I notice this consultation on the Environmental Framework was not included in the Council’s recently published Local Development Scheme (LDS). The LDS also lacks detail concerning its content, timing and who will be consulted at each stage of plan making. The Inspector involved with examining the Council’s withdrawn Development Strategy criticized the Council’s consultation process. A detailed LDS would help counter this criticism and contribute to improving the quality of comment from public and statutory consultees.

The Green Belt is a major contributor to maintaining Central Bedfordshire’s rural environment by preventing urban sprawl. We are disappointed the Green Belt does not feature in the Environmental Framework and Green Belt expansion is not being considered as a means of protecting Central Bedfordshire’s existing rural environment.

The Environmental Framework does not cover the design of new urban environments or the regeneration of existing urban environments.  There has been no assessment of the effects on people living, working and traveling in Central Bedfordshire due to their interactions with the natural, social, rural and urban environments.

The credibility and usefulness of residents and business surveys about the importance of the environment is dubious. The methodological basis of the survey is not included or cited.

None of the document’s hyperlinks accurately reference the evidence that underpins the environment framework.

Question 1 – How to evaluate environmental value

The NPPF says the allocation of land for development should prefer land of lesser environmental value.

– How should the environmental value of land across Central Bedfordshire be assessed?

The environmental value of areas of land has already been assessed and designated as Green Belt, AONB, SSSI, CWS etc. The environmental value of non-designated land should be assessed by communities.

– Are there some elements of environmental value more important than others?

No. They should all carry equal weight when deciding what land to allocate for development.

– Are there elements of environmental value that we have not assessed in this Environmental Framework?

Yes. Clean air, agricultural land, Green Belt, the built environment, the layout of new urban environments and the regeneration of existing urban environments. An assessment of the effects on people living, working and traveling around Central Bedfordshire due to their interactions with the natural, social and built environments.

Question 2 – Improving environmental standards and green features in development

As a council, we are keen to embrace innovation and ensure that development delivers the best outcomes for Central Bedfordshire. A key challenge is working with developers to deliver projects that go beyond the minimum statutory environmental standards. We would therefore like to get your views on:

– How do we encourage development to deliver to a higher environmental standard and what information, policy and guidance would support this?

Delivery of higher environmental standards should be delivered through policy, not guidance, and underpinned by incentives.

What “green” features would you most like to see in new developments? (Pick up to three)

– Solar panels on roofs

 – Green/brown roofs (roofs with plants / habitats on top)

 – Rainwater collection and reuse

Question 3 – Reflecting the importance of the environment in planning policy

How should the importance of the environment to Central Bedfordshire’s businesses and residents be reflected in the future Central Bedfordshire Plan

– Integrating environmental considerations across all relevant policies (e.g. locations for growth, site allocations)?

 – Having specific environmental policies?

 – A combination of the above approaches?

Specific environmental policies should be used to reflect the importance of the environment in Central Bedfordshire’s future Local Plan.

Question 4 – Landscape designations

National policy says that the planning system should protect and enhance valued landscapes. Central Bedfordshire has part of a nationally designated landscape (the Chilterns), but we do not have local landscape designations.

– Should we define what a valued landscape is?

Yes.

– Should we designate locally valued landscapes?

Yes.

– Should designations include different standards for development to areas not designated for landscape value?

Yes.

– Should designations have an emphasis on limiting development or be orientated more towards requiring additional landscape enhancement?

The emphasis should be on limiting development.

– Or should we rely on the Landscape Character Assessment to inform landscape enhancement and development decision making? 

The Landscape Character Assessment should inform choice of Designations.

Question 9 – Managing the Chilterns and their setting

What issue regarding the landscape of the Chilterns is of most concern to you?

Housing and infrastructure development are of concern.

How can the impact of recreational activities in the Chilterns be managed whilst urban growth and populations increase?

 The impact of recreational activities in the Chilterns should be managed by the Chilterns Conservation Board.

The AONB Board has produced guidelines to safeguard the “setting” (i.e. the area immediately around, but not within) of the AONB. Should we try to define and map this zone, bearing in mind the impact will vary depending on the type and scale of development proposed?

 The area around the Chilterns AONB should be mapped and accord with the Board’s guidelines on safeguarding its setting.

Question 15 – Use of sustainable drainage systems

National Policy requires Sustainable Drainage Systems (SuDS) as standard in major developments (for example, 10 homes or more).

– Should CBC require SuDS as standard in all developments (i.e. minor and major, residential and commercial)?

 Yes.

– Should SuDS be used to provide more than just flood risk management? For example, to clean runoff water from developments, and provide amenity and biodiversity benefits.

Yes.

 Question 17 – Energy efficiency in new developments

Should new development be energy efficient and deliver carbon emissions reductions?

Yes.

National policy allows councils to set targets for renewable energy generation from new developments; should the Council be flexible and allow carbon emission reduction through both energy efficiency measures and renewable energy technologies?

 Yes.

 Question 18 – Generating renewable energy in Central Bedfordshire

Which renewable technology do you think is best for Central Bedfordshire?

Solar PV farms

Solar PV on commercial roofs

Solar PV on domestic roofs

Wind turbines on domestic properties

Solar powered Stirling engine energy systems

 

 

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