Policy DS1(S) Resources and climate change

Support

Representation ID: 9250

Received: 27/07/2022

Respondent: Met Office

Agent: Mr Adam Kindred

The Met Office support the thrust of this policy and consider to be consistent with paragraph 153 of NPPF which requires plans “to take a positive approach to mitigating and adapting to climate change” and ensuring “future resilience of communities and infrastructure to climate change impacts”. The policy is also consistent with paragraph 154 of the NPPF and the National Planning Practice Guidance (‘NPPG’) as it seeks to reduce carbon emissions through location, orientation and design of new development, and emphasises the need to maximise carbon storage and sequestration as well as targeting new development in less vulnerable locations.

Support

Representation ID: 9256

Received: 27/07/2022

Respondent: Mrs Alison Myers

Development should integrate energy generation - particularly to exploit large roofs of commercial buildings.
Urban cooling - through treeplanting in existing built up areas is fully supportd.

Support

Representation ID: 9388

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

We support this policy and welcome link to creating and restoring habitats to maximise carbon storage and sequestration.

Comment

Representation ID: 9421

Received: 29/07/2022

Respondent: Luton & Bedfordshire Green Party

We would challenge the use of passive language in this policy, e.g. A iii "contributing to more walkable and cycle-able neighbourhoods" and instead request that instead there are specific requirements e.g. "a minimum of a doubling of walk-able and cycle-able" or similar language. Too much of what is written permits insufficient action to be taken.

Object

Representation ID: 9430

Received: 29/07/2022

Respondent: Prologis

Legally compliant? No

Sound? No

Duty to co-operate? No

Please see attached report

Comment

Representation ID: 9493

Received: 29/07/2022

Respondent: Biddenham Society

The Biddenham Society believe a far stronger position should be taken on enforcing the implementation of renewable energy. All developments should incorporate solar power generation and storage at the initial build stage. This would take advantage of economies of scale rather than the higher cost of incorporating it retrospectively. Historically, developers have been directed to provide community services in exchange for receiving development permission; we can see no reason why they should not provide solar panels and batteries within the houses or solar power generation fields as part of this Local Plan.

Object

Representation ID: 9557

Received: 20/07/2022

Respondent: English Regional Transport Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy DS1(S) The Borough must reduce net-zero CO2 emissions and improve Borough's transport infrastructure in order to support the gravity in the local economy. The congestion must be reduced in the Borough and should include journeys by public transport,walking and cycling.

Comment

Representation ID: 9571

Received: 20/07/2022

Respondent: L&Q Estates Limited

L&Q supports the Council’s intention to reduce carbon emissions within new development and
ensure that new development mitigates and adapts to climate change, as outlined at Draft
Policy DS1(S). L&Q endeavours to reduce carbon emissions through on-site measures
wherever possible and we are in the process of developing our plan to become a net zero
carbon business by 2050.

Object

Representation ID: 9640

Received: 29/07/2022

Respondent: Arnold White Estates Ltd

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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 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 AWG supports the principle of Policy DS1(S) and in particular, the importance of
development being located to minimise the need to travel and where there are
opportunities to maximise the ability to make trips by sustainable modes of transport.
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. AWG therefore
consider that the Plan is unsound as it is not consistent with national policy. To make
the Plan sound, Policy DS1(S) should be revised to include reference to strategic
renewable energy, such as onshore wind and solar. There should also be a requirement
within the strategic allocations to deliver renewable energy as part of these
developments.
3.9 Of further 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 and revise the Local
Plan ahead of submission.
10 Pre-Submission Local Plan Consultation Response ● APL–251
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.

Comment

Representation ID: 9656

Received: 26/07/2022

Respondent: Historic England

We welcome the reference to the consideration of heritage in relation to retrofitting buildings at Avii.

Support

Representation ID: 9722

Received: 29/07/2022

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

Cloud Wing supports the principle of Policy DS1(S) and in particular, the importance of development being located to minimise the need to travel and where there are opportunities to maximise the ability to make trips by sustainable modes of transport. It also supports the reference to protecting and taking opportunities for more sustainable movement of freight. Indeed, development at their land at Kempston Hardwick would clearly support this objective.

Comment

Representation ID: 9744

Received: 29/07/2022

Respondent: Mr Kevin Levvit

4. With regard to transportation, it is all well having cycleways available for the new builds, but what about improvements to the existing infrastructure provisions for villages such as Wilstead whereby the aging population find it increasingly difficult to travel because of the lack of suitable bus routes? There is NO provision in the 2040 Plan to rectify some of the issues that previous plans have created or suppliers have ceased providing the appropriate levels of service. If the intention is to encourage the entire population of Bedford Borough to travel on public transport, it needs to be planned for and put in place – currently sadly lacking in some areas. It also needs to have adequate numbers of vehicles – as provision by the lack of available transport at the park-and-ride sites during the recent River Festival event.

Object

Representation ID: 9760

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We consider the spatial strategy including site selections will not minimise the need to travel and hence fail to minimise carbon emissions from new development.
The location of some of the proposed allocations are not considered to be well related to existing urban areas and whilst new places of certain scale are able to become more self-sufficient over time depending on the mix of development and deliverability, there is uncertainty and risk over the means by which to achieve this. Some of the locations seem not to relate well to facilities within Bedford Town and Kempston and some will be reliant on
provision of East-West Rail which as our other representations have identified remains uncertain.
Land at Box End, West of Bedford performs well in accessibility and connectivity terms. The development will be designed to be a 20-minute community, where day-to-day facilities are accessible within 20-minutes by active travel. As the development will provide a mixed-use community, internalised based trips will be maximised.
As it stands the plan in our view is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The objective of delivery of sustainable development will only be realised if sites are well related to Bedford Town and Kempston or can be largely self-sufficient in terms of the scale and mix of development.
These tests of soundness are applied to non-strategic policies within the local plan in a proportionate way, taking into account the extent to which they are consistent with relevant strategic policies for the area.
Paragraph 66 of the NPPF states that strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply
and mix of sites, taking into account their availability, suitability and likely economic viability.
Bedford Borough Council is the strategic policy-making authority in this instance and we accept that the Council has undertaken a call for sites and has taken this into consideration in arriving at the proposed strategy and objectives but we consider there is a fundamental issue
over deliverability.
The policy does not include any target or means by which to assess performance against policy and hence it is not measurable and hence it is not achievable.

Object

Representation ID: 9773

Received: 22/07/2022

Respondent: Environment Agency

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Policy DS1(S) has many positive elements to it and we support the Council’s aim to be carbon neutral and deliver climate change mitigation and adaptation.

The development strategy (paragraphs 4.3 and 4.7) explains that to meet assessed needs to 2040, there has been an uplift of the housing requirement of 40% from 970 dwellings per annum (2030 plan) to 1355 dwellings per annum. We have reviewed sections 5.3 Potable Water and 5.4 Wastewater of the Infrastructure Delivery Plan dated May 2022. We are concerned that the IDP doesn’t provide sufficient evidence to demonstrate that the proposed growth put forward by the plan can be delivered sustainably, and not place further pressures on a water environment (notably rivers and groundwater) which is already under pressure from abstraction for public water supply and wastewater discharges. We are therefore concerned that Policy DS1(S) ‘Resources and Climate Change’ and potentially Policy DS3(S) ’Amount and timing of growth’ are unsound as they are not consistent with paragraphs 20 and 153 of the NPPF. Paragraph 20 sets the baseline in requiring that strategic policies should make sufficient provision for (b) infrastructure for water supply and wastewater (amongst other strategic issues). Paragraph 153 is requiring that plans take a pro-active approach to mitigating and adapting to climate change, taking into account the long-term implications for (amongst various issues) water supply.

Section 5.3 (Potable Water) of the IDP describes the predicted deficits in future water supply faced by Anglian Water as detailed in their Water Resources Management Plan (2019). A draft update to the company’s WRMP is about to be published in Autumn 2022, with the final plan expected in 2024. The Council at the earliest opportunity should seek advice from Anglian Water on how relevant the 2019 WRMP remains as a long-term planning tool. This particularly relates to the figures quoted in 1.4.12 and 5.3. We advise extreme caution in using the figures quoted in the 2019 WRMP unless they are demonstrated to remain relevant in the context of the company’s forthcoming WRMP24. The 2015 Anglian Region River Basin Management Plan (RBMP) that current levels of water abstraction are causing, or risk causing, environmental damage in various river catchments across East Anglia and measures have been identified in the RBMP to address this. We have recently undertaken abstraction licence reviews to ensure waterbodies comply with the Water Framework Directive objectives. Given the water resource pressures in the region, we cannot rule out further reductions in the supplies available to Anglian Water to prevent deterioration of water related ecology. Any resultant loss in available supplies will need to be addressed in the company’s WRMP24. It should be noted that replacement supplies are likely to require strategic supply options (for example, reservoirs and long-distance transfers) that could have significant delivery times. This should be an important consideration and inform Policy DS3(S) which sets out the amount and timing of growth. The stepped trajectory noted in Local Plan paragraph 4.25 refers to ‘critical infrastructure’ and paragraph 4.27 alludes to transport infrastructure. However, for the plan’s policies to be effective and deliverable, it needs to be proven that water supplies can be delivered sustainably and review the trajectory of growth accordingly.

Whilst section 5.3 of the IDP notes that Bedford is not the only local authority supplied by the Ruthamford Water Resource Zone, the effects of growth need to be considered at the company/regional scale and in combination with the other authorities’ local plans to assess the overall effect on the ability to supply water whilst meeting environmental obligations. Spare capacity in the Ruthamford resource zone may already be allocated to 1. Growth in resources zones elsewhere in the company’s network, 2. Transfers to other companies in the region, or 3. To offset supply reductions to protect the environment. The local plan needs to take account of the combined effect of growth across the region, including in neighbouring authorities, and therefore the overall increase in demand for water and not just that of Bedford Borough area.

For wastewater we are concerned that the IDP relies on Anglian Water’s now out-of-date Water Recycling Long Term Plan 2018 which will be reviewed as part of the forthcoming Drainage and Wastewater Management Plan due in Autumn 2022. It’s not demonstrated whether the proposed level of growth in the 2040 (or indeed 2030) plan has been accounted for in the water companies plans and the in-combination effects of proposed growth in neighbouring districts whilst utilising infrastructure in Bedford has been accounted for. It needs to be demonstrated that the delivery of the 2040 plan will not result in a breach of environmental legislation due to the increase in foul drainage generated (and discharged via sewerage infrastructure into local watercourses). Assessments carried out should highlight locations where upgrades to the foul water infrastructure are necessary and identify measures, including phasing new development, so that wastewater infrastructure will be in place to avoid creating local environmental problems.

There also doesn’t appear to be an assessment of whether there are likely to be significant effects from the plan’s proposed growth on habitat sites or features from a reduction in water quality because of increased discharges of sewage and surface water drainage. Although the existing Local Plan 2030 policies 33, 34 and 48 do provide a means of protecting the local water environment from increased volumes of wastewater generated from new development, the strategic assessment to ensure growth can be accommodated by wastewater infrastructure is insufficient.

Support

Representation ID: 9812

Received: 25/07/2022

Respondent: Pertenhall & Swineshead Parish Council

Policy DS1 (S) Resources and climate change – specifies a range of ways in which development must support a move to carbon neutrality.
This is comprehensive and can be supported.

Support

Representation ID: 9865

Received: 29/07/2022

Respondent: CPRE Bedfordshire

Climate Change
19. CPRE Bedfordshire commented in response to the Local Plan consultation of 2021 that we would like to see the plan go beyond general statements of intention to work towards making Bedford a carbon neutral borough and build in some stronger and more specific targets in support of this objective.
20. The expanded consideration of these issues in the Submission Draft are very welcome. Policy DS1(S) Resources and climate change sets out a number of ways in which development must support a move towards carbon neutrality.

Support

Representation ID: 9944

Received: 25/07/2022

Respondent: Barton Willmore

Draft Policy DS1 (Resource and Climate Change) provides a number of requirements for development, in order to support a move to carbon neutrality and (a) minimise carbon emissions (b) maximise carbon storage and sequestration and (c) mitigate and adapt to the impacts of climate change (d) respond to the economic and policy changes that are likely to accompany climate change (e) provide a Sustainability and Energy Statement demonstrating how mitigating and adapting to climate change has been considered.
The wording of the policy and the move towards carbon neutrality is supported by IM Land, who are committed to creating a sustainable future and have a proactive Environmental, Social Governance programme to deliver a range of benefits to communities. The proposed development at Rushden Road, Wymington will support Bedford Borough’s target for carbon neutrality and comply with draft policy DS1 by way of the following:
• In accordance with criteria A) i. and D) i. of the draft policy, key local amenities are located within walking distance of the Site, which will minimise the need to travel by private vehicle. There are bus stops on Rushden Road, approximately 400m from the Site, which provide services to Bedford and Kettering. Wellingborough railway station is approximately 6.2 miles away (a 16-minute drive or 34 minute cycle) and this offers regular services to Corby via Kettering and London St Pancras via Bedford and Luton airport;
• With regards to A) iii. the proposals will retain and enhance the public rights of way on site for pedestrian and cycle usage. New routes are also proposed which will enhance the sustainable connections through the Site and provide improved accessibility to local facilities and the surrounding countryside;
• In terms of A) v. and vi., the homes at Rushden Road will be constructed to meet the full Future Homes Standard and will therefore produce 75% less carbon emissions than homes delivered under current regulations. This means homes will be heated and powered by renewable heat provided by a heat pump and use renewable electricity powered by roof mounted solar PV cells. Homes will also be designed to specify sustainable materials, considering the whole life cycle of materials to reduce the embodied carbon of development;
• In relation to B) ii. and C) ii. the proposed development will retain and enhance existing hedgerows and planting across the Site and along the Site boundaries;
• With regards to C) i. the development is located entirely within Flood Zone 1 and therefore has a low risk of flooding from the river or sea, making it suitable for development. Sustainable Drainage Systems will be used throughout the development to provide amenity and biodiversity improvements;
• In relation to C) iii. areas of formal and informal public open space are proposed. The existing allotments will also be retained and potentially expanded which promote social interaction;
• Criteria C) iv. refers to delivering an environmental net gain. The Site is presently arable land and of relatively low ecological value and therefore a 10% net gain on site is achievable;
• In accordance with C) v. new homes will achieve a water consumption rate of 110 l/p/d by incorporating water efficiency measures. All homes with gardens will be provided with water butts to capture rainwater for re-use.

Comment

Representation ID: 9972

Received: 29/07/2022

Respondent: Gladman Developments Ltd

It is acknowledged that the planning system has an important role to play in tackling the effects of climate change. In this respect, the overarching environmental objective of sustainable development cited in paragraph 8 of the National Planning Policy Framework highlights how the planning system should help to mitigate and adapt to climate change, and support the transition to a low carbon economy.
This objective filters through to other elements of the Framework, including Section 14 that deals specifically with Meeting the Challenge of Climate Change. In this regard, paragraph 152 of the Framework identifies how the planning system should:
“support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure”
Gladman therefore recognise the increasing importance of tackling climate change and encourage sustainable housing developments to mitigate its impact. The Council should continue to take account of climate change in its plan-making, including any updates to guidance in relation to the Framework and PPG. It is important to recognise that mitigating and adapting to climate change must also be compatible with other important objectives for the planning system, including the requirement to boost housing delivery and build a strong, competitive economy.
Bedford Borough Council have declared a climate emergency and Gladman is committed to contributing towards providing solutions to address these concerns. Gladman takes climate change seriously and our sites across Bedford can deliver numerous environmental commitments to assist the Council in meeting its climate related strategies:
Provision of Public Open Space
Well-designed open space will support an active lifestyle, by encouraging people to walk and cycle. It can also assist in terms of climate change resilience, through the provision of tree planting providing shading and CO2 absorption.
Sustainable Transport Methods
Our sites will deliver a comprehensive package of pedestrian and cycle infrastructure which will promote sustainable transport, including a suite of practical measures aimed at reducing traffic impact. All our sites could potentially deliver new bus stops and electric vehicle charging points, subject to further discussion with the Council and relevant stakeholders.
Renewable Energy & Energy Performance
Renewable energy technologies will be considered at the detailed design stage. These proposals will follow energy performance and efficiency targets, using a fabric-first approach to construction with the aim of reducing CO2 emissions.
Construction Management Plan
A construction management plan will be submitted at the reserved matters stage, which will put in place best practice measures such as re-using topsoil where possible, modern methods of construction and keeping landfill waste to a minimum.

Support

Representation ID: 9996

Received: 29/07/2022

Respondent: Wates Developments

Agent: Boyer

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.

Support

Representation ID: 10044

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

SUPPORT

Policy DS1(S) seeks to support a move towards carbon neutrality, and refers to minimising the need to travel, accessibility by sustainable modes of transport, the density of development, the use of renewable and low carbon energy, and the delivery of green infrastructure. The approach towards carbon neutrality is consistent with national policy contained in the NPPF, and in particular Sections 8, 9 and 14. The two promoted developments by the Southill Estate at Abbey Field West of Elstow and Pear Tree Farm Elstow are in accessible locations, and are well related to the urban area, to other proposed strategic developments, and to proposed transport infrastructure projects in the A421 Corridor. The promoted developments include policy requirements for pedestrian and cycle connections with the surrounding area and existing networks - see Policies HOU 5 and EMP 5. There is a clear opportunity for the promoted developments to minimise the need to travel and encourage the use of sustainable modes of transport. The promoted developments also include policy requirements for the delivery of open space and green infrastructure, and for connections to green corridors. As set out in the Southill Estate’s representations to Policy HOU 5, the promoted development at the Abbey Fields West of Elstow site could accommodate more dwellings than currently indicated in the housing trajectory. An increase in the number of dwellings at the promoted development would increase the density, which would be more consistent with the aims of carbon neutrality. It is too early to determine the energy strategy for the promoted developments, but it is anticipated that the buildings would be energy efficient, and the developments would incorporate renewable and low carbon energy technologies. Therefore, the promoted developments would contribute towards carbon neutrality. The policy of moving towards carbon neutrality is supported, and no changes are required.

Object

Representation ID: 10344

Received: 29/07/2022

Respondent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In terms of the Plan’s strategic policies, Policy DS1(S) Resources and Climate Change states that development must support a move to carbon neutrality. It then sets out a detailed series of points under the following headings:
(A) Minimising carbon emissions;
(B) Maximising carbon storage and sequestration;
(C) Mitigating and adapting to the impacts of climate change;
(D) Responding to the economic and policy changes that are likely to accompany climate change;
(E) “New development will be required to demonstrate through Sustainability and Energy Statements how it will take account of embedded carbon and contribute to mitigating and adapting to climate change and to meeting targets to reduce carbon dioxide emissions having regard to the above”.
2.9 The Trust corporate objectives support the national agenda and objective of achieving net zero carbon and is underpinned by an Estate Strategy and Net Zero Carbon plan, both of which inform the Trust’s Site Master Plan. The Trust’s Estate Strategy includes significant infrastructure development to deliver this approach on their estate, and this will likely include new sub-stations, an energy centre, new efficient buildings and green space. We therefore support the Council’s aspirations and strategic approach towards addressing climate change and minimising environmental impacts. However, we are concerned that setting out a broad and extensive policy – as in Policy DS1(S) – could result in an overly onerous policy context. For example, point (E) refers to Sustainability and Energy Statements as a requirement for new development. However, this is not qualified in terms of which developments would be expected to provide such statements. This requirement would be excessive for many minor developments and could create a barrier to appropriate and sustainable development.
2.10 Most environmental and performance standards associated with new development are managed through Building Regulations, and it is important that planning policies do not seek to replicate these. There is the risk that policies will quickly become outdated and inconsistent when Building Regulations are revised and updated. This causes confusion and, as mentioned, can create a context which negatively impacts on new development coming forward.
2.11 We suggest that Policy DS1(S) is clearly identified as a strategic policy – setting out the Council’s aspiration and objective regarding resources and climate change.

Comment

Representation ID: 10372

Received: 29/07/2022

Respondent: Liberal Democrat Party Bedford Borough Council

• With a growing climate catastrophe – that the Liberal Democrats have led action against – threatening the viability of humanity and life on earth, the need for environmentally sustainable housing to be delivered has never been more important. We welcome the measures outlined to mitigate and adapt to the impacts of climate change. However, we believe local government needs more powers to ensure developers build low carbon housing. For example, we welcome the new requirements for EV charging points to be provided in new homes, but the Government has not gone far enough. It would be very easy to also add requirements for all new homes to have solar panels, heat pumps and other sustainable features yet they have consistently failed on this basis . Viability assessments on developments are currently used to avoid delivering sustainable and affordable housing. These must be reformed or scrapped to ensure that sustainability in its widest sense is not subservient to maintaining land values.

Object

Representation ID: 10390

Received: 29/07/2022

Respondent: FCC Environment UK Ltd

Agent: Axis PED Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

On behalf of our client FCC Environment (UK) Ltd (FCC), we set out our comments to the Bedford Local Plan 2040 Plan for Submission Consultation Document. Where necessary, these representations draw on the comments previously made to the 2020 Local Plan Issues and Options and Call for Sites submissions and 2021 Draft Plan Strategy Options and Draft Policies consultations.
We support the vision and objectives set out within Chapter 2 of the Local Plan. The vision acknowledges the benefits the development of East West Rail and the Oxford and Cambridge arc will deliver in increasing connectivity, investment and growth. We support the vision for the development of high quality commercial and office spaces. FCC’s site at Elstow South, Wilstead Road, is sustainability located to help deliver the vision and objectives of the Local Plan.
Policy DS1 (S) – Resources and Climate Change – The Local Plan 2040 proposes to replace the existing Local Plan 2030 policy 51S with this additional strategic policy. This new policy which builds on the existing climate change policy within Local Plan 2030 is supported.
However, the current wording of the policy is not clear with regards to which and how many criteria a proposed development would need to meet in order to satisfy the policy requirements.
Paragraph 16 (d) of the National Planning Policy Framework (NPPF) confirms that plans should contain policies that are clearly written and unambiguous, so that it is evident how a decision maker should react to development proposals.

Object

Representation ID: 10498

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst Hallam Land Management supports the overall intent of Policy DS1(S) there are pertinent questions to be raised in whether the principles set out under A) i and A) iii can be fully met due to the proposed spatial strategy set out in Policy DS2(S), levels of stepped housing growth proposed in Policy DS3(S) and distribution of growth in Policy DS5(S).
In this context, Hallam is deeply concerned that the spatial strategy, by omitting key sustainable development options, will not fully achieve the Borough ambitions for resources and climate change and in this context will be unsound for not being positively prepared, justified or effective. A key reason is that the full potential for growth in locations that are well related to Bedford is not being fully recognised – the strategy being based on a preferred option that favours locations that are either less well related to Bedford or physically connected.

Support

Representation ID: 10511

Received: 29/07/2022

Respondent: National Highways

Climate Change
National Highways welcomes inclusion of specific polices within the local plan to address the issues of climate change and notes that following declaring a climate
emergency in March 2019, the Council has pledged to make its own operations carbon neutral by 2030. As part of their strategy the Council has pledged to incorporate the carbon neutral ambition into all Council strategies, including the Local Plan 2040.
This is translated into Policy DS1(S) Resources and climate change where it sets out how a move to carbon neutrality is to be achieved. In respect to the spatial strategy,
Policy DS2(S) Spatial strategy looks to achieving delivery sustainable development and working towards making Bedford a net zero carbon emissions borough.
National Highways is committed to contributing to governments target of achieving Net Zero by 2050, delivering Department of Transport’s De-Carbonisation Plan, as set out in our Net Zero Highways: our 2030 / 2040 / 2050 plan. In particular we aim by 2040 to have in place Net zero for maintenance and construction works. This aligns with Committee on Climate Change’s call for the construction industry to be largely decarbonised by 2040.
The Local Plan’s spatial strategy is significant with targets aimed to delivering up to 1700 dwellings per annum, associated employment sites and transport interventions.
Given the level of proposed construction and noting that any interventions on the Strategic Road Network will need to be close to achieving Net-Zero, it is suggested
that these policies are revisited with a change of focus from achieving carbon neutrality goals to net-zero wherever possible by 2040.

Comment

Representation ID: 10526

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DS1 (Resource and Climate Change) provides a number of requirements for development, in order to support a move to carbon neutrality and (a) minimise carbon emissions (b) maximise carbon storage and sequestration and (c) mitigate and adapt to the impacts of climate change (d) respond to the economic and policy changes that are likely to accompany climate change (e) provide a Sustainability and Energy Statement demonstrating how mitigating and adapting to climate change has been considered.
The wording of the policy and the move towards carbon neutrality is supported by IM Land, who are committed to creating a sustainable future and have a proactive Environmental, Social Governance programme to deliver a range of benefits to communities. The proposed development at Rushden Road, Wymington will support Bedford Borough’s target for carbon neutrality and comply with draft policy DS1 by way of the following:
• In accordance with criteria A) i. and D) i. of the draft policy, key local amenities are located within walking distance of the Site, which will minimise the need to travel by private vehicle. There are bus stops on Rushden Road, approximately 400m from the Site, which provide services to Bedford and Kettering. Wellingborough railway station is approximately 6.2 miles away (a 16-minute drive or 34 minute cycle) and this offers regular services to Corby via Kettering and London St Pancras via Bedford and Luton airport;
With regards to A) iii. the proposals will retain and enhance the public rights of way on site for pedestrian and cycle usage. New routes are also proposed which will enhance the sustainable connections through the Site and provide improved accessibility to local facilities and the surrounding countryside;
• In terms of A) v. and vi., the homes at Rushden Road will be constructed to meet the full Future Homes Standard and will therefore produce 75% less carbon emissions than homes delivered under current regulations. This means homes will be heated and powered by renewable heat provided by a heat pump and use renewable electricity powered by roof mounted solar PV cells. Homes will also be designed to specify sustainable materials, considering the whole life cycle of materials to reduce the embodied carbon of development;
• In relation to B) ii. and C) ii. the proposed development will retain and enhance existing hedgerows and planting across the Site and along the Site boundaries;
• With regards to C) i. the development is located entirely within Flood Zone 1 and therefore has a low risk of flooding from the river or sea, making it suitable for development. Sustainable Drainage Systems will be used throughout the development to provide amenity and biodiversity improvements;
• In relation to C) iii. areas of formal and informal public open space are proposed. The existing allotments will also be retained and potentially expanded which promote social interaction;
• Criteria C) iv. refers to delivering an environmental net gain. The Site is presently arable land and of relatively low ecological value and therefore a 10% net gain on site is achievable;
• In accordance with C) v. new homes will achieve a water consumption rate of 110 l/p/d by incorporating water efficiency measures. All homes with gardens will be provided with water butts to capture rainwater for re-use.