Question 9
2.15 MGH is committed to improving the environmental performance of the new homes that they build and delivering development in sustainable locations where new residents are not overly reliant on the use of the private car. The emerging plans for Beauchamp Park are testament to this with proposals to enhance cycle and pedestrian connectivity with Bromham and the delivery of an abundance of open space and landscaping that will meet the amenity needs of residents alongside having high ecological value. 2.16 MGH believes that the Council should support a national approach to improving the energy performance of residential developments through building regulations rather than local authorities setting their own standards. The use of planning policies to require the use of renewable technologies in new residential development does not necessarily result in a sustainable development as residents are thereafter required to maintain them. The fabric first approach, which the increasing standards in building regulations will deliver, is therefore a more appropriate way to deliver carbon savings over the lifetime of a development. 2.17 Moreover, where different local authorities introduce a plurality of standards through Local Plan policies it leads to delays in the planning process and inefficiencies for volume and regional and national housebuilders that develop sites across different local authority areas. September 2020 | CAM.0109 September 2020 | CAM.0109 Page | 7 2.18 The Government already proposes to introduce measures to increase the environmental performance of new homes through the Future Homes Standard. These were proposed to be mandatory for new residential developments in 2020 with new regulatory targets coming into force in 2025. The negative impact on the economy as a result of the lockdown to control the Covid-19 pandemic will be felt for years to come. Therefore, now is not the time to be adding additional burden to the construction industry and the Government recognises this. It is equally important the Councils support the recovery by not seeking to introduce additional standards above those that will be introduced at the national level, the costs of which will ultimately be passed onto the consumer or may result in some sites being undeliverable.
9.1 O&H is of the view that it would be beneficial for the Council to produce further guidance for developers on how to respond to climate change. 9.2 O&H consider that the Council could be more ambitious and go beyond what other authorities have done previously by seeking to deliver a series of physical developments which incorporate innovations and the highest standards of sustainability as showpieces to accompany any future guidance document for developers. 9.3 O&H responded to the Authority’s ‘Call for Sites’ consultation on 14 August 2020 to put forward five sites that are completely within O&H’s ownership which could be developed during the emerging Plan period. Of the five sites, Randalls Farm is proposed for development as a Model Village’, the function of which will be to demonstrate, and test innovative and low carbon technologies as well provide a knowledge exchange and educational hub. 9.4 The purpose of the site is to contribute towards a step-change in construction quality and innovation in the Vale as well as support small rural start-up businesses and local knowledge exchange. A key component of this opportunity site would be the delivery of circa 24 demonstrator homes (a conservative assumption). 9.5 The Council could capitalise on this opportunity and some of the demonstrator homes could be used as physical use examples of the guidance / benchmark the Council are seeking to achieve with regards to responding to climate change.
There should be overarching directives concerning reductions in carbon emissions in support of a carbon Neutral Borough and this should be given priority within the Plan. All future development applications should include a response to these requirements. Encouragement should be given to solar and wind energy generation and support provided to encourage both air-and -ground-based heat pumps. Shared community heating and energy generation schemes should be approved where this is feasible and beneficial to the climate. Transportation and other movement options should be a key part of any development plan with an emphasis on walking and cycling to key points in the town and to transport hubs for longer journeys. Use of the car should be minimised and electric propulsion encouraged. A thorough review of local public transport should be undertaken in order to maximise its utility and benefit in saving energy and reducing pollution and congestion.
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.
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.
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.
We have no developed view on this but we do see a risk of increasing house prices if housing policy is driven by an environmental brief beyond national requirements.
The housebuilding industry, through the HBF, recognises that there is a need to move towards stronger measures to improve the environmental performance of new residential development. This is in terms of reducing carbon emissions in new homes, providing gains in biodiversity on all developments, green infrastructure and improving the environment around new developments. However, the HBF, and our members, consider a national and standardised approach to improving such issues as the energy efficiency of buildings, the provision of renewable energy and the delivery of electric vehicle charging points to be the most effective approach that balances improvements with continued deliver of housing and infrastructure. It is the industry’s preference for a national approach to improving the environmental performance of residential developments, rather than local authorities setting their own standards. We consider this is necessary to allow research and development and supply chains to focus upon responding to agreed national targets, and for training providers to plan their programmes to equip the labour force to meet these new requirements. It is fundamentally inefficient to create a plurality of standards. The industry will clearly need to consider the Government’s measures on the Future Homes Standard which were proposed to be mandatory for new residential developments in 2020. In terms of the new regulatory targets that will apply to new development from 2025 onwards – to deliver the objectives of the Future Homes Standard – the industry, with the leadership of the HBF, will be commissioning work to consider what the industry can do, taking into account developments in research and product development within that time-frame, and what new standards can feasibly be adopted and implemented by the industry. Therefore, when considering their approach to such matters the Council should ensure that they are working within the current policy and legislative framework and not seeking to deliver a different range of standards that will work against the collective drive on this matter. The importance of a collective approach will also balance the cost of delivering the energy efficiency improvements required alongside other planning obligations and development aspirations that the Council are seeking to deliver through the Local Plan, such as meeting housing needs in full and improving the affordability of homes in this area. The Council will therefore need consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer or leave some sites undeliverable. Prior to the future standards the Councils must take account of current guidance which sets out the approach that Councils should take with regard to technical standards relating to energy efficiency with paragraph 150 of the NPPF stating that: “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.” The Planning Practice Guidance (PPG) expands on this provision outlining that policies requiring higher energy performance standards than building regulations should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes. As such the aspirations of this plan with regard to improving the energy efficiency of new homes must be made within the context of this guidance if the plan is to be consistent with national policy and found sound. Such an approach will ensure that, in line with paragraph 148 of the NPPF, the local plan supports the transition to a low carbon future whilst also ensuring new development continues to provide the homes needed for future generations.
As members of the House Builders Federation, their consultation response on behalf of the industry has been shared with us prior to submission. We support their response to this question and do not wish to add further comment.
As members of the House Builders Federation, their consultation response on behalf of the industry has been shared with us prior to submission. We support their response to this question and do not wish to add further comment.
There are already government policies for climate change and they should be in all guidance for developers within the local plan
Pavenham PC queries whether this is really necessary. The Borough Council has set standards in its Local Plan that have been approved by the Secretary of State and the Government is not slow to produce its own Guidance on the subject. The Parish Council believes the Council’s objectives to be clear and would query whether a degree of flexibility might actually be beneficial - thereby implicitly encouraging the introduction of innovation which goes beyond what sometimes can be seen as the “straight-jacket” of Guidance?.
The analysis needed to formulate the proposed new policies on climate change, (See Q1) namely – • Include policies to ensure that new allocated development is at least neutral, and if possible negative, in terms of its contribution to climate change. • Include policies to ensure that new allocated development is built to explicit standards that mitigate the potential impacts of future climate change. will necessarily involve identifying the construction techniques and standards that developers will have to apply in planning applications. Any further guidance need only be to provide detail to the policy requirements.
Yes – greater clarity over the precise measures that can be adopted to achieve the government’s 2050 target. It is essential that the council plans appropriate policies to prevent a potential challenge over the Local Plan’s ability to decarbonise the economy. Such a challenge would delay critical development.
The prominent inclusion of climate change within the Local Plan vision is supported, although specific policies to address this will need to be deliverable; i.e. aspirational but achievable.
Climate change is a national if not a global issue. We consider that the existing policies are sufficient and that there is no need for any supplementary planning document. Question 10 The Government is developing new house-building standards to be implemented through building regulations. Is there any local evidence or need to go beyond national standards? The Borough Council itself does not appear to have produced any convincing evidence of the need to go beyond national standards. Eclipse Planning Services view is that there is in any event no need to do so.
In principle yes, but I doubt that the BBC has the capacity to produce anything that others have not done already, so the issue is not producing more guidance but ensuring that what exists is (a) best practice and (b) implemented.
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 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.
Bedford BC should produce further guidance for developers on how to respond to climate change and climate change measures in commercial, business and public estate premises in addition to housing. Quantified targets should be introduced for biodiversity & environmental net gain and for climate change measures. Cambridgeshire has agreed to a doubling of land managed for nature and Bedford BC should do so and, in addition, follow the Nature’s Arc guidance produced by Wildlife Trusts, RSPB & the Woodland Trust. Sustainable housing standards should also be enforced.
Developers should be encouraged - indeed mandated to install solar panels and also vehicle charge points for electric charging on all developments.
YES! Compulsory inclusion of solar panels and encouragement for use of geo thermal technology etc. Less white elephants such as the archimedes screw.
Yes. All houses should have solar panels where possible all houses should have water butts on all down pipes if possible.
Ravensden Parish Council does not have a view on the need for further guidance but, if it is not part of the Local Plan Review, any revised guidance should be the subject of full public consultation before it is adopted.
Yes, we agree. Alternative energy sources Use of plastic to be reduced and non biodegrables (plastic windows and doors - Necessary???) Stop provision of large scale concrete block paved areas. Water conservation.
No Comment
Agreed response: This is a national issue and there is a great deal of guidance available to developers. Rather than producing more guidance, the Borough resources would better concentrated on ensuring that this guidance is applied in local development.
Bedford Borough has excellent green spaces, they need to be maintained. Focus upon green transport links, maintaining existing green spaces and rural areas. Any development to limit impact on existing countryside areas. Introduce more cycleways, bridleways and bus routes. Introduce a river taxi service to make use of the river as a means of transport and as a means of attracting visitors Use of Green roof space in town centre areas and policy relating to the use of solar panels on new and renovated business and residential properties. New developments and roads should have more green space with the use of Wild flower planting to encourage the bee population and the increase in trees and hedgerows around new developments and roads. Consider the introduction of an Air quality zone in Bedford Town Centre and in the wider Borough. Consider wider Pedestrian zone in Bedford town centre and a private vehicle exclusion (except for Buses, Taxis, Privately Owned Electric Vehicles).
Yes.
The Council’s Supplementary Planning Document “Climate Change and Pollution” previously guided developers on issues relating to climate change. However, this is no longer part of the development plan. Given the urgency of climate change the Council should prioritise new guidance to focus developers on addressing this issue at the inception stage of development.
The Council’s Supplementary Planning Document “Climate Change and Pollution” previously guided developers on issues relating to climate change. However, this is no longer part of the development plan. Given the urgency of climate change the Council should prioritise new guidance to focus developers on addressing this issue at the inception stage of development.