Date: 29 August 2017 Our ref: 220438 Your ref:

Jason Longhurst Director of Regeneration and Business Customer Services Central 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 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.

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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, , CB2 8DR

Tel: Mobile:

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Annex 1: 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.

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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 , New Villages to the East of and East of , 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 adequately address adverse effects. Our advice, in the context of paragraphs 115 and 116 of the NPPF, is that housing allocations in the AONB would be classed as major development. Consequently any proposals taken forward in these locations will need to:  demonstrate need for the development in that location, including national considerations and the impact of permitting it, or refusing it, upon the local economy. Justification and robust evidence to demonstrate need will be required.  show what reasonable alternatives have been considered. The LPA must consider the cost of, and scope for, developing outside the designated area, or meeting the need for the development in some other way. The SA should set out the alternative locations/sites considered to meet the housing need elsewhere or alternative ways of meeting the need, as well as the rationale for selecting the allocation site.  provide detailed mitigation measures to demonstrate that any detrimental effects on the AONB and/or its setting can be moderated.

Natural England will not support any proposals for development within the AONB or its setting without adequate and robust evidence to address the above requirements. Our advice is that these requirements can be most appropriately addressed through an LVIA. We recommend that the Council seeks further advice on this matter from the Chilterns Conservation Board.

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Policy SP3 Development in the Green Belt Natural England generally welcomes this policy to protect and enhance the beneficial uses of the Green Belt including biodiversity, visual amenity and access.

Policy SP7 Gypsy and Traveller and Travelling Showpeople Pitch Requirement Natural England advises that potential site allocations will need to be assessed through the HRA and SA to ensure development will not have an adverse effect on the natural environment including designated sites and landscapes. This should be acknowledged in Policy SP7 along with a requirement for mitigation to address adverse effects.

Policies EMP1, EMP2, EMP4 and EMP6 Natural England advises that these policies promoting new employment sites / uses should include a requirement for proposals to demonstrate no adverse impact to the natural environment including designated sites and landscapes.

Policy EMP5: Rural and Visitor Economy We welcome that proposals for static holiday and touring caravan parks and holiday chalet developments will be considered against the need to protect valuable landscapes and environmentally sensitive sites. Our advice is that this should apply to all rural and visitor economy proposals, hence the policy should be amended accordingly.

Section 15 Transport We advise that policies (such as Policy T2) are strengthened with links to policies on GI and ecological networks in order to recognise the contribution that highways verges and railway embankments can make to local biodiversity and in strengthening ecological networks.

This section should also recognise the potential for transport proposals to protect and enhance the natural environment including designated sites. Proposals should be required to demonstrate no adverse effect to air quality sensitive designated sites, directly or indirectly, including through changes in air quality.

Section 16 Environmental Enhancement Natural England is strongly supportive of this section which seeks to ensure the protection and enhancement of Central Bedfordshire’s natural environment including designated sites and landscapes, strategic green infrastructure areas such as the Greensand Ridge NIA and the Forest of Marston Vale.

We advise that the Bedfordshire Local Nature Partnership (BLNP) is referenced within the Local Plan to evidence the Councils’ historic and ongoing involvement in the BLNP.

Policy EE1 Green Infrastructure Natural England generally supports this policy; however, we advise that the first sentence should be reworded as follows:  Developments of new buildings Proposed residential development must demonstrate a net gain in green infrastructure;

The policy should recognise the importance of GI as a key land use providing a counterpoint to the need for development land, serving to balance built development. The policy should clearly recognise the multi-functionality and value of GI provision and enhancement for people and wildlife. Its function in helping to absorb recreational pressure and divert additional pressure away from more sensitive sites is particularly important in light of current pressures on designated sites, and the levels of proposed growth through the Plan. We advise that the policy be amended to address these points.

The issue of additional recreational pressure associated with proposed growth, and measures needed to address this, should be addressed through the SA, having regard to the objectives of the strategic and district Green Infrastructure strategies. The findings of the SA, relating to GI, should be referenced in Policy EE1. Mitigation measures identified in the SA should be secured through the

Page 5 of 17 relevant site allocation policies together with a clear delivery/funding mechanism. Natural England is studying general patterns of visitor behaviour through the Monitoring Engagement with the Natural Environment (MENE) project. You may find it helpful to refer to the further information available on our website: https://www.gov.uk/government/collections/monitor-of-engagement-with-the-natural-environment- survey-purpose-and-results

We advise that this policy needs to include more robust requirements for proposals to deliver the objectives of the strategic and district GI strategies and thus achieve net gain.

Central Bedfordshire includes areas identified by Natural England where landscape scale biodiversity enhancement is needed to enhance resilience of designated sites through creation of buffering and connecting habitat. These include the Ouse Valleys, Bedfordshire Greensand Ridge and the West Hundreds ancient woodlands (located within/close to the CBC district boundary). Policy EE1 should recognise these areas and include requirements for proposals to deliver or contribute towards landscape scale enhancements.

It is not clear how the plan makes provision for an appropriate quality and quantity of natural green space to meet identified local needs, as part of wider open space provision, and to plan positively to remedy any deficiencies. This should be addressed / clarified within Policy EE1, or Policy EE12, although this latter policy seems to be more about formal open space provision.

Policy EE2 Enhancing biodiversity We welcome the requirement for proposals to deliver net gain in biodiversity. We recommend that this Policy might be strengthened by linking enhancements, ecological networks and Priority Habitats to national and local targets.

To make developers aware of the benefits of the emerging district level great crested newt (GCN) licence we advise inclusion of additional wording along the following lines:  A District Level Licence for GCN in Central Bedfordshire is currently being prepared. The aim of this licence is to reduce delays, costs and uncertainty for developers whilst providing strategic habitat compensation to improve long-term nature conservation for GCNs.

We recommend that reference is made to the work of the Bedfordshire Local Nature Partnership and its role in the planned Natural Capital Investment Plan for the Oxford-Milton Keynes-Cambridge Growth Corridor.

Policy EE3 Nature conservation Recognising that there are no European designated sites within the administrative boundary of Central Bedfordshire, we re-iterate our advice of 31 August 2016, that “a number of European designated sites will fall under the influence of the Plan” and therefore European Sites should be referenced in Policy EE3 in accordance with paragraph 113 of the National Planning Policy Framework (NPPF). Natural England advises that the following additional policy wording, or similar, is included:

Developments that are likely to have an adverse effect, either alone or in-combination, on European designated sites must satisfy the requirements of the Habitats Regulations, determining site specific impacts and avoiding or mitigating against impacts where identified. Mitigation may involve providing or contributing towards a combination of the following measures: i. Access and visitor management measures within the SAC; ii. Improvement of existing greenspace and recreational routes; iii. Provision of alternative natural greenspace and recreational routes; iv. Monitoring of the impacts of new development on European designated sites to inform the necessary mitigation requirements and future refinement of any mitigation measures.

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v. other potential mitigation measures to address air pollution impacts e.g. emission reduction measures, on site management measures.

We find the layout of the bulleted points difficult to comprehend as it currently suggests that development proposals involving County Wildlife Sites (CWS) or Species and habitats of principal importance could be considered sustainable development. We suggest alternative wording along the following lines: Nationally designated sites Development proposals within or outside a SSSI, likely to have an adverse effect on a SSSI (either individually or in combination with other developments), will not be permitted unless, on an exceptional basis, the benefits of the development, at this site, clearly outweigh both the adverse impacts on the features of the site and any adverse impacts on the wider network of SSSIs.

Local Sites Development likely to adversely affect locally designated sites, their features or their function as part of the ecological network, will only be permitted where the need and benefits of the development clearly outweigh the loss, and the coherence of the local ecological network is maintained.

Policy EE3 should also require development proposals to:

 Conserve and enhance the network of habitats, species and sites (both statutory and non- statutory) of international, national and local importance commensurate with their status and give appropriate weight to their importance;  Avoid negative impacts on biodiversity and geodiversity, mitigate unavoidable impacts and as a last resort compensate for residual impacts;  Deliver a net gain in biodiversity where possible, by creating, restoring and enhancing habitats and enhancing them for the benefit of species.

We support the recognition in this Policy that indirect effects can occur at some distance from a development site and that mitigation will be required in these circumstances, and advise that developer contributions may be required as a mechanism to mitigate these impacts.

Policy EE4 Trees, woodlands and hedgerows Natural England fully supports this policy to protect existing trees and woodland including ancient woodland and veteran trees, orchards and hedgerows. We welcome requirements for new tree planting within development schemes, taking into consideration local landscape character, climate change and ecological enhancement.

Policy EE5 Landscape Character and Value We welcome that all development will need to have regard to the key characteristics and sensitivities of the site and its setting, as set out in the Central Bedfordshire Landscape Character Assessment. Natural England supports the requirement for all major development to demonstrate how they incorporate landscape enhancement, in accordance with the guidelines in the LCA, the Central Bedfordshire Design Guide and other relevant documents for specific areas e.g. the Chilterns AONB, Marston Vale Community Forest or the Greensand Ridge Nature Improvement Area. We welcome that Landscape and Visual Impact Assessments will be expected as part of planning applications, including the assessment of local landscape character.

Policy EE6 Tranquillity Natural England welcomes policy requirements for new development to protect areas of high tranquillity having regard to impact to biodiversity and visual intrusion. We support requirements for development to seek opportunities to enhance tranquillity through mitigation, for example through removal of disruptive sources of noise and lighting.

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Policy EE7 The Chilterns Area of Outstanding Natural Beauty The Council’s continued support of the Chiltern Conservation Board’s management plan and protection against inappropriate development is welcomed. We generally support the criteria for restricting development to protect the AONB and its setting, however, we advise the Council to seek the specialist advice of the Chiltern Conservation Board on specific policy wording. We welcome the requirement for development within or affecting the setting of the Chilterns AONB to be informed by landscape and visual impact assessment to understand impacts and mitigation requirements.

Please note our advice above on Section 8.5 Summary of Housing Growth Locations. A number of proposed housing growth locations are within / within the setting of the Chilterns AONB. Natural England will not support such allocations/proposals unless robust evidence is provided to 1) justify the need for development in that location; 2) demonstrate that suitable alternatives have been fully explored; 3) demonstrate that adequate mitigation can be delivered to address adverse effects.

Policy EE8 Greensand Ridge Nature Improvement Area We fully support this policy and the protection it offers and opportunities it encourages to enhance the biodiversity, ecological connectivity, landscape and access in this important area. We welcome requirements for proposals to demonstrate biodiversity net gain, in accordance with paragraph 109 of the NPPF. Natural England strongly advocates strengthening of this policy to require new development to demonstrate that any adverse effects to the natural environment can be appropriately mitigated. Cross-reference with Policy EE3 would help.

Policy EE9 Forest of Marston Vale Natural England welcomes the Council’s commitment to the Forest of Marston Vale and its adopted Forest Plan, requiring development proposals to demonstrate how they contribute to the delivery of the Forest Plan. This will ensure that development contributes to the environmentally led regeneration of the Forest of Marston Vale area by ensuring that development delivers a net gain in environmental quality and providing social, economic and environmental benefits across the area. We support the policy requirements as detailed and advise that any views expressed by the Marston Vale Trust should be taken into consideration.

Policy EE10 The Bedford & Milton Keynes Waterway Park We welcome the requirement for development to be designed to relate positively to the Waterway Park and that proposals having an adverse effect in its delivery will not be permitted.

Policy EE11 Public Rights of Way Policy requirements to protect and enhance Public Rights of Way are fully supported for the benefits this will provide in improving people’s access to and enjoyment of the countryside and improving health and wellbeing.

Policy EE12 Outdoor sport, leisure and open space Natural England welcomes this policy to protect and enhance provision of leisure and open space. Informal open space provides multi-functional benefits: biodiversity enhancement, improved health and wellbeing and enjoyment of the outdoors. We fully support the requirement for on-site open spaces to protect priority habitats and be designed to complement proposals for green infrastructure, landscaping, ecological enhancement, and climate change adaptation.

Policy EE13 Applications for Minerals and Waste Development Natural England supports requirements for high quality restoration of relevant sites within a reasonable timescale, incorporating habitat creation, where practical and desirable. Requirements to preserve best and most versatile (BMV) land where possible are also welcomed. A requirement for proposals to demonstrate no adverse effect to the natural environment, including designated sites, should be included. A specific requirement for proposals to be accompanied by Ecological Impact Assessment, including consideration of hydrogeological impacts, should be added.

Policy CC1 : Climate Change and Sustainability We support policy requirements to ensure development is sustainable and incorporates measures to help mitigate and adapt to the effects of climate change. These measures will provide wider

Page 8 of 17 environmental benefits including enhanced green infrastructure, landscape and biodiversity and improved air quality.

Policy CC2 Renewable Energy Development We welcome requirements for proposals to demonstrate no adverse impact and for mitigation measures to address any negative effects.

Policy CC3 Flood Risk Management Natural England looks to the Environment Agency as lead authority on flood risk issues to provide detailed comments on this policy. We recommend that flood risk management should give consideration to the need to protect the natural environment including designated sites. We welcome that the Council will support development which includes mitigation measures to maximise water efficiency and contribute to a net gain in water quality, biodiversity, landscape character and green infrastructure.

We advise reference to the Upper and Bedford Ouse Catchment Partnership as a delivery mechanism to manage flood risk in the county and beyond.

Policy CC4 Development Close to Watercourses This policy aims to protect and enhance the riparian ecological environment which Natural England fully supports. We advise that a requirement to protect and enhance priority and protected species such as otter and water vole is added.

Policy CC5: Sustainable Drainage Natural England welcomes recognition of the multi-functional benefits of SuDS including flood control, improved water quality, recreational and amenity benefits and wildlife enhancement. We advise that potential risks to water-dependent designated sites, through changes in water quality / quantity, should be recognised. The SA will need to assess this issue against proposed site allocations and any mitigation measures will need to be secured through relevant allocation policies.

Policy CC6: Water Quality We support this policy and requirement for relevant proposals to be accompanied by a Water Framework Directive assessment and to contribute positively to the water environment and its ecology. However, this appears to be deferring the sustainability assessment of proposals to the project stage. In our view this poses a potential risk to designated sites and the deliverability of development which should be minimised by assessing water quality effects and deliverability of measures to address adverse effects through the SA (informed by an up to date Water Cycle Strategy).

We are not clear how the issue of waste water management and water treatment capacity is dealt with through the Plan. The SA, informed by an up to date Water Cycle Strategy, needs to demonstrate that sufficient infrastructure / Waste Water Treatment Works capacity exists to serve the proposed development without adverse effect to designated sites. Any measures needed to ensure this, including implementation of any infrastructure /upgrades to meet development timescales, should be included within the relevant plan policies.

Natural England will not support Local Plan allocations where appropriate measures to address adverse impacts to internationally and nationally designated wetland sites cannot be demonstrated.

Policy CC7: Pollution Natural England welcomes and supports this policy for the protection it affords to the natural environment. The policy, or a separate policy, should include requirements to ensure protection of the water environment through development of contaminated land. Development of contaminated land can mobilise pollutants and contaminate ground and/or surface waters, posing a potential risk to water-dependent designated sites.

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Policy HQ6: High Quality Development We support these requirements for the multi-functional benefits they will deliver being complimentary to the existing natural environment, taking account of the landscape setting, landscape character, Rights of Way, biodiversity, and Green Infrastructure.

Policy HQ9: Larger Sites Natural England advises the inclusion of an additional requirement for proposals to be accompanied by an Ecological Mitigation and Enhancement Plan, to demonstrate delivery of biodiversity net gain in accordance with paragraph 109 of the NPPF.

Policy HQ10: Small Open Spaces We welcome this policy to safeguard verges, landscape strips and other areas which provide opportunities for recreation or contribute positively to the visual amenity and/or the ecological networks of the area.

Section 20 Development in the Countryside: this section appears to provide adequate consideration and protection to the natural environment hence we are generally supportive of related policies. However, we would advocate cross-reference with the requirements of policies EE3 and EE7 to ensure the protection of designated sites and landscapes.

Policy DC6: Agricultural Land Natural England welcomes this policy which seeks to protect BMV land as far as possible, taking into account the significance of the loss; the grade of the land, the size of the proposed site and the quantum of BMV land affected.

Growth locations We understand from section 8.5 Summary of Housing Growth Locations that at this stage the Plan does not include allocation policies for specific sites but instead it shows a number of ‘growth locations’. We note that each of the assessments includes named Heritage Assets in the vicinity. We advise that Biodiversity Assets (designated and non-designated sites) should be included in the Detail sections. We acknowledge that sites that have passed through the assessment process will not be automatically allocated so we provide general advice on those passing at this stage, and will provide further advice on technical studies and the SA process. We may need to review our advice once individual sites are being considered in terms of environmental opportunities and risks.

General advice on potential allocations1 Whilst it is difficult for us to advise without seeing masterplan proposals or firmer allocations, we are able to provide the following principles for consideration in the further stages of Plan preparation:

1. Net-gain in biodiversity. We would expect strategic proposals2 to demonstrate how they will achieve net gain in biodiversity. We acknowledge that a country park may form part of some proposals (e.g. NLP054 and NLP191), together with woodland creation (as part of contributions toward the achievement of the Forest Plan targets of the Forest of Marston Vale where the site is within the Forest area): where proposals are within the Forest area, we advise that proposals support the aspirations and targets of the Forest Plan. More widely, the Council should consider natural capital and ecosystem services studies to inform the net- gain achievable from proposals, and where appropriate contribution toward the targets of the Greensand Ridge NIA and/or the Forest of Marston Vale. These studies should consider the strategic connection of potential development sites to environmental networks such as priority corridors and ecological networks as described in the Councils’ Environmental Framework and in the Nature Conservation Strategy for Central Bedfordshire. This baseline intelligence would be required in order to inform requirements under Policy EE2 and allocation policies.

1 We note that the Site Assessments considers sites that are 200 hectares or more in size (approximately 3,600+ homes) have been identified as ‘strategic’. 2 Such as NLP054, NLP370 and NLP463

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2. Green Infrastructure and off-site recreational pressures. We advise that at an early stage the principles regarding quantity and quality of GI is agreed, and that this is considered together with plans for links to existing habitats and the known ecological networks. Such links would include the provision of early-successional habitats that can develop as proposals progress. The broad approach recommended is for master plans to retain the highest value habitats and create new habitats on- or off-site that allow species to utilise. GI provides a means to bring nature into every neighbourhood. However, proposals will also need to investigate the level and type of residual off-site impacts – particularly those arising from increased recreational pressure. This is in order that appropriate avoidance and off-site mitigation measures can be achieved to protect designated sites. Such mitigation could usefully include developer contributions towards minimising impacts at designated sites as well as toward improvements in the Greensand Ridge NIA where the site is within the NIA. The priority would be to ensure that development enhances designated sites by making them more resilient to, and buffered against, predicted impacts.

3. BMV Agricultural land. A number of potential growth areas (e.g. West of Luton, Aspley Triangle, East of Arlesey, East of Biggleswade, South/Tempsford Airfield, and North of Luton) appear to have significant proportions of high-quality BMV land. We advise that where no site-specific Agricultural Land Classification (ALC) survey information exists, the Council should specify the need for those proposing sites to undertake a suitable site- specific ALC survey to inform the assessment process. We expect that the site-specific ALC survey data is used to consider the impact on soils through the SA to fully explore the justification for allocating BMV land, and ultimately to inform site specification and masterplans.

We would welcome discussions with the Council regarding strategic sites. We also encourage site proposers to seek advice through our Discretionary Advice Service about opportunities to deliver net gain in biodiversity at local landscape scale. Ahead of the detailed design phase, we would be pleased to provide further advice on strategic principles at this stage: e.g. the opportunities of GI layouts to bring nature into every neighbourhood and mixtures of compensatory and other habitats. Proposals should clearly demonstrate that onsite measures will minimise residual impacts from increased recreational pressure within an appropriate zone of influence. GI should be planned as a means to manage the movement and impact of people undertaking a variety of leisure/recreation activities - including but not exclusively dog-walking.

Natural England’s detailed advice on the potential allocations is provided in Annex 2 to this letter.

Other advice Natural England advises that the Plan should include a policy to ensure sustainable use of agricultural land, including BMV land (Agricultural Land Classifications 1 – 3a), in accordance with paragraph 112 of the NPPF. This should include similar requirements to those for minerals and waste proposals, set out in section 16.15. Where not already completed, site promoters should be required to undertake site-specific ALC survey. The policy should include an additional requirement to prioritise development on non-BMV land / lowest ACL grading, wherever possible, to maximise protection of BMV land.

Habitats Regulations Assessment (HRA)

As a requirement of the Habitats Directive [transposed through the Conservation (of Habitats and Species) Regulations 2010 (as amended) (the Habitats Regulations)] the assessment of a plan is a process that should be undertaken during the preparation of the plan, preferably from the earliest stages, so that the assessment influences the evolution of the plan. It is important, and a requirement of the SEA Directive, that reference is made to the HRA findings within the Sustainability Report. The findings of the HRA should be used to inform the summary of significance of effect (particularly in relation to test F(i) of the SEA Regulations Annex A. The Sustainability Appraisal (SA) report (Enfusion, July 2017) has not been informed by the findings and recommendations of a HRA; however, we note from section 8.9 of the SA report that the HRA

Page 11 of 17 screening of the previous draft plan will be updated and published at the next stage of plan making and the results used to inform the SA report. Natural England advises that the individual and cumulative effects of development, alone and in-combination with cross-boundary development, will need to be assessed and mitigation identified to address adverse impacts.

Sustainability Appraisal (SA)

Natural England provided advice on the scope of the SA in our letter of 31 August 2016 (our ref: 190688).

As advised above the Sustainability Appraisal (SA) report (Enfusion, July 2017) is not currently informed by the findings and recommendations of a HRA. It is therefore difficult for Natural England to provide detailed comments at this stage. We understand that this will be addressed through the next stage of plan making. In the interim our advice on the current SA is provided below.

The SA report provides an overview, rather than a detailed assessment, of the effects of the Central Bedfordshire Draft Local Plan on sustainability objectives. The SA objectives, assessment methodology and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment Regulations. However, as stated above, the statutory requirement for the assessment to take into consideration the findings of HRA will need to be addressed.

We note from section 10.9 that a further SA report will be prepared to include details for each proposed strategic growth location and the smaller non-strategic sites.

With regard to proposed growth locations Section 4.10 indicates that despite mitigation to address negative effects through the emerging development management policies, uncertainty of the significance of effects remains until further studies on the water cycle and transport impacts/capacities are completed. Natural England advises that these studies should be completed as soon as possible to provide the evidence required to inform the SA and enable sound judgements to be made regarding which allocations are sustainable and can be taken forward. Similar evidence-based assessments are required to address landscape, air quality and recreational pressure issues – to demonstrate that allocations will not have any adverse effect on the AONB or its setting and designated nature conservation and geological sites. ALC surveys are also required, where possible, to assess the impacts of allocations on BMV land and identify measures to mitigate adverse effects.

Natural England advises that the SA cannot rely alone on the emerging development management policies to mitigate the potential adverse effects of proposals on the natural environment, including designated sites and landscapes. Evidence will need to be provided to demonstrate that proposed growth locations are sustainable in terms of deliverability of appropriate mitigation to address any adverse impacts.

We welcome recognition of the hierarchy of designated sites, however reference needs to be made to European sites beyond the district boundary which could be impacted by plan development, through indirect effects such as recreational pressure and changes in air quality, water quality and water quantity/flooding.

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Annex 2 Natural England Detailed Advice on Potential Allocations

Our overarching advice is that 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 and landscapes. Natural England strongly advocates the use of appropriate evidence based assessments such as LVIA, recreational / visitor studies, an up to date Water Cycle Study, ALC study and Air Quality Assessment to inform the SA and identify mitigation measures to address adverse effects. Mitigation measures will need to be secured and a mechanism for their delivery/funding identified through clearly worded allocation policies.

Town Expansion: North of Luton We note that impacts on Greenbelt, AONB and designated areas are described; however we have the following concerns regarding potential development in this geographical area that includes sites NLP426 North Luton SUE site proposal (~5K dwellings3), NLP322 Land East of Junction 11A and North of Vauxhall Plant (~630 dwellings) and NLP368 Manor Farm, Lower Sundon (~50 dwellings):

1. Designated sites. a. The major increase in local population has the potential to increase recreational pressure on a number of designated sites overlying chalk geology. These sites include SSSI, Smithcombe, Sundon and Hills SSSI, Barton Hills SSSI and NNR, Deacon Hill SSSI, SSSI and NNR and Hill CWS. Town expansion proposals in the North of Luton will need a coherent package of funding for off-site mitigation measures to make these designated sites more resilient to visitor pressure on their sensitive chalk grassland habitats, whilst also contributing to provision of buffer land around the designated sites. These areas of buffer land will create the opportunity to link habitats through restoration and creation. Provisions could also include new or improved areas of attractions/visitor parks to ‘divert’ population from SSSI/CWS sites to help decrease visitor pressure on them. b. We note that the proposed development map (Figure 8.1 in the Draft Local Plan) shows a planned road; the Site Assessment Form for Sundon parish describes that the NLP426 North Luton SUE site proposal (~5K dwellings) could provide a new link road to the M1 and A6, that “The delivery of the M1-A6 link road is… critical for development in this location”. We also note on p81 of the Draft Local Plan that “the Government have approved a significant contribution through the South East Midlands Local Enterprise Partnership, to help fund the proposed M1-A6 Link Road”. Whilst the alignment of the potential Link Road has yet to be established, we are keen to ensure that such critical infrastructure achieves net gain for biodiversity. We have concerns about its general location and alignment with regard to potential air quality and other impacts on nationally designated sites4 and on the Chilterns AONB protected landscape. There is also the potential for impacts from the East Luton Circular Road (a 'safeguarded road' policy in the recently examined Luton Local Plan).

2. Protected landscape. Proposals are likely to have direct impact on a nationally designated landscape and/or its setting. They would require strategic landscape and GI master planning to enhance and to link development to existing landscape and ecological networks. We are keen to engage with site promoters through our Discretionary Advice Service (DAS) to advise on avoidance and minimisation of impacts to the Chilterns AONB. We also encourage the Council to engage with the Chiltern Conservation Board regarding impacts of the potential development.

3. Agricultural land quality. We note from the Site Assessment Form for Sundon parish that

3 Al figures for dwellings in our response relate to figures as per CBC methodology, rather than proposed number from pro forma. 4 Potentially Sundon Chalk Quarry SSSI and Smithcombe, Sundon and Sharpenhoe Hills SSSI

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sites NLP426, NLP322 and NLP368 contain high proportions (>75%) of ALC Grade 2 and Grade 3 land. These sites cover a significant area (e.g. NLP426 covers ~283 ha). See our General advice on potential allocations regarding BMV agricultural land, above.

Town Expansion: West of Luton This general area within the urban fringe of Luton contains a number of potential development sites e.g. NLP436 West of Luton ~6K dwellings. We have the following general comments:

1. Existing biodiversity habitats. We draw your attention to a number of high-value sensitive biodiverse CWSs in the vicinity together with two SSSIs (Kenworth Chalk Pits ~2km away and Blow’s Down ~2.5km away). We understand from the recent consultation on Sustainability Appraisal and Strategic Environmental Assessment for the Luton Borough Gypsy and Traveller Local Plan Part 2 (2011-2031) that development has recently taken place on CWSs. This unwelcome activity, when combined with the lack of provision of open space, exposes the SSSIs and CWSs to a greater risk of adverse impacts: such as unsustainable increases in recreational access or the unauthorised dumping of materials. Ancient woodland also occurs in this area and in accordance with paragraph 118 of the NPPF we advise that inappropriate development would have a detrimental impact on these assets.

2. Protected landscapes. The sites in this area are either within the Chilterns AONB or are within the setting of the AONB. We encourage the Council to engage with the Chiltern’s AONB Board regarding impacts of the potential development.

3. Agricultural land quality. We note from the Site Assessment Forms it is not known whether the soils are ALC Grade 3a or 3b. See our advice under General advice on potential allocations regarding BMV agricultural land, below.

To provide for net gain in biodiversity, appropriately designed and sufficient area of GI and landscaping are required to ensure that impacts on designated sites and ancient woodland are minimised, and the development harmonised within the context of the AONB. One possibility could be developer contributions towards the management and facilities at Stockwell Park in order to make the Park more resilient to larger numbers of visitors.

New Market Town: Tempsford South and Tempsford Airfield This location is within/close to areas which Natural England believes should be prioritised for delivery of landscape scale biodiversity net gain(Ouse Valley, Bedfordshire Greensand Ridge and West Cambridgeshire Hundreds Woodlands). Consequently we strongly advocate that proposals in these locations are able to demonstrate delivery / contribution towards delivery of landscape scale biodiversity net gain. Two potential allocations - NLP450 Tempsford Airfield and NLP452 Land South of Tempsford – have the potential for ~5K dwellings in addition to potential allocations for employment land. Place-shaping through development should enable clear demonstration of net- gain in biodiversity by capitalising on environmental opportunities. For a proposal of this scale we strongly recommend the commissioning of research to examine the opportunities to increase natural capital and ecosystem services in this area. Such research would then inform the design, and would usefully also identify whether any areas of brownfield site are of high environmental value, and the masterplan adjusted in accordance with paragraph 111 of the NPPF. Please also see our advice on the loss of BMV agricultural land in General advice on potential allocations, above.

Whilst we recognise the opportunities for green and blue infrastructure, the description is currently generic and hence our advice at this stage can only be general in nature. There is no mention of strategic infrastructure such as a country park, which might be expected in a potential new market town of this size. There is the potential for off-site impacts to nearby designated sites such as the cluster of SSSI Woodlands in West Cambridgeshire Hundreds around 3km away to the east (Weaveley and Sand Woods SSSI, Gamlingay Woods SSSI, Wood SSSI, Buff Wood SSSI and Waresley Wood SSSI) and at SSSI (~5km to the south) which is included within the RSPB’s The Lodge reserve. There are also a number of CWSs. These potential impacts will

Page 14 of 17 need to be evaluated and addressed at an early stage through discussion with the land managers of nearby designated sites, and a coherent package of mitigation and funding contributions prepared.

We advised on 21 July 2016 (our ref: 189708) that that the Local Plan’s Technical Site Appraisal should “assess the strategic spatial relationship of Site(s) to facilitate the connection and enhancement of environmental qualities and networks”. We would expect to see evidence of how this proposal connects with and enhances the Ivel River Valley strategic GI corridor5, together with connections to the Greensand Ridge NIA. There are particular risks of the severing of ecological corridors from the A1 Route Enhancement and East West Rail strategic transport schemes. Any proposals should demonstrate how opportunities might be created from such transport schemes – for example the use of green bridges and creation of a diversity of new habitat.

We note that the Site Assessment Form for Tempsford parish that development of NLP450 Tempsford Airfield has the risk of the “loss of old grassland” and from the Site Assessment Form for Everton parish that NLP452 Land South of Tempsford there is significant areas of Grade 2 and 3 BMV agricultural land.

New Villages: New Villages to the East of Biggleswade The Draft Plan describes “informal open space including an extension to Biggleswade Common”. Biggleswade Common, as well as SSSI (~3km away), Sandy Warren SSSI (~2.5km away) and the adjacent RSPB The Lodge site are likely to be at risk from additional recreational impacts from the potential proposal of ~3K new dwellings. We advise that development in this location should seek to make these wildlife sites more resilient and buffered from additional impacts. The proposals will need to demonstrate avoidance and mitigation of such impacts, and this could include developer contributions to mitigate off-site impacts as well as strategic GI within the development. The development of these New Villages could achieve net-gain through appropriate complementary biodiversity enhancement of the A1 Route Enhancement strategic transport scheme.

Town Expansion: East of Arlesey The potential sites within this growth area avoids designated sites6 and protected landscapes. We welcome the provision of a country park between Arlesey and Fairfield. We note that site NLP419 Land to the East of Arlesey (which contains NLP251) contains “Over 50% Agricultural Grade 2 land remainder is Grade 3”: please see our General advice on potential allocations regarding BMV agricultural land, above.

New Villages: Marston Vale New Villages Examining the Site Assessment Forms for , Marston Moretaine and parishes, we note that two strategic development sites (NLP054 Land South of Marston Moretaine ~3.2K dwellings, and NLP370 Marston Valley ~10.5K dwellings) have been assessed as viable, available, suitable and achievable sites:

 NLP054 Land South of Marston Moretaine. NLP054 is adjacent to a number of designated sites, including SSSI (~200m to the south-west) and the area contains habitat known to support Great Crested Newt meta-populations. We would expect any proposals to consider potential impacts on these. A District Level Licence for GCN in Central Bedfordshire is being prepared by the Environment Bank. The aim of this licence is to reduce delays, costs and uncertainty for developers whilst providing strategic habitat compensation to improve long-term nature conservation for GCNs. We are also aware that NLP054 contains a significant section of the potential Bedford and Milton Keynes Waterway Park.  NLP370 Marston Valley. NLP370 contains a number known biodiversity assets – including two CWS and it is a Great Crested Newt re-colonisation area. NLP054 is near to a number of designated sites including Marston Thrift SSSI (~450m to the south-west), Cooper’s Hill

5 as shown in the Environmental Framework that has been produced by the Council 6 The Detail section of the Draft Plan describes on page that the site contains a SSSI however we do not believe that there is a SSSI in this area

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SSSI (~3km to south-east) and Kings Wood and Glebe Meadows, SSSI (~3.2km to the east). We are aware that there is a relatively high level of existing access pressure at these sites: see our advice on Green Infrastructure and off-site recreational pressures. NLP054 lies partially within the Green Sand Ridge NIA and is within the Forest of Marston Vale.

We provide the following advice on the potential Marston Vale New Villages sites:

1. Net gain in biodiversity: A number of ‘site specific opportunities’ are described on p99 of the Draft Local Plan. We welcome further details on the vision for biodiversity enhancement. We advise that a natural capital/eco-system services study should be undertaken to inform the net gain achievable from the proposals and contribution toward the targets of the Greensand Ridge NIA. We draw your attention to a piece of recent research that includes natural capital in the Forest of Marston Vale

2. Geodiversity. The opportunity exists to highlight the importance of geodiversity, particularly in the context of the local historic use of the Marston Vale for brick working.

3. Protected species. We previously advised on 31 August 2016 (our ref: 190688) to include in the evidence base the SITA funded Marston Vale Great-crested Newt meta-population mapping project. We would expect any proposals to consider the known meta-populations of this Great Crested Newt. As mentioned above, a District Level Licence for GCN in Central Bedfordshire is being prepared by the Environment Bank. The aim of this licence is to reduce delays, costs and uncertainty for developers whilst providing strategic habitat compensation to improve long-term nature conservation for GCNs.

We note that in Canfield parish the Council has determined that several potential sites (e.g. NLP486 Land at Cranfield Airport, for 500 dwellings and ALP188 Land at Wharley Farm for ~250 dwellings) have been assessed by the Technical Site Assessment as being inappropriate for development. Whilst these particular sites may be assessed as inappropriate, the number of sites put forward is indicative of future potential development opportunities.

New Villages: Aspley Triangle SSSI is ~2.5km to the south of NLP463 Triangle/Milton Keynes South East (South East Opportunity Area). Given the close proximity of the potential site to the nearby mature habitats and open space at (which includes this SSSI), there is a need to ensure good quality on-site GI provision to reduce potential impacts on adjacent areas and nearby areas of biodiversity interest and public open space. We also advise that appropriate off-site measures to connect and enhance nearby natural greenspace and biodiversity habitats.

The site development is described as providing net gain for biodiversity, yet how this will be achieved is not clearly defined. One method could be the production of a natural capital/ecosystem services study that would inform types of net gain within the context of Greensand Ridge NIA targets. It could also include opportunities afforded from the Bedford and Milton Keynes Waterway Park. We note from the Site Assessment Forms that this is a potential site for ~4.6K dwellings. We have concerns relating to adverse impacts on BMV agricultural land from potential allocations in Aspley Guise parish: see our General advice on potential allocations on BMV agricultural land, above.

Town Expansion: Land South of Regarding NLP191 Wixams Southern Extension (~450 dwellings), we note from the Site Assessment Form for Houghton Conquest parish that a country park – which we support - would form part of this development. It would provide recreation opportunities to access natural greenspace and the country park would maintain a landscape separation between Wixams and Houghton Conquest. However, noting the proximity of NLP370 we recommend that in addition to preventing urban coalescence, the country park should complement the Marston Vale New Villages potential sites. The country park and potential site should deliver important early-successional habitats for invertebrates, and waterbodies including habitats for Great Crested Newts. The creation

Page 16 of 17 of temporary early-successional habitats will provide valuable places for species and habitats to use in the intervening period before the site is developed. Proposals should seek to create temporary habitat on areas that will be developed in future phases, rather than sterilise the site.

We advise that the masterplan of this proposed site should ensure that sufficient landscape buffer is designed together with suitable quantity and quality of GI to satisfy the requirements of new residents together with existing residents at the existing allocated site of MA2 at Wixams itself. This would serve the purpose of minimising the impact of additional recreational pressure on the nearby Kings Wood and Glebe Meadows, Houghton Conquest SSSI (~1.5km to the south) and the cluster of three SSSIs that are ~3.75km to the south ( Wood and Pennyfather’s Hill SSSI, SSSI and SSSI). The potential site NLP191 should also clearly support the delivery of the Forest of Marston Vale’s Forest Plan.

Other growth areas Examining the Parish Maps and Site Assessments, there are additional potential sites that do not appear to be described in the headline growth options:

1. Barton-le-Clay extensions. Our advice on North of Luton growth area (above) applies to sites ALP418 Land north of Higham Road/east of Bedford Road / NLP382 Barton-le-Clay Northern Extension (~1.3K dwellings) and NLP158 Land to the East of Barton le Clay (~800 dwellings).

2. parish. NLP469 RAF Henlow (~700 dwellings) We note that over 50% of the site is non-agricultural land i.e. it is brownfield. Please refer to our General advice on potential allocations, above.

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