Plan for submission evidence base

Comment

Representation ID: 9641

Received: 29/07/2022

Respondent: Arnold White Estates Ltd

Agent: Arrow Planning Limited

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: 9644

Received: 29/07/2022

Respondent: Arnold White Estates Ltd

Agent: Arrow Planning Limited

The Local Plan is not sound, as it is not justified or effective. To make the Plan sound the
trajectory should be amended. Reflecting the fact that the Local Plan may not be
adopted until 2023, and thus higher delivery in 2024 (compared to the Local Plan 2030),
the trajectory should be as follows:
2020/21- 2023/24: 970dpa
2024/25 – 2039/40: 1,423dpa