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New searchWhen considering climate change policies, this should include how other policies such as flood risk, open space etc will contribute to the management and mitigation of climate change.
“Tackling climate change and adapting to and mitigating against its effects will be at the heart of new development throughout the borough” This is a laudable aim but it’s important to recognise that there are existing areas currently at flood risk (and other environmental risks) and redevelopment can be utilised to reduce flood risk. Sustainable development is often used to encapsulate this idea but in reality sustainability is about maintaining the current state rather than achieving new gain (reducing flood risk overall). Therefore, there are benefits of explicitly stating the aim to get new gain through development and an ambition to achieve wider environmental net gain. The review mentions the Covid Recovery Plan as a separate piece of work, but you may wish to include in the Vision references to the likely future changes, not only in people’s shopping habits, but in their working arrangements (and the potential for commercial office space to be available for other uses), the way people travel (including cycling) and the greater appreciation of nature that has resulted from the lockdown.
No specific comment. However, you will be aware that Central Bedfordshire and Milton Keynes are working on their visions for 2050.
Your Strategic Flood Risk Assessment (SFRA) should include an assessment of these scenarios to determine where flood risk is a constraint and where development is an opportunity to reduce the existing risk.
It is essential that the Infrastructure Delivery Plan includes environmental infrastructure, including water services infrastructure and green/blue infrastructure. This will need to take a strategic and holistic approach to water management in order to fulfil the planned increase in growth. Existing flood risk infrastructure that either the new development or existing developments should be considered within the definition of ‘infrastructure’. There are some significant flood risk assets within the Borough that will require investment to maintain the standard of protection provided, or improve it to manage the increased flows due to climate change. Another aspect of flood risk infrastructure is our telemetry assets that allow us to issue timely warnings. If development is allocated (or windfall allowed within the floodplain) then they will be reliant on our telemetry infrastructure to provide the warning necessary to keep people safe. The forms the middle of the Great Ouse catchment and this provides the opportunity to provide strategic flood risk management solution that will benefit the Borough and those districts downstream. Although there is no current proposal to provide such assets, it would be worth considering the planning policy position on the potential provision of such infrastructure within the district.
Agree that further guidance for developers would be useful. There is much valuable guidance on the Planning Portal/Gov.uk and Natural England website (specifically on the use of green and blue infrastructure to adapt to and mitigate the impacts of climate change). It should also include guides on how the sequential test will be applied to take into account climate change over the lifetime of development, how managed adaptation measures can be incorporated to ensure that development is future proof, how development can feasibly contribute the net reduction in flood risk.
We encourage you to follow the joint EA/AWS/NE position statement on water efficiency.
We agree that incorporating safe and green cycleways, dedicated busways etc. within developments can support alternatives to the car.
We welcome references to environment-led regeneration (in relation to the Forest of Marston Vale) and references to natural capital in relation to trees, but could include more recognition of the value of nature to the economy of the Borough more widely, including reduced costs to the NHS through increased activity, access to greenspace etc., role of the green economy. They could also consider how policies relating to green and blue infrastructure can result in an overall increase in natural capital. This might include making use of data from the Local Natural Capital Plan work to identify opportunities for environmental enhancement and improvement. The current flood risk policy does provide a good policy position to manage flood risk within the borough. However, several developments within flood risk management will need to be taken into account with the revised Local Plan. This includes, but not necessary limited to: New climate change allowances for planning are due to be released late 2020 Environment Agency Flood Risk Management Strategy Defra Flood Risk Management Policy Position New Guidance on Flood Emergency Planning in Local Plans. New Best Practice Guide for creating SFRAs We recommend that the flood policy is reviewed alongside those being proposed to manage the impact of climate change as they are intrinsically linked.
We welcome references to the importance of access to green space and policies for the protection, enhancement and provision of green infrastructure in relation to impact on public health.
