Object

Representation ID: 8380

Received: 02/09/2021

Respondent: Bedford Borough Councillor

In terms of quality of development, the single most important change that should be made would be to include embodied carbon as a material planning consideration. This is the most direct relationship between planning and climate impacts that could be influenced by planning policy. Only by including embodied carbon as a material planning consideration is there a remote hope that “the carbon neutral ambition” will be meaningfully incorporated into the Local Plan 2040.

Parking Standards for Sustainable Communities SPD 2014 needs supplementing at minimum for the rapidly increasing number of residential developments in the town centre where there are homes with no right to park a car. In such cases there is a need for greater provision of cycle parking, and also provision for car-club parking.
More generally, a standard of one cycle space per bedroom is not sufficient for use by households who may wish to cycle together. The minimum provision should be one cycle space per bedspace (ie two per double-bed or twin bedroom), plus sufficient storage for trailers and/or non-standard cycles. Where there are homes with no right to park a car, it is also reasonable to expect a proportion of residents will have more than one cycle (for example a cheap cycle for trips to the shop, in addition to a good cycle for longer journeys where there is secure parking at both ends of the journey).

We oppose the detail of the plan to replace Local Plan 2030 Policy 43. Since “Environmental net gain = biodiversity net gain + natural capital gain”, environmental net gain is not necessarily greater than biodiversity net gain. It would be compatible with biodiversity net loss if there was “compensating” natural capital gain. The policy should be that there is never any biodiversity net loss nor natural capital net loss in any case, while overall there is Environmental net gain in every case.
Detailed Policies – Required amendments to current policies
Current Policy 8 - Key development sites in St Paul’s Square, Bedford. While it is not mentioned for change, it would be appropriate for this policy to be changed to include explicit provision for the continued use of the riverside path and the route across the Bank Building site as a safe cycle path, but without the current barriers associated with wheelchair access to the Shire Hall building.
Current Policy 10 – The station area, Ashburnham Road, Bedford. While it is not mentioned for change, it would be appropriate for this policy to be changed to include explicit recognition of the value in retaining nos 2, 4, 8-12 and 20, with their greater architectural and historic value than neighbouring buildings. Amendment to include explicit recognition of the need for safe cycle routes to/from the station (including after dark) would be highly desirable. Similarly Policy 11 – Greyfriars, Bedford should be amended to include explicit mention of cycle access to the bus and rail stations, even though it is not mentioned for change in the draft.
Current Policy 13 – Land at Borough Hall, Bedford, again not mentioned for change, would be appropriately considered for change. Since that policy was made, there has been a considerable shift from office-based working towards home working, meaning that the key principles of development in that policy should be revised, without the “Retention of the riverside and main Borough Hall buildings for office and other uses”. “Provision of car parking at Prebend Street” should cease to be a ‘key principle of development’. While continued provision of some car-parking is appropriate, the climate emergency requires a modal shift away from car use, which needs to be accompanied by a reduction in car parking. There is scope, space and a need for there to be a cycleable off-street route between Prebend Street and St Mary’s Gardens that should be provided for.
Current Policy 14 – Land south of the river, Bedford should be amended to permit the closure of Kingsway and the return of the Kings Brook as part of the new neighbourhood, rather than explicitly requiring it to be an “urban boulevard” lined with “larger scale buildings and more continuous frontages”. There should also be explicit protection for green space on the former St Johns station site. Again, this policy is not mentioned for change in the draft.
Current Policy 16 – Bedford High Street should be retained in full. Proposed TC3 – Bedford town centre – changes of use - does not include the same provisions. In particular, the aim to reduce vehicular traffic in the High Street should be retained. While the situation has improved in recent years, changes such as the removal of the pelican crossing at Lurke St/Lime Street make further reductions in traffic important. Further, reductions in use by motor vehicles could enable provision of cycle paths both northbound and southbound to contribute to the needed modal shift and increase in active travel and active lifestyles. The requirement for shop fronts and signage to have “full regard to the architecture and heritage of the buildings” and the requirement for refurbishment of buildings to “contribute positively to the character and heritage” of the town should be retained, when they are proposed to be deleted.
Current Policy 29 – Design quality and principles is not proposed for amendment, but should be amended to include embodied carbon as a material planning consideration, and a requirement for tree-coverage (perhaps at half the level required within the Forest of Marston Vale, current policy 36S – ie at 15%). Accessibility and permeability should explicitly include provision for safe and pleasant cycling and walking as part of integrated networks enabling the walkable neighbourhoods and active travel that the draft plan claims to promote.
Current Policy 32 – The impact of development, disturbance and pollution impacts – is not proposed for amendment, but should be amended to include explicit mention of pollution caused by road traffic. Pollution should be explicitly defined to include global as well as local impacts.
Current Policy 34 – Advertisements – is not proposed for amendment, but should be amended, so that considerations that can be considered also include energy use.
Current Policy 39 – Retention of trees – is not proposed for amendment, but should be amended, so that in all cases when trees are lost, proposals should be included for them to be replace by an equivalent volume of trees that will include at least an equivalent diversity of species, and with at least one tree in a location no less urban than the current location of any tree lost.
While replacing current policy 43 is appropriate, proposed policy NE1 Environmental net gain should be clearer that neither net biodiversity nor natural capital net loss is acceptable.
Current Policy 44 – River Great Ouse – is not proposed for amendment, but should be amended, so that there is a requirement for development proposals to improve and protect marine environmental gain within the borough, such that marine biodiversity and marine natural capital losses may not be offset by on-land biodiversity and natural capital gains.
Current Policy 46S – Use of previously developed land and use of undeveloped land – is not proposed for amendment, but should be amended to recognise that agricultural land of the same grade may be have different levels of biodiversity, so that land that has been at a lower level of biodiversity for 30 or more years should be used in preference to the same grade of agricultural land that has a higher level of biodiversity (or has done within the last 30 years – this proviso being to remove any incentive to degrade land).
Current Policy 47S – Pollution, disturbance and contaminated land – is not proposed for amendment, but should be amended to include explicit mention of pollution caused by road traffic. Pollution should be explicitly defined to include global as well as local impacts.
Current Policy 51S – Climate change strategic approach – is not proposed for amendment, but should be amended to include energy use and to explicitly include emissions under all of scopes 1-3. The word “reducing” should be replaced by the word “minimising”.
Current Policy 53 – Development layout and accessibility – is not proposed for amendment, but should be amended. Developments that cannot demonstrate “convenient access to local services by foot, cycle and public transport” should not be acceptable, except where mitigation is made for such deficiencies, with developers required to implement or contribute towards measures to mitigate adverse impacts before their development is occupied, and such mitigation shall be provided in ways that mean the net equality impact of the development and mitigation improves accessibility most for those who are more disadvantaged. While natural ventilation is beneficial, it should not be at the expense of high levels of insulation: ventilation with heat exchange should be the preferred option.
Current Policy 54 – Energy efficiency – is not proposed for amendment, but should be amended. It is too easy for developers to claim that requirements “would make the development unviable”, and the policy needs to be amended both to remove (or dramatically reduce) this loophole, and to strengthen requirements, given that both technologies to improve energy efficiency have improved, and the need for energy efficiency has increased with continued climate breakdown. Among the strengthening of requirements should be some requirements on somewhat smaller non-residential developments.
Current Policy 57 – Renewable energy, general impact – is not proposed for amendment, but should be amended given the severity of the climate emergency. Current requirements for wind energy schemes are excessive, and the standards should generally be relaxed for community energy projects (other than biomass/’energy from waste’). The requirements for consultation and engagement with affected local communities should be lifted for wind energy schemes and solar energy schemes that are not on agricultural land.
By contrast, for biomass/’energy from waste’, impacts that should be considered should include traffic impacts and other potential ways of dealing with the fuel material, including options further up the waste hierarchy. In doing so, climate damaging emissions should be considered at all of scopes 1, 2 and 3.
Current Policy 58S – Affordable housing – is not proposed for amendment, but should be amended. Failure to amend it will allow the continued worsening of problems of housing affordability and inequality. As with Current Policy 54, it is too easy for developers to claim that requirements “would make the development unviable”, and the policy needs to be amended both to remove (or dramatically reduce) this loophole. The lower threshold for size of site should be reduced, and the proportion of affordable housing required should be increased. The requirement that “a lower percentage [than 80% of open market rents] should be set where this would preclude access to housing benefit.” is absolutely essential, and must in all circumstances be retained. Without such a proviso, the whole policy becomes meaningless and would inevitably fail in its aims.
Current Policy 69S is planned to be replaced by Policy E1S. In doing so the current explicit “focus for jobs growth … [on] the urban area of Bedford and Kempston” is removed, when this should be retained. As mentioned above, it also references policy 72S of Bedford Local Plan 2030, which should be amended.
Current Policy 71 - Other employment sites – is not proposed for amendment, but should be amended. Where existing employment sites are in locations suitable for travel-to-work by public transport, walking and cycling, the primary aim should be that they are retained for employment use, and if considered for redevelopment to non-employment uses criterion ii should be strengthened, for example by requiring advertising of the site’s availability for alternative employment uses.
As already mentioned, Current Policy 72S – Additional strategic employment development should be amended, even though no proposal for amendment has been made in the consultation. Sites should not be considered appropriate if the range of transport modes does not include both public transport at relevant hours for employees and practical access at relevant hours for those using active transport to/from substantial concentrations of housing.
Current Policy 76 – Improvement and provision of new visitor accommodation – is not proposed for amendment, but should be amended. In addition, visitor-related buildings should only be granted planning permission if both there is provision for workers to travel between the site and significant housing concentrations without use of private cars, and the plans include measures for at least one quarter of those using the site to arrive/depart without use of private cars when the site opens and for that minimum level to increase each year.
Current Policy 86S – Delivering infrastructure – is not proposed for amendment, but should be amended. Provision of infrastructure for road transport should not be considered an acceptable form of infrastructure for the provisions of this policy.
Current Policy 89 – Electric vehicle infrastructure – is not proposed for amendment, but should be amended to remove the mistaken impression it conveys that electric vehicles are “sustainable modes of transport”, while making provision for some shift from internal combustion to electric vehicles in existing urban areas. Thus, the final paragraph should be amended to read
“New residential developments should be designed to enable charging of plug-in and other ultra-low emission vehicles in safe, accessible and convenient locations and, where appropriate, provide electric charging points at a rate of one per dwelling. Where developments are made in the urban area that increase the size of a residential property, an electric charging point should be provided. If there is no off-street parking on the premises, the developer should contribute to the provision of an electric charging point for public use in a nearby street”.
Current Policy 90S – Transport infrastructure and network improvements – is not proposed for amendment, but should be amended. Measures such as the “Dualling of the Bedford Western Bypass” and “Improvements on Highway England’s strategic road network” are not consistent with measures to combat climate breakdown and to meet the needs of the climate emergency. Reducing congestion should not, as mentioned above, be an aim in itself. Instead, modal shift towards public transport and active travel should be the aim, since such modal shift implies less energy consumption and less land taken for road transport.