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Date: 29 August 2017 Our Ref: 220438 Your Ref: Jason Longhurst Director

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Date: 29 August 2017 Our Ref: 220438 Your Ref: Jason Longhurst Director Date: 29 August 2017 Our ref: 220438 Your ref: Jason Longhurst Director of Regeneration and Business Customer Services Central Bedfordshire Council Hornbeam House Crewe Business Park Electra Way BY EMAIL ONLY Crewe [email protected] Cheshire CW1 6GJ T 0300 060 3900 Dear Mr Longhurst Central Bedfordshire Draft Local Plan, Regulation 18 consultation Thank you for your consultation on the above dated 04 July 2017 which was received by Natural England on 11 July 2017. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. SUMMARY OF NATURAL ENGLAND’S ADVICE There are many elements of the Plan which Natural England supports, including policies which aim to protect and enhance the natural environment. However, a number of issues need to be addressed as follows: The Plan needs to demonstrate how proposals will deliver biodiversity net gain, including buffering and enhancing the resilience of designated sites. The Plan must be accompanied by a Habitats Regulations Assessment (HRA) to assess the effects of Plan development, alone and in-combination, on European sites. This must be used to inform the Sustainability Appraisal (SA) on the potential effects of proposals alone and cumulatively; All allocations should be assessed alone, and cumulatively, through the SA to demonstrate that sites taken forward can be developed sustainably and without adverse effect to the natural environment including designated sites. Evidence based assessments should be used to inform the SA and identify mitigation needed to address adverse effects. Relevant policies should require proposals to implement those mitigation measures and specify a clear funding mechanism for their delivery; The Plan needs to address the issue of increased recreational pressure associated with proposed growth on designated sites and the wider green infrastructure network. Again, this should be assessed through the SA and appropriate mitigation to address adverse effects identified. Page 1 of 17 Our detailed advice is provided in Annex 1 to this letter. Detailed advice on the potential site allocations is provided in Annex 2. I hope these comments are helpful. For any queries relating to the specific advice in this letter only please contact Steve Roe on 0208 225 7685 or Lynne Collins on 0208 026 1677. For any new consultations, or to provide further information on this consultation please send your correspondences to [email protected]. Yours sincerely Aidan Lonergan Area Manager West Anglia Area Team, Eastbrook, Shaftesbury Road, Cambridge, CB2 8DR Tel: Mobile: Page 2 of 17 Annex 1: Central Bedfordshire Draft Local Plan (2015-35) Natural England Detailed Comments Central Bedfordshire Draft Local Plan Section 2.3.2 Natural England welcomes that the Council will seek opportunities to maximise the use of available, previously developed or ‘brownfield’ land before looking to sites within the Green Belt or green field sites elsewhere in Central Bedfordshire to accommodate future growth requirements. In accordance with paragraph 111 of the NPPF we advise the inclusion of a policy / policy wording to encourage the re-use of brownfield land provided that it is not of high environmental value. This should be inherent in the site allocation process and development management policies. Section 2.6 Environment, Heritage Assets and Sustainability Natural England welcomes this section and recognition that much of Central Bedfordshire is of high landscape and biodiversity value supporting key assets such as the Greensand Ridge Nature Improvement Area (NIA), parts of the Chilterns Area of Outstanding Natural Beauty (AONB) and the Forest of Marston Vale. We advise that this section should also recognise geodiversity assets and heritage, particularly given the importance of geology within the National Character Areas, especially the Greensand Ridge. This will ensure consistency with later sections in the Plan which recognise the need to protect and enhance sites of geological and geomorphological importance, including policies EE1 and EE2. Natural England agrees that a key challenge of the Local plan is to find ways in which new development can be used to strengthen and enhance natural environment assets, in addition to creating new green infrastructure. Natural England advises that specific issues for the natural environment, associated with proposed growth, should be identified at this early stage in the Plan. A number of nationally and internationally designated SSSIs are particularly sensitive to the effects of development including increased recreational pressure, changes in air quality and changes in water quantity and water quality. The Local Plan, informed by the SA will need to ensure there will be no adverse effect to these sites through site allocations and policies. Vision and Objectives Natural England is generally supportive of the Local Plan Vision and Objectives; however, we would expect the Vision for Central Bedfordshire 2035 to aspire to a high quality natural environment, rather than just a high quality landscape. Notwithstanding this, we welcome environmental objectives S011-SO13 and recognition of the multi-functional benefits of green infrastructure including biodiversity enhancement, improved health and well-being and helping to mitigate the effects of climate change. Paragraph 5.3.2 We understand from the Growth Studies that have been undertaken that developer contributions are required for large strategic sites to allow the developments to be considered sustainable. We have not been able to examine the Growth Studies, due to time constraints; however, we are keen to ensure that developer contributions include the provision of appropriate natural capital infrastructure to achieve biodiversity net gain in accordance with paragraph 109 of the NPPF, where relevant, and to mitigate the impacts of increased recreational pressure on the existing green infrastructure network. Section 7.5 Spatial Strategy Approach We welcome recognition of the environmental constraints and opportunities across the district such as Greensand Ridge NIA and the proposed extension to Forest of Marston Vale. The Plan includes generic policies to protect and enhance these areas; however, relevant site allocations policies will need to include robust requirements to deliver specific mitigation and enhancement measures in these areas, along with a clear mechanism for their delivery / funding. Mitigation and enhancements for each allocation should be identified through the SA. Page 3 of 17 We recognise that the County faces challenges in accommodating new economic growth and housing provision to meet needs. We also recognise that appropriately sited strategic infrastructure – such as East West Rail, improvements to the A1 and the Oxford – Cambridge Expressway are important to facilitate development. We advise that such improvements should clearly demonstrate how they can deliver connections with strategic green infrastructure (GI) corridors and known ecological networks, in order to achieve biodiversity net gain. In particular, every effort should be made to ensure that strategic infrastructure does not sever existing GI corridors and ecological networks. Policy SP1: Growth Strategy We note that the Plan proposes to deliver a minimum of 20,000 new homes. Policy SP1 indicates that, subject to further assessment of sustainability and deliverability, new development will be planned for at a selection of the sites listed. Notwithstanding the need for further detailed assessment, Natural England has provided some comments on proposed growth locations below. With reference to section 8.4.5 we welcome that strategic locations should be accompanied by a comprehensive masterplan for the whole site. Natural England’s advice is that this should include an assessment of existing natural capital and ecosystem services in the location in order to provide a baseline to demonstrate how the proposal will deliver biodiversity net gain in accordance with paragraph 109 of the NPPF. Section 8.5 Summary of Housing Growth Locations We note that the long list of growth locations will be refined to form a shortlist of preferred site allocations in the next version of the plan. A number of these locations, including North of Luton, New Villages to the East of Biggleswade and East of Arlesey, include land designated as SSSI. Natural England will object to any allocation likely to have an adverse effect on a SSSI. The SA will need to carefully assess the potential impacts of development in these locations, alone and cumulatively, on the natural environment, including designated sites. Potential pathways for impacts include increased recreational pressure, changes in air quality and changes in water quantity and water quality. Appropriate mitigation will need to be identified to address any adverse effects. Implementation of mitigation measures and a mechanism for their delivery/funding will need to be secured through the relevant allocation policies. A number of growth locations, such as North of Luton and West of Luton, are within / within the setting of the Chilterns AONB. We are not aware that a Landscape and Visual Impact Assessment (LVIA) has been undertaken to assess the impact of development in these locations on the AONB and its setting and to identify whether mitigation measures could
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