Question 9
It is considered that the provision of guidance for developers on how to respond to climate change would be useful in providing clarity on the expectations of the Council on this matter. It is considered that any guidance should focus on matters of planning rather than duplicating requirements covered by alternative regimes such as Building Regulations.
Questions 9, 10 and 11 Yes, we support new planning standards and guidance for developers on how to respond to climate change. These standards should support local and renewable energy generation, connectivity – including at every opportunity the building in of full-fibre broadband capacity, and sustainable transport links and green corridors. We should support sustainable modes of transport and accessible transport but note that the local authority should seek to secure sufficient funding to support this from central government. We note in this context the 38% cuts (Institute of Fiscal Studies) in local government funding from central government over the last 10 years.
Further guidance is welcomed on how to respond to climate change and specifically expanding on policies within development plan documents which will give further clarity to applicants, developers and site promoters.
Whilst we support the Council’s aim in reducing climate change, we would not wish to see significant requirements and complication added to the development process. It is clear from the Planning for the Future White Paper that it is the Government’s ambition to reduce and simplify the documentation produced by the local government, and not reproduce guidance and policies provided at a national level. Any further guidance must be justified and have regard for the viability of new development.
Yes. Developers have mainly a national focus dictated on profit and little consideration of local needs. Bedford is seeing greater climate impacts such as flooding, so additional guidance is required. It is suggested that a Citizens Assembly with leading experts and local knowledge is set up to discuss how we can respond to climate change
Yes. It is a very important matter and it must not just be left to greedy, profit orientated developers who promise the earth and then cut corners and are not held accountable for failing to reach basic energy efficient targets. All new homes should be fully insulated, have compulsory photo voltaic roofing to feed grid and supply electricity to Bedford residents as standard and be energy efficient. The Borough officers should be more vigilant and should have the powers to monitor and fine those who do not comply. Revised guidance should be subject to full public consultation. Renewable energy should be used for heating, lighting, electric car charging points, etc.
9.1 The NPPF (paragraph 20) makes it clear that planning measures to address climate change are a strategic matter. Therefore, the issue should be at the heart of decisions made about the spatial strategy. 9.2 Paragraph 149 of the NPPF states the Local Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the implications for matters such as flood risk and biodiversity. 9.3 At a high level, this means development being avoided in areas which are more vulnerable to the impacts of climate change and ensuring that adaption measures, such as new green infrastructure, are built into plans. 9.4 The location of development is therefore the key aspect of how the Local Plan should respond to climate change, rather than detailed guidance for developers. As has already been discussed, ensuring development is well located in relation to transport infrastructure will be key to this, as will ensuring there are opportunities for existing rural settlements to remain viable with a range of services and facilities for new and existing residents. 9.5 Whilst guidance on how the layout of development and the design of buildings would be helpful to ensure matters such as orientation, massing and landscaping contribute to minimising energy consumption, the setting of standards to be achieved by new development should be avoided unless they relate to the application of the Government’s technical standards, as required by paragraph 150 of the NPPF.
10.1 The NPPF (paragraph 20) makes it clear that planning measures to address climate change are a strategic matter. Therefore, the issue should be at the heart of decisions made about the spatial strategy. 10.2 Paragraph 149 of the NPPF states the Local Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the implications for matters such as flood risk and biodiversity. 10.3 At a high level, this means development being avoided in areas which are more vulnerable to the impacts of climate change and ensuring that adaption measures, such as new green infrastructure, are built into plans. 10.4 The location of development is therefore the key aspect of how the Local Plan should respond to climate change, rather than detailed guidance for developers. Ensuring development is well connected to transport infrastructure will be vital to ensuring the environmental impacts of development are minimised. In addition, sustainable construction methods and building materials will help ensure that the carbon impact of development is reduced as much as possible as well as reducing energy consumption. Notwithstanding this, the setting of standards to be achieved by new development should be avoided unless they relate to the application of the Government’s technical standards, as required by paragraph 150 of the NPPF.
All developers should be made to use all the sustainable/environmental techniques currently available to ensure that all new buildings are carbon emission free. All new developments should be linked sustainably to existing or new bus routes, be near existing or proposed new railway stations and have high quality segregated cycle links to existing networks.
Combatting climate change: Employment sites-mostly distribution centres along the A421 bringing in yet more heavy traffic. We would like to see that all new warehouses and distribution centres with their flat roofs are built with solar pannelling and/or a 'green' roof. See example of Adnams warehouse and distribution centre, Southwold , Suffolk which has the largest green roof in the UK, 0.6 hectares.
shrubs rather than clearing everything and replanting, as has been done at St Mary’s Field. Solar panels and water-saving/recycling facilities are built-in.
10.1 We have no comments at this time but reserve our position to consider specific policy proposals as part of subsequent stages of consultation.
10.1 We have no comments at this time but reserve our position to consider specific policy proposals as part of subsequent stages of consultation.
10.1 We have no comments at this time but reserve our position to consider specific policy proposals as part of subsequent stages of consultation.
7.1 Guidance in respect of responding to climate change should be included within the Local Plan, rather than as an additional document. In order to achieve BBC’s Vision and aims, and to respond to climate change, the approach to responding to climate change should be at the heart of the Plan. It should not be left to additional guidance, and instead should be set out in the appropriate level of detail within the Plan. 7.2 In addition, the approach to climate change should include support for innovative and changing technology. It should not be prescriptive, and it should recognise that technology will change rapidly over the lifetime of the Plan. In particular, it should support and actively encourage those applicants who are proposing innovative and ground-breaking solutions which respond to climate change.
9.1 Paragraph 20 of the NPPF makes it clear that planning measures to address climate change are a strategic matter. Climate change should therefore be at the heart of decisions made in relation to the spatial strategy. 9.2 Paragraph 149 of the NPPF states the Local Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the implications for matters such as flood rick and biodiversity. 9.3 At a high level, this means development being avoided in area which are more vulnerable to the impacts of climate change, such as flood plain, and ensuring that adaption measures, such as new green infrastructure, are built into plans. The location of development is therefore the key aspect of how the Local Plan should respond to climate change. As has already been discussed, ensuring development is well located in relation to transport infrastructure will be key to this, as will ensuring there are opportunities for existing rural settlements to remain vital with a range of services and facilities for new and existing residents. 9.4 Whilst guidance on how the layout of development and the design of buildings would be helpful to ensure matters such as orientation, massing and landscaping contribute to minimising energy consumption, the setting of standards to be achieved by new development should be avoided unless they relate to the application of the Government’s technical standards, as required by paragraph 150 of the NPPF. 9.5 Climate change policy and good practice is changing quickly, there needs to be flexibility to accommodate these changes within the lifetime of any planning documentation. Climate change scenarios predict extensive changes by the end of the earliest plan period of 2040, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. 9.6 Needless, stringent policy and guidance may inadvertently impede progress towards later years in the plan or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate quickly changing technology, as well the current grid challenges in implemented EV charging places. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As noted on page 10 of the Zero Carbon Futures Symposium Report (2019) where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on north facing roofs merely to achieve policy compliance not to produce effective carbon reductions. 9.7 Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 16 targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. 9.8 Importantly, the scope of any policies may also be limited by the changes proposed in the Housing and Planning White Paper which suggests local polices on matters such as climate change will no longer be appropriate. This reinforces the point that the main influence on climate change that local plans can make is ensuring development occurs in the most appropriate locations and design and layout utilises best practice with regard to energy consumption.
Yes. It is a very important matter and it must not just be left to greedy, profit orientated developers who promise the earth and then cut corners and are not held accountable for failing to reach basic energy efficient targets. All new homes should be fully insulated, have compulsory photo voltaic roofing to feed grid and supply electricity to Bedford residents as standard and be energy efficient. The Borough officers should be more vigilant and should have the powers to monitor and fine those who do not comply. Revised guidance should be subject to full public consultation. Renewable energy should be used for heating, lighting, electric car charging points, etc.
See answer to question one in relation to Climate Change.
9.1 The NPPF (paragraph 20) makes it clear that planning measures to address climate change are a strategic matter. Therefore, the issue should be at the heart of decisions made about the spatial strategy. 9.2 Paragraph 149 of the NPPF states that Local Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the implications for matters such as flood risk and biodiversity. 9.3 At a high level, this means development being avoided in areas which are more vulnerable to the impacts of climate change, such as in flood plains, and ensuring that adaption measures such as new green infrastructure are built into plans. 9.4 The location of development is therefore the key aspect of how the Local Plan Review should respond to climate change, rather than detailed guidance for developers. As has already been discussed, ensuring development is well located in relation to transport infrastructure will be a key consideration, as will ensuring there are opportunities for existing rural settlements to remain viable with an improved range of services and facilities for new and existing residents. 9.5 Whilst guidance on how the layout of development and the design of buildings would be helpful to ensure matters such as orientation, massing and landscaping contribute to minimising energy consumption, the setting of standards to be achieved by new development should be avoided unless they relate to the application of the Government’s technical standards, as required by paragraph 150 of the NPPF.
Yes, we fully support the provision for more detailed guidance to tackle climate change. As set out within the attached Vision Document for land at Gibraltar Corner, tackling climate change is a central part of the development proposals. To adequately tackle climate change, support is given to ensuring sustainable urban drainage is integrated into development proposals and that biodiversity net gain policies set clear targets for delivering on- site biodiversity net gain. Whilst we do not want to set out prescribed building standards for Energy Efficiency, we would be supportive of a Supplementary Planning Document that sets out clear standards. It is our view that climate change can also be tackled by ensuring that development is located in the correct place and in sustainable locations with ease of pedestrian and cycle access to the two principle settlements of Bedford and Kempston.
We suggest that a policy approach to climate change, sustainable design and energy efficiency should take into account the historic environment. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric- buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations.
8.1 Guidance in respect of responding to climate change should be included within the Local Plan, rather than as an additional document. In order to achieve BBC’s Vision and aims, and to respond to climate change, the approach to responding to climate change should be at the heart of the Plan. It should not be left to additional guidance, and instead should be set out in the appropriate level of detail within the Plan. 8.2 In addition, the approach to climate change should include support for innovative and changing technology. It should not be prescriptive, and it should recognise that technology will change rapidly over the lifetime of the Plan. In particular, it should support and actively encourage those applicants who are proposing innovative and ground-breaking solutions which respond to climate change.
2.16 Whilst we support the Council’s aim in reducing climate change, we would not wish to see significant requirements and complication added to the development process. It is clear from the Planning for the Future White Paper that it is the Government’s ambition to reduce and simplify the documentation produced by the local government, and not reproduce guidance and policies provided at a national level. Any further guidance must be justified and have regard for the viability of new development.
1.33. Yes, it is considered very important that clear guidance is provided so that developers are aware of the expectations. 1.34. However, it is respectfully submitted that the ‘planning’ system is not the correct vehicle for imposing strict climate change standards for construction. This is a matter which should be controlled through Building Regulations. 1.35. Building Regulations provide a national standard and developers accept and do not seek to avoid Building Regulation requirements. Building Regulations must be adhered to or developments cannot be insured and sold. 1.36. Where the planning system has sought to introduce detailed construction requirements including policies relating to carbon reduction, green energy etc., this has resulted in major differences between local authorities in terms of what is required. Some have little or no detailed policy on such matters others have highly onerous policies which make construction in one area far more costly than may be the case on the other side of an authority boundary line. Developers therefore seek to avoid and minimise requirements placed on them through the planning system because of this inconsistency and so a sense that what is being asked for is unfair or unnecessary. 1.37. It is considered that planning should provide guidance on how layouts can assist in combating climate change, sustainable drainage, ecological enhancements, environmental requirements etc. but should not seek to duplicate or go beyond building regulations in terms of construction specification, energy and water use. This creates confusion and inconsistency between local authority areas as outlined above.
1.31. Yes, it is considered very important that clear guidance is provided so that developers are aware of the expectations. 1.32. However, it is respectfully submitted that the ‘planning’ system is not the correct vehicle for imposing strict climate change standards for construction. This is a matter which should be controlled through Building Regulations. 1.33. Building Regulations provide a national standard and developers accept and do not seek to avoid Building Regulation requirements. Building Regulations must be adhered to or developments cannot be insured and sold. 7 PHILLIPS PLANNING SERVICES LTD 1.34. Where the planning system has sought to introduce detailed construction requirements including policies relating to carbon reduction, green energy etc., this has resulted in major differences between local authorities in terms of what is required. Some have little or no detailed policy on such matters others have highly onerous policies which make construction in one area far more costly than may be the case on the other side of an authority boundary line. Developers therefore seek to avoid and minimise requirements placed on them through the planning system because of this inconsistency and so a sense that what is being asked for is unfair or unnecessary. 1.35. It is considered that planning should provide guidance on how layouts can assist in combating climate change, sustainable drainage, ecological enhancements, environmental requirements etc. but should not seek to duplicate or go beyond building regulations in terms of construction specification, energy and water use. This creates confusion and inconsistency between local authority areas as outlined above.
1.23. Yes, it is considered very important that clear guidance is provided so that developers are aware of the expectations. 1.24. However, it is respectfully submitted that the ‘planning’ system is not the correct vehicle for imposing strict climate change standards for construction. This is a matter which should be controlled through Building Regulations. 1.25. Building Regulations provide a national standard and developers accept and do not seek to avoid Building Regulation requirements. Building Regulations must be adhered to or developments cannot be insured and sold. 1.26. Where the planning system has sought to introduce detailed construction requirements including policies relating to carbon reduction, green energy etc., this has resulted in major differences between local authorities in terms of what is required. Some have little or no detailed policy on such matters others have highly onerous policies which make construction in one area far more costly than may be the case on the other side of an authority boundary line. Developers therefore seek to avoid and minimise requirements placed on them through the planning system because of this inconsistency and so a sense that what is being asked for is unfair or unnecessary. 6 PHILLIPS PLANNING SERVICES LTD 1.27. It is considered that planning should provide guidance on how layouts can assist in combating climate change, sustainable drainage, ecological enhancements, environmental requirements etc. but should not seek to duplicate or go beyond building regulations in terms of construction specification, energy and water use. This creates confusion and inconsistency between local authority areas as outlined above.
1.23. Yes, it is considered important that clear guidance is provided so that developers are aware of the expectations. 1.24. However, it is respectfully submitted that the ‘planning’ system is not the correct vehicle for imposing strict climate change standards for construction. This is a matter which should be controlled through Building Regulations. 1.25. Building Regulations provide a national standard. Developers accept and do not seek to avoid Building Regulation requirements. Building Regulations must be adhered to or developments cannot be insured and sold. 1.26. Where the planning system has sought to introduce detailed construction requirements including policies relating to carbon reduction, green energy etc., this has resulted in major differences between local authorities in terms of what is required. Some have little or no detailed policy on such matters while others have highly onerous policies that make construction in those areas far more costly than may be the case on the other side of an authority boundary line. Developers therefore seek to avoid and minimise requirements placed on them through the planning system because of these 6 PHILLIPS PLANNING SERVICES LTD specific inconsistencies and a more general sense that what is being asked for is unfair or unnecessary. 1.27. It is considered that planning should provide guidance on how layouts can assist in combating climate change, sustainable drainage, ecological enhancements, environmental requirements etc. but should not seek to duplicate or go beyond building regulations in terms of construction specification, energy and water use. This creates confusion and inconsistency between local authority areas, as outlined above.
Whilst we support the Council’s aim in reducing climate change, we would not wish to see significant requirements and complication added to the development process. It is clear from the Planning for the Future White Paper that it is the Governments ambition to reduce and simplify the documentation produced by the local government, and not reproduce guidance and policies provided at a national level. Any further guidance must be justified and have regard for the viability of new development.