Object

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

Representation ID: 6239

Received: 09/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

Representation Summary:

3.1 The first statement contained within the Local Plan’s Vision (Chapter 2) rightly
sets an aim of tackling climate change and adapting to and mitigating its
effects being at the heart of new development in the Borough.
3.2 This is then reinforced, with Theme 1 (p.13) setting an objective to making
Bedford Borough a carbon neutral Borough. The draft Local Plan, however, does
not currently carry this commitment through in such a way as to suggest
meaningful action.
3.3 Firstly, the Local Plan does not include any proposed strategy or approach
concerning renewable energy development. If the Borough is serious about
becoming carbon neutral and tackling climate change, it is essential that the
Local Plan includes positive policies which encourage both renewable
energy developments, and net zero carbon developments, to come forward.
3.4 The NPPF is clear (Chapter 14 – para 152 in particular) that the planning system
should, inter alia, support renewable and low carbon energy and associated
infrastructure. Para 153 states that Plans should take a proactive approach to
mitigating and adapting to climate change.
3.5 Moreover, para 155 states that Plans should both provide a positive strategy for
energy from renewable and low carbon sources and consider identifying
suitable areas for such developments.
3.6 The Local Plan fails to tackle this issue. As currently drafted, it lacks any
meaningful proposals or aims in order to meet these requirements of national
policy.
3.7 In the same fashion that the Local Plan has considered issues and options
around future growth (scale, location, pattern etc), this iteration of the Local Plan
should have also included options proposing a positive strategy for energy from
renewable and low carbon sources, including potential locations.
3.8 It must encourage growth that comes forward where renewable energy
goes hand in hand with development proposals, with positive policies
encouraging such developments (be they as allocations and/or applications)
to be considered favourably. The NPPF makes particular reference (para 155 c)
to identifying opportunities for development to draw its energy supply from
decentralised, renewable or low carbon energy supply, and for co-locating heat
customers and suppliers.
3.9 Of particular concern is the lack of any focused evidence base document(s)
addressing these matters. The list of Local Plan 2040 Supporting documents
provided by the Council is absent any topic papers, studies or the like which
address these matters.
3.10 It is essential that BBC undertake such work as a matter of urgency to inform
the next stage of the Local Plan. AWG propose that the Local Plan will need to
include policies allocating sites for renewable energy, as well as allocating
strategic developments which could come forward alongside renewable
energy. The land West Park Farm, as set out later in these representations, is a proposed development that would be in accordance with such an approach as
advocated by the NPPF.