Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10274

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Representation Summary:

Natural Environment policies
13.6 CBC support the proposed new policy DM7 – Environmental Net Gain, which aims to increase overall Environmental Net Gain, over and above just Biodiversity Net Gain.
13.7 However, the supporting text alongside the policy references the Arc Environmental Principles, which all Local Authorities within the Central Area, including Bedford in June 2021, have signed up to. Whilst it is appreciated that the Government are no longer taking forward the Arc as previously anticipated, it is considered that the Environmental Principles are a robust foundation upon which to deliver environmental and biodiversity net gain.
13.8 It is therefore surprising that whilst proposed policy DM7 specifies a requirement to secure a minimum of 10% BNG in relation to major proposals, the policy or supporting text does not specifically make reference to the 20% ambition set out within the Arc Environmental Principles.
13.9 It is also noted that Policy DM7 does not apply to sites below 10 units or <0.5ha. As identified within our response to the consultation in September 2021, in relation to smaller development schemes that come forward, we would be interested to understand how will it be ensured that BNG and NEG will be addressed?