Issues and Options

Yes

We agree with the scope, but consider policies and standards on climate change, natural environment (including Biodiversity Net Gain and Environmental Net Gain) and updated open spaces policies to be essential (not just “to be considered” and that these need to be considered alongside all other policy to ensure there is a consistent approach to issues such as the environment and climate change – isolated policies which are not properly embedded risk being perceived as less important/more peripheral. It will also be essential for the Local Plan to incorporate the requirements of the Environment Act when it comes into force in 2021. The Local Plan should also consider the impacts of the introduction of a potential Development Corporation.

We note the importance of the natural environment of Bedford Borough is recognised throughout the vision – the first adjective is “greener” and strong references appear throughout. This is critical as it helps establish early on that the environment is not a ‘nice to have’ but a fundamental essential. We suggest the term “Net Environmental Gain” is embedded at this point so it can be established as a concept and inform wider policy. We also welcome specific reference and continued support to major GI initiatives such as the Forest of Marston Vale, Bedford River Valley Park and the Bedford-MK Waterway Park. We suggest specific mention is made of the River Great Ouse and its importance to the town and borough, in environmental, economic and social terms, forming a key element of the ‘sense of place’ now and in the future. The only true omission is reference to wildlife. The benefits of the natural environment and green spaces for people are mentioned, but the vision should also aspire to increased opportunities for nature to expand and flourish. It would also be useful to embed the terms “Natural Capital” and “Ecosystem Services” at this early stage in the document.

I agree with this plan period

We do not have a strong view, 2020-2040 is acceptable.

Nothing chosen

Given that it is likely that a combination of the suggested approaches will be used, we feel it is more important to ensure that whatever the outcome it is underpinned by strong policy and guidance. Any growth will need to represent a step change in quality and quantity of environmental provision (including Net Biodiversity / Environmental Gain). While we would expect new settlements to have the highest design, environmental and sustainability standards, we equally wish to ensure that if the same, very high level of growth is translated into a much more dispersed pattern that it would still be important to ensure the same high standards. Equally we would expect whichever growth scenario is selected to take account environmental limits, such as:  Water resources (including carbon implications of pumping water)  Ability of watercourses to accept sewage discharges without adverse impacts on water quality  Avoiding important wildlife sites It is also important to ensure that sustainable transport options are available for people wherever they live, which would support a growth pattern that creates employment close to growth and delivers sustainable travel options. The Bedfordshire LNP is currently working with BBC and the other Bedfordshire authorities on a project to map Bedfordshire’s Natural Capital assets, and the Ecosystems Services they deliver, as well as where demand currently is. It would be extremely beneficial to re-run this element of the exercise again once the options for growth are narrowed down, to help identify what natural capital will be needed to support different growth options, and feed into the decision-making process. It would also be beneficial to look at how natural capital can be provided at different levels in the size of development hierarchy, e.g. up to 50 houses, up to 150 and 150+. The LNP would be keen to explore opportunities for taking such work forward collaboratively and better informing development decisions.

It is essential that existing natural capital (including GI) is protected and enhanced wherever possible to ensure growth improves the quality of life, health and wellbeing of local residents. It is also essential that new natural capital is established as early as possible so that more mature habitats and environments are established prior to occupation. This will also help ensure that the ecosystem services provided are performing at a higher level. Natural capital delivers vital ecosystems services for development, often saving money on developing harder infrastructure solutions through provision of flood regulation, carbon sequestration, water quality regulation, air pollution mitigation and many more. This will need to include:  Quality, multi-functional greenspaces, including accessible green spaces and connecting routes for people and acting as corridors for wildlife. Housing layouts will need to be part of this rather than the green space element being treated as an ‘add-on.  Adequate water resources, surface water management and water treatment.  High speed broadband connectivity to facilitate working from home (reducing the need to travel)  Renewable energy options at the household/community level  Energy and water efficient housing (including where converted from commercial properties) Wherever possible existing development should also be retro-fitted to meet these standards.

There should be clear environment and sustainability standards for commercial development including:  Energy and water efficiency  Renewable energy on site production  Access by sustainable transport  Quality layouts – landscaping, green space, biodiversity (resulting in net biodiversity and net environmental gain)  Adequate water resources and water treatment facilities,  Facilities to support electric vehicles

It is important that the opportunity of the station on the East-West Rail line maximises this opportunity, and helps Bedford act as both a destination and a gateway to the wider borough, including the rural areas, attracting tourists/day visitors to Bedford. The value of the natural environment in underpinning this offer must not be under-estimated, and strategic enhancements such as enhancing river corridors/areas particularly to the east and west of the town centre will help increase this value. Quality design is essential, ensuring (for example) that accessible public spaces embrace and provide safe access to the river. To support the ‘gateway’ function cycle and walking connectivity should be improved (including enhanced routes, better signage and information), alongside improvements to public transport at the train station, with new links created where required.

No.

I agree

It definitely should, highlighting the role that natural capital can play through delivering ecosystem services that either mitigate climate change impacts or reduce carbon emissions. The LNP’s Natural Capital work will involve looking at where potential climate change impacts will be greatest, and where habitat enhancement such as tree planting will be best targeted to combine carbon sequestration and biodiversity/environmental net gain benefits. There should be quantified targets to give developers a clear steer. We would therefore wish to be involved in the development of such guidance. It will also be important for sustainable housing standards to be monitored and enforced.

High water efficiency standards should be introduced as the east is one of the driest areas of the country. Space requirements need to take account of greater working from home. More flexibility for employees to work from home contributes to quality of life and reducing travel. The Covid-19 pandemic and resulting measures have increased the movement towards this, it is important therefore to maintain this momentum. There is the opportunity to go beyond the national standards, incorporating a range of measures to reduce energy consumption and increase energy efficiency, to help make the ambitious vision a reality.