The Paddock Riseley

Who are AECOM?

Riseley Parish Council, through the Riseley Neighbourhood Plan Steering Group, subcontracted the Site Suitability Assessments to the multinational consulting firm AECOM plc  www.aecom.com 

Dear Duncan

October 2021

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.

 t 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

October 6 2021

Morning Duncan

Please find below an email from AECOM confirming that AECOM do not take decisions on site allocations and as you have confirmed to me, it is the Parish Council which makes the final decision on allocation.  What can I do from my end to get Site 512 reconsidered for allocation?

When you get a moment please do give me a call on 07768 197549.

Many thanks

George

------ Forwarded Message --------
From: Fearn, Tim <tim.fearn@aecom.com>
Date: 22/09/2021 12:33:14
Subject: RE: [EXTERNAL] Re: Re Site 512 in the Riseley Neighbourhood Plan Site Options Assessment
To: George Davies <georgedavies160@gmail.com>

Dear Mr Davies,

Thank you for your email.

Unfortunately we are unable to enter into direct dialogue with landowners and site promoters over the content of our independent site assessment reports. No decisions on site allocations are taken by AECOM. They are the responsibility of the Parish Council or other Qualifying Body in consultation with the local community and key stakeholders. While our reports are intended to assist them in this process we do make it clear to Qualifying Bodies that they should continue to engage with landowners and other interested parties when selecting sites for allocation. This includes consideration of any evidence which may affect the conclusions in our site assessment reports, which are intended to be a snapshot in time based on the information available to us at the time of assessment.

Our technical support to Riseley Parish Council formally concluded in February 2021 when we delivered our final report, although we recently responded to the Neighbourhood Plan Steering Group following queries about the site assessment. I recommend that you contact the Parish Council directly if you wish to discuss the possibility of Site 512 being allocated in the Neighbourhood Plan.

Kind regards,

Tim 

Tim Fearn BA (Hons.), MSc

Senior Planner

Buildings + Places

UK + Ireland

Tel: +44 (0)7502 166 726
tim.fearn@aecom.com

Email to Riseley Parish Council 24 May 2022 

Please find belowa 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.