Sustainability Appraisal - Supplementary Report [EXAM 115/115B]

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Chapter 2

Scope of Work

2.1 This chapter sets out the findings of LUC's review of the SA process that has been carried out for the Central Bedfordshire Local Plan up to 2019. This review was undertaken by LUC immediately following appointment by CBC, and it has informed decisions about the supplementary work to be undertaken. This chapter also sets out the scope of the supplementary work that has now been carried out, and includes the following:

  • A summary of the Inspectors' comments on the SA work undertaken previously.
  • Information about the updated evidence that is now available to inform the further SA work that has been undertaken.
  • A Quality Assurance (QA) review of the Regulation 19 SA Report for the Local Plan, identifying whether it meets all the requirements of the SEA Regulations.
  • A review of the strategic options considered through the SA process to date and a description of the changes now made to those options and the further SA work that has been undertaken.
  • A review of the approach that has been taken to the SA of strategic site options and a description of the Supplementary SA work that has now been undertaken.

2.2 Chapters 4 and 5 of this report present findings of the Supplementary SA work described in this chapter, and Chapter 6 summarises what has changed from the SA work set out previously in the Regulation 19 SA Report (January 2018).

Summary of the Inspectors' comments relating to the SA

2.3 The Inspectors' post-hearing letter to CBC dated 30th September 2019 included a number of comments relating to the SA work that had been undertaken for the Local Plan to date. These points can be summarised as follows:

  • Lack of robust justification for the strategy set out in Policy S1 (Growth Strategy): while the SA considered a number of alternative options, the North of Luton allocation is a consistent feature in all scenarios (except the no growth option) which indicates that not all reasonable alternative options have been appraised. It is also unclear why the SA has used a capacity of 2,000 dwellings to consider the land west of Luton, when the site promotors and the Luton HMA Growth Options Study[4] both refer to higher figures (5,500 and 2,500 respectively).
  • Comments about how the SA has considered alternative strategies for employment growth: the SA only tests two scenarios which are based on the allocations in the Local Plan, with and without the Sundon Rail Freight Interchange (RFI). There is a lack of clear justification for allocating sites through the Local Plan which require land to be released from the Green Belt, when sites are being promoted by representors which do not require Green Belt release.
  • Lack of consistency between the SA and other evidence sources: inconsistencies were highlighted between the SA findings and the Council's site assessment work. The effects identified in the SA for two particular sites in relation to sustainable transport and landscape are cited.

2.4 The purpose of this Supplementary SA work is to address these issues, which are considered in more detail below.

Updated evidence base and baseline

2.5 The evidence base for the SA was originally set out in the Baseline Information section of the SA Scoping Report[5] in 2016. The Scoping Report was appended in full to the Regulation 19 SA Report and the baseline information was summarised in Chapter 3 of that report. Paragraph 3.26 of the Regulation 19 SA Report refers to the evolving evidence base and the need to update the baseline information as the SA process progresses. Therefore, work has now been undertaken to update the baseline (see Appendix A). As well as taking into account updated evidence sources, the baseline information update reflects developments such as the consent that has now been granted for the M1-A6 link road.

2.6 A list of the updated evidence sources that have become available since 2016, and which are relevant to the SA, is provided in Table 2.1 below. These evidence sources have been taken into account in the further SA work now carried out and set out in this report. It is noted that various site-specific studies such as landscape and visual impact assessments (LVIAs) have also been produced by developers and site promoters; however these have not been taken into account in the SA as they are not available consistently for all of the reasonable alternative site options.

Table 2.1: Updated evidence sources for the SA

Updated evidence sources

Summary of document and relevance to the SA

Functional Economic Market Assessment and Employment Land Review (July 2017)

This study was undertaken by Peter Brett Associates (PBA) on behalf of CBC. It forecasts the demand and supply of employment land over the Local Plan period.

Water Cycle Study Stage 2 Final Report (August 2018)

This study was undertaken by JBA on behalf of CBC. Following on from the Stage I Water Cycle Study it assesses the potential issues relating to future development within Central Bedfordshire and the impacts on water supply, wastewater collection and wastewater treatment. The Water Cycle Study is required to assess the constraints and requirements that will arise from potential growth on the water infrastructure.

QA review of the Regulation 19 SA Report

2.7 A review was undertaken to check the compliance of the Regulation 19 SA Report with the requirements of the SEA Regulations, in order to identify where Supplementary SA work is required. The review was undertaken in relation to all requirements of the SEA Regulations, although particular consideration was given to the aspects of the SA Report that have already been highlighted by the Inspectors as needing further work.

2.8 LUC reviewed the SA Report against each of the requirements of the SEA Regulations and identified where further work is needed. This is to ensure that the requirements have been fully addressed, based on LUC's extensive SA experience and understanding of good practice, as well as the current guidance contained in the online National Planning Practice Guidance. Table 2.2 below summarises the areas where additional work is required in order to ensure compliance with the SEA Regulations. This additional SA work has now been carried out and is presented later in this report.

Table 2.2: Supplementary work required to meet SEA Regulations requirements

SEA Regulations requirements

Supplementary work required

a) an outline of the contents, main objectives of the plan, and relationship with other relevant plans and programmes;

Because the review of plans, policies and programmes was originally prepared in 2016, it has been necessary to review and update it. This can be found in Appendix B.

b) the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan;

Because the baseline information was originally prepared in 2016, it has been reviewed and updated. This can be found in Appendix A.

f) the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors (these effects should include secondary, cumulative, synergistic, short, medium and long-term, permanent and temporary, positive and negative impacts);

The supplementary work carried out to complete the meeting of this requirement can be found in Chapter 4.

h) an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information;

An exercise has been carried out to consider whether the suite of options appraised was reasonable and to determine the supplementary appraisal work required (detailed further ahead in this section).

i) a description of the measures envisaged concerning monitoring in accordance with Reg. 17;

The SA Report should include a clear monitoring framework setting out proposed indicators, linked to the likely significant positive and negative effects identified in the SA. A monitoring framework has now been prepared and can be found in Chapter 7.

j) a non-technical summary of the information provided under the above headings.

A separate Non-Technical Summary has been prepared to accompany this Supplementary SA report.

Review of strategic options and further SA work required

2.9 As described above, the Inspectors' comments on the SA focus largely on the appraisal of reasonable alternative options for the spatial strategy, and whether the strategy taken forward in the Local Plan is justified.

2.10 Audit trails have been prepared (see Appendix C) listing the strategic options that have been appraised at each stage of the SA, the Council's reasons for selecting or rejecting each one and identifying whether there are additional or revised options that needed be subject to SA. The following groups of options have been considered:

  • Areas for development growth
  • Approaches to distributing development growth
  • Growth scenario options – housing
  • Growth scenario options – employment
  • Growth locations for development growth – housing
  • Growth locations for development growth – employment

Areas for development growth

2.11 Four areas (A-D) were identified prior to the Regulation 18 stage, recognising the different characteristics of Central Bedfordshire:

  • Area A: South & West/M1 Corridor
  • Area B: East/A1 Corridor
  • Area C: East/West Corridor
  • Area D: Central Section

2.12 These areas were not intended as four alternatives, but rather as distinct areas to help guide plan-making. The four areas were appraised in the Regulation 18 SA Report, and the findings were reported again in the Regulation 19 SA Report. There are no changes to these options and no further SA work has been required.

Approaches to distributing development growth

2.13 Seven options for approaches to distributing development growth were originally identified. These are not necessarily alternatives, but rather approaches that might be suitable and sustainable depending upon the likely effects for each of the four Areas for Development Growth. The SA findings (along with those for the Areas for Development Growth) informed consideration of possible scenarios for growth and the overall growth strategy.

2.14 These options were developed during late 2016 and were subject to SA with the findings being first presented in the Regulation 18 SA Report. The findings were again presented in the Regulation 19 SA Report.

2.15 A number of changes have now been made to the suite of options, so that they represent high level alternative options for the spatial distribution of development.

2.16 Table 2.3 below summarises the changes that have been made to the options for approaches to distributing development growth. These changes have been proposed to ensure the distribution options are more reflective of the range of schemes being considered as alternative options. The changes also ensure there are distinct differences between the options. Previously options 4 and 6, for example, could have been one and the same. In the revised options, a distinction has been made between growth around existing road networks, and growth that is based around sustainable transport networks. These could have significantly different sustainability effects.

Table 2.3: Approaches to distributing development growth

Options appraised previously

Revised options in the Supplementary SA

Option 1: New settlement (village scale) – assumed to be between 2,000 to 5,000 new homes

Option 1: New settlement (village scale) – 1,500-5,000 new homes

Option 2: New settlement (town scale) – assumed to be between 7,000 to 10,000 new homes

Option 2: New settlement (town scale) – more than 5,000 new homes

Option 3: Village extensions – especially those with services and facilities

Option 3: Village extensions – especially those with services and facilities

Option 4: Growth in transport corridors

Option 4: Growth around strategic roads

Option 5: Urban extensions – assumed to be 1,500-2,000 (and up to 4000) and for the larger settlements

Option 6: Urban extensions assumed to be 1,500-4,000 (option has been renumbered to allow the two transport-related options to follow on from one another).

Option 6: Urban intensification around transport hubs – for settlements with railway stations, bus stations and park and rides

Option 5: Growth around sustainable transport hubs (option has been renumbered to allow the two transport-related options to follow on from one another).

Option 7: Higher densities – development offering around 75 to 130 dwellings per hectare

Option has been removed.

2.17 The combined SA matrix prepared previously for the seven original options has been revised to reflect these changes and the findings summarised (see Chapter 4 and Appendix D of this report).

Growth scenario options - housing

2.18 In the Reg 19 SA, five growth scenarios for housing were developed with potential growth locations in each of the four areas A-D and applying the opportunities for each of the approaches to distributing growth, aiming to minimise negative effects and maximise positive effects. The options appraised were:

  • Scenario 1: Higher levels of growth across all Central Bedfordshire (30,500 homes)
  • Scenario 2: No growth to the west of Luton and east of Biggleswade (25,500 homes)
  • Scenario 3: No strategic transport infrastructure delivered in the A1 corridor (Area B) (21,500 homes)
  • Scenario 4: No growth in the Green Belt (Area A) (22,500 homes)
  • Scenario 5: A mixed approach with higher growth in villages (20,650 homes)

2.19 These five options are very specific, listing the site allocations that would be included in each scenario and giving a total housing figure, each of which varies from the Objectively Assessed Need (OAN). Under this approach there are numerous other possible combinations of site allocations that could also considered as alternative scenarios; therefore LUC's review of the SA involved taking a step back and firstly considering how much development there should be, separately from the question of where it should be.

2.20 The Pre-Submission Local Plan (January 2018) includes a housing target for Central Bedfordshire of 39,350 new homes between 2015 and 2035. This is comprised of 32,000 homes to meet Central Bedfordshire's OAN over that period, plus 7,350 homes to meet the unmet need arising from Luton. Because the Local Plan housing target is based on the OAN, it is not considered by the Council that there are reasonable alternative options for the amount of housing to be delivered through the Local Plan, which should be subject to SA. This is also not something that has been raised as a concern by the Inspectors.

2.21 A lower housing target would not meet the OAN and, given that there is sufficient land available in Central Bedfordshire to provide the identified housing requirement, this is therefore not a reasonable approach.

2.22 There is no requirement to deliver new homes over and above the OAN figure. The Plan already seeks to go beyond CBC's OAN, to deliver homes to meet the unmet needs of Luton Borough. Bearing in mind the Council has also committed to an early partial review, meaning that the housing target will be reviewed again in the near future, the Council believes it is appropriate to plan to meet the identified OAN at this stage and then to determine a longer-term housing target within the early partial review. As such, no higher than OAN option has been tested.

2.23 Alternative options for the quantum of housing development to be delivered through the Local Plan are therefore not considered in the Supplementary SA. Further consideration is given to where the housing development should be located further ahead in this report (see section on growth locations for development growth – housing).

Growth scenario options – employment

2.24 Two growth scenarios for employment were developed for the original SA. These options were:

  •  Scenario 1: 6,000 new jobs:
    • – Area A: 2,300 new jobs at Sundon Rail Freight Interchange (RFI)
    • – Area B: 2,000 new jobs at Biggleswade
    • – Area C: 1,700 new jobs at M1 Junction 13
    • – Area D: 0 new jobs
  •  Scenario 2: 3,700 new jobs:
    • – Area A: 0 new jobs
    • – Area B: 2,000 new jobs at Biggleswade
    • – Area C: 1,700 new jobs at M1 Junction 13
    • – Area D: 0 new jobs

2.25 As alluded to in the Inspectors' post-hearing letter, there are alternative overall strategies for employment growth which could include whether or not to cater for the 'footloose' demand in the logistics and distribution sector. Therefore, Supplementary SA work has been carried out in relation to the following options:

  • Option 1: Provide land to meet some of the footloose regional demand for strategic warehousing, in addition to the land allocated to meet local employment need.
  • Option 2: Do not provide land to meet some of the footloose regional demand for strategic warehousing.

2.26 A new combined SA matrix has been prepared to appraise these options (see Appendix E) and the findings are summarised in Chapter 4). The appraisal of these options focuses on the likely 'in principle' sustainability effects of providing or not providing land to meet some of the footloose regional requirement for strategic warehousing. Because this footloose regional demand has not been quantified, there is no evidence on which to base a set of more detailed alternative options considering specific amounts of such development that could be provided within Central Bedfordshire. Instead, the appraisal focuses on the principles of providing this type of development or not and reflects the uncertainty about how much there might be. The SA findings for the reasonable alternative employment site options will then inform CBC's decision making about whether particular sites should be allocated to contribute to this need.

2.27 In terms of the quantum of employment land to be provided to meet the Objectively Assessed (local) Need, the evidence[6] shows that a minimum of 24,000 jobs will be required over the Local Plan period. It is not considered by the Council to be a reasonable option to allocate land for fewer than 24,000 new jobs because there are sufficient available sites within Central Bedfordshire and so there is no justification for planning not to meet the identified need for jobs. The option of providing additional employment land is considered in relation to the provision of sites for footloose strategic warehousing only, as described above.

Growth locations for development growth – housing

2.28 Thirty eight options for strategic housing site allocations were identified at the Regulation 18 stage, with nine of these being considered reasonable alternative options for the purposes of SA. In addition, four options involving growth in the villages in each of areas A-D were also appraised alongside the strategic sites.

2.29 A review was undertaken to determine whether the strategic sites appraised previously still remain the reasonable alternative options – see Appendix C. For the purposes of the Supplementary SA, a number of changes have been made to the list of reasonable alternatives, including the addition of some further reasonable alternative options based on the Inspectors' comments about there being potential discrepancies between the capacities considered for certain sites. The changes made to the suite of reasonable alternative strategic housing site options are detailed in Appendix C and the updated SA findings for these options are presented in Chapter 4.

2.30 As described earlier in this note, the Inspectors' post-hearing letter to the Council identified potential inconsistencies between some of the SA scores for certain strategic sites and other assessment work that had been undertaken. Supplementary SA work has been undertaken to address these inconsistencies, as described further ahead in this section.

Growth locations for development growth – employment

2.31 The original SA Report included an appraisal of three alternative strategic employment sites to contribute to the regional footloose demand that had been identified:

  • Sundon RFI
  • Biggleswade, West of A1
  • Ridgmont, M1 Junction 13

2.32 A further 13 reasonable alternative employment site options have now been appraised in the Supplementary SA. These sites had passed the strategic site assessment stage in the Strategic Employment Site Assessment Technical Document[7] (see Appendix D) and so are considered to be reasonable alternative options for the purposes of SA; however they were previously omitted from the SA process on the basis that they had been assessed in more detail in the Strategic Employment Site Assessment Technical Document and discounted for not meeting specific criteria that the Council considered necessary and appropriate for the delivery of strategic, stand-alone warehousing and distribution uses. Whilst an assessment of all but one of these sites was carried out, which included sustainability criteria, they should have been included and appraised within the SA and assessed consistently against the SA objectives. One site was also omitted in error. An updated summary of the SA findings for all 16 site options has been prepared (see Chapter 4 and Appendix G).

Approach to the SA of site options

2.33 As described earlier in this note, the Inspectors queried potential inconsistencies between the SA findings for certain site options and some of the other assessment work carried out by the Council.

2.34 A review was undertaken of the assumptions that were used to inform the appraisal of sites against each SA objective and consideration was given to whether any changes to the assumptions should be made. The review did not identify any fundamental gaps in the evidence used to inform the SA which could have led to the identified inconsistencies and did not result in any changes to the assumptions used.

2.35 In order to ensure that the SA is consistent with other evidence, the appraisal work for strategic sites that was undertaken previously has been reviewed and any areas of inconsistency identified have been addressed in this Supplementary SA report.

SA of the Spatial Strategy – Stage 2

2.36 Once the Supplementary SA work described in this chapter had been carried out, it was necessary to undertake a second stage of work. This involved drawing together the findings from the various strands of the SA (i.e. the different sets of strategic options) and considering the headline questions and decisions that the Council needs to address in preparing the Local Plan, in the light of the updated SA findings. This second stage of work is presented in Chapter 5 of this report.

Summary

2.37 This chapter has introduced the findings of LUC's review of the Regulation 19 SA Report and has described the scope of the Supplementary SA work that has now been undertaken.

2.38 The findings of the Supplementary SA work are set out in the following chapters.


[4] LUC with BBP Regeneration (November 2016) Luton HMA Growth Options Study

[5] Enfusion (October 2016) Central Bedfordshire Local Plan - Sustainability Appraisal Scoping Report: Final

[6] Functional Economic Market Assessment and Employment Land Review (Examination Document C08)

[7] Strategic Employment Site Assessment Technical Document (July 2017) – Document F02

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