Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Object

Representation ID: 6652

Received: 14/09/2021

Respondent: Bedfordshire Great Ouse Valley Environmental Trust

Beds GOVET is aware that the spatial framework for the Oxford Cambridge Arc and the East West rail route are still in the process of being finalised. The spatial framework for the Arc will not be available until January 2023. As a result, it is difficult to make judgements about the LP2040 plan without detailed information on the strategy of the Oxford Cambridge Arc or the EW Rail route in Bedfordshire.

Object

Representation ID: 6653

Received: 14/09/2021

Respondent: Bedfordshire Great Ouse Valley Environmental Trust

With regard to subsection 1.45, when will the documents listed as unavailable be made available for review? We are concerned about the settlement hierarchy, the sustainability appraisal report and the infrastructure delivery plan, as these will all impact on the river Great Ouse and on the Great Ouse Valley.

Support

Representation ID: 6654

Received: 14/09/2021

Respondent: Bedfordshire Great Ouse Valley Environmental Trust

1.46 - 1.48
For those parishes which have submitted their local NDPs and identified sites for development, it would be difficult to ask parishes to revise these figures for housing growth. We would strongly oppose any plans for such changes especially if these changes are without the consent of the parishes.

Object

Representation ID: 6655

Received: 14/09/2021

Respondent: Bedfordshire Great Ouse Valley Environmental Trust

1.46 - 1.48
For those parishes which have submitted their local NDPs and identified sites for development, it would be difficult to ask parishes to revise these figures for housing growth. We would strongly oppose any plans for such changes especially if these changes are without the consent of the parishes.

Support

Representation ID: 6656

Received: 14/09/2021

Respondent: Bedfordshire Great Ouse Valley Environmental Trust

Beds GOVET believe the vision and associated themes are good but we have concerns about how Council will achieve this at the same time as the proposed level of housing growth and economic development.
More information is required as to how the net zero borough is to be achieved. In particular details regarding plans for insulation, solar power, heat pumps, electrification of heating cooking and transport.
For transport we need stronger actions to support cycling and pedestrians.
More information is also needed regarding flood risks and how these are to be managed and risk minimized. For example, more detailed consideration needs to be given to the permeability of driveways and road surfaces and the introduction of swales and ponds to reduce flow.
River Great Ouse: The vision, as stated, refers to the River Great Ouse and its riverside villages forming the backbone of the boroughs rich green and blue infrastructure. This comes across as a very weak statement for such a valuable and important County asset. It fails to reflect the historical, cultural, symbolic value and ecological importance not only of the River Great Ouse but the Great Ouse Valley overall across the borough and Bedfordshire. Protection of the river and the Great Ouse Valley is of great concern to all of the parishes along the river.
Protection of the Great Ouse valley should be given the highest priority and made a key objective in the Local Plan 2040. Beds GOVEG urges Bedford borough Council to develop policies and plans now to:
• Protect the river from potential environmental damage from the effects of sewage outflows and agricultural runoff, such as nitrates and phosphates
• Prevent any developments which may cause damage or adversely impact biodiversity in the river and the Valley as a whole along its entire length
• Enhance its role in flood management
• Enhance its value as an amenity which increases the well-being of all communities that use the river.
Council should support actions to enable the Great Ouse Valley to achieve the designation of protected Natural Landscape.

Object

Representation ID: 6657

Received: 14/09/2021

Respondent: Bedfordshire Great Ouse Valley Environmental Trust

If a net zero borough is to be created, one of the key activities will be delivery and demonstration of environmental
net gain. Environmental net gain has wider implications than biodiversity net gain (it also includes natural capital), Both environmental net gain and biodiversity net gain should be specified in the Council’s policy.
However, it is noted that there are dangers in using a habitat-based method biodiversity metric 2 or 3 to demonstrate biodiversity net gain in that it does not address living species (e.g., animals, insects). There is a danger, for example, that the habitat of the development area might be relocated and enhanced but important species lost. A detailed assessment should be made of all species present to ensure that they are not lost during development.
Due to the very high level of uncertainty in environmental net gain calculations, Beds GOVET would prefer the amount of net gain to be set at 20% for both environmental and biodiversity net gains rather than the 10% currently recommended in Government legislation. This should ideally be delivered on or within 5km of the development site and with appropriate interconnectivity between habitats.