Support

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9996

Received: 29/07/2022

Respondent: Wates Developments

Agent: Boyer

Representation Summary:

4. POLICY DS1 - RESOURCES AND CLIMATE CHANGE
4.1 Wates supports the principles set out at draft Policy DS1, which will facilitate the move towards carbon neutrality, in the context of the ‘Climate Emergency’ (declared by BBC in 2019). The Wates Group has itself committed to achieving zero carbon and zero waste, in respect of its operations, by 2025. Wates Innovation Network also undertakes research and works with SMEs to help develop new sustainable construction / building services technologies and bring these to market.
4.2 Part A(i) of this draft policy recognises that the most effective way to reduce carbon emissions is to concentrate development at sustainable locations, which minimise the overall need to travel and present opportunities for travel by sustainable modes. At Part A(ii) the importance of ensuring that developments are provided at a density “that makes the most of accessible sites” is also emphasised as a mechanism to promote self-containment and trip internalisation, as another key factor in reducing carbon emissions.
4.3 To this, Wates would add that higher levels of density are essential to creating the ‘critical mass’ necessary to sustain local schools, shops and other forms of infrastructure, which create walkable and self-contained communities. Low and zero carbon developments are also often comparatively dense, as this can assist in implementing thermally efficient designs (e.g., through a reduction in external elevations) and may facilitate community renewable energy generation strategies, district heating schemes, etc3. As we note in our comments on draft Policies DS2 and DS15, the Plan should not shy away from seeking higher densities at appropriate locations.
4.4 It is welcomed that the draft policy also recognises the potential for carbon sequestration to be achieved through the provision and/or restoration of habitats. The provision of new areas of woodland can contribute to this goal. Indeed, Wates’ interests at Land South of Wixams are well-placed to accommodate a new area of woodland, which will facilitate the expansion of the Forest of Marston Vale as a key community and environmental benefit.
Compliance with the Tests of Soundness
4.5 Wates agrees with the proposals set out in draft Policy DS1, as these are justified in the context of the declared climate emergency and national priorities to achieve net zero carbon. As set out in our comments on Policies DS2, HOU12 and HOU15, the Plan expressly seeks to concentrate future growth in areas that benefit, or which will benefit, from new rail infrastructure. In seeking to direct development to locations with inherent sustainability benefits, Part A(i) of draft Policy DS1 impacts positively on the overall spatial strategy and effectiveness of the Plan.