Bedford Borough Local Plan 2040 Plan for Submission

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Comment

Bedford Borough Local Plan 2040 Plan for Submission

2.1

Representation ID: 9385

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

The Bedfordshire Local Nature Partnership welcomes the recognition of the importance of the environment in the Vision, and the commitment to securing a net gain in biodiversity and environmental quality. We also welcome the statement that development will be sensitively planned to complement the borough's natural environment, but this needs to explicitly mention its wildlife alongside intrinsic beauty and character.
We also welcome reference to key green infrastructure initiatives, delivering multiple benefits in the borough. The Greensand Ridge Nature Improvement area, although occupying a small proportion f the borough's area, has been recognised by the LNP and should be referenced.

Full text:

The Bedfordshire Local Nature Partnership welcomes the recognition of the importance of the environment in the Vision, and the commitment to securing a net gain in biodiversity and environmental quality. We also welcome the statement that development will be sensitively planned to complement the borough's natural environment, but this needs to explicitly mention its wildlife alongside intrinsic beauty and character.
We also welcome reference to key green infrastructure initiatives, delivering multiple benefits in the borough. The Greensand Ridge Nature Improvement area, although occupying a small proportion f the borough's area, has been recognised by the LNP and should be referenced.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

2.2

Representation ID: 9386

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

We welcome Theme 1 and its content, but would suggest it includes a stronger reference to protecting and enhancing biodiversity, including through the forthcoming Local Nature Recovery Strategy.
Suggested revision: "Protect and enhance our natural capital resources and the ecosystem services that they provide....."
Suggested revision: Improve access to high quality green and blue infrastructure, including natural green spaces,....."

Theme 2 must make wider reference to sustainable modes of travel and supporting an increase in use beyond the town centres to support a more holistic delivery.

Full text:

We welcome Theme 1 and its content, but would suggest it includes a stronger reference to protecting and enhancing biodiversity, including through the forthcoming Local Nature Recovery Strategy.
Suggested revision: "Protect and enhance our natural capital resources and the ecosystem services that they provide....."
Suggested revision: Improve access to high quality green and blue infrastructure, including natural green spaces,....."

Theme 2 must make wider reference to sustainable modes of travel and supporting an increase in use beyond the town centres to support a more holistic delivery.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

3.1

Representation ID: 9387

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

The Climate Crisis needs to be considered alongside the Biodiversity Crisis - the two are interlinked, with the natural world providing important regulation to climate systems. The Plan must recognise that it will need to deliver against both to help develop solutions and ensure we mitigate and adapt to a changing world.

Full text:

The Climate Crisis needs to be considered alongside the Biodiversity Crisis - the two are interlinked, with the natural world providing important regulation to climate systems. The Plan must recognise that it will need to deliver against both to help develop solutions and ensure we mitigate and adapt to a changing world.

Support

Bedford Borough Local Plan 2040 Plan for Submission

Policy DS1(S) Resources and climate change

Representation ID: 9388

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

We support this policy and welcome link to creating and restoring habitats to maximise carbon storage and sequestration.

Full text:

We support this policy and welcome link to creating and restoring habitats to maximise carbon storage and sequestration.

Support

Bedford Borough Local Plan 2040 Plan for Submission

Policy HOU11 Land at Bedford River Valley Park

Representation ID: 9394

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

We support the policy and its objectives, for which the proposed masterplan would be essential. We recommend that the objectives place even greater emphasis on delivery of Forest of Marston Vale objectives and targets, and include an objective around enhanced Biodiversity Net Gain, given the 'flagship' nature of this site for both the Forest and the borough.

Full text:

We support the policy and its objectives, for which the proposed masterplan would be essential. We recommend that the objectives place even greater emphasis on delivery of Forest of Marston Vale objectives and targets, and include an objective around enhanced Biodiversity Net Gain, given the 'flagship' nature of this site for both the Forest and the borough.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Policy HOU12 South of Bedford area

Representation ID: 9396

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

We welcome this approach. For resulting development to truly deliver against this policy it must be genuinely environmentally led. This must be fully reinforced through the SPD. This opportunity to demonstrate how an environmentally-led policy can lead to high quality, sustainable development and must be delivered against in full. Looking forward, this should be the model for the whole of the borough (and beyond) as standard within a Local Plan.
We strongly suggest for it to be an "Arc leading new settlement" that development must deliver against all Arc Environmental Principles, including a minimum of 20% Biodiversity Net Gain.

Full text:

We welcome this approach. For resulting development to truly deliver against this policy it must be genuinely environmentally led. This must be fully reinforced through the SPD. This opportunity to demonstrate how an environmentally-led policy can lead to high quality, sustainable development and must be delivered against in full. Looking forward, this should be the model for the whole of the borough (and beyond) as standard within a Local Plan.
We strongly suggest for it to be an "Arc leading new settlement" that development must deliver against all Arc Environmental Principles, including a minimum of 20% Biodiversity Net Gain.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Policy DM7 Environmental Net Gain

Representation ID: 9401

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

We welcome this policy and the inclusion of Net Environmental Gain in addition to Net Biodiversity Gain. We highlight the fact that the Borough Council has signed up to the Arc Environment Principles, and therefore the target must be 20% BNG not 10%.
Planning applications must demonstrate the proposed BNG through a calculation based on the latest adopted version of the Defra Biodiversity Metric, while it is suggested that an appropriate mechanism (e.g. the Econometric tool) is used to demonstrate Environmental Net Gain. terminology must be completely clear and ensure that NEG is considered over and above BNG.

Full text:

We welcome this policy and the inclusion of Net Environmental Gain in addition to Net Biodiversity Gain. We highlight the fact that the Borough Council has signed up to the Arc Environment Principles, and therefore the target must be 20% BNG not 10%.
Planning applications must demonstrate the proposed BNG through a calculation based on the latest adopted version of the Defra Biodiversity Metric, while it is suggested that an appropriate mechanism (e.g. the Econometric tool) is used to demonstrate Environmental Net Gain. terminology must be completely clear and ensure that NEG is considered over and above BNG.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

6.60

Representation ID: 9405

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

While 10% BNG is not yet enshrined in law it will be, and furthermore the Borough Council has signed up to the Arc Environment Principles requiring delivery of 20% BNG.

Full text:

While 10% BNG is not yet enshrined in law it will be, and furthermore the Borough Council has signed up to the Arc Environment Principles requiring delivery of 20% BNG.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Policy DM7 Environmental Net Gain

Representation ID: 9407

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

We welcome this policy and the inclusion of an Environmental Net Gain requirement over and above BNG. Terminology must be clear, and ensure that this is understood. Furthermore, by signing up to the Arc Environmental Principles, a commitment of 20% BNG is essential.
BNG proposals must be demonstrated through a calculation based on the Defra Metric (latest version). ENG must also be demonstrated in any supporting statement using an endorsed methodology (e.g. the Econometric).

Full text:

We welcome this policy and the inclusion of an Environmental Net Gain requirement over and above BNG. Terminology must be clear, and ensure that this is understood. Furthermore, by signing up to the Arc Environmental Principles, a commitment of 20% BNG is essential.
BNG proposals must be demonstrated through a calculation based on the Defra Metric (latest version). ENG must also be demonstrated in any supporting statement using an endorsed methodology (e.g. the Econometric).

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