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Sustainability Statement BEDFORD TOWN CENTRE WEST

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Page 1: TCW Sustainability Statement[1]

Sustainability Statement

BEDFORD TOWN CENTRE WEST

Page 2: TCW Sustainability Statement[1]

Sustainability Statement

BEDFORD TOWN CENTRE WEST

Client:

ST MODWEN DEVELOPMENTS LTD

Reference: EN5367/R/1.2.4/SW

Status: FINAL

Date: JANUARY 2007

Author: Issued by: Waterman Environmental

Name Sarah Waterhouse MA DIC MSc Kirkaldy House

Signature 99 Southwark Street

Position Senior Consultant London SE1 0JF

Approved by: Telephone: 020 79287888

Name Jacqui Fincham Diploma in Sus.Dev. BSc (Hons)

Fax: 020 79020981

Signature [email protected]

Position Associate Director www.watermangroup.com

This report has been prepared by Waterman Environmental, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating of our General Terms and Condition of Business and taking account of the resources devoted to us by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

We accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at its own risk.

© Waterman Environmental 2005

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CONTENTS

1.0 Introduction

2.0 The Proposed Site and Surroundings

3.0 Background to the Development

4.0 The Proposed Development

5.0 Sustainable Development

6.0 Policy Objectives

6.1 National Policy Objectives

6.2 Regional Policy Objectives

6.3 Local Policy Objectives

6.4 St. Modwen Developments’ Corporate Policy

7.0 Approach to Sustainability for the Development

7.1 EcoHomes

7.2 Design Team Meetings and Workshops

7.3 Tender Stage Selection Criteria for Contractors

7.4 Detail Design Stage

8.0 Sustainability Statement

8.1 Environment

8.2 Social

8.3 Economic

9.0 Summary

10.0 References

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Contents

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1.0 INTRODUCTION

St Modwen Developments Ltd (hereafter referred to as the Applicant) is seeking to obtain outline planning permission for the redevelopment of a site to the west of the main shopping area in Bedford Town Centre. Waterman Environmental and Halcrow Yolles have been instructed to provide support to the design team during the pre-planning design stage of the development to maximise the sustainability credentials of the scheme and meet the policy requirements of the developer and the Local Authority, Bedford Borough Council (BBC).

This Sustainability Statement, submitted in support of the planning application, describes the approach that the Applicant has taken to sustainability during the design process and considers the extent to which the development proposals accord with the principles of sustainable development. It has been prepared by Waterman Environmental following a review of national, regional and local policy objectives, including those outlined in the Adopted Bedford Borough Local Plan and the emerging Local Development Framework (LDF) (Ref. 1, 2 & 3). Subsequent to this policy review, a design team sustainability workshop was held by Waterman Environmental and attended by key members of the design team, namely:

• St Modwen Developments Ltd (Developer); • Lyons & Sleeman & Hoare (Architect); • Halcrow Yolles (Mechanical & Electrical Engineer and EcoHomes assessor); • Halcrow Group (Transport & Highways Engineer); • Rodgers Leask Ltd (Structural Engineer); • Donaldsons (Planning Consultant and Environmental Impact Assessment (EIA) project

managers); and • Waterman Environmental (Environmental and Sustainability Consultants).

Opportunities for incorporating features into the development that contribute to the objectives of sustainable development were explored during the design process, to ensure that where possible, the proposals achieve best practice. A number of commitments have been made to increase the sustainability credentials of the scheme including the requirement for a minimum ‘EcoHomes’ rating of ‘Very Good’. Key initiatives incorporated into the development include the use of renewable energy resources to supply a minimum of 10% of the developments energy needs and achieve a 10% reduction in carbon dioxide emissions; a range of measures to increase energy efficiency including low energy lighting throughout the site where feasible and potential for external solar energy lamps; measures such as the use of pervious paving, rainwater harvesting and greywater systems to reduce water runoff and conserve water.

2.0 THE PROPOSED SITE AND SURROUNDINGS

The Site occupies an area of approximately 7.7 hectares and is located within the centre of Bedford, approximately 400m north of the River Great Ouse and west of the main shopping area. The Site is bounded by Beckett Street to the north; Allhallows Street to the east; Midland Road to the south and Greyfriars to the west. The Site currently consists of hardstanding, buildings and roads and has no significant ecological resources. The following mixes of uses currently exist on the Site:

• Bedford bus station and taxi rank; • Retail; • Multi-storey car park; • Offices; • Hotel; • Police Station;

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• Financial services; • Food and drink; and • Residential units (predominately Bedford Pilgrim Housing Association properties).

The site boundary is provided below as Figure 1 and an aerial photograph of the Site is provided in Figure 2.

Part of the Site lies within an identified ‘Opportunity Area’ as designated within the Bedford Local Plan. BBC has also designated the majority of the Site as being the ‘Primary Shopping Centre’, and the Bedford Town Centre Conservation Area (CA) includes a small part of the northern area of the Site. An area of land in the south of the Site around Midland Road is identified in the Local Plan as land that is liable to flood.

The surrounding area is characterised by intense urbanisation. Uses to the north of the Site include Bedford High School and Bedford Prison. East and south of the Site comprises the main shopping area of the town and two managed shopping centres: the Howard Centre and the Harpur Centre. Beyond the southern and western boundaries lie predominantly terraced and semi-detached residential areas, together with Priory Recreation Ground. Bedford train station is located approximately 0.7km to the west, and the Site is well served by local and regional bus routes.

Figure 1: Site Boundary

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• provide a major foodstore and a department store together with unit shops of various sizes for multiple and independent retailers;

Figure 2: Aerial Photograph of the Proposed Site

3.0 BACKGROUND TO THE DEVELOPMENT

Bedford Town Centre is within a relatively affluent catchment area. However, its growth has been held back due to competition from other regional centres that have attracted higher levels of investment. This has resulted in leakage of trade out of the town and long term economic decline. The current negative image for the town potentially discourages significant new retail development further. In addition to this long term economic decline, the Bedford Town Centre Development Framework Study (Ref. 4) highlights a number of other areas of weakness for Bedford including the:

• mundane and ordinary shopping available; • lack of variety and vitality in the evening economy; • limited cultural activity; • poor productivity and legibility; • failure to take advantage of the opportunities presented by the proximity of the centre to the River

Great Ouse; • congestion and through traffic in the town centre and on the radial approaches to it; and • lack of a major visitor attraction to draw people in to the centre.

BBC and its development partners have recognised these shortcomings and are committed to securing Bedford’s future economic growth through investment in high profile developments and appropriate infrastructure. The ‘Bedford Town Centre Area Action Plan Submission Version’ published in July 2006, aims to address the identified weaknesses and covers the central areas of Bedford, providing guidance on how the town centre should change between now and 2021. It sets out the Council’s vision for the area and provides more detail on how their objectives will be met in practical terms, through the development of a number of key sites in the town, Bedford Town Centre West being one. The key objectives for Bedford Town Centre West as identified in the Area Action Plan can be summarised as follows:

• create an attractive extension to the primary shopping area of the town centre, providing modern accommodation suited to the dynamic sections of the retail industry. This should be high quality in terms of the design, materials and finishes used;

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tre;

These a sign team which are set out in Chapter 3: Alternatives and Des ent (ES). The primary aim being to deliver a sustainable,

• imise waste and encourage recycling wherever possible; el of retail provision and

dable units; and

The aTown C ervation Area to the north of the Site and a number of nearby listed buildings including

4.0 THE PROPOSED DEVELOPMENT

po due consideration to the constraints imposed by the setting and nature of the Site, the project team was appointed by the Applicant to implement a phased

prising Use Classes A1, A2, A3, A4 and/or A5 (shops; financial stablishments), Use Class C1 (Hotel); Use Class C3 (Dwelling

• provide a mix of uses, in addition to the retail provision, including cafes, leisure, residential units, affordable housing and car parking;

• improve the permeability of the Site, providing direct pathways through the development to increase links with the rest of the cen

• provide a new ‘state-of-the-art’ bus station and bring about a number of highway and public transport improvements; and

• provide public realm improvements.

re mirrored in the objectives of the deign Evolution of the Environmental Statem

retail led redevelopment that is compliant with the Urban Design Principles set out in Policy TC39 of ‘BBC’s Area Action Plan, Submission Version’ and considers the comments that have arisen from the consultation process. In relation to sustainability objectives in particular, the project team has sought to:

• reduce any environmental impact of the proposals through the use of carefully thought-out layout, design and specification;

• improve efficiency in the use of land, energy, water and raw materials; take positive action to min

• provide an appropriate mix of shops and services to increase the levvariety of uses on offer within the town centre;

• provide an new transport interchange and improve accessibility and movement between the station and the town centre;

• help meet local housing needs through the provision of a range of housing types and tenures, including a proportion of affor

• improve pedestrian connectivity through the creation of a series of high quality linked public spaces.

te m were also instructed to consider various design constraints, including the location of Bedford entre Cons

those adjacent to the northern boundary. The height and design of the proposed Development seeks to respond to surrounding heritage features, creating a distinctive and high quality design that reinforces the character of the town centre. The proposals also seek to provide a layout and building massing that allows suitable microclimate conditions for pedestrians within a quality shopping environment.

In res nse to these design objectives and giving

redevelopment of the Site. It is therefore proposed that all of the existing buildings are demolished. This will include flats, various buildings associated with the bus station, the multi-storey car park, the police station and retail and other commercial units.

The proposed Development comprises:

‘the erection of a mixed-use buildings comand professional services; food and drink ehouses); Use Class D1 and / or D2 (non-residential institutions; assembly and leisure); bus interchange facilities, a multi-storey car park and police unit; including associated alterations and modifications to the existing highway network and public realm.”

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Figure 3: Layout of the Proposed Development

As outlined in Chapter 5: Description of the Proposal of the ES, the key elements of the Development can be summarised as follows:

• Provision of approximately 35,490 square metres gross of retail floorspace, including food and drink (A1 to A5 Use Classes) and a department store;

• Provision of approximately 8,906 square metres gross of floorspace for non-residential institutions and leisure across the rest of the development (D1 and D2 Use Class);

• Provision of up to 330 residential units (C3 Use Class), including affordable units; • Provision of a police unit of approximately 400 square metres (sui generis); • Improved permeability and established linkages between the proposal and existing town centre

uses and other adjoining areas; • Provision of a replacement bus station; • Significant local highway improvements; and • Provision of up to 1,100 car park spaces for the above uses, including a multi-storey car park.

Building heights will range across the Site, varying from approximately 3 to 11 storeys.

It is anticipated that the demolition and construction works will take place in a phased manner over approximately 3 years commencing in mid 2009. The estimated year of completion is therefore 2012.

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Figure 4: Image of the Proposed Department Store/ Community Use Building

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5.0 SUSTAINABLE DEVELOPMENT

In May 1999, the Government published a Sustainable Development Strategy entitled 'A Better Quality of Life - A Strategy for Sustainable Development in the UK' (Ref. 5). This sets out the key issues, aims and priorities for sustainable development in the UK. Many definitions of sustainable development exist, although the common objective for all is the integration of economic, social and environmental issues to ensure a better quality of life for people today, without compromising the needs of future generations.

In applying the principles of sustainable development to the UK, the Government identified four aims that should be met concurrently:

• social progress which recognises the needs of everyone; • effective protection of the environment; • prudent use of natural resources; and • maintenance of high and stable levels of economic growth and employment.

In March 2005, the Government published a new strategy for sustainable development entitled ‘Securing the Future’ which updates the previous strategy to take account of new policies produced in the UK since 1999 (Ref. 6). The strategy demonstrates a new determination to make sustainable development a real priority and highlights the renewed international push for sustainable development which came about as a result of the World Summit in Johannesburg in 2002. The strategy sets out around 250 commitments to action in four key areas:

• sustainable construction and production; • climate change and energy conservation; • protection of natural resources; and • sustainable communities.

Of particular relevance to new developments, the strategy also proposes a new code for sustainable buildings that will establish new voluntary standards on key issues such as energy, waste, water and materials.

In July 2002, the Government also published a paper entitled 'Sustainable Communities - Delivering Through Planning' (Ref. 7) which sets out proposals for maximising the planning system's contribution to the delivery of the Government's sustainable development aims and objectives. How a development affects society in terms of the interaction of occupants with neighbouring communities and the general public is fundamental to sustainable development. Issues to be considered in the creation of sustainable communities include access to health, education, welfare, community and recreational facilities and public open space as well as public safety and crime prevention.

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6.0 POLICY OBJECTIVES

6.1 National Policy Objectives

The Government’s approach to planning highlights the importance of sustainable development. The Planning and Compulsory Purchase Act (PCPA) 2004, is the most radical overhaul of the planning system for many years, the aim of which is to streamline and speed up the framework within which planning decisions are made (Ref. 8). The new Act also requires that sustainable development should be considered for all development proposals.

6.1.1 Planning Policy Statement (PPS) 1: Delivering Sustainable Communities, 2005

PPS1 was published in February 2005 and sets out the key policies and principles, which should underpin the planning system (Ref. 9). It puts sustainability and community involvement at the heart of the planning process. PPS1 emphasises the importance of building well-designed homes, offices, factories and leisure facilities that will benefit the local community and be successful in the long term. Effective community involvement is considered to be crucial and requires processes for informing people about policies and proposals in adequate time; enabling communities to express their own ideas and participate in developing proposals and options; consultation on formal proposals; and feedback.

6.1.2 Planning Policy Statement (PPS) 10: Planning for Sustainable Waste Management, 2005

PPS10, published in 2005, emphasises the need to drive the management of waste up the ‘waste hierarchy’ of reduction, reuse, recycling, composting and energy recovery (Ref. 10). PPS10 promotes the concept of waste as a potential resource with the disposal of waste as the last option. Waste management should be given significant weight in planning applications with the aim to:

‘ensure that the layout and design of new development supports sustainable waste management’.

6.1.3 Planning Policy Statement (PPS) 22: Renewable Energy, 2004

PPS22, published in 2004, sets out the national Government policy on renewable energy and emphasises its role in achieving sustainable development (Ref. 11). It states that all new development should consider opportunities for incorporating renewable energy systems with regard to technologies such as biomass heating, wind turbines, photovoltaic cells and Combined Heat and Power (CHP) systems.

6.2 Regional Policy Objectives

6.2.1 Regional Planning Guidance for the South East (RPG) Note 9, 2001 Regional Planning Guidance (RPG) Note 9 was published in March 2001 and sets out the regional context for development in South East England over the period up to 2016 (Ref.12). It acknowledges that there is a growing understanding that economic, social and environmental issues are intrinsically linked. There is an emphasis on concentrating development in places well served by public transport, especially town centres, within urban areas and on previously developed sites, before considering the development of greenfield sites. The document sets out a number of key development principles, specifically: urban areas should be preferred for development with brownfield regeneration rather than greenfield development; sufficient housing should be provided including affordable housing (with a more sustainable mix of housing in terms of sizes, types and tenures) and sustainable patterns of activity should be promoted. Quality of life is promoted in the document through ensuring that the economy, society and environment develop in harmony. Reference is made to the urban renaissance, which seeks to create the quality of life that makes urban living desirable, and guidance is provided on the form and design of urban development to create an attractive and more sustainable environment in which to live.

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Chapter seven of RPG9 covers the regional economy and seeks to support and encourage its further development to ensure that it contributes fully to national growth and follows the objectives of sustainable development. 6.2.2 East of England Plan – Draft Revision to the Regional Spatial Strategy (RRS), 2004 The East of England Regional Assembly has prepared a new Regional Spatial Strategy (RSS) for the East of England called the East of England Plan (Ref. 13). It will update and replace RPG6 - East Anglia and RPG9 - South East which currently cover the East of England, to guide planning and transport policy up to 2021. The East of England Plan or ‘RSS’ sets out the regional strategy for planning and development in the East of England to the year 2021. It covers economic development, housing, the environment, transport, waste management, culture, sport and recreation, mineral extraction and therefore has a key role in contributing to the sustainable development of the region. A major feature of the RSS is that it identifies the significant investment that will be needed in social, environmental, economic and transport facilities, if it is to achieve its goals. That investment is expected to come from a variety of sources, including central and local government funding and private developer funding 6.2.3 Bedfordshire Structure Plan, 1997 At the regional level, the Development’s proposals should also comply with the requirements set out in the Bedfordshire Structure Plan 2011, which was adopted in March 1999 (Ref. 14). The document is intended to provide long term guidance over a period of at least 15 years for development and land use change in the County. Complying with Government and regional guidance, this plan seeks to ensure sustainable locations and forms of development, which firstly, contribute towards the environmental enhancement of the County’s natural and built resources and secondly, enhance the economic and social opportunities available to its population. Policy 10 specifically seeks to improve the built environment through high standards of design. Policy 13 deals with the preservation of historic features (including listed buildings). Such features will be preserved and managed by the consideration of proposals, which may have adverse affects on the character and appearance of historic buildings. Policies 26 and 27 relate to employment land and encourage local authorities to define, within their local plans, areas for employment to meet the needs of existing firms wishing to expand or relocate and firms wishing to move into the County. The housing chapter states the number of units to be provided in Bedford Borough: 4,500 units are required for the period 2006 – 2011. The Structure Plan also confirms the requirement to provide an element of affordable housing for those households whose income denies them the opportunity to purchase or rent homes on the open market. 6.3 Local Policy Objectives

6.3.1 The Bedford Borough Local Plan, 2002

More specific to the Bedford Town Centre West proposals are the plans and policies of the Bedford Borough Local Plan that aim to deliver the national planning objectives at a local level (Ref. 15). The Bedford Borough Local Plan was adopted by the Council in October 2002 and covers the period up to 2006. The Local Plan sets the pattern and character of future development in the Borough and provides the basis that the Council will use for determining planning applications. Its policies and proposals aim to encourage appropriate forms and locations of development, thereby improving the quality, convenience and sustainability of the environment. The Local plan has a number of Borough Strategy Policies, one of which, Policy S2, seeks to encourage land owners of ‘opportunity sites’ to investigate and bring forward proposals for mixed use redevelopments. Part of the site falls within one such ‘Opportunity Area’.

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As a result of the changes introduced by the PCPA, the Bedford Local Plan will be replaced by a Local Development Framework (LDF) consisting of a series of Local Development Documents (LDDs), which must be in general conformity with the new Regional Spatial Strategy (RSS) for the East of England.

6.3.2 The Core Strategy and Rural Issues Development Plan Document: Submission Version, July 2006 (Bedford Town Centre)

The Core Strategy and Rural Issues Development Plan Document (Ref. 16) includes a spatial vision and strategy for the broad location of development, along with specific policies for the regeneration and revitalisation of Bedford town centre, the creation of sustainable rural communities and the protection of distinctiveness and environmental assets as set out in strategic Policy CP2. Policy CP27 sets out the requirements of the Council for developments to have regard to climate change and pollution, as follows:

• “Minimise the emission of pollutants into the wider environment; • Have regard to cumulative impacts of development proposals on air quality, in particular in

relation to air quality management areas; • Minimise consumption and use of energy, including fossil fuels by design and choice of materials; • Achieve a 10% reduction in carbon emissions (below the normal requirement of the Building

Regulations) in all new dwellings; • Follow a sustainable construction code such as that produced by the Building Research

Establishment (BREEAM and EcoHomes) and achieve a rating of at least ‘Very Good’; • Utilise sustainable construction techniques; • Incorporate facilities to minimise the use of water and waste; and • Limit any adverse effects on water quality, reduce water consumption and minimise the risk of

flooding”. 6.3.3 The Development Framework Study (Bedford Town Centre), 2005

The Development Framework Study sets out a series of proposals that aim to ensure that future development within Bedford Town Centre follows a more sustainable pattern, balancing environmental, social and economic objectives (Ref. 17). It offers a strategy and outlines the key principles that will guide planning, urban design and development so as to fit in with national and local planning policies. Importantly, it also sets out the guiding principles that should be followed when redeveloping some of the key town centre sites, the aim being to aid integration and co-ordination of development within the town centre. Bedford Town Centre West is one such site. It is expected that all development will be of high quality, grounded in the principles of sustainable development and with the overarching aim of achieving a ‘beautiful town/urban environment’. New buildings must demonstrate the highest standards and quality of design, including energy efficiency and the principles of sustainability, such as the use of locally resourced materials, waste reduction techniques and economic construction methods.

6.3.4 Bedford Town Centre Area Action Plan Submission Version, 2006

Bedford Town Centre Area Action Plan Preferred Option builds on the Development Framework Study described above (Ref. 18). The document explains how the town centre should change in the period up to 2021 and gives detailed policies and objectives to help bring this about, turning the vision into a reality. The key objectives include the:

• Successful integration of new development and existing town centre; • Improve the number and quality of connections within the town centre, between the centre, the

River Great Ouse and railway line; • Achieve high quality design and public realm improvements; • Create a more diverse and vital mix of uses, including major increase in retail; and • Achieve significant growth in town centre living.

It also requires the:

‘incorporation of sustainable forms of construction, energy conservation measures and renewable energy’.

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Earlier this year the Council consulted on the submission version of the Bedford Town Centre Area Action Plan. A number of representations were made which will be considered by an independent Inspector at a public examination due to be held next year. Prior to this, the Council is required to publish and consult on the representations which affect any site allocation policies of the Plan. This period of consultation is now open and runs until 11 December 2006.

6.3.5 Local Sustainable Development Policies

In addition to the local planning policies summarised above, BBC also has a number of documents and policies specifically relating to sustainable development. For example, BBC has been attempting to create a sustainable society through the creation and delivery of a Borough-wide Local Agenda 21 Action Plan and a Sustainable Development Action Plan which covers all departments within the Council. A Sustainable Development Policy also sets out what the Council intends to do, in practical terms, to achieve sustainable development in the area including promoting and encouraging energy efficiency and waste minimisation, reuse and recycling and general resource efficiency to the community. Bedford Borough Council is therefore committed to building a better quality of life for everyone within the Borough.

6.4 St Modwen Developments’ Corporate Policy

St Modwen Developments’ Corporate Policy states that the Applicant is dedicated to:

‘improving the built environment, and undertakes projects that seek to transform areas of dereliction and decay into sustainable communities’.

The Applicant’s commitment to sustainable development is demonstrated in a number of ways:

• the regeneration of brownfield industrial sites that often require remediation prior to development; • undertaking infrastructure improvements to alleviate traffic problems and provide new transport

solutions; • the use of sustainable designs with good quality landscaping and the provision of public open

spaces; • community involvement/consultation; • the provision of community facilities; and • employee policies and practices that create equal opportunities in recruitment and career

progression and high standards of health and safety for employees and the public.

The importance that the company places on community, social and environmental issues is reflected in the fact that ultimate responsibility for them lies with the Chief Executive.

Figure 4: Image of the Proposed Development from Midland Square

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7.0 APPROACH TO SUSTAINABILITY FOR THE DEVELOPMENT

The following sections describe the approach the design team and Applicant have taken to applying the principles of sustainable development for the Bedford Town Centre West redevelopment.

7.1 EcoHomes

Buildings have a major environmental impact during their lifecycle. The Building Research Establishment (BRE) developed a voluntary, standard environmental assessment method (known as BREEAM) in 1990 (subsequently updated) by which the environmental impact of a building is assessed against a range of issues and credits are awarded where the building achieves a benchmark performance. BREEAM seeks to bring about reductions in the environmental impact of buildings through recognition of the business benefit which can be achieved. The method addresses impacts of a building on the global, local and internal environments across a range of issues. The BREEAM methodology tailored to new residential units, including houses and flats, is known as ‘EcoHomes’.

Under the guidance of Halcrow Yolles, an independent and licensed EcoHomes organisation, the design team has completed a Pre-Assessment Estimator for the residential element of the scheme. This exercise provides a quick evaluation of the likely EcoHomes rating to be achieved under a formal assessment and is a means of monitoring the environmental sustainability performance of the residential buildings against this established, independent benchmark. Based on the information provided by the design team, the commitments made by them and a number of assumptions, the development has a predicted EcoHomes rating of “Very Good”, thereby meeting the requirements of the emerging ‘Core Strategy and Rural Issues Development Plan Document’. The residential component currently performs well under the Energy, Transport and Materials categories.

The Applicant has committed to undertaking a full EcoHomes assessment during the detailed design stage and to achieve a minimum EcoHomes standard of ‘Very Good’.

7.2 Design Team Meetings and Workshops

A series of design team meetings were organised in which the issues of sustainability were discussed. This included a workshop session, co-ordinated and facilitated by Waterman Environmental, to discuss how the scheme performs against sustainability objectives. The feasibility of a range of low carbon emission and renewable energy options were also assessed by Halcrow Yolles, the Mechanical and Electrical engineers and therefore a number of these meetings focused on the energy strategy for the Development. Consideration has been given to community heating schemes including biomass and Combined Heat and Power (CHP), photovoltaic panels, solar water heating and small scale wind turbines. Some preliminary calculations were also produced to enable a cost/benefit analysis of each technology. Further detail on the proposed energy strategy for the Site is provided below in Table 8.1.

7.3 Tender Stage Selection Criteria for Contractors

The demolition and construction phase of the development offers opportunities to reduce potential adverse environmental impacts and implement a range of sustainability initiatives. As a consequence, the applicant will prepare a tender stage sustainability questionnaire for Bedford Town Centre West setting out specific requirements. The questionnaire will assist in the appointment of those that operate according to best practice. It will also be a means of raising the awareness of contractors and ensuring their active involvement during the works.

In addition to this, contractors will be obliged to:

• obtain formal certification under the national Considerate Contractors Scheme; and • comply with a site specific Code of Construction Practice.

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7.4 Detail Design Stage

The questionnaire will be the first stage in what will be an ongoing review of the requirements relating to sustainability. Subsequent stages are to be managed by the contractor and will include an initial response to the questionnaire, completion of the questionnaire following the contractor’s appointment and that of relevant sub-contractors and regular reviews of decisions and actions throughout the implementation phase including at Practical Completion to ensure that commitments made in response to the questionnaire are being fulfilled. The contractor will be required to keep records of such reviews and any necessary corrective action.

7.0 SUSTAINABILITY APPRAISAL AND METHODOLOGY

Following the workshop, a Sustainability Appraisal was undertaken, beginning with an initial desk-top review of all relevant national, regional and local level policy documents (as summarised in Section 6.0). This review was focused towards gaining an understanding of the guiding policies on sustainable development for the Site.

The basic framework employed for this appraisal has been the sustainability objectives developed for the Sustainability Appraisal (SA) of the Core Strategy and Rural Affairs Plan, and the Town Centre Area Action Plan. These can be summarised as follows:

• Environment issues (sub-divided into: energy; renewable sources; water and flood risk; transport; waste; high quality environment; biodiversity; historic and cultural environment; and high quality design in places and buildings);

• Social issues (sub-divided into: housing; crime; human health; and culture, leisure and recreation); and

• Economic issues (sub-divided into: high performing and stable economy; employment, vitality of the town centre; and poverty and social exclusion).

Consideration has also been given to BBC’s Local Plan policies where appropriate, in order to support and enhance these main headline issues. This has resulted in the inclusion of the sub-issue ‘Materials’ under the environment heading. Further detail on these local objectives is provided in the tables below.

These topics are considered to provide an appropriate framework for the comprehensive appraisal of the sustainability of the proposed Development, as they allow an assessment of whether or not the project would contribute to the sustainability objectives relevant to Bedford Town Centre.

The following tables detail site-specific initiatives which demonstrate how the Development helps to meet the sustainability objectives set out in the Core Strategy and Rural Issues Plan and the Town Centre Area Action Plan Sustainability Appraisal documents, together with BBC’s Local Plan. Since the majority of the detailed design and layout is unknown at this stage, for the purposes of the appraisal some assumptions have been made where information is not currently available.

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8.1 Environmental Issues

Table 8.1: Environmental Issues

Description Commentry To ensure that energy and water consumption is as efficient as possible, thereby reducing overall consumption

The principles of passive design have been considered during the design of the masterplan. For example, Block C has been set back to allow light into Greyfriars Walk and improve the level of daylight entering surrounding buildings. The form and orientation of the proposed buildings are also intended to maximise the amount of natural light entering all public spaces. The top floor of the proposed department store building has rooflights and light wells to increase the incidence of natural light and therefore reduce the need for artificial lighting. In addition, the rooflights would provide the space with natural ventilation, thereby negating the need for active cooling, with its associated energy use.

The Development would incorporate a number of energy efficiency measures in order to reduce energy demand for the proposed residential and retail uses. For example, the Development aims to achieve low U-values for external walls, glazing, roof and floors. Standards of airtightness would be applied to minimise air leakage and infiltration rates through gaps and openings in the building fabric. Depending on the outcome of feasibility studies to be undertaken during the detailed design stage, other energy efficiency measures to be employed within the Development may include: • A ‘condenser water loop’ circulated around the retail units and hotel to allow heat rejection. This system would then be used to provide heat to

the proposed Department store, leisure unit, community area, cinema and hotel. This use of waste heat that would otherwise be lost to the atmosphere, would contribute significantly to an overall reduction in the gas and electrical demand of the Development as a whole.

• The use of a central heating and cooling system (reducing the capacity of the plant required by a minimum of 20%). • Energy metering of the landlord and retail areas will allow the retail tenant to be ‘billed’ for the heat rejection used to encourage a reduction in

energy consumption. • Electrical, water, drainage, heat rejection and heating systems for the leisure unit, library and cinema would be connected to the landlord system

to allow for separate metering. • Natural ventilation and heat metering for the residential units. • Energy efficient lighting design for the car parks and residential units which would minimise running costs and carbon emissions. • Information on energy efficient ‘white goods’ would be provided in homestarter packs for future residents to promote eco labelled white goods

such as washing machines. The Development has taken into account the need to promote water conservation and has considered a range of measures to reduce water consumption such as dual-flush toilets, flow restrictors and aerated taps. Water metering would be installed to encourage residents and building users to monitor and reduce their water use. Moreover, consideration has also been given to the installation of rainwater storage tanks to collect water for washing buses and flushing toilets, further reducing the need to use water from the mains supply system.

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Description Commentry To encourage the use of renewable resources and the provision of renewable energy within the area

The feasibility of a range of renewable and low energy sources has been considered to reduce the reliance on traditional energy sources. This has included an assessment of the energy demand of the buildings, together with an appraisal of technologies such as solar water heating, ground source heating/cooling, biomass boilers, Combined Heat and Power (CHP), wind power and photovoltaics (PV's).

Standing alone, the most viable renewable solution of the residential units would be a biomass boiler that could provide the energy base load. However, it has been concluded that, if linked to a central condenser water loop, the residential apartments, small retail units, department/anchor store, leisure unit, community use, cinema and hotel would benefit most from a technology that can provide heating and cooling, the best technology being ground source heat pumps. Consideration has also been given to the potential use of a combined heat and power (CHP) unit for the Site. This would compliment the renewables technology mentioned above by providing a significant ‘base’ load input of heat. As the CHP plant would not be more than 1MVA in size, it could not be powered by a renewable biomass fuel. However, a gas fired unit could provide significant savings in terms of energy, running costs and utility charges. External solar lighting would also be incorporated throughout the Development where feasible.

The Applicant is committed to achieve 10% of energy creation on-site and an estimated 10% reduction in carbon emissions. However, further detailed investigations are required before the renewable technologies for inclusion within the development can be confirmed.

To reduce car journeys and congestion

Given its central town location, the Site benefits form a number of excellent public transport connections. Bedford railway station is situated within 700m of the Site offering frequent mainline services to local and regional destinations such as Brighton, Bletchley, London St Pancras, Nottingham, Derby and Sheffield. Located within the Site itself, Bedford bus station offers numerous local and regional bus services. In addition, there are three bus stops situated along River Street, one of which serves the Park and Ride scheme at Elstow launched in Autumn 2005.

In addition to the public transport provision that already exists at the Site, a number of transport improvements are proposed including:

• The replacement of the existing bus station, located off Thurlow Street with a new ‘state-of-the-art’ bus station, located in the north west corner of the Site, alongside Greyfriars;

• An improved multi-storey car park for up to 1,100 spaces; • Realignment of junctions along Greyfriars to optimise traffic flow; • Closing the junction between Greyfriars and Alexandra Place to reduce ‘rat-running’; • Enhanced walking routes, with dedicated footways to open up the Site and allow easy and safe access to adjacent shopping areas; and • A safer environment for pedestrians with the introduction of signal operations, additional crossings and tactile paving.

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Description Commentry To reduce car journeys and congestion (Cont)

Moreover, in accordance with current policy, secure cycle parking will be provided at ‘gateways’ to the Site/town to avoid potential conflicts between pedestrians and cyclists in what will become a pedestrianised shopping environment. Cycle storage facilities would also be provided for residents, thereby providing an integrated transport system to encourage the use of more sustainable modes of transport.

Whilst the existing 577 car parking spaces will be replaced with approximately 1,100 located in an improved multi-storey car park, various measures will be employed to minimise the use of the private car such: promoting the use of the Park and Ride schemes through displaying travel information on notice boards and the implementation of a Mobility Management Plan (MMP) (or Travel Plan) which will provide incentives to increase the use of more sustainable modes of transportation. The MMP will be delivered in four key phases:

1. Preparation of the outline travel plan; 2. A travel demand survey; 3. Development of travel plan measures and 4. Implementation.

In general, the MMP would aim to provide realistic, affordable and sustainable access to Bedford Town Centre for residents, employees, shoppers, leisure users and visitors. Targets will be set for each individual occupier based on the results of staff surveys and following consultation with BBC and Bedford County Council (BCC). A number of measures would be considered as part of the occupier travel plans to such as:

• reduce car use (by promoting the use of the existing Park and Ride scheme); • encourage car sharing (establish a database and priority parking); • promote bus use (investigate alternative bus routing, bus stops and through tickets around the centre of the Site and develop bus priority

routes; • enable the use of public transport (travel information boards/plasma screens and interest free season ticket loans); and • promote and enable cycling and walking (cyclist facilities and pedestrian friendly areas on key shopping streets).

The Transport Assessment (TA) for the Site concludes that, with the implementation of these mitigation measures, the local highway network would operate generally no worse than those conditions which would have otherwise prevailed, with some improvements to queuing and delay, especially for pedestrians as well improved cycle links between the Site and Railway Station.

To minimise waste production and support the recycling of waste products

A site specific Code of Construction Practice for the Development will ensure that best practice techniques will be employed in respect of waste and recycling. A commitment has also been made to ensure that all contractors sign up to the Institute of Civil Engineers (ICE's) Demolition Protocol (Ref.19) to maximise the reuse of materials on-site. The specification of prefabricated or recycled materials where possible would also minimise the level of waste generated during the demolition and construction phases.

Adequate space for the storage of recyclable waste during the operational phase of the Development would be provided within bin stores located at ground floor level. These bin stores would be accessible mainly via service yards, but occasionally via pedestrianised areas during non-business hours. In addition, all residential units would have provision for the separation and storage of materials for recycling in accordance with the EcoHomes standard.

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Description Commentry To maintain a high quality environment in terms of air, soil and water quality

All contractors would be required to sign up to the nationally recognised Considerate Constructors Scheme which requires, amongst other things that dust emissions, potential noise pollution, impacts on water quality and the potential for ground contamination are minimised during demolition and construction. As mentioned above, the Contractor would also be obliged to adhere to a site specific Code of Construction Practice to reduce potential nuisance effects.

A Phase I Geo-environmental audit, undertaken by Halcrow Group Ltd in June 2005 has indicated that historical uses at the Site may have resulted in ground contamination. The Applicant has therefore committed to undertaking a ground investigation survey to determine the ground conditions at the Site and remediate where necessary. Wherever possible, preference will be given to on-site remediation techniques, as the most sustainable method of treating contaminated material. The Development would therefore bring about an increase in the quality of the environment in this respect.

An air quality assessment of the potential impact of the Development has been undertaken which confirms that the predicted concentrations are well within the current air quality objectives. In order to minimise the impact on local air quality, boilers integrated within the communal heating system would have nitrogen oxide (NOx) emissions of less than 70mg/kWh. Located within the basement, all plant would be easily accessible via a ramp, allowing easy access for regular servicing to enable equipment to operate at peak performance.

It is proposed that a number of mitigation measures are put in place to reduce the impact of the Development on local water resources. This includes the use of stored roof drainage, provision of tanks for rainwater storage, greywater systems for containment and redistribution of water on site, specification of green roofs (where possible), use of pervious paving for pedestrian walkways and provision of light liquid interceptors. All of these measures will serve to reduce water consumption and therefore improve river and groundwater quality due to reduced abstraction rates.

To reduce the risk of flooding A Flood Risk Assessment (FRA) of the Site has been undertaken which confirms that the Development is not expected to have any significant adverse impacts on existing groundwater flows. The incorporation of Sustainable Urban Drainage Systems (SUDS) including the use of pervious paving and a rainwater harvesting system will reduce surface water run-off by approximately 60%, resulting in a decreased risk of sewer and river flooding.

To conserve and enhance biodiversity

The Development utilises an existing previously developed site in the centre of Bedford and is therefore of limited ecological value. The Development would inevitably result in a loss of existing grass areas and mature trees which provide a limited habitat for breeding and foraging birds. This will in part, be mitigated by the provision of bird boxes around the Site. The landscape scheme is focused on hard landscaping, given the urban location of the Development. The Development will aim to incorporate green roofs, where applicable, and also includes some tree and shrub planting, including flowering and berry rich species to help attract birds and insects.

To maintain and enhance the diversity and distinctiveness of landscape and townscape character

It is considered that the proposals provide a complimentary and distinctive new quarter for Bedford town centre. It would possess a strong urban grain formed by the perimeter blocks that would help to create a series of well defined areas of public open space, different from those in the existing town centre as they would form a series of progressively tighter spaces, squares and landmarks. Pilgrim Square, the new public square located in the heart of the new Development would also be smaller and less formal in style than nearby Harper Square which has a more important, civic role. In addition to this, the larger scale and massing of the new Development would contribute to a sense that this is new and distinctive district.

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Description Commentry

To conserve and enhance the historical and cultural environment

An appraisal of the impact of the Development on Built Heritage in and around the Site has concluded that none of the buildings within the Site are of any intrinsic historic value and are neither nationally nor locally listed. It did, however, identify a total of eight Grade II listed buildings and one Grade II* listed buildings close to the Site boundary. The proposals will have a negligible impact on these buildings. In fact, there is some potential for minor beneficial impacts resulting from the removal of the modern high rise buildings in the north of the Site that currently have a negative impact on the settings of the adjacent Bedford Town Centre Conservation Area (CA) and listed buildings.

In terms of Townscape and Visual impacts as a result of the redevelopment, it is considered that:

• the opening-up of Thurlow street towards Pilgrim Square will have a positive impact on the townscape when viewed from Church Square, providing an enhanced character and sense of place/identity;

• There will be a loss of views into the Site from Allhallows, as Greenhill Street is to be replaced by the car park proposals. This is not a significant loss in visual terms, but it will alter the character of Allhallows; and

• The foodstore will have an impact on views from Roise Street and Hassett Street (both views from within the Conservation Area). The materials and form of the building should respond to this where possible, and be sympathetic to the local character, in order to reduce the townscape impacts.

An assessment of potential impacts on archaeological resources has also been undertaken. Given that that a large part of the Site has been affected by development in the past, it is likely to have resulted in varying degrees of truncation. Therefore in summary, there is a high potential for survival of Roman remains in the north of the Site, although the proposed highways works in this area would not be expected to have a significant impact on them. There is also limited potential for the survival of Middle Saxon or Late Saxon and medieval remains along the southern and eastern margins of the Site. The possible medieval or post-medieval building remains in the south west of the Site lie within areas of high and moderate truncation. As such there is only, at best, limited potential for survival of truncated sub-surface remains of these buildings. Disturbance to any remains, which are likely to be truncated and fragmentary, would not be considered as more than a minor adverse impact. It is considered that adverse impacts to known archaeological remains of local importance, or any unknown remains, within the Site could be mitigated through a phased programme of targeted archaeological investigation and recording. Only very small areas identified as having potential for archaeological remains and high potential for survival lie outside the footprints of buildings or highways.

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Description Commentry The Development seeks to achieve high standards of both architectural and urban design that will aid in the formation of a sustainable community in the long term. The following aspects of the proposals are considered to result in what can be termed ‘a high quality design’:

To create or enhance spaces, places and buildings that wear, look and work well. • a strong urban grain formed by a series of blocks providing an interface between the traditional centre and the surrounding quarters to the north,

west and south;

• scale and massing that is sensitive to the scale and massing of adjacent buildings towards the existing town centre, with a more intense scale towards the re-aligned Greyfriars Walk in order to provide a stronger urban grain on the western approach to the Site;

• a mix of uses and active frontages that will provide natural surveillance;

• new public realm including a new square (Midland Square) with a clear legibility that has been designed to interact with the existing public realm;

• enhanced permeability through a well defined series of spaces connecting the west of the town centre to its surroundings;

• the retention of the long vistas through Midland Road and Greyfriars Walk;

• use of landmark buildings to create a sense of place;

• consideration of the impact of buildings in terms of daylighting and overshadowing. For example, the cinema/leisure complex is recessed from the retail frontage by some 10m to allow for adequate sunlight and the highest buildings around Pilgrim Square are located to the north to avoid overshadowing; and

• the wind microclimate is considered to be suitable for the intended use of the Site.

The design has evolved as a result of an extensive consultation process with a range of stakeholders including BBC, the Commission for Architecture and the Built Environment (CABE) and the general public. Early involvement and consultation with BBC in particular, has resulted in an iterative process by which the inception stages of the masterplan were developed in tandem with planning advisors and the resulting proposals assisted the Council in developing their vision for the Bedford Bus Station Area, now set out in ‘The Bedford Town Centre Framework Study’. The basic concept of the development, overriding urban design principles, scale and massing, proposed land uses and quantum of accommodation have therefore been agreed in principle by the major parties involved through this consultation process and as a result of a series of technical studies that have formed part of the Environmental Impact Assessment (EIA) process.

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8.2 Social Issues

Table 8.2: Social Issues

Sustainability Objective Commentry To ensure that everyone has access to a good quality affordable home that meets their needs

The design team are committed to providing a mix of new, high quality residential units, comprising studio flats and one, two and three bedroom apartments to replace those which are demolished. Subject to agreement with BBC, some 30% of the 330 residential units would be affordable. This will contribute to meeting the housing target set out in the Bedfordshire Structure Plan. Although the proposals will result in the occupiers of the existing residential accommodation being displaced from the Site, a rehousing strategy including a dedicated liaison officer will help relocate existing residents in accordance with their requirements.

To reduce crime and the fear of crime Consideration has been given to the principles of “Secured by Design” to increase pedestrian and resident comfort and safety. For example, the Development provides direct and open routes through the Site with active retail uses at ground level and residential uses above to increase the level of natural surveillance. All routes would be well lit, easily navigable with structural planting designed to avoid the creation of hidden corners or concealed entrances. CCTV could also be installed to further enhance security.

To maintain and enhance human health Key considerations with regard to human health and quality of life include noise, access to recreation and amenity space.

The Applicant has committed to achieving, and looking to exceed where possible, the noise performance standards set out in Approved Document E for the residential units, carrying out a programme of pre-completion testing and undertaking remediation works if any tests are shown to fail.

Amenity space will be provided in the form of balconies and roof terraces for all residents and the creation of new public realm will increase the amount of open, useable space on the Site, to the benefit of residents, employees, office workers and the general public.

The proposals may include a health and fitness suite that will promote a healthier lifestyle for residents and employees in an urban area, as will the provision of improved pedestrian access routes for employees and residents alike.

To make opportunities for culture, leisure and recreation available to all

As discussed above, the proposals are considered to respect nearby listed buildings and improve the setting of the adjacent Bedford Town Centre CA. Public art has a role to play in the cultural life of communities and the Applicant has committed to including some form of public artwork as part of the proposals. It is also intended that any potential adverse impacts to known archaeological remains within the Site would be mitigated through a phased programme of targeted archaeological investigation and recording for the benefit of future generations.

In terms of the provision of leisure and recreation facilities it is also proposed that a total of approximately 8,900 square metres of leisure use is provided. The exact form that this will take is yet to be confirmed. Community uses also form part of the proposals, thereby contributing to the development of sustainable communities where people can live, work, relax and feel an integral part of. The proposed hotel is also likely to provide additional health and leisure facilities for patrons.

The provision of high quality public open space, cafes, bars and restaurants will provide people with the opportunity to meet and socialise,

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8.3 Economic Issues

Table 8.3: Economic Issues

Sustainability Objective Commentry To encourage a high performing and stable economy

A better quality of life for all will require improved, more widely available goods and services; high quality housing; energy and access to a growing range of leisure activities. A stable and competitive economy is required to achieve this.

The Development proposals, which incorporate a range of new retail, leisure and commercial uses together with up to 330 new dwellings, will help stimulate the regeneration of the area and are in accordance with local planning policy objectives. The Development will create a range of new job opportunities, providing significantly more employment within the retail and leisure services sector than are currently represented in Bedford

To help people gain access to satisfying work appropriate to their skills and potential

To meet the challenges of sustainable development, a skilled and adaptable labour force and a flexible labour market is necessary. The promotion of jobs and employment, better education and training are essential. In a world which is changing rapidly, people need the skills to adapt and opportunities to update them throughout their lives.

The Development will provide a mix of business types to compliment existing businesses and skills in the local area. The redevelopment of the Site will result in an estimated 135 net additional local jobs during construction and 349 from operation of the completed Development. Ongoing discussions with owners and occupants will ensure suitable settlements for existing businesses including the potential option of providing new accommodation within the Development for a number of the existing occupiers.

To maintain and enhance the vitality of the town centre

As highlighted above, there is a recognised need for redevelopment in this area of Bedford Town Centre. The Proposed Development would deliver a high quality, mixed use development, with retail units at ground floor, with the potential for cafés, bars and restaurants. This will address the problem of a lack of variety and vitality in the evening economy, an identified current weakness for Bedford Town Centre.

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Sustainability Objective Commentry To help reduce poverty and social exclusion

An Access Statement has been produced and submitted in support of the Planning Application to demonstrate that the design will meet the requirements of the Disability Discrimination Act (DDA), 1995 (Ref. 20). All retail buildings and public realm space will therefore allow access to those with disabilities. All residential units would be designed to meet Lifetime Homes Standards and a commitment has also been made to adapt up to 10% of the proposed apartments to wheelchair standards.

The inclusion of retail units within the Development would increase accessibility to high quality goods and services for local residents and office workers and the proposed landscaping scheme would provide an improved urban environment for all.

As stated above, the total housing provision is likely to be approximately 330 residential units, of which it is expected that 30 percent will be affordable. The composition of this housing will be a mix of low cost housing for sale, shared purchase and social rented housing making the Development accessible to those in a variety of financial situations. The affordable housing will be distributed throughout the site to promote social integration amongst new residents.

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8.0 SUMMARY

An appraisal of the proposed Development has been undertaken against key sustainability objectives identified from relevant policy guidance. The framework for the appraisal was guided by headline issues from the Core Strategy and Rural Issues Plan and the Town Centre Area Action Plan Sustainability Appraisal documents and BBC’s Local UDP. This process has ensured that the proposed Development responds to the sustainable development objectives that are relevant to the area. Key sustainability initiatives of the proposed Development include:

• Efficient reuse of previously developed land;

• Commitment to achieving an ‘EcoHomes’ standard of Very Good’;

• Incorporation of a number of energy efficiency measures such as low U Values, high standards of air tightness and energy efficient plant and lighting;

• Use of renewable and low energy resources to achieve an estimated 10% of the buildings energy supply and 10% reduction in carbon emissions;

• Use of external solar lighting where feasible;

• Incorporation of water efficient sanitary systems to promote low water consumption and commitment to install rainwater harvesting for use as non-potable water in the residential units to reduce surface water run-off and incorporation of greywater systems where feasible;

• Undertake a number of transport improvements including provision of a new bus station, multi-storey car park and changes to the local road network, increased permeability of the Site and provision of improved routes for pedestrians. More sustainable modes of transport would be promoted through the incorporation of cycling facilities and implementation of a Mobility Management Plan;

• Reduction, reuse and recycling of waste materials during the demolition/construction and operational phases of the Development;

• 100% use of sustainable timber sources and consideration of materials with low environmental impact and the use of locally sourced materials;

• Commitment to sign up to the Considerate Contractors Scheme and compliance with a site specific Code of Construction Practice;

• Improvements to the local environment in terms of soil and water resources by remediating contaminated soils, where encountered;

• Provision of a high quality design that responds to the varying scale and architecture of the surrounding townscape including nearby listed buildings and the Bedford Town Centre CA;

• The provision of a mix of housing, including affordable and community and leisure facilities;

• The net creation of 135 jobs during construction and 349 for the operational phase and a mix of uses that will create vitality in the town centre and a new evening economy; and

• A Development that is fully inclusive for all members of society.

The sustainability assessment indicates that in considering the design proposals for Bedford Town Centre West, the Development, with its aim of providing a high quality, mixed-use scheme, would make a positive contribution towards the economic regeneration of the town centre and the creation of sustainable communities; and as such can be said to meet the objectives set out in The Bedford Town Centre Area Action Plan Preferred Option document.

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9.0 REFERENCES

1. East Midlands Regional Assembly, 2002, East Midlands Regional Sustainability Checklist.

2. Bedford Borough Council, 2002, The Adopted Bedford Borough Local Plan.

3. Bedford Town Centre Area Action Plan Preferred Option

4. Bedford Borough Council, 2005, Bedford Town Centre Development Framework Study.

5. Department for the Environment, Transport and the Regions (DETR), 1999: A Better Quality of Life - A Strategy for Sustainable Development in the UK. DETR.

6. Department for Environment, Food and Rural Affairs (DEFRA), 2005, Securing the Future: Delivering UK Government Sustainable Development Strategy, HMSO.

7. Office of the Deputy Prime Minister (ODPM), 2002: Sustainable Communities - Delivering Through Planning, ODPM, London.

8. The Planning and Compulsory Purchase Act 2004.

9. Office of the Deputy Prime Minister (ODPM), 2004: Planning Policy Statement 1 (PPS1): Delivering Sustainable Communities. ODPM, London.

10. Office of the Deputy Prime Minister (ODPM), 2005: Planning Policy Statement 10 (PPS10): Planning for Sustainable Waste Management. ODPM, London.

11. Office of the Deputy Prime Minister (ODPM), 2004: Planning Policy Statement 1 (PPS22): Renewable Energy. ODPM, London.

12. Office of the Deputy Prime Minister (ODPM), 2005. Regional Spatial Strategy for the East Midlands (RSS8). The Stationary Office (TSO), London.

13. East Midlands Regional Assembly, 2005. England’s East Midlands Integrated Regional Strategy: Our Sustainable Development Framework. East Midlands Regional Assembly.

14. East Midlands Regional Assembly, 2002. England’s East Midlands: The Sustainability Checklist. East Midlands Regional Assembly.

15. Bedford Borough Local Plan was adopted by the Council in October 2002

16. Core Strategy and Rural Issues Development Plan Document

17. Bedford Town Centre Development Framework Study

18. Bedford Town Centre Area Action Plan Preferred Option

19. London Remade, 2006, A Report on the Demolition Protocol

20. Disability Discrimination Act, 1995