlation, which is a non-parametric measure of rank correlation and Student’s t test against a null hypothesis.
Since first receiving a copy of the AECOM Site Suitability Assessment on 20 August, AECOM have corrected two RAG errors, giving two additional green scores to Site 512. The Policy AD40 issue is now correctly identified in the AECOM Site Suitability Assessment section in "Policy Constraints" and correctly and significantly is scored amber not red. In the "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". To make the "overall rating" red is over reach by AECOM.
With regard to Policy AD40, we need to go back to the appendix to the Inspector’s Report on the Examination into the Bedford Allocations and Designations Local Plan – June 2013. The Inspector stated:
145.I am concerned, however, about the overly stringent wording of Policy AD42 which states that development will not be permitted on land designated as a village open space or view. I consider that in reality an important consideration in determining proposals on such areas will be whether the reasons for designation would be compromised if the development was allowed to proceed. There may, for instance, be occasions where the loss of a small part of an open space may not prejudice the overall integrity of the space or undermine its contribution to the local area. Furthermore it may be the case that the retention of a designated space may be outweighed by other material considerations, for instance significant community benefits that could not otherwise be achieved.
146.Consequently I consider that the wording of Policy AD42 needs to be revised to make it clear that in determining proposed development account will be taken of the reasons for designation and other material considerations. Without these wording changes Policy AD42 would not be effective or accord with the NPPF.
The wording was changed in line with the Inspectors request and it became Policy AD40.Village Open Space and Views. The word "important" was dropped by Bedford Borough Council in 2013.
It should not be up to AECOM to conclude Policy AD40 will prevent development on Site 512 when the Inspector in 2013 was clearly concerned "about the overly stringent wording" and relaxed Policy AD40 to make it more flexible and therefore accord with the National Planning Policy Framework NPPF.
Policy AD40 designation is not equivalent to “Green Belt” as was implied at the Public Consultation exhibition. Local Green Space designation, of which Riseley has two, the playing field and Ross Meadow is equivalent to “Green Belt”. Bedford Borough Council in the 2030 Local Plan acknowledge that Policy AD40 is a lower tier of protection than Policy 46 Local Green Space. Site 512 was not considered worthy enough even be put up for consideration as a possible Local Green Space in Riseley.
Policy AD40 seems to be the only reason Site 512 is not allocated in the Riseley Neighbourhood Plan by AECOM. Site 512 should be allocated with the caveat that consultation with Bedford Borough Council would be required to determine if a layout/design can be agreed that does not compromise the two reasons for designation D and E and to take into account the material considerations of public access to the site for the first time ever, together with the provision of disabled friendly allotments and a 106 agreement to confine sales of the retirement bungalows to people with a connection to Riseley. Clear material benefits which are not being proposed on any other sites in Riseley.
In the AECOM Riseley Site Options Report, Site 512 currently scores only 3 reds (Grade 3b land, The National Habitat Enhancement Zone and Greenfield). It is hard to argue against Grade 3b land and Greenfield but with regard to The National Habitat Enhancement Zone, we have had an Ecological Study done, including eDNA testing for Great Crested Newts and a reptile survey. The full report is available if you want to see it. The ecologist told us that because the site is adjacent to houses and gardens on three sides, is too attractive to the local cats, who patrol the site constantly to the detriment of wildlife. The ecology report is evidence that this site does not have the potential to support priority species nor does it contain local wildlife-rich habitats. It should score green which would give just two reds Greenfied and Grade 3b soil which apply to most of the sites.
I am also still waiting for a reply to my question regarding "Significant trees adjacent to the site" which AECOM scored Yes -amber. Which tree or trees are being referred to? This item should be green.
The Parish Council should pay more regard to local opinion and less regard to AECOM and Site 512 should be allocated for development in the Riseley Neighbourhood Plan with the caveat listed above.
Regards
George and Sue Davies