Object

Representation ID: 8577

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

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 also 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.
3.11 The Sustainability Appraisal (‘the SA’) should also be updated to reflect this requirement. The climate crisis is a significant, national issue and the SA methodology must be amended to provide greater weighting to matters relating to climate change and energy.