Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Ended on the 3 September 2021
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8.0 Position statements

(59)8.1 This section sets out the Council's position in relation to those subjects we asked about in the 2020 consultation but have decided not to update existing or introduce new policies. It also explains where work is currently being carried out that may result in additional policies being included in the plan for submission.

Climate change

Why is it important to address climate change?

(5)8.2 It has been established that changes to the global climate are happening at an ever-increasing rate. Increasing average temperatures, changes to weather patterns, rising sea levels and greater risk of flooding are all potential consequences of a 'change-nothing' approach to the way we develop our communities going forward.

(1)8.3 The government has recognised the increasing risks to the country climate change poses and, through the Climate Change Act 2008 and the subsequent Amendment Order (Climate Change Act 2008 (2050 Target Amendment) Order 2019) has committed the UK to reaching net zero greenhouse gas emissions by 2050.

8.4 The Paris Agreement in December 2015 resulted in international agreement to keep global temperature increases "well below" 2.0C and "endeavour to limit" the rise to 1.5C.

National Policy

(1)8.5 The Planning and Compulsory Purchase Act 2004 requires local planning authorities to include in their local plans policies to ensure development, and use of land contribute to the mitigation of and adaptation to climate change.

(2)8.6 To achieve sustainable development, the National Planning Policy Framework states as part of its environmental objective of sustainable development that the planning system should "contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy."

(2)8.7 It requires plans to "take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures".

8.8 The government's online national planning policy guidance sets out examples of how local plans might address climate change.

Bedford Borough Council Approach

(8)8.9 Bedford Borough Council declared a climate emergency in March 2019 and pledged to make its own operations carbon neutral by 2030. It has developed a Carbon Reduction Delivery Strategy setting out how it will achieve this aim. As part of this strategy the Council has pledged to incorporate the carbon neutral ambition into all Council strategies, including the Local Plan 2040.

(5)8.10 Future development will need to incorporate different features to not only reduce their carbon emissions but also to be resilient to the climate change already happening. This will include more efficient building, flood resilience, the incorporation of renewable energy sources and to allow the means for communities to shift their methods of travel. The role of the local plan in affecting climate change is one of facilitating the right environment for measures to be included in existing and future development. It will take the combined efforts of communities, residents, businesses and the development industry in the borough to embrace those measures.

8.11 The Mayor has also set up a climate change fund, which offers grants to community groups to help with the cost of carbon reduction projects.

(1)8.12 The Local Plan 2030 incorporated both methods of adaptation and mitigation in response to the climate change emergency. Adaptation seeks to reduce the risk results from a changing climate, for example through flood defences whilst mitigation seeks to reduce the causes of climate change, such as reducing greenhouse gas emissions from new development. It includes a chapter on resources and climate change which contains policies requiring the effective use and re-use of land, consideration of water quality and supply and energy efficiency.

What can we do in the Local Plan 2040?

(6)8.13 A large part of combating climate change is in the pattern of development that will occur in the borough going forward and this will be directly influenced by the spatial strategy that the Council adopts. By choosing a spatial strategy which will encourage fewer greenhouse gas emissions, the Council can work towards adapting development to reduce climate change risk and mitigate against the causes of climate change, for example through the promotion of walkable neighbourhoods.

8.14 We commissioned consultants to prepare a new Strategic Flood Risk Assessment (SFRA). The SFRA is an essential piece of the evidence base which models the flood zones for the borough. Since the Local Plan 2030 was adopted, new guidance has been released by the government on how to take into account climate change allowances in modelling the flood zones. The climate change allowances are a percentage increase on the current flood zone 3a. This allows the Council to see what the extent of flooding might look like in different scenarios. The percentage increase applied will depend on the situations, for instance the type of development (residential, commercial, etc.) and the likely lifetime of the development (usually forecast as 60 years for commercial development and 100 years for residential). The SFRA will help with the selection of development sites.

Future homes standards

(1)8.15 Between October 2019 and February 2020 the government consulted on proposed changes to building regulations in relation to energy efficiency.

8.16 It published a summary of the comments received and its response to those comments on 20 January 2021. The conclusions to the consultation were:

  • A change in building regulations requiring new buildings to produce 31% less carbon dioxide will come into effect in June 2022
  • Technical consultation on the specification for the Future Homes Standard is planned for spring 2023
  • New building regulations requiring even greater reduction in carbon dioxide emissions from new buildings to come into effect in 2025.

(2)8.17 Policy 54 of the Local Plan 2030 currently requires new dwellings to have an energy efficiency standards equivalent to Level 4 of the Code for Sustainable Homes, which amounts to a 19% improvement on current building regulations. By the time this plan reaches the point of adoption the national standards will have overtaken this. Policy 54 will therefore remain in place until new building regulations are adopted that exceed its requirements.

(1)8.18 Given the existing development plan policies, apart from making the relevant amendments to Policy 54 Energy Efficiency, the Council is not aware of the need for additional climate change policies.

Gypsies, Travellers and Travelling Show People

(3)8.19 The Council has commissioned an updated Gypsy & Traveller Accommodation Assessment (GTAA). The purpose of this Assessment is to provide a robust analysis of the current and future need for Gypsy, Traveller and Travelling Show People's accommodation in Bedford Borough in the years up to 2040. Full details are set out in the evidence base document GTAA.

8.20 In relation to Gypsies, Travellers and Travelling Show People, national policy draws a distinction between those who travel and those who do not. The planning system must make provision for those who travel; this is often referred to as the 'planning definition'. The GTAA only formally identifies the needs of Gypsies, Travellers and Travelling Show People who meet the planning definition.

8.21 The additional needs of those members of the Gypsy and Traveller community who do not meet the planning definition are set out in the Local Housing Needs Assessment. However, the way that these needs are accommodated are in practice the same. Recent case law says that it is inappropriate to require any of the travelling community to live in bricks and mortar dwellings, and instead their needs should be met through the provision of plots and pitches.

8.22 In the plan period there is an identified need for an additional 46 Gypsy and Traveller pitches and 13 Travelling Show People plots, as follows:

Plan years











Gypsies & Travellers (meeting definition)






Gypsies & Travellers (not meeting definition)






Total pitches












Travelling Show People (all meet the definition)






(3)8.23 The Council will submit planning applications to meet the required need for additional pitches and plots. There is therefore no requirement to allocate sites in the local plan.

Crematorium and burial capacity

8.24 The Council is aware that there may be a future requirement for additional crematoria and burial capacity within the borough and has commissioned a study to determine more precisely the land and facilities required. Once the study is complete the Council will decide how any additional capacity can be delivered. This may be by allocating a site, by preparing a development management policy to help guide future planning applications or by submitting a planning application.

(1)8.25 If a new allocations policy or development management policy is required, it will be included in the plan for submission.

Healthy weight environments – hot food takeaways

(1)8.26 The development plan already contains up-to-date and relevant policies in relation to Healthy Communities (Policy 2S) and for the protection, enhancement and provision of green infrastructure, and walking and cycling routes.

8.27 In 2020 Public Health England published guidance 'Healthy weight environments: using the planning system' for local authority public health and planning teams which recommended actions relating to updating and referencing the changes to the Use Classes Order, monitoring, and ensuring decisions are made based on local physical and mental health and wellbeing evidence. Further detail is set out in the evidence base document Healthy Weight Environments Topic Paper.

8.28 As referenced in the 2020 Issues and Options paper, due to concerns about excess weight and obesity, particularly in young people, the Council was reviewing whether there was sufficient evidence to justify a restriction on the opening of hot food takeaways in proximity to schools and other locations where young people congregate.

8.29 However, the government's recent changes to the Use Classes Order mean that it is no longer possible for local planning authorities to control changes from shops to restaurants and cafés. Such premises are already allowed to sell some hot food for consumption off their premises.

8.30 It is only where a change of use is proposed to create a hot food takeaway, which primarily serves the takeaway market, that planning permission is now required.

8.31 In deciding whether such a change of use should be permitted, a number of factors and policies would be considered. The draft town centre and retail policies in section 6.0 above explain that in Bedford town centre, Kempston district centre and in local centres hot food takeaways are amongst the uses that are likely to be acceptable. The draft policies also state that this range of uses will be supported provided that they avoid a concentration of similar uses where the cumulative impact will be detrimental to environmental quality, amenity, parking or increase the risk of anti-social behaviour. Draft Policy TC9 in particular specifically covers these potential impacts of town centre uses. Concentration, environmental and disturbance issues are therefore sufficiently covered.

8.32 Public Health colleagues both nationally and locally continue to be concerned about the potential impacts of hot food takeaways on the health of residents. Unfortunately the Covid-19 pandemic has meant that resources within public health have been prioritised elsewhere. We will continue to work with colleagues over the coming months to see whether there is a sufficient evidence to justify any additional policies.

Hotel and visitor accommodation

(1)8.33 We have commissioned an update to the hotel and visitor accommodation evidence base to consider the following questions:

  • Is demand for visitor accommodation likely to continue to grow as anticipated in the 2014 study, particularly given the impact of Covid-19?
  • Is there still potential for some of the more innovative rural accommodation offers to be developed in the borough?
  • Is Local Plan 2030 Policy 76 adequate to plan effectively for the hotel and visitor accommodation proposals that are likely to come forward during the Plan period?

(1)8.34 The outputs from this work will feed into the plan for submission.

Infrastructure delivery plan

(17)8.35 New and upgraded infrastructure of all kinds will be needed to support the growth to be allocated in the local plan. Once the development strategy has chosen, infrastructure requirements can be identified and set out in an Infrastructure Delivery Plan which will be published alongside the Local Plan 2040 plan for submission.

Open space standards

(10)8.36 Bedford Borough Council has commissioned a Playing Pitch Strategy to assess the existing provision of, and future demand for, outdoor sports, and to prepare a strategy for how those needs will be met. This work is yet to be finalised but, when it is, it may require new standards for the provision of open space within development. If new policies are needed, they will be included in the plan for submission.

(6)8.37 In the meantime Sport England have requested that attention is drawn to the Active Design guidance which is available on their website https://www.sportengland.org/how-we-can-help/facilities-and-planning/design-and-cost-guidance/active-design. The document outlines 10 principles of active design to inform the layout of new development and includes such things as having multifunctional open space, providing the infrastructure to take part in sport and physical activity, walkable communities and connected cycling and walking routes.

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