7.30

Support

Representation ID: 4963

Received: 02/09/2021

Respondent: Dean and Shelton Neighbourhood Planning Group

The Bedfordshire Natural Capital Assessment supporting document which provides a detailed natural capital (habitat) basemap for Bedford Borough, is noted. However, it is not clear to us how the delivery of biodiversity net gain will work in practice and whether this will be achieved though further policy development by the Council or whether it is intended that this will be delivered through the net environment gain metric, referred to in para 7.40, which is to be developed from the Arc Environment Strategy. Further explanation in this respect would be welcome.

Object

Representation ID: 5099

Received: 02/09/2021

Respondent: Ms Ginny Ford

Can't the Borough be more proactive and include net gain requirements from the start? If not we will risk losing more biodiversity with little or no compensation or enhancement in the next 2-3 years with a substantial amount of allocations wanting to start in this early period , that's a lot of potential loss of biodiversity and opportunity missed to improve .

Support

Representation ID: 6377

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Paras 7.30 to 7.40 – SUPPORT with comments

The draft plan Policy NE1 –Environmental Net Gain is welcomed as an indication of the way the Council is setting out its approach to delivering biodiversity net gain on development sites. The Bedfordshire Natural Capital Assessment supporting document which provides a detailed natural capital (habitat) basemap for Bedford Borough, is noted.

However, it is not clear to us how the delivery of biodiversity net gain will work in practice and whether this will be achieved though further policy development by the Council or whether it is intended that this will be delivered through the net environment gain metric, referred to in para 7.40, which is to be developed from the Arc Environment Strategy. Further explanation in this respect would be welcome.

Object

Representation ID: 6657

Received: 14/09/2021

Respondent: Bedfordshire Great Ouse Valley Environmental Trust

If a net zero borough is to be created, one of the key activities will be delivery and demonstration of environmental
net gain. Environmental net gain has wider implications than biodiversity net gain (it also includes natural capital), Both environmental net gain and biodiversity net gain should be specified in the Council’s policy.
However, it is noted that there are dangers in using a habitat-based method biodiversity metric 2 or 3 to demonstrate biodiversity net gain in that it does not address living species (e.g., animals, insects). There is a danger, for example, that the habitat of the development area might be relocated and enhanced but important species lost. A detailed assessment should be made of all species present to ensure that they are not lost during development.
Due to the very high level of uncertainty in environmental net gain calculations, Beds GOVET would prefer the amount of net gain to be set at 20% for both environmental and biodiversity net gains rather than the 10% currently recommended in Government legislation. This should ideally be delivered on or within 5km of the development site and with appropriate interconnectivity between habitats.

Object

Representation ID: 6926

Received: 15/09/2021

Respondent: Bromham Parish Council

Other Environmental Issues
It is considered that “Environmental Net Gain” should be specified rather than “Biodiversity
Net Gain” and that it should be set at 20% rather than the 10% in Government legislation and
should be delivered on or within 5km of the development site.
Protection for the River Great Ouse Valley should be included in policies.
The Parish Council sincerely hopes that these observations are helpful and that the Borough
Council will be prepared to focus its proposals for growth locations consistent with
endeavours to protect existing sustainable communities from the harm that excessive growth
will cause the immediate and neighbouring rural communities.

Support

Representation ID: 7238

Received: 17/09/2021

Respondent: Bedford and Milton Keynes Waterway Trust

The B&MK Waterway Trust wishes to press for:
• stronger policies to protect the route of the waterway park and facilitate its delivery
• recognition that the waterway park has the potential to offset impacts of other development.
• Assessment of the Waterway Park as an opportunity to create new natural capital.

The B&MK Waterway Trust recognises that the Council already has planning policies to protect and enhance the natural environment. However, as the new Environment Bill passes through its various parliamentary stages, the Council will need to consider how any of these policies might need to change to bring them up to date. Given the close alignment between the B&MK Waterway Park project and national and emerging OxCam Arc policies the B&MK Water Trust believes that the opportunity to strengthen Local Plan policies which relate to the Waterway Park should be taken. The project also offers an opportunity to establish a means by which new development projects, particularly in and around the development opportunities identified at Stewartby and along the East/West Rail route, for offsetting environmental impacts and facilitating increases in biodiversity which cannot be achieved on site. Proposed draft policies are set out below:
The Bedford & Milton Keynes Waterway Park
Background
The Bedford and Milton Keynes Waterway Park will establish a new waterway, within a multifunctional green corridor, linking the Grand Union Canal at Milton Keynes with the River Great Ouse in Bedford. It will close a small but very significant gap in the UK waterway network, enhancing opportunities for flood risk management in the upper Ouse catchment area and for water transfer between the main network and the drier areas of East Anglia. It will build on the achievements of the Marston Vale Community Forest in regenerating parts of the corridor and creating new habitats between Bedford and Milton Keynes. It will set the context for, and embed new natural capital into, new and expanding communities thus, contributing towards the Government’s commitment to leave the environment in a better state.
The Council is part of a Consortium of partner organisations that have agreed to work together with the aim of delivering the Bedford & Milton Keynes Waterway Park.
Policy:
1. Development on the route of the Bedford and Milton Keynes Waterway Park will be expected to deliver the section of the Waterway Park within the development boundary, incorporating a Waterway channel and ‘towpath’ for non-motorised users within a multifunctional green corridor.
2. Development should be designed to relate positively to the Waterway Park, and should be designed to complement adjacent areas and sites along the route of the Waterway Park.
3. Development that would adversely affect the implementation of the Waterway Park, or that does not provide accommodation for the Waterway and associated infrastructure will not be permitted.
4. The Waterway Park is a Strategic Environmental Opportunity for offsetting in relation to biodiversity net gain.
Sustainability Appraisal response
The sustainability appraisal objectives include:
• Protect, maintain and enhance biodiversity and habitats.
• Reduce emissions of carbon dioxide and improve energy efficiency.
• Protect and enhance landscape and townscape character and the sense of place in settlements.
• Protect the quantity and quality of water resources.
• Minimise flood risk.
• Reduce the need to travel and promote sustainable modes of transport.
Several of the objectives of the plan are directed at enabling Bedford to
• respond to the impacts of climate and economic change
• offer the opportunity to live healthier lifestyles
• Improve access to green and blue infrastructure for the enjoyment and health of all.
• Protect and enhance our natural resources including air, soil, minerals and water to minimise the impacts of flooding, climate change and pollution
However, despite its alignment with these objectives the sustainability appraisal makes no reference to the Bedford and Milton Keynes Waterway. The Trust requests that this omission is addressed.
Natural Capital Assessment response
The Natural Capital Assessment makes no reference to the Waterway Park despite is being a significant opportunity to increase natural capital in the Borough. The B&MK Waterway Trust requests that this omission is addressed.

Object

Representation ID: 7941

Received: 20/09/2021

Respondent: Pavenham Parish council

The Parish Council recognises that the Borough Council is in some difficulty in promoting a policy that essentially will have to anticipate the provisions of the Environment Bill – which on the basis of latest reports, may well be delayed yet further by reason of amendments made to the Bill by the House of Lords which are being resisted by Government.
Whilst the Parish Council supports the positive approach that is being taken by the Borough Council with regard to “environmental net gain”, the Parish Council would be very concerned if the Borough Council introduced environmental concepts that went beyond the terms and concepts as defined in what will eventually be the Environment Act – as and when it receives Royal Assent.

The Parish Council to an extent wishes to reserve its comments at this stage in that once the Bill has received Royal Assent the concepts discussed by the Borough Council in this Consultation will have been clarified.

The Parish Council does have some concern, however, that by recognising the concepts of “biodiversity net gain” – natural capital gain” – and “environmental net gain” it is running the risk with its proposed “Policy NE1 – Environmental net gain” of introducing a degree of confusion in terminology which, if that terminology itself conflicts with the wording employed by the Environment Act will ultimately lead to confusion as to interpretation and implementation which, with a draft Plan that is contemplating an additional 12,500 new dwellings in the Plan period, could be very dangerous.

Support

Representation ID: 8588

Received: 27/09/2021

Respondent: Elstow Parish Council

The Parish Council feel it would be a better approach by the local authority if they set clear
objectives within the document immediately which show a proactive stance, as well as the
important value from net gain requirements from the start of this plan being developed. National
planning policy will come into effect shortly and it would be logical for this to be built in as the
Plan emerges, rather than potentially being not included, which would be a pity. This re-enforced by Natural England who recommend that a commitment to biodiversity net gain
is made within a bespoke policy to demonstrate best practice. If the policy is not active than it
will be impossible for the local authority Officers not only at Planning Policy level but also when
planning applications come forward, any potential benefit in terms of biodiversity will be lost.

Support

Representation ID: 8866

Received: 29/09/2021

Respondent: Mrs Alison Myers

6. Environmental Net Gain para 7.30
This approach is supported , and that the Oxford -Cambridge Arc target of 20% net gain will be used.
It is a concern that the Ecosystem Services Report does not assess Agricultural Land Value as a key asset. Soils underpin the environment and quality soils need to be valued and conserved. It is stated that Natural Capital "is the stock of natural assets, including soil".

My key concern with the Biodiversity Net Gain is the metric requires staff able to assess the data. Bedford Borough Council will need to employ an Ecologist to work with the Applicant's to achieve net gain. Space has to be designed in at the concept stage for this to be realised.
I would like the need for net gain to apply for all developments, not just Major developments over 10 dwellings.
Every development has an environmental impact - whether it is a house extension or a redevelopment on plot. In Ravensden there has been a steady loss of trees and hedges as buildings are adapted and front gardens lost to parking. To benefit climate change, biodiversity and general amenity, an approach which requires replacement of trees and hedges should apply to all scales of development.