Issues and Options

Yes

Natural England agree that the local plan review will need to “consider the need to change current policies for the natural environment following the publication of the Environment Act”. We are also aware of recent policy documents such as the “Planning for the Future” White Paper, and the “changes to the current planning system” government consultation which could output fundamental changes to the local planning process. Whilst there are no proposals to weaken existing environmental protections, we are mindful of the need to balance huge growth aspirations against potential environmental impacts to ensure sustainable development that puts nature at its heart. We do believe that due to the 35% in growth proposed by this local plan review (up to 15,000 new homes), that the existing environmental policies and safeguards will need reviewing, particularly in the context of the Habitats Regulations. This is because the impacts of a 35% increase in growth will need to appropriately consider environmental risks.

Local Nature Recovery Strategies will be the chief and mandatory mechanism for planning local delivery of Nature Recovery Networks (NRNs) as set out within the Environment Bill 2020. The Environment Bill also introduces a mandatory requirement for biodiversity net gain in the planning system. Natural England advises that your authority considers proactively integrating NRNs and biodiversity net gain principles within your vision for Bedford Borough.

Nothing chosen

The expansion of the Bedford / Kempston urban area: We are aware that a band of ancient woodland exists west of Kempston, stretching south from Hanger Wood SSSI to Wootton Wood. We would encourage your Council to consider such protected environmental features as assets that could – with carefully strategic planning - sit alongside anticipated development. For example, an opportunity exists here to join these woods together creating a bigger, better and more sustainable green space around Bedford. Expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots: Development pressure east of Rushden is a current concern for Natural England due to the potential destruction of Functionally Linked Land and or the potential for increased recreational pressures on the Upper Nene Valley Pits Special Protection Area, SSSI and Ramsar. Please refer to the East Northamptonshire Local Plan documents for our current position regarding development around Rushden. Our most recent statutory response to the East Northamptonshire Local Plan is letter dated 19 March 2020 (Our Ref: 308298). Consequently, cumulative / in-combination effects Page 3 of 5 will need to be considered for sites such as the Upper Nene Valley Gravel Pits SPA. In addition, there is already significant growth proposed around St. Neots through the Huntingdonshire Local Plan with main issues likely to be recreational pressure, water / flood risk management / Sewage Treatment Works discharge, and air quality. The Water Cycle Study for the Huntingdonshire Local Plan confirmed that St Neots Waste water Treatment Works is almost at capacity and without further improvements there is potential for adverse effect in the Ouse Washes and Portholme N2K sites. Consequently, cumulative / in-combination effects will need to be considered for sites such as Portholme SAC and the Ouse Washes SAC/SPA/SSSI and Ramsar. Referring back to our 07 August 2019 response (Our Ref: 291131) to the Bedford Local Plan 2030 HRA Addendum we write: “In terms of the Growth Arc proposals, uncertainty also remains surrounding the future water quantity and quality in the tributaries of the River Great Ouse pending independent assessments by Anglian Water, which will have their own HRA’s. However, it is clear within the current Water Resource Management Plan (WRMP) that Bedford area is in a water-stressed zone, and the report predicts potential deficits under dry year annual average conditions within the Bedford area in 2026/27 (page 330).” It is clear that Bedford Borough is a water stressed area. It is important for your Council to ensure that development does not go ahead unless Anglian Water is confident that there is going to be water available for the growth identified in this new plan. Further, your Council should explore the topic of water resources within the HRA. Development along the A421 corridor: Development here will need to be considered in-combination with other potential environmental impacts within the area resulting from developments such as the Black Cat to Caxton Gibbet Improvement Scheme NSIP, and developments such as the Marston Vale New Villages within Central Bedfordshire Local Plan. The A421 is already constrained from an air quality perspective (confirmed within the SA Scoping report attached to this present consultation). Development around an East West Rail northern station: Regarding the East West Rail section from Bedford Midland to Tempsford, a series of ancient woodlands are within this corridor, including Tilwick Wood SSSI, which should be safeguarded from development, and preferably buffered with additional woodland planting. The countryside north of Bedford is relatively undeveloped. We understood from the 2030 Local Plan HRA process that further work on the Growth Arc will take place within a Local Plan review process. We advise that when information does becomes available on the East West Rail route and other growth arc developments, that it is considered within the HRA process. Once enough information is available, we expect the environmental impacts of the growth arc projects to be assessed alone or in-combination with the Bedford Borough growth proposals. New settlements in locations with good accessibility & More dispersed development throughout the borough including the expansion of villages: When considering development across the borough, a number of tools are available to help inform sustainable options. 1. National Character Area profiles https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making/national-character-area-profiles#ncas-in-east-midlands 2. The Habitat Opportunity Mapping done by the Bedfordshire Local Nature Partnership. 3. The Bedfordshire and Luton Green Infrastructure Plan and the Bedford Green Infrastructure Plan

Green Infrastructure is key to delivering sustainable growth in Bedford Borough. The National Planning Policy Framework defines Green Infrastructure (GI) as: A network of multifunctional green space, urban and rural, which is capable of delivering a wide range of environmental and quality of life benefits for local communities’. Please find Natural England’s guidance on GI here: http://publications.naturalengland.org.uk/publication/35033.

Nothing chosen

Climate change is complex and fast moving. Natural England have recently published the second edition of its Climate Change Adaptation Manual, which addresses the gap between the general principles of climate change and how adaptation to climate change may work: http://publications.naturalengland.org.uk/publication/5679197848862720. To note, there are now specific sections on Green Infrastructure and Access and Recreation. Nature-based Solutions (NbS), can contribute to reducing net greenhouse gas emissions as part of the government’s wider strategy for achieving Net Zero Greenhouse Gas emissions by 2050. Achieving ‘Net Zero’ greenhouse gas (GHG) emissions by 2050 is a statutory requirement for the UK and England; this will require major changes in the way we manage the natural environment, alongside changes in energy, transport and other sectors. NbS is an increasingly prominent concept to describe actions that address societal challenges, such as climate change, in ways that benefit both people and biodiversity. Not all environmental management for Net Zero is true NbS and not all NbS deliver climate change mitigation. Woodland creation and peatland restoration offer the largest potential contributions to Net Zero. New woodland takes up carbon from the atmosphere via photosynthesis, and peatland restoration stops stops GHG emissions from the oxidation of degraded peat. The Reducing UK emissions: 2020 Progress Report to Parliament (https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/) includes new advice to the UK Government on securing a green and resilient recovery following the COVID-19 pandemic. It recommends that Ministers seize the opportunity to turn the COVID-19 crisis into a defining moment in the fight against climate change. It’s report highlights key investment priorities such as tree planting, green infrastructure, and infrastructure to make it easy for people to walk, cycle, and work remotely.

Within Natural England letter dated 07 August 2019 (Our Ref: 291131) in response to the Bedford Borough Local Plan 2030 Habitats Regulations Assessment Addendum, we voiced our concerns regarding the following circumstance. If the review of the local plan policy doesn’t take place to the required timeframe (three years), the local plan policies in relation to the natural environment may also be considered to be out of date (as written in Policy 1 of the Local Plan 2030). We advised that a commitment to ensuring the impacts on the natural environment, particularly European sites are also considered as part of any review. We note that our suggested wording to this effect was not captured within Policy 1. Considering that this review is not only being put forward to comply with the 2019 NPPF, but also to allocate 35% more housing, we remain of the opinion that a commitment towards ensuring that environmental impacts are considered, is essential.

To provide sustainable development, we advise that Bedford Borough new Local Plan incorporates new and separate policies on Local Nature Recovery Strategies, biodiversity net gain and nature-based solutions. This would go some way to ensuring that the ~15,000 homes proposed within this new Local Plan are delivered sustainably. Sustainability Appraisal Scoping report Within paragraph 4.25 of the SA Scoping report, it is unclear whether the commitment to biodiversity net gain is within the local plan, or an aspiration of the Bedfordshire Local Nature Partnership. We note that the current Local Plan 2030 only provides a commitment to a net gain in Green Infrastructure. As advised above, we recommend that a commitment to biodiversity net gain is made within a bespoke policy to demonstrate best practice. Housing and Employment Land Availability Assessment Methodology – July 2020 We note that location maps of all of the sites that have been assessed will be published on the Council’s website. We look forward to viewing these when they become available.

Evidence Base Natural England does not consider that this Sustainability Appraisal Scoping Report poses any likely risk or opportunity in relation to our statutory purpose, and so does not wish to comment on this consultation. The lack of comment from Natural England should not be interpreted as a statement that there are no impacts on the natural environment. Other bodies and individuals may wish to make comments that might help the Local Planning Authority (LPA) to fully take account of any environmental risks and opportunities relating to this document.