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

Ended on the 12th August 2020
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Appendix E

SA Matrix for the Alternative Employment Strategy Options

Table E.1 SA matrix for the employment strategy options

SA Topic

SA Objective & Assessment of Effects Nature of the likely sustainability effect (including positive/negative, short - medium term (5-10 years)/long term (10-20 years plus), permanent/temporary, secondary, cumulative and synergistic); Uncertainty

Approaches for employment strategy

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, in addition to the land allocated to meet local employment need.

1. Housing

To ensure that the housing needs of all residents and communities are met

To ensure that the housing needs of all residents and communities are met

0

0

Providing land to meet some of the regional demand for footloose strategic warehousing (Option 1) would not have a direct effect on the delivery of new housing in Central Bedfordshire. The nature of sites that could be used for strategic warehousing means that their use for that purpose is not expected to impede the delivery of housing as it is not likely to be an appropriate alternative use.

This type of development would, however, increase the number of jobs within Central Bedfordshire, and it is necessary to consider whether this could in turn lead to an imbalance between housing supply and jobs, with a shortage of housing to support the local workforce. If this were to be the case then Option 1 would have a negative effect on this SA objective.

Examination document 33[1] provides information about the relationship between jobs and the workforce in Central Bedfordshire. It explains that the SHMA[2] concluded that there was broad alignment between planned jobs growth and the projected changes to the workforce between 2015 and 2035. However, this is based on the household projection-based housing need figure, rather than the higher Objectively Assessed Need (OAN) figure. The SHMA noted that providing more housing than the figure identified by the household projections (i.e. basing growth on the higher OAN figure) is likely to yield a larger population, including additional workers. This could lead to a surplus in workers, leading to larger increases in net out-commuting than otherwise predicted. The housing target in the Local Plan is based on the higher OAN figure; therefore it is not expected that the provision of strategic warehousing sites (in addition to the 24,000 jobs provided for in the emerging Local Plan to meet local needs) under Option 1 would result in an imbalance between employment growth and housing delivery. This is particularly the case because it is recognised that strategic warehousing sites have less of a labour impact compared to other types of employment sites, with the impact in terms of job creation being more widespread[3]. Both Options 1 and 2 are therefore expected to have negligible effects on this SA objective.

2. Communities

To maintain and enhance community and settlement identities

To maintain and enhance community and settlement identities

?

0

The effects of Option 1 on the identities of communities and settlements in the plan area would depend largely on the location and size of the sites developed for strategic warehousing. However, it is assumed that strategic warehousing would be developed in close proximity to the main strategic roads through Central Bedfordshire, in particular along the M1 corridor which crosses Central Bedfordshire from Milton Keynes in the west to Luton in the south east, and along the A1 corridor which crosses Central Bedfordshire past Sandy and Biggleswade in the north east.

The extent to which the development of strategic warehousing in any location would affect the identity of nearby settlements or integrate within the existing settlement pattern would be determined by the location, scale and design of the sites. Similarly, the extent to which there may be opportunities to enhance settlement identities is also dependent on the location.

While there is no Green Belt within proximity of the A1 in the north, parts of the M1 corridor are within the Green Belt around Luton.

Therefore, the effects of Option 1 are uncertain and could be either positive or negative depending on the eventual scale and location of the strategic warehousing. The total amount of provision will also influence effects. Option 2 is expected to have a negligible effect.

3. Services & Facilities

To improve accessibility to services and facilities

To improve accessibility to services and facilities

+?

0

Neither of the options would have a direct effect on the delivery of new services and facilities in Central Bedfordshire. However, the location of new strategic warehousing sites could influence the extent to which existing services and facilities are accessible to employees at the sites around working hours.

It is assumed that new strategic warehousing would be located mainly along the M1 and A1 corridors. If development were to come forward close to the towns in those areas, such as Biggleswade and Sandy near to the A1, there may be good levels of access to services and facilities for employees. There are fewer larger centres along the M1 corridor within Central Bedfordshire, although if strategic warehousing development were to occur at the north western or south western boundaries of Central Bedfordshire employees may benefit from access to towns including Milton Keynes, Luton, Dunstable and Houghton Regis. It is also noted that there may be new services and facilities available at the upgraded station at Ridgmont which is expected as part of the east-west rail development.

It may be that Option 1 has an indirect minor positive effect on this objective, if higher levels of employment locally lead to increased use of local services and facilities as a result of employees having more disposable income. This would potentially boost the viability of those services and facilities.

Therefore, the effects of Option 1 are potentially minor positive although this is uncertain negative depending on the eventual location of any strategic warehousing that may be provided in relation to local centres. Option 2 is expected to have a negligible effect.

4. Employment

To support the economy and ensure that there are suitable opportunities for employment

To support the economy and ensure that there are suitable opportunities for employment

+?

-

Providing new strategic warehousing in Central Bedfordshire under Option 1 would create additional employment opportunities in the plan area which would benefit residents and the local economy, including potentially local suppliers. It would also contribute to meeting the identified need in the wider region for footloose strategic warehousing provision, although the extent of positive effects on the economy will depend on the amount of land provided for this purpose. Additional employment provision will promote and enable a more buoyant local economy and may attract other new businesses to the area, while additional people commuting into the area on a regular basis may increase patronage of local services and facilities such as shops, which would further benefit the local economy.

Central Bedfordshire Council is of the view[4] that not allocating land for strategic warehousing may incur a risk given that unplanned development for such uses could otherwise displace local occupiers, taken to include other employment uses.

The impacts of strategic warehousing sites in terms of job creation is likely to be less than may be assumed for a 'normal' employment site, on a jobs per square metre basis. The labour catchment areas associated with this type of development are likely to extend into the surrounding districts[5] and therefore the impacts would be spread further afield than 'normal' employment sites. This is because the location of sites near to the strategic road network would enable more people to commute to the sites over longer distances. As such, the effects of the new job creation may be more dispersed across a wider area than just Central Bedfordshire, compared to the effects of other employment sites.

Therefore, Option 1 could have minor positive effects on the economy and access to employment opportunities, which would be permanent and long-term. However, this is uncertain depending on factors including the total amount of provision made and its location in relation to the main population centres. Option 2 is expected to have a minor negative effect because there is widely acknowledged regional demand for footloose logistics warehousing sites associated with the strategic transport network. Given Central Bedfordshire's location on the strategic transport network, it is well-placed to contribute towards meeting a proportion of this demand. If the Council were not to make any provision for such footloose warehousing through the Local Plan, this would have a minor negative effect on support for the regional and local economy, and would also reduce the number and range of job opportunities that would otherwise be made available.

5. Health & Equality

To improve the health and wellbeing of communities and reduce inequalities

To improve the health and wellbeing of communities and reduce inequalities

+/-?

0

The effects of Option 1 on health and wellbeing would depend largely on the specific location of sites. The location of sites will influence the extent to which people may commute to and from work via active modes of travel such as walking and cycling, which have health benefits.

It is assumed that development of this nature would be provided in close proximity to the main strategic routes through Central Bedfordshire, in particular along the M1 and A1 corridors. Development along the A1 in close proximity to larger centres such as Sandy and Biggleswade may enable more journeys to be made by walking and cycling if residents of the towns are able to commute relatively short distances to work. It is noted that these towns link to the National Cycle Network, and healthcare centres and recreational facilities are located at both towns, which nearby employees might be able to access around working hours. Away from the large towns of Milton Keynes and Luton, the M1 in Central Bedfordshire is less well-related to larger settlements although there may be potential for sustainable transport use around the Luton/Dunstable/Houghton Regis conurbation. In any location it is expected that there would be high levels of car use to commute to strategic sites located along the A1 and M1, although it may be possible to incorporate mitigation such as new bus links.

The provision of additional employment opportunities at strategic warehousing sites would benefit the local economy and should help to address economic inequalities within Central Bedfordshire. The extent of any positive effects of this nature will depend on the location of sites in relation to areas of highest deprivation. There are particularly high areas of deprivation around Luton/Dunstable/Houghton Regis, which further employment opportunities along the M1 corridor could help to address.

Therefore, Option 1 could have both minor positive and minor negative effects on health, which would be permanent and long-term, although this is uncertain depending on the eventual location of any strategic warehousing that may be provided and whether mitigation is designed into sites in the form of sustainable transport links (i.e. new bus routes). Option 2 is expected to have a negligible effect.

6. Highways & Air Quality

To maintain and improve the existing highway network and reduce associated indirect impacts on air quality and greenhouse gas emissions

To maintain and improve the existing highway network and reduce associated indirect impacts on air quality and greenhouse gas emissions.

--?

0

The effects of Option 1 on this objective will depend largely on the location of the strategic warehousing provided, particularly in relation to areas that are known to already be affected by congestion and poor air quality. Additional traffic generation in those areas, particularly from HGVs travelling to and from warehousing sites, could compound such issues.

It is assumed that development of this nature would be located in close proximity to the main roads through Central Bedfordshire, in particular along the M1 and A1 corridors. An Air Quality Management Area (AQMA) has already been declared along the A1 at Sandy, and development in that area could therefore have particularly negative effects on air quality.

It is understood that the labour catchment for strategic warehousing sites is likely to be quite large and would extend into the surrounding districts[6]. As such, Option 1 could result in higher levels of commuting over longer distances, much of which is likely to be via car although this will be influenced by the location of sites in relation to sustainable transport links. If sites are located with direct access onto the strategic road network, this should reduce the impacts on air quality in residential areas. It is noted that there are already high rates of out-commuting in Central Bedfordshire and providing more employment opportunities within the area may reduce the need to travel longer distances for some people. Depending on the location, the development of new strategic warehousing sites could also offer opportunities for local bus services to new sites as well as shuttle buses which could mitigate effects to some extent.

It could be argued that contributing to meeting the recognised regional need for footloose strategic warehousing under Option 1 would not in itself increase overall levels of HGV traffic and the associated carbon emissions and air pollution; however providing the regionally-required strategic warehousing sites within Central Bedfordshire could mean that associated air quality and carbon-related impacts are more concentrated in Central Bedfordshire, particularly where vehicles are moving at lower speeds into and out of warehousing sites.

Therefore, Option 1 could have a significant negative effect on air quality, which would be permanent and long-term, although the extent of the likely negative effect is uncertain depending on the eventual location of any strategic warehousing that may be provided and on the extent of mitigation that could be incorporated, for example through the provision of shuttle bus links. The total amount of provision will also influence effects. Option 2 is expected to have a negligible effect.

7. Sustainable Transport

To encourage a demonstrable modal shift and reduce the need to travel

To encourage a demonstrable modal shift and reduce the need to travel

-?

0

The effects of Option 1 on sustainable transport would depend largely on the location of sites. However, it is assumed that development of this nature would take place in close proximity to the strategic road network through Central Bedfordshire, in particular along the M1 and A1 corridors.

Locating development along the main road corridors could mean that high numbers of employees at the sites travel to and from work via car, although this may not be the case if sites are located close to the main settlements such as Sandy and Biggleswade along the A1 corridor or Dunstable and Houghton Regis near to the M1. However, it is noted that the labour catchment for strategic warehousing sites is likely to be quite large and would extend into many of the surrounding districts[7]. This increases the likelihood of a high proportion of commuters travelling by car. There may be opportunities to incorporate mitigation such as bus links (which could take the form of dedicated transport) into strategic warehousing sites. Effects may also be able to be mitigated if sites come forward close to railway stations which may provide opportunities for commuting via rail, for example the railway station at Ridgmont which is expected to be improved as part of the east-west rail development.

Therefore, Option 1 could have a minor negative effect in terms of sustainable transport use, which would be likely to be long-term, although this is uncertain depending on the eventual location of strategic warehousing sites and whether or not mitigation is incorporated. Option 2 is expected to have a negligible effect on sustainable transport.

8. Energy & Climate Change

To maximise the potential for energy efficiency, reduce greenhouse gas emission and withstand the effects of climate change

To maximise the potential for energy efficiency, reduce greenhouse gas emission and withstand the effects of climate change

?

0

The effects of the options on greenhouse gas emissions from transport are considered separately above under SA objective 6. This objective considers the effects on greenhouse gas emissions from built development and the resilience of that development to climate change.

The effects of Option 1 on this objective are uncertain at this stage as they will depend on the design of the sites, for example whether they incorporate renewable energy generation – effects could be either positive or negative. Option 2 is expected to have a negligible effect.

9. Water Resources & Quality

To minimise the demand for water and maintain or improve water quality

To minimise the demand for water and maintain or improve water quality

-?

0

The effects of Option 1 on water resources and quality would depend largely on the specific location of sites. However, it is assumed that development of this nature would be provided in close proximity to the strategic road network through Central Bedfordshire, in particular along the M1 and A1 corridors. The course of the River Great Ouse and River Ivel in the north of the plan area means that some (although not all) areas of land along the A1 lie in close proximity to water bodies. Along the M1 there are points where Broughton Brook and tributaries of the River Flit cross this route. While there is potential for run off into water bodies during the construction period which could have adverse impacts in terms of water quality it is likely that risks of this nature could be mitigated, for example by the implementation of construction management plans. There could also be impacts during the operational period of sites, for example if there were fuel or oil spills from HGVs using the sites.

There are areas of Central Bedfordshire which fall within Source Protection Zones (SPZs), including areas along the A1 to the south of Biggleswade and along the M1 to the west of Flitwick. In these areas, vulnerabilities relating to the potential for pollution of raw water sources used to provide drinking water have been identified. As such the development of strategic warehousing at these locations may result in adverse impacts in terms of water quality, although the risk of this occurring should be able to be mitigated through the implementation of appropriate preventative measures.

Therefore, Option 1 could have minor negative effects in terms of water resources although this is uncertain depending on the eventual location of any strategic warehousing that may be provided, and on the construction and operational practices at the sites which may be able to mitigate risks. Option 2 is expected to have a negligible effect.

10. Flood Risk

To reduce the risk of flooding from all sources

To reduce the risk of flooding from all sources

-?

0

The effects of Option 1 on flood risk will depend largely on the specific location of sites. However, it is assumed that development of this nature would be provided in close proximity to the strategic road network through Central Bedfordshire, in particular along the M1 and A1 corridors. The course of the River Great Ouse and River Ivel in the north of the plan area means that much of the land surrounding the A1 (most notably to the west and north west of Sandy and to the west and north of Biggleswade) lies within flood zone 2 or 3. Along the M1 there are points where Broughton Brook and tributaries of the River Flit cross this route. At these locations, areas of land fall within flood zone 2 and 3 but the total area covered is not as sizeable as along the A1. There are also substantial areas of land near to the strategic road network that fall within Flood Zone 1.

Both of these routes pass largely through open countryside and are mostly bordered by greenfield land. As such, development is likely to result in an increase in the extent of impermeable surfaces which could increase local flood risk. It is noted that storage and distribution development falls within the 'less vulnerable' land use types as classified in national guidance[8]. Furthermore, it is expected that development would be designed to incorporate SuDS to mitigate the risk of flooding as part of planning requirements.

Therefore, Option 1 could have a minor negative effect in terms of flood risk, which would be expected to be permanent and long-term, although this is uncertain depending on the eventual location and design of any strategic warehousing that may be provided and in particular on the incorporation of mitigation measures such as SuDS. Option 2 is expected to have a negligible effect.

11. Soil

To protect and conserve soil

To protect and conserve soil

-?

0

The effects of Option 1 on soils would depend largely on the specific location of sites. However, it is assumed that strategic warehousing sites would be located in close proximity to the main strategic roads through Central Bedfordshire, in particular along the M1 and A1 corridors. While the A1 passes the towns of Sandy and Biggleswade, it is mostly bordered by greenfield land within the open countryside beyond these settlements. Furthermore, the A1 passes through sizeable areas of Grade 1 and 2 agricultural land, although there are also some areas of Grade 3 land (it is not known if this is Grade 3a or 3b) and pockets of land that is classified as urban. The M1 cuts through large areas of the undeveloped land in the south east of Central Bedfordshire. The land surrounding the M1 almost all comprises Grade 3 agricultural soils (again, it is not known if this is Grade 3a or 3b), with small areas of Grade 2 soils present in the north west of Central Bedfordshire. Development along these routes is likely to require greenfield land take and could result in the loss of high quality agricultural soils. The potential for developing strategic warehousing on brownfield sites is unknown.

Therefore, Option 1 could have a minor negative effect on soils although this is uncertain depending on the eventual location and size of any strategic warehousing that may be provided. The scale of development likely to result means that effects are not considered likely to be significant, although this is uncertain until specific proposals come forward. Effects are expected to be permanent and long-term. The total amount of provision will also influence effects. Option 2 is expected to have a negligible effect.

12. Biodiversity & Geodiversity

To protect, enhance and manage biodiversity & geodiversity

To protect, enhance and manage biodiversity & geodiversity

-?

0

The effects of Option 1 on biodiversity and geodiversity would depend largely on the specific location and design of sites. Effects may result due to habitat loss, fragmentation and disturbance both during construction and when sites are operational. However, it may also be possible to incorporate biodiversity enhancements through high quality design incorporating the creation of new habitats.

It is assumed that development of strategic warehousing would be located in close proximity to the strategic road network through Central Bedfordshire, in particular along the M1 and A1 corridors. The A1 is located in close proximity to a number of County Wildlife Sites, including one that runs alongside the A1 for much of its length within Central Bedfordshire and crosses the road in a number of places. The closest SSSI to the A1 is within 1.2km of the road to the south east of Sandy. Numerous County Wildlife Sites also lie in close proximity to the M1 in the southern part of Central Bedfordshire and there are also SSSIs and areas of Ancient Woodland in the vicinity of the M1. However, such features would be taken into account in the siting of strategic warehousing to reduce the risk of significant effects occurring. There may also be a risk of effects on undesignated sites and features, which cannot be assessed until the specific location and design of sites is known.

Therefore, Option 1 could have minor negative effects on biodiversity and geodiversity although this is uncertain depending on the eventual location, size and design of any strategic warehousing that may be provided, and on whether mitigation is incorporated. Proximity to national designations will be key in determining the significance of effects. Effects are expected to be permanent and long-term if caused during the operational phase of sites but effects that may occur during construction could be shorter-term and may be temporary. The total amount of provision will also influence effects. Option 2 is expected to have a negligible effect.

13. Landscape

Protect and enhance the landscape and townscape

Protect and enhance the landscape and townscape

--?

0

The effects of Option 1 on the landscape would depend largely on the specific location and design of strategic warehousing sites. However, it is assumed that development of this nature would be provided in close proximity to the strategic road network through Central Bedfordshire, in particular along the M1 and A1 corridors. While the A1 corridor is located away from any designated landscapes, the M1 passes close to the Chilterns AONB - at the nearest point, the distance between the AONB and the M1 is approximately 890m. Depending on the size and design of any strategic warehousing that may be provided in that area, there may be potential for negative effects on the AONB.

Similarly, there are a number of Areas of Great Landscape value covering parts of the A1 and M1 corridors, and so strategic warehousing provision in those areas could have particular potential for negative effects on the landscape, although this is again uncertain depending on factors such as the size, design and visibility of the site and whether mitigation can be achieved.

The M1 and A1 corridors largely pass through rural areas; and strategic warehousing in currently undeveloped locations could affect the rural character of the landscape. However, it may be possible for development to be focussed at the towns within the corridors of the M1 and A1, particularly Sandy and Biggleswade.

Given the sensitivity of some of the local landscape and the large scale of warehouse developments, Option 1 could have significant negative effects on the landscape, which would be permanent and long-term, although this is uncertain depending on the eventual location, size and design of any strategic warehousing that may be provided, particularly the location in relation to the Chilterns AONB. There may be cumulative effects if sites are in close proximity of other new development. Option 2 is expected to have a negligible effect.

14. Historic Environment

To ensure the protection and enhancement of heritage assets, the historic environment and its setting

To ensure the protection and enhancement of heritage assets, the historic environment and its setting

--?

0

The effects of Option 1 on the historic environment will depend largely on the specific location and the design of sites. However, it is assumed that development of this nature would be provided in close proximity to the main roads through Central Bedfordshire, in particular along the M1 and A1 corridors. The A1 and the M1 both pass in close proximity to a number of designated heritage assets and areas which have been identified as having special character. There are numerous Listed Buildings and Conservation Areas located along the A1 and the M1 also passes in close proximity to a number of heritage assets including Listed Buildings and Scheduled Monuments. Within the southern part of the plan area, through which the M1 passes, Areas of Special Character have been identified as part of the 2004 South Bedfordshire Local Development Plan to protect and enhance environments regarded as being of high quality. The closest of these areas to the M1 lies within Toddington but is more than 1.2km from the motorway.

Strategic warehousing provision in these areas in particular could therefore have potential for negative effects on the historic environment, although this is again uncertain depending on factors such as the size, design and visibility of sites which come forward. There may also be effects on undesignated assets.

Therefore, Option 1 could have the potential for significant negative effects on the historic environment, which would be permanent and long-term, although this is uncertain depending on the eventual location, size and design of any strategic warehousing that may be provided. Option 2 is expected to have a negligible effect.


[1] Exam 33: Note on Population, Housing and Employment (July 2019, Opinion Research Services)

[2] Luton and Central Bedfordshire Strategic Housing Market Assessment (December 2017)

[3] Central Bedfordshire Council (2019) Central Bedfordshire Local Plan Examination – Matters, Issues and Questions Central Bedfordshire Council Hearing Statement – Matter 6 Strategic Sites (Policies SP3, SA1-SA5, SE1-SE4)

[4] Central Bedfordshire Council (2019) Central Bedfordshire Local Plan Examination – Matters, Issues and Questions Central Bedfordshire Council Hearing Statement – Matter 6 Strategic Sites (Policies SP3, SA1-SA5, SE1-SE4)

[5] Central Bedfordshire Council (2019) Central Bedfordshire Local Plan Examination – Matters, Issues and Questions Central Bedfordshire Council Hearing Statement – Matter 6 Strategic Sites (Policies SP3, SA1-SA5, SE1-SE4)

[6] Central Bedfordshire Council (2019) Central Bedfordshire Local Plan Examination – Matters, Issues and Questions Central Bedfordshire Council Hearing Statement – Matter 6 Strategic Sites (Policies SP3, SA1-SA5, SE1-SE4)

[7] Central Bedfordshire Council (2019) Central Bedfordshire Local Plan Examination – Matters, Issues and Questions Central Bedfordshire Council Hearing Statement – Matter 6 Strategic Sites (Policies SP3, SA1-SA5, SE1-SE4)

[8] Ministry of Housing, Communities & Local Government (2014) Planning Policy Guidance, Paragraph: 066 Reference ID: 7-066-20140306

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