Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10312

Received: 29/07/2022

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We do not consider that the Local Plan 2040 Submission Version addresses our concern, as expressed in our previous representations, that the impacts of further development on the health of rivers, watercourses, groundwater resources and the agricultural and natural ecosystems that depend on them, have not been adequately assessed.
We are re-presenting this concern because the world-wide climatic events this year, including the unprecedented heatwaves and drought in Europe, point to an acceleration in the advance of global climate change that would increase the vulnerability of natural water resources to the impacts of the water demands of development and accompanying infrastructure.
We are not looking to have the Local Plan 2040 thrown out at this stage. Rather, as we proposed in our last-round representation, that the situation regarding the Plan’s assessment of the possible impact of the development planned for on the future health of the natural water cycle is presented prominently in the relevant parts of the Plan.
The options as we see them for prominent statements within the Plan are;
1. that we have missed or misunderstood evidence presented in the supporting documents of the Plan that supports an assessment that the health of rivers, watercourses, groundwater resources and the agricultural and natural ecosystems that depend on them will be preserved or improved given the development proposed to 2040. If this is the case then the Plan should have a prominent statement that such an assessment has been carried out.
2. that an evidence-based assessment of the impact of the development proposed to 2040 on the health of rivers, watercourses, groundwater resources and the agricultural and natural ecosystems that depend on them is not available. In this case the Plan should have a prominent statement to this effect, together with a commitment to review the Plan’s development proposals in response to improved understanding of impacts on the natural water cycle, of the stresses on the water cycle of building development or of increasing stress due to accelerating climate change.
We trust that the Inspector will see the importance of adding clarity on this issue to the text of the Plan in signalling to its users and readers the extent to which this critical area of environmental impact is understood and how future change in both understanding and climate will be monitored as part of the Plan’s implementation.

Addendum;
Cardington Parish Council’s comments relevant to this issue submitted to the last Local Plan 2040 consultation, 2021, were as follows;

1. Para 7. Development management policies. 7.30 – 7.40 Natural environment policies.
We do not think that the Environmental and Biodiversity Net Gain approach, as currently formulated, treats the protection and enhancement of water resources adequately. Any further development of housing and the employment and transport infrastructure accompanying it will add to demands for water supplies, management of waste water and affect the pattern of flow of surface water to rivers, water courses and groundwater reserves. The additional infrastructure needed to satisfy the demand for water supply and manage waste water will additionally have an impact on water resources, particularly so in our already water-stressed region.
Cardington Parish Council has raised the need for a proper assessment of water resource impacts in every Local Plan consultation since 2002. With the evidence of steadily increasing climate change impacts on this crucial natural resource this is probably the last chance we have of recognising the issue and managing our response.
We urge that Local Plan 2040 either;
i) includes a detailed and authoritative analysis of what the impact of 25500 additional homes would be on the health of rivers, watercourses, groundwater resources and the agricultural and natural ecosystems that depend on them would be or
ii) admits that such an analysis has not been carried out and that the impacts of local Plan 2040 on water resources are unknown.

2. Policy NE1 – Environmental net gain.
This policy is fundamentally flawed in that it proposes to deliver Environmental Net Gain on a site-by-site management basis on the unfounded assumption that the end result of 25500 houses in 2040 can be achieved with an Environmental Net Gain.
As the Policy admits, achieving Environmental Net Gain may mean enhancing or creating off-site habitats. Other important environmental issues, which should also be listed in the Policy such as maintaining or enhancing water permeability, managing surface run-off and treatment of waste water, are also likely to require off-site measures. Similarly, building and infrastructure development standards cannot be left to site-by-site decisions but must be specified as a result of analysing what standards are necessary for the total development target.
The Plan must offer evidence that 25500 houses can be achieved with Environmental Net Gain and the protection of crucial resources such as water, together with minimum standards, specified through Policy NE1, that every development must comply with in order to achieve this. If it does not do this, a site-by-site management process alone runs the risk of demonstrating, sometime before 2040, that Environmental Net Gain and protection of water resources can only be achieved within a housing target less than 25500.