Employment Technical Paper [EXAM 112]

6. Consideration of alternative options

6.1. Overview

6.1.1. As noted in section 3 above, one of the biggest concerns in EXAM 69, in relation to employment, is the consideration of alternative options. Whilst officers are content that the most appropriate sites were selected through a robust site assessment process, it is acknowledged that further assessment of options should have been undertaken as part of the SA.

6.1.2. This has now been undertaken and the results are summarised within the discussion below.

6.2. Supplementary Sustainability Appraisal (SA)

6.2.1. Overall, the Supplementary SA illustrates that the likely sustainability effects of the 16 employment site options are not particularly varied in terms of the number of likely significant positive and negative effects identified.

6.2.2. Whilst the SA does not rule any sites out specifically based on their consideration against the SA Objectives, some sites did perform more poorly than others, scoring higher numbers of significant negative effects. Some sites also stand out as having a higher number of significant positive effects and fewer significant negative effects than others.

6.2.3. The Supplementary SA does recognise that there may be possible mitigation measures that can be implemented to reduce or limit the negative impacts, however, it is likely that the higher number of significant negative impacts there are, the more mitigation would be required and the higher the potential impact upon a sites deliverability and viability.

6.2.4. Whilst the Supplementary SA does not specifically draw definitive conclusions about the sites that should be included within the local plan, a number of observations have been made which support and reinforce the judgements made by the Council in relation to the identification and selection of the three proposed strategic employment allocations within the local plan. These are summarised below:

• Holme Farm (identified within the SA as Land West of the A1, Biggleswade) has the joint highest number of significant positive effects and with only one likely significant negative effect, is therefore identified within the SA as performing the best out of all 16 site options in SA terms.

• Sundon Rail Freight Interchange has the second most significant positive effects. Whilst this location is identified as having 4 significant positive effects, it also has 3 significant negative effects identified in relation to the SA Objectives. However, as identified above, the Supplementary SA recognises that measures could be implemented to mitigate negative effects.

• Marston Gate (identified within the SA as Land at Ridgmont) is identified as having 3 significant positive effects and only 1 significant negative effect. When directly compared to another location nearby such as Winterwoods Farm, for example, which also has 1 significant negative impact but only 2 significant positive impacts, this again reinforces and supports the Council's proposed allocations.

6.2.5. As previously noted, the SA has considered a site that the Council initially omitted from the initial site assessment process. This site, known as New Spring Farm, also came out well within the Supplementary SA having been identified as having 3 significant positive effects and only 1 negative effect. Whilst this site came out well in relation to SA Objectives, at the current time, it is considered that access to the site is difficult to achieve.

6.2.6. During the Regulation 19 consultation on the local plan (Feb 2018) the site promoters for New Spring Farm proposed that a larger site of approximately 71ha should be allocated within the plan, as an alternative to the Holme Farm allocation. This wider proposal confirms that the parcel within the scheme known as New Spring Farm is not as easily accessible without two initial phases of development being delivered first to provide the necessary infrastructure and access. Whilst access is possible in theory, it is not considered it would deliver the most appropriate stand-alone scheme. The site is not, therefore, being put forward as an allocation within the Local Plan.

6.2.7. Whilst this wider site may be a consideration for the committed partial plan review, the Council are not seeking alternative sites. Having undertaken a robust Call for Sites and Site Assessment process to identify sites within the plan, it is not considered appropriate or necessary to consider sites that were promoted to the Council at such a late stage in the process. The Inspectors themselves confirmed this approach by stating at the start of the Hearing Sessions in May 2019, that they were considering the Plan as submitted and that they were not seeking to identify or consider omission sites as part of the hearing sessions.

6.2.8. In terms of those sites not allocated within the Local Plan, these have all now been assessed within the SA, which has helped to inform the Council's decisions, alongside consideration of other evidence, on whether any alternative sites should have been included as allocations within the Local Plan. A summary of some of the key considerations is below.

6.2.9. The Council recognises that in order to deliver growth and development, there is inevitably going to be an impact upon the local landscape and therefore seeks to limit this impact where possible by avoiding those sites that would have the most detrimental impact. There are a number of sites that are identified within the SA as having significant negative effects in relation to SA Objective 13: To Protect and Enhance the Landscape and Townscape, which are therefore not considered to be as appropriate for the delivery of strategic, stand-alone employment opportunities. These include Aspley Guise Triangle/Milton Keynes South East Opportunity Area; Checkley Wood Garden Village; West Sunderland Farm; and Land at Hitchin Road, Shefford. In addition, Land at Bedford Road, Husborne Crawley is also expected to have significant negative effects in relation to this SA objective as the site lies within the vale landscape of the Aspley Triangle which is identified to have moderate – high landscape sensitivity. New Spring Farm, Biggleswade; and Land adjacent to Popes Farm have been identified as having landscape sensitivities which are likely to mean that the scope for development is limited.

6.2.10. There are also a number of sites that do not have direct or very good access to the strategic road network, an attribute that the Council considers essential for strategic employment and one that is supported in the Employment Land Review as well as the Employment Land Update. Sites that are less well located and are therefore unlikely to be appropriate for the delivery of strategic employment uses include Land at Wharley Farm, Cranfield; Hitchin Road, Shefford; Checkley Garden Village; and Cranfield University. The latter is also considered to be suited to specialist uses only and therefore also unlikely to deliver strategic warehousing, or indeed employment opportunities to meet identified 'local' needs.

6.2.11. In addition to above, there are a number of sites that have individual attributes that collectively reduce their appropriateness for meeting this demand. For example,

• Land Adjacent to Popes Farm is identified within the Supplementary SA to have a significant negative impact in relation to SA Objective 6 as it could intensify the air quality issues at the AQMA already identified on the A1 at Sandy. The Supplementary SA also identifies that development at this site could have negative effects in relation to SA Objective 10 (Flood risk) as the site contains substantial areas of land (40% of the site) that fall within Flood Zones 2 and 3; and that negative effects are also likely in relation to SA Objective 14 (Historic Environment) as the site is in close proximity to a Heritage Asset and development may have an impact on its setting.
• Land at Marston Moretain and Lower Shelton was identified as the only site that would have a significant negative impact on the second part of SA Objective 2 (settlement identities), as development would reduce the open space between Marston Moretain and Cranfield, and it would contribute to coalescence between Lower Shelton and Marston Moretaine;
• Land East of Junction 11A & North of the Vauxhall Plant is identified within the SA as having significant negative effects in relation to the Green Belt as well as in relation to SA Objective 6 in that development could intensify air quality issues at the AQMA on the M1 at Luton. The SA also identified that development would impact upon the identify of a nearby hamlet which is part of Charlton. Overall, the SA identified that this was one of the sites that performed least well;
• Land at Winterwoods Farm was assessed reasonably well within the Supplementary SA, however, the site is located to the west of the A421, and development here would be within open countryside. A planning Application was submitted in November 2016 for B8 Uses and ancillary B1. This application was refused on the grounds that by virtue of its scale and introduction of urban highway features, such as the realigned road and roundabout, the development would result in significant harm to the character and appearance of the area. It was also considered that there would also be harm to the setting of a number of key listed buildings within close proximity to the development, and overall, the adverse impacts of the development would significantly and demonstrably outweigh the benefits. Furthermore, to the east of the A421, there is an existing employment area and planning permission has recently been granted between the A421 and Bedford Road for further employment opportunities. The Marston Gate proposals are also within this location. The Marston Gate site is considered to relate better to the existing built development and is also in close proximity to Ridgmont Station. Having achieved a higher number of significant effects within the SA, and taking into account the above, it is considered that Marston Gate and not Winterwoods Farm should be taken forward as an allocation. It would not be appropriate to allocate both sites as it is considered that the cumulative impact would have detrimental impacts on the landscape character; and
• Land East of the M1, South of Broughton Road scored well against a number of SA Objectives. However, this site is physically disconnected as it is comprised of two parcels of land which sit either side of the M1. It is unclear at the current time how the site would be accessed. Direct access on to the M1, if achievable, would be costly and would require significant infrastructure investment that could impact upon the viability of the site.

6.2.12 It has been established that there is a strong need and demand for strategic employment opportunities along the two strategic routes (M1 and A1) that pass through Central Bedfordshire and that there is currently a limited supply of land and sites to meet this demand. The Council has sought to identify locations along these two routes that are not only capable of delivering the quality and attributes required to accommodate such uses, but also those sites that are available, achievable and as far as practically possible, capable of delivering sustainable development.

6.2.13 When planning balance is applied and factors such as the physical location and attributes of each location are taken in to consideration, the Supplementary SA reinforces the judgements made in relation to the sites identified to meet the strategic demand and supports the strategy set out within the plan.

6.2.14 Further information is provided to justify the site allocations proposed within the submitted Local Plan and to address any other issues raised by the Inspectors in EXAM 69 in relation to these sites, under individual site headings below.

6.3. Sundon Rail Freight Interchange (Policy SE1)

Overview

6.3.1. As detailed in section 3 above, the Inspectors identified concerns regarding the proposed RFI and employment allocation being dependent upon the delivery of the new M1-A6 link road; a lack of wider assessment of alternative locations outside of the Green Belt to serve the wider Luton/Dunstable/Houghton Regis conurbation, or with neighbouring authorities; and the justification of exceptional circumstances for the release of Green Belt. These are addressed in turn below.

Response to EXAM 69

6.3.2. Central Bedfordshire Council is keen to ensure future growth is sustainable and delivered in appropriate locations. At the same time, the Council is committed to ensuring that future growth contributes to combatting climate change and reducing CO₂ emissions.

6.3.3. This approach is consistent with the National Planning Policy Framework (NPPF, March 2012), in its chapter entitled 'Promoting Sustainable Transport', which requires strategies for the provision of viable infrastructure necessary to support sustainable development, including large scale facilities such as RFIs (paragraph 31) and it is identified that plans should protect and exploit opportunities for the use of sustainable modes of movement of goods.

6.3.4. This support is reinforced in the February 2019 NPPF, that similarly requires planning policies to identify and protect, where there is robust evidence, sites which could be critical in developing infrastructure to widen transport choices (paragraph 104(b)).

6.3.5. In addition, the National Policy Statement for National Networks (NPS) (December 2014) identifies that there is a compelling need for a network of strategic RFI's across the country, and highlights the environmental benefits of RFI's including significantly less CO₂ than road freight as well as lower Nitrogen Oxides (NO_x)and Particulate Matter (PM₁₀ ) emissions. The decongestion of roads is also highlighted as a particular benefit, with each train estimated to take up to 43-77 HGV's from the road network.

6.3.6. The provision of employment alongside the RFI is considered to be integral to the RFI. Footnote 42 to the NPS defines a SRFI as "a large multi-purpose rail freight interchange and distribution centre linked into both the rail and trunk road system. It has rail-served warehousing and container handling facilities and may also include manufacturing and processing activities".

6.3.7. Paragraph 4.83 to the NPS goes on to state that "Rail freight interchanges are not only locations for freight access to the railway but also locations for businesses, capable now or in the future, of supporting their commercial activities by rail. Therefore, from the outset, a rail freight interchange (RFI) should be developed in a form that can accommodate both rail and non-rail activities".

SA Findings

6.3.8. As noted above, the Council is keen to ensure future growth is sustainable and delivered in appropriate locations. The delivery of an RFI within Central Bedfordshire is therefore considered to fully support this due to the proximity of the site to the rail network and the environmental and sustainability benefits this will provide. The Supplementary SA identifies a number of positive attributes of the proposed Sundon RFI site which further support this approach. For example, the RFI proposals are 1 of only 2 sites that the SA considers to have minor positive effects in relation to SA Objective 5 (To improve the health and wellbeing of communities and reduce inequalities) due to the close proximity of the site to Luton. The site is also identified as being within, or in close proximity to, areas of the strategic green infrastructure network, therefore supporting improved links to the strategic green infrastructure network which could provide employees at the sites with access to open space and recreational areas. This is considered to be a significant positive effect.

6.3.9. The Supplementary SA also identifies that in relation to Objective 7 (To encourage a demonstrable modal shift to more sustainable forms of transport and reduce the need to travel) the proposals would have a significant positive effect as the site is located adjacent to a railway line in close proximity to existing railway stations at Harlington and Leagrave as well as bus stops which benefit from frequent services. New bus connections to the existing stations serving the site would also support sustainable transport connections with the potential for enhanced positive effects. The SA further identifies that these links could be used by employees travelling to and from the site and that the proposed use of the site as a rail freight interchange also contributes to the positive effects as it would help to take freight traffic off the roads.

6.3.10. There is the potential to provide a new cycle network to connect to National Cycle Route 6, which is to the south of the site as well as to the new cycleway which will be delivered along the full length of the M1-A6 Link Road. A footpath could also be provided to link with the North of Luton allocation (SA1). There is, therefore, significant potential for the creation of sustainable transport connections and to encourage a modal shift. The location of the allocation adjacent to major settlements (Dunstable, Houghton Regis and Luton) also reduces the need to travel for many potential employees.

6.3.11. As the site is identified as being able to provide a good level of access to sustainable transport links, development is also expected to help minimise increases in greenhouse gas emissions in Central Bedfordshire as development is delivered. Minor positive effects are therefore identified for the site in relation to SA objective 8 (To maximise the potential for energy efficiency, reduce greenhouse gas emission and ensure that the built, natural environment and its communities can withstand the effects of climate change).

6.3.12. As part of the proposed allocation of the RFI at Sundon, the local plan also identifies the delivery of 40ha of strategic employment land for warehousing. As noted above, the provision is considered to be integral to the proposals and is supported by the NPS.

6.3.13. The delivery of the proposals at this location is further supported by the Supplementary SA (Appendix G) which identifies that the allocation will deliver new employment land and jobs to support the economy with the potential for major long term positive effects. The SA further identifies that the proximity of the site to Luton, Houghton Regis and Dunstable indicates further positive effects through opportunities to support and enhance the vitality and viability of town centres.

6.3.14. The Supplementary SA continues stating that the employment allocation is in close proximity to deprived areas in the North of Luton and that development can therefore provide employment opportunities for local people, which will help address deprivations within the local communities.

6.3.15. Whilst the Supplementary SA identified a number of positives and significant positive effects on SA Objectives, the site also scored less well in relation to other SA Objectives and in some instances, is identified to have significant negative effects on SA Objectives.

6.3.16. Sundon RFI is likely to have a mixed effect overall on SA objective 6, to maintain and improve the existing highway network and reduce associated indirect impacts on air quality and greenhouse gas emissions, as the proposed use of the site as a rail freight interchange should contribute to taking vehicles off the road.

6.3.17. The proposed site is located within the Green Belt and within the parcel (L2) which is considered to make a strong contribution to the purposes of the Green Belt. However, whilst the SA identifies that this has a significant effect on SA Objective 2, the Council considers that the economic and sustainability benefits associated with the provision of an RFI and associated employment, provide the exceptional circumstances to justify the release of the land from the Green Belt. This is discussed further later in this section.

6.3.18. The site is also considered within the Supplementary SA to have negative effects in relation to SA Objectives 11 and 13. In relation to Objective 11, to protect and conserve soil, the site is considered to have negative effects as it contains some Grade 2 best and most versatile agricultural land in the southern part of the site and some grade 3 (sub-grade 3a or 3b no known) in the west. The SA also identifies, however, that there is an element of uncertainty attached to the effects recorded given that the full effects will need to be informed in part by site surveys.

6.3.19. With regard to SA Objective 13, to protect and enhance the landscape and townscape, it is identified that the proposed RFI site is the only proposed employment site that is in close proximity to the Chilterns AONB. Appendix G states that development at this location has the potential to negatively affect the AONB setting through urbanisation in a previously undeveloped area.

6.3.20. The SA Appendix continues, that it is recognised that there is some existing development between the proposed site and the AONB which would provide some degree of buffering. However, adopting a precautionary approach the potential for significant long-term negative effects against SA Objective 13 are identified with an element of uncertainty at this stage.

6.3.21. In terms of examining this in more detail, the Landscape Visual Impact Assessment that has been undertaken in relation to the proposed allocation (EXAM 5O Annex 14) concludes there is likely to be a very limited opportunities of seeing the proposed development from within the Chilterns AONB. It is identified that to the east of the site, glimpsed or partial views towards the highest parts of some of the building units may be possible from the edge of the designated landscape at the Manor Road/ Streatley Road junction, yet beyond this there are not likely to be any views towards the proposed development from the AONB.

6.3.22. It also states that, in general terms, the site occupies a visually contained context with landform variations and nearby woodland and mature planting restricting its visibility, particularly to the east and south. It is a settled and varied landscape context and the presence of the M1 motorway corridor, large substation, pylons and power lines and edge of Luton provide existing large scale and urbanising influences over the site.

6.3.23. In these respects, the site is considered in visual terms to have the capacity to assimilate a well-planned and designed RFI development. Subsequent care and attention at the design stage to the location, sizes, heights and elevational treatments of the building units and to the associated rail infrastructure and landscape mitigation proposals will, however, be important to ensure that any adverse visual effects are fully assessed and mitigated.

6.3.24. The SA identifies in relation to SA Objective 12 (Biodiversity and Geodiversity) that due to the site's proximity to a SSSI site, area of Priority Habitat and a CWS site, there is the potential for minor negative effects. However, the SA also identifies that the employment area has the potential to provide enhancements to the local biodiversity through the creation of new areas of habitat as well as ecological corridors which could be used to link isolated areas of Priority Habitat to the south and east, with benefits for local wildlife movement. Furthermore, the SSSI that is adjacent to the proposed allocation often attracts anti-social behaviour and is used as a motor cross track. The development of the proposed allocation therefore offers the opportunity to ensure these activities cease and to restore the SSSI to its former natural state.

6.3.25. Adjacent to the proposals, the Council are allocating land to the North of Luton for a mixed-use urban extension. The Council have also recently granted permission for the M1-A6 link road (discussed further below). Given the new road is a commitment, which means built development will already impact the AONB in this area, it is considered this further lessens any likely impact of the RFI proposals.

6.3.26. Whilst there is the potential that the RFI may have a limited impact on the setting of the Chilterns AONB, the Council has considered this carefully and has determined that the social and economic benefits of delivering growth within this area, including the RFI and associated employment provision, but linked to a new strategic road link and housing to meet the needs of LBC, do outweigh the impacts. The provision of an RFI is in accordance with national guidance, which encourages a proactive approach.

M1-A6 Link Road

6.3.27. As identified by the Inspectors, the delivery of the RFI proposals is dependent upon the delivery of the M1-A6 strategic link road.

6.3.28. Access into the site will be via a dedicated roundabout on the new M1-A6 link road which will link to Junction 11A on the M1 motorway. The short distance to the motorway from the site entrance, which is approximately 900 metres, represents a key attribute of this location, contributing significantly to its suitability for RFI and strategic employment development.

6.3.29. The Council has recently granted full permission for this road (January 2020). As such the issues raised within EXAM 69 in terms of the alignment of the road are no longer applicable. Further details on this can be found within the Transport Technical Paper (EXAM 114).

Wider site assessment and Exceptional Circumstances

6.3.30. In relation to a broader assessment of alternative locations outside of the Green Belt, to serve the wider Luton/Dunstable/Houghton Regis conurbation, the site promoters have undertaken an Alternative Site Assessment. The Sundon Rail Freight Interchange Alternative Sites Assessment (ASA) can be viewed in full on the website (EXAM 107).

6.3.31. The ASA sets out in full the methodology undertaken in the consideration of alternative sites for an RFI, including the identification of the area of search.

6.3.32. It identifies, that as evidenced in the Council's FEMA study and supported by an independent review undertaken by consultants, Savills, the M1 supports Central Bedfordshire's primary logistics market with a focus of accommodation in Luton, Dunstable, Milton Keynes and Marston Gate.

6.3.33. A secondary market is located along the A1(M), with Stevenage, Letchworth and Biggleswade supporting strategic warehousing. These facilities represent the most likely source of RFI freight. With no existing or other proposed RFI in Central Bedfordshire and the nearest alternative facility (Northampton Gateway to the north and Radlett SRFI to the south – both committed proposals which benefit from relevant permissions) located too distant to efficiently serve this need, the search area for the ASA extends to include both the M1 and A1(M) markets.

6.3.34. It is considered that the methodology used for the ASA is consistent with methodologies adopted by other ASA's that have considered RFI development potential. Cross referencing for consistency has also been undertaken with the Radlett ASA, the findings of which were endorsed by the Inspector in that planning appeal and the Secretary of State.

6.3.35. As outlined within the Council's Note on Green Belt Exceptional Circumstances (EXAM 25), outside Central Bedfordshire, the former Radlett aerodrome (St Albans City and District) has planning permission for an SRFI. At that planning appeal, the question of the relative roles of Sundon and Radlett was specifically addressed and, as set out in the SoCG between Prologis and CBC, the Secretary of State endorsed Network Rail's view 'that Sundon is a significantly smaller site than Radlett and that [Network Rail] does not consider that the two proposals fulfil the same purpose or act as alternatives to each other'.

6.3.36. Overall, the analysis undertaken within the ASA identified a total of 24 potential RFI sites across the qualifying search area of Central Bedfordshire, 10 of which were also considered within the Radlett ASA.

6.3.37. An assessment of the suitability of all these locations identified only three where it was considered there was any real potential to accommodate RFI development: the proposed allocation at Sundon; land at Toddington Park, Harlington; and land south of Westoning. No non-Green Belt locations were identified.

6.3.38. However, as both land at Toddington Park, Harlington; and land south of Westoning are being promoted for non-RFI development (the Harlington site is being promoted by I M Properties as 'Toddington Park', a 90.7 hectare B8 employment development, whilst the Westoning site is being promoted as an urban extension to the Village), and as it is considered that there is an inability to secure a rail access to either site, neither site is considered to be a credible alternative for an RFI. Whilst the site promoters for Toddington Park have made previous references to the opportunity for a rail connection at the Toddington Park site (p.3 of the Vision document forming Appendix 1 to the Barton Willmore Matter 6 Statement) the ability to achieve such a connection is not demonstrated. Furthermore, the Toddington Park Vision Document identifies its 'advantageously positioned within proximity of the Rail Freight Interchange (RFI) proposed at Sundon, providing a potential opportunity for rail connectivity for the transportation of goods'.

6.3.39. The proposed Sundon RFI by comparison, is located directly adjacent to the Midland Main Line (MML) that runs from Sheffield to London St Pancras and is situated between the length of railway operating between Harlington Station and Leagrave Station. There are four railway tracks, two for high speed trains and two for lower speed trains with the lower speed tracks located adjacent to the site, enabling direct rail access to the site.

6.3.40. In addition, Network Rail has already constructed a freight siding (the 'Sundon Loop') that runs for a distance of 2km, alongside the mainline just to the north of the site. Network Rail created this facility to allow for the future accommodation of freight traffic entering and exiting the site, whilst also providing a 'passing lane' for other freight services on the mainline.

6.3.41. Whilst the proposed location of the RFI therefore benefits from having direct access to the Midland Main Line and there is significant rail infrastructure already in place in the form of the Sundon Loop, there is still a need to provide further infrastructure to enable the RFI to be appropriately connected to the Loop. The Site promoters have confirmed that the delivery of that further infrastructure is readily achievable.

6.3.42. Overall, the ASA concludes that, consistent with the findings of the earlier Radlett Study, it can be demonstrated that there are a lack of alternative RFI development opportunities across Central Bedfordshire (and beyond), and that other than the proposed Sundon site, there are no locations, either within or beyond the Green Belt that could credibly accommodate an RFI.

6.3.43. In relation to a wider assessment of alternative locations with neighbouring authorities, during the production of the local plan, extensive Duty to Cooperate (DtC) meetings were held with both officers and Members during which the Council shared that part of the strategy for the plan was to deliver stand-alone strategic employment sites to help meet a footloose demand as identified through our Employment Land Review. It was identified that three such sites were proposed at Junctions 11a and 13 of the M1 and on the A1 south of Biggleswade and that the site proposed at Junction 11a would also deliver a Rail Freight Interchange.

6.3.44. At these meetings, the agenda's and notes of which have been published alongside the Local Plan within the DtC Statement (ED D02), none of the Council's DtC partners identified or raised specific concerns about the provision of an RFI within Central Bedfordshire, or indeed specifically at the proposed location at Sundon. The Council is in the process of confirming with each neighbouring authority that they still do not have any specific concerns about the proposed allocation at Sundon.

6.3.45. Furthermore, for completeness, the Council has sought confirmation from each neighbouring authority that they do not have an alternative location within their administrative area that could be considered as an alternative location for an RFI and associated strategic employment uses, and that they are not aware of any other reasonable alternative outside of their administrative area that could accommodate this.

6.3.46. The responses that have been received from neighbouring authorities confirm that they did not previously identify and still do not have any specific issues about the provision of an RFI within Central Bedfordshire, that there are no issues or objections to the proposed location of the RFI at Sundon and that they do not consider there to be any reasonable alternatives within their administrative area. A summary of comments received to date are provided below:

• MK Council confirmed that they do not raise any objection to or concerns with the proposed Sundon Rail Freight Interchange employment allocation and that they are not aware of any land that could form a reasonable alternative for a Strategic RFI within the administrative area of Milton Keynes.
• Bedford BC had no objection to the RFI at Sundon, but re-iterated previous concerns around the employment provision associated with it;
• Luton Borough Council have confirmed that they did not question the principle of the proposed allocation or the consequential change to the Green Belt to accommodate it but that they did previously raise some concerns about whether the wider transportation implications of the Sundon RFI in its chosen location had been sufficiently appraised to show there would be no adverse effects on traffic and transport in the conurbation and wider area. With regards to Luton Borough Council, it is also noteworthy that their position has previously been set out within the adopted Luton Local Plan (November 2017),where it is stated "The Council will encourage proposals for rail freight interchange that serves the conurbation, such as the freight consolidation centre proposed at the former Sundon Quarry".
• Dacorum Brough Council confirmed they did not, and still does not, have any issues or concerns in specific relation to the proposed allocation of a Rail Freight Interchange (RFI), and specifically, not at the location proposed at Sundon.
• North Herts confirmed that they did not, and still do not, have any 'in principle' concerns with the proposed allocation of a Rail Freight Interchange (RFI) at the location proposed at Sundon. They commented that an RFI at Sundon would principally serve the M1 corridor and the Luton / Milton Keynes area. Concerns were reiterated about potential road-borne, east-west freight movements from the RFI particularly in light of the proposed M1-A6 link road (and any future onward connections to the A505 and Hitchin). However, these are considered to be relatively low volume and that appropriate mechanisms already exist to address any impacts upon North Hertfordshire.
• St Albans City & District Council confirmed that they have no objections to a RFI within Central Beds and/or the proposed Sundon location.
• Huntingdonshire confirmed they do not have any concerns to inclusion of a RFI in principle nor the specific location proposed at Sundon, and that they support the principle of facilitating a RFI as it provides additional opportunities to transport goods by rail and reduce the need for long distance lorry based freight transport which is beneficial for reducing nitrogen dioxide emissions. It was commented that the choice of Sundon as a location for an RFI appears to maximise accessibility to the strategic highway network in CBC in the more urbanised south western part of your area being situated close to the M1, A5 and A6. It would be anticipated that given this southerly location and the fact that it connects to the Midland Mainline rather than the East Coast Mainline which serves Huntingdonshire, it would be sufficiently far removed from the proposed East West rail route not to have an adverse impact on this project in relation to Huntingdonshire.
• Stevenage Borough Council have confirmed that they did not and still does not have any issues or concerns in relation to the proposed allocation of either the RFI itself, or its proposed location at Sundon. In addition, the Borough Council confirmed that Stevenage is not in a position to accommodate a RFI within their administrative boundary and reiterated that they have a shortage of employment land provision and are looking to neighbouring Local Authorities to provide land within their administrative boundaries to meet their needs.

6.3.47. The assessment of alternative options that has been described above, goes some way towards demonstrating exceptional circumstances for the release of Green Belt to meet this need and clearly demonstrates that there is a lack of any reasonable alternatives outside of the Green Belt. The other benefits of providing an RFI are also illustrated in the previous paragraphs (6.3.8 to 6.3.14) - the numerous sustainable, local and environmental benefits that RFI's provide and the economic benefits the RFI and associated strategic employment development would provide to the wider area. The wider community benefits as detailed within paragraphs 6.3.8-6.3.10 above, further support the exceptional circumstances for releasing the site from the Green Belt.

6.3.48. The NPS itself recognises that promoters of strategic RFIs may find that the only viable sites for meeting the need for such facilities are on Green Belt land. The Sundon RFI ASA notes that it is also the case that several Section 78 planning appeals for RFI developments have been progressed at sites around London, all at Green Belt locations, where there has been a need to demonstrate Very Special Circumstances exist in order to justify the grant of permission for inappropriate development in the Green Belt.

6.3.49. Helpfully, these proposals have been the subject of their own site assessment appraisals, that have considered the availability of alternatives. In doing so, they have established a tested and approved methodology for such studies, and whilst it is accepted that each site presents individual characteristics that need to be considered in any appraisal, this precedent provides a clear appreciation of relevant matters and scope of such work.

Post Examination Modification

6.3.50. A modification is proposed to Policy SE1 to confirm that the allocation will contribute to the delivery of the M1-A6 link road. In addition, it will be confirmed that the site will have direct access to M1, Junction 11a via an internal spur from the RFI and a new roundabout.

The INSERTED:land designated for Sundon RFI, as identified on the DELETED:Proposal INSERTED:Policies Map, willINSERTED: provide a Rail Freight Interchange alongside new employment land.

INSERTED:Development proposals will be permitted where they: ….

……

• INSERTED:contribute to the delivery of the proposed M1-A6 link road, including its integral spur to the RFI from its roundabout between the Midland Mainline and Sundon Park Road;

6.4. Marston Gate (Policy SE2)

Overview

6.4.1. As detailed in section 3 above, the Inspectors identified concerns regarding the significant visual impact of the mass, size and type of development proposed on the surrounding network of public footpaths and local landscape character; and the inconsistency between the Employment Site Assessment evidence and the SA in relation to landscape. These are addressed below.

Response to EXAM 69

Inconsistency between the SA and Evidence Base

6.4.2. As noted above in section 6.2, the Inspectors identified within their letter that there were some inconsistencies between the SA findings and the original Site Assessment. In relation to Marston Gate, the inconsistency was identified as being between Councils Employment Site Assessment as detailed within Exam Document ED F02, and the findings of the SA in relation to Landscape.

6.4.3. The Site Assessment process undertaken in relation to the Employment sites was primarily undertaken by Stantec (then PBA) with input from specialist officers within the Council. The elements completed by the Council's specialists included those relating to landscape.

6.4.4. Having reviewed both assessments, it is clear there is a distinct difference in the level at which the assessments have taken place. Employment site assessment provides a very detailed analysis, whereas the SA provides a high-level assessment looking at the principal of development. The assessment undertaken for the employment site assessment is also undertaken by a technical specialist with an overall objective to preserve landscape, as such, it does have a particular emphasis on the negative impacts, with that being the scope of the exercise.

6.4.5. The assessment undertaken within the Supplementary SA, takes a higher level approach to the assessment of landscape impacts and provides an appraisal of the effects of a development on a location. It is also noted that the council's assessment is not based on objectives that have been fully scoped and considered against a robust baseline, as with the SA. Therefore, the approach within the SA is considered to be a more balanced and consistent approach, rather than a restrictive approach.

6.4.6. The SA also considers the potential benefits that could be provided to the location through development, and it is identified within the Supplementary SA Appendix F/G, that in relation to Objective 13: Landscape that the proposed allocation is within the Bedfordshire and Cambridgeshire Claylands National Character Area, and that the statements of environmental opportunity identify the potential to create high quality green infrastructure (identified against SA Objective 5) and landscape regeneration in new development and the need to protect the aquifers and quality of the River Great Ouse. It is identified that development in this allocation is considered overall to support these objectives with the potential for minor long term positive effects against SA Objective 13.

6.4.7. It continues, that the site is within the Salford-Aspley Clay Vale Landscape Character Type and that visually sensitive features in this area includes the views to the Greensand Ridge and Woburn, and landscape sensitive features include hedgerow patterns and remnant areas of deciduous woodland, and that the landscape strategy for the area focuses on conserving the subtle tributary valleys associated with the Great Ouse and enhancement/renewal of the landscape. The SA concludes that development at the site can contribute to the landscape strategy where applicable, with a positive effect although there is some uncertainty in this until master planning has been completed.

SA Findings

6.4.8. In order to contribute to meeting the wider strategic warehousing needs, as previously identified, the Council proposed to allocate land adjacent to the M1 Junction 13 known as Marston Gate.

6.4.9. Having considered this site alongside the others, the Supplementary SA identified that looking across all the SA objectives, the Marston Gate employment site was one of those that performed most strongly.

6.4.10. The SA identifies that the site performs well against a number of Strategic Objectives, including SA objective 4: To support the economy and ensure that there are suitable opportunities for employment as well as SA objective 5: To improve the health and wellbeing of communities and reduce inequalities as the site is identified as being within, or in close proximity to, areas of the strategic green infrastructure network, therefore supporting improved links to the strategic green infrastructure network which could provide employees at the sites with access to open space and recreational areas. This is considered to be a significant positive effect.

6.4.11. The Site also performs well against SA Objective 7: to encourage a demonstrable modal shift to more sustainable forms of transport and reduce the need to travel, where it is identified that these positive effects are likely to be significant for Land at Ridgmont (M1 Junction 13) as the site is in close proximity to railway stations as well as bus stops which benefit from frequent services which can be used by employees travelling to and from the sites.

6.4.12. The Supplementary SA also identifies that the site performs well in relation to SA Objectives 8: To maximise the potential for energy efficiency, reduce greenhouse gas emission and ensure that the built, natural environment and its communities can withstand the effects of climate change; 12: To protect, enhance and manage biodiversity & geodiversity; and 13: To protect and enhance the landscape and townscape.

6.4.13. However, the SA also identifies that the development of this site would have negative effects on two SA Objectives, these being SA objective 11: to protect and conserve soil, and SA objective 14. to ensure the protection and enhancement of heritage assets, the historic environment and its setting.

6.4.14. In relation to Objective 11, the site is considered to have negative effects as it contains some Grade 3 best and most versatile agricultural land and some grade 3 (sub-grade 3a or 3b no known). However, the assessment recognises there is an element of uncertainty attached to the effects recorded, given that the full effects will need to be informed in part by site level surveys.

6.4.15. With regard to SA objective 14, the Supplementary SA identifies that there are limited heritage assets in the employment allocation area and that the nearest Conservation Areas and Listed Buildings to the south of the junction are approximately 1km away. It is noted that there is a Listed Building adjacent to the south of the allocation and approximately 1.5km north of the M1, there is also a Scheduled Monument. It is therefore considered within the SA that development at Marston Gate may have an effect on the setting of the heritage assets, and therefore mitigation measures may be required.

Site Planning Application

6.4.16. An outline planning application for the proposals at Marston Gate was submitted to the Council in December 2018 for the development of up to 166,000 sqm (gross) of storage and distribution facilities (Use Class B8) with ancillary office accommodation; HGV and car parking (including a dedicated lorry park and separate recreational use car park); works to footpaths, cycle routes and bridleways; landscaping, drainage and associated works.

6.4.17. As the application had been submitted to the Council, during the Hearing Sessions, specific details relating to the planning application were raised and discussed. Of particular concern were the height and massing of the proposed buildings within the site as well as the visual impact that the development would have on the local landscape.

6.4.18. The Inspectors noted that most of the proposed allocation is relatively flat running parallel to the M1 and the A507 before the land rises up to the north and east, and that the strategic warehousing proposed would be viewed alongside the existing business park and the infrastructure associated with the M1/A507.

6.4.19. However, the Inspectors also noted that whilst the development of the site would bring about significant economic benefits, there would be significant visual impacts from the surrounding network of footpaths and that in the current proposed form, harm would be caused to the landscape character of the area which would not be mitigated by landscaping alone.

6.4.20. In order to address the Inspectors concerns, the site promotors of the Marston Gate proposals have undertaken a detailed landscape study for the site. The Marston Gate Comparison Document (April 2020) can be viewed in full on the Council's website (EXAM106).

6.4.21. Taking on board the observations of the Inspectors, the document assesses the benefits arising from the adoption of a number of mitigation measures that the site promoters have been identified and are now being proposed. The proposed measures include:

• The use of multi-barrel vaulted roof profiles which replicate those within the existing Marston Gate site (the Amazon, XPO and Dwell units) but with a further softened roof line. This will result in the effective 'visual' height being lower, with reduced eaves and no parapets;
• The use of colour banding and darker shades at lower levels, to add gravitas to the base of the building, with colours lightening up the elevations. The colour palette, which will be agreed with the Council, is proposed to consist of browns, greens and greys to aid with 'tying' the buildings back to the surrounding landscape; and
• The use of targeted off-site planting to aid with mitigating key views in one location where prior agreement has been secured with landowner.

6.4.22. In addition, and in direct response to the concerns that have been identified through the Hearing Sessions, it is proposed that the building heights at the Marston Gate Expansion site are restricted to a maximum of 18.5 metres across the development, with a maximum height of 15 metres in Zone 3, which is the upper most plot within the site. This represents a reduction from that proposed in the current planning application by some 3 metres across the entire site. For clarity, the zones are identified within Appendix 7.2.

6.4.23. The Comparison document states that it is envisaged that this new scheme parameter would be included as a maximum building height in Policy SE2 within the local plan, and the site promoters have confirmed that Prologis would agree to such clarification within an amended policy.

6.4.24. In addition to the above and the updated landscape assessment, the Comparison document provides a revised assessment of the residual effects on heritage assets, with the mitigation outlined above in place. This is appended to the Comparison document and has been provided in the context of the Statement of Common Ground between the Council and Historic England (Sept 2019), dated 31st January 2020 (EXAM 100) and the Historic England objection in principle to SE2. The proposed mitigation detailed above, refers to the following paragraph of the Statement of Common Ground:

'Any future development at SE2 must demonstrate that any negative impacts on the significance of the designated heritage assets identified in this policy, including through development in their settings, have been avoided and if this is not possible, mitigated. Specific details regarding the siting; scale, colour and massing of the buildings and the landscaping scheme will be agreed through a site-specific Design Code'

6.4.25. The Council considers the mitigation being proposed by the site promoters would be of significant benefit in relation to reducing the visual impacts of the scheme and the allocation performs well in terms of the Supplementary SA work. Whilst the SA identifies that in relation to SA Objective 14, the proposal may have an effect on the setting of the heritage assets, it is considered that the economic benefits of the proposals outweigh any potential harm.

Post Examination Modification

6.4.26. Modifications will be proposed to Policy SE2 which identify maximum building heights across the allocation as well as the measures outlined above to ensure the visual impact of the development is limited and mitigated where possible.

6.4.27. In addition, modifications would be proposed in line with the Statement of Common Ground as agreed with Historic England.

6.5. Holme Farm (Policy SE3)

Overview

6.5.1. As detailed in section 3 above, the Inspectors identified concerns regarding the contrived site boundary, sustainability of the proposed site in relation to sustainable transport, including pedestrian and cycle access; the visual impact of development on the landscape and the nature of strategic employment attracting workers from further afield and not applying a jobs uplift to the housing requirement. These are addressed in turn below.

Response to EXAM 69

6.5.2. The Council is keen to ensure that the strategy set out within the local plan delivers choice and variety in the area's employment land portfolio to support the growth of the local economy as well as helping to meet needs relating to strategic warehousing. To this end, Holme Farm has been identified by the Council as one of the locations able to help meet strategic needs, which, as outlined above, will also contribute to preventing the displacement of employment opportunities identified to meet local needs.

Inconsistency between the SA and Evidence Base

6.5.3. As noted above, the Inspectors identified within their letter that there were some inconsistencies between the SA findings and the original Site Assessment. In relation to Holme Farm, the inconsistency was identified as being between the Council's Employment Site Assessment as detailed within Exam Document ED F02, and the findings of the SA in relation to Landscape. This is considered to be due to the very detailed, criteria-based assessment of one, and the higher-level assessment of effects of the other.

6.5.4. The Site Assessments, as detailed within Exam Document ED F02, were undertaken using very specific criteria. In relation to sustainable transport, this included specific distances from the town centre, train station and closest bus stops. Based upon this very specific criteria, which was RAG rated, the proposed site at Holme Farm scored 2 Reds, an Amber and a Green.

6.5.5. However, the assessment undertaken within the Supplementary SA, takes a higher level approach to the assessment of sustainable transport and provides an appraisal of the effects of a development on a location. Therefore, the approach within the SA is considered to be a more balanced approach rather than a strict, criteria-based approach. It has also been consistently applied across all employment sites that have now been assessed within the Supplementary SA.

6.5.6. The SA considers the proximity of the site to Biggleswade and the services and facilities available as well as the potential effects for example, the Supplementary SA Appendix F/G identifies in relation to Objective 7: Sustainable Transport, that the site is within close proximity to the station and that development has the potential to extend existing bus services to enhance sustainable transport connections between the site and railway station thus encouraging a modal shift and enhancing the potential positive effects.

6.5.7. It is further identified that development can contribute to Cycle Route 12, which connects with Biggleswade railway station, and have cumulative positive effects on sustainable transport. There are also opportunities to retain and enhance existing public rights of way routes within the site allocation, with associate positive effects.

6.5.8. The location adjacent to a major settlement in the Plan area also reduces the need to travel for many potential employees. However, the location is separated by the A1 and would require infrastructure in the form of a bridge or underpass to access the town and railway station, so uncertainty at this stage.

SA Findings

6.5.9. The Supplementary SA identifies that the site performs well against a number of Strategic Objectives, including SA Objective 4: To support the economy and ensure that there are suitable opportunities for employment, as well as Objective 5: To improve the health and wellbeing of communities and reduce inequalities, as the site is identified as being within, or in close proximity to, areas of the strategic green infrastructure network, therefore supporting improved links to the network which could provide employees at the sites with access to open space and recreational areas. This is considered to be a significant positive effect.

6.5.10. The Site also performs well against SA Objective 7: to encourage a demonstrable modal shift to more sustainable forms of transport and reduce the need to travel, where it is identified that these positive effects are likely to be significant for Holme Farm, as the site is in close proximity to railway stations as well as bus stops which benefit from frequent services which can be used by employees travelling to and from the sites.

6.5.11. The Supplementary SA also identifies that the site performs well in relation to Objectives 8: To maximise the potential for energy efficiency, reduce greenhouse gas emission and ensure that the built, natural environment and its communities can withstand the effects of climate change; 12: To protect, enhance and manage biodiversity & geodiversity; and 13: To protect and enhance the landscape and townscape.

6.5.12. However, the proposed site at Holme Farm is considered to have a negative impact in relation to Objective 11, to Protect and Conserve Soil; as the site contains Grade 1 and Grade 2 best and most versatile agricultural land. Therefore, it is considered there is the potential for a long-term major negative effect on soil resources. Whilst the potential loss of high-quality soils would be avoided where possible, the Council considers that the wider economic benefits, the proximity of the proposed site to the strategic road network and other factors outlined below, outweigh the impacts.

Land supply update

6.5.13. In addition to the above, as discussed in Section 5 of this paper, updated monitoring information taken into account in the Employment Land Update (ELU) also illustrates the supply of land to meet local needs has been reduced to the level where it could now be demonstrated that additional sites to meet local needs (over and above those allocated for mixed use) are required. In general terms, due to the time it takes to deliver a new Local Plan, it is inevitable that changes in circumstance will occur during the process. A pragmatic approach must be taken to considering any new information and a line must be drawn in terms of what can realistically be taken into account, within the Local Plan and the accompanying SA, without continually reviewing evidence and updating strategies. However, because of the Council's proactive approach in seeking to allocate additional employment sites to meet a regional need, this does present an opportunity to realign the provision to meet this need (an additional 27ha).

6.5.14. The recent Coop permission at Stratton Business Park has resulted in a lack of available land at this location and along the A1 corridor within Central Bedfordshire as a whole, to deliver local employment needs, which has contributed to this recently identified shortfall. As the Employment Land Update indicates that there is strong demand within this location, it suggests that the shortfall in meeting local employment needs could be met at Holme Farm, with the site delivering both strategic warehousing as well as B use supply to meet more local needs based upon market demand.

6.5.15. As such, a more flexible approach is proposed to ensure both of these needs are met at Holme Farm which will include identifying within Policy SE3 the need to deliver both strategic and local employment opportunities, based on Market Demand.

6.5.16. In order to address the Inspectors specific concerns, the site promotors of Holme Farm have produced a Planning, Design and Delivery Analysis report (PDDA). The Holme Farm PDDA (April 2020) can be viewed in full on the Council's website (EXAM 108).

Site Boundary

6.5.17. In relation to the 'contrived' boundary as identified by the Inspectors, the boundary of the Holme Farm site has been increased by 15ha to a total area of 77ha and now includes additional land that is within the ownership of the Council. The additional 15ha does not increase the amount of floorspace that will be delivered within the site but provides for a more logical boundary and provides the additional land the site promotors require in order to assist in addressing sustainable transport and landscaping concerns identified by the Inspectors.

6.5.18. As set out within the PDDA, the site has been increased along the eastern boundary adjacent to the A1, and the additional land within the boundary is proposed for the following:

• an extension of the Biggleswade Green Wheel corridor northwards which can be used as a gateway to the site for pedestrians arriving from the west on the new footbridge which is proposed to across the A1;
• retention ponds to serve the development;
• a terminus for the shuttle bus service which will be provided for the site; and
• a small retail outlet to serve the development.

Sustainable Access

6.5.19. In relation to the Inspectors concerns about the sustainability of the location in terms of access to the site by workers, the site promoters have enhanced existing proposals and identified additional access opportunities that will enable workers to access the site sustainably through a variety of transport options. The PDDA includes a transport and movement strategy analysis and identifies a number of recommendations which includes a comprehensive network of footpaths and cycle links to ensure that the development is suitably connected to Biggleswade and the following key areas:

• via the existing 'Green Wheel' and new footbridge which is proposed across the A1 to the employment area immediately to the east of the site and then connecting northwards along existing footpaths in Stratton Park, Saxon Road and London Road towards Biggleswade town centre;
• via the existing 'Green Wheel' pedestrian and cycle route which uses the subway (which is proposed to be upgraded as part of the scheme proposals) and connects the north of the site to Windermere Drive housing area and then via Dells Lane towards Biggleswade; and the 'Green Wheel' cycle route along Holme Court Avenue to the south of Biggleswade;
• via the existing 'Green Wheel', pedestrian and cycle route eastwards across the railway level crossing (with opportunity to be replaced by a bridge) and onwards past the nearby rugby pitch to Jordan's Mill and beyond towards Biggleswade.

6.5.20. It is also proposed to provide a shuttle bus service for those working in and visiting the new development. This will take staff and visitors from the train station within Biggleswade to and from the site as well as to the retail park. It is anticipated that services will operate every hour in each direction between 6am and 10pm during weekdays and services could be increased at peak times as the site is built out. A reduced service would also be provided at weekends.

6.5.21. Journeys are to be provided free of charge and covered by the service charge, or at least part thereof, and sustainable options including electric buses will also be considered.

6.5.22. It is proposed that the shuttle bus terminus will be located close to the proposed pedestrian footbridge at the eastern entrance to the site and adjacent to the 'Green Wheel' pedestrian / cycle network where there will also be an opportunity for an outdoor recreational and retail outlet providing a range of facilities including bike hire and other recreational pursuits.

Visual Impact

6.5.23. With regard to the visual impact of the proposed development on the local landscape and Biggleswade, it is identified within EXAM 69 that the northern section of the proposed allocation is reasonably well located to Biggleswade and would be viewed in the context of the existing industrial buildings on Stratton Business Park to the east and the wind farm to the south and west of the site. It is considered however, that the remainder of the site would extend the main built-up area of Biggleswade and that the size and shape of the allocation would result in visually prominent development that would fail to integrate with the form and character of Biggleswade.

6.5.24. To address these issues, the site promoters have undertaken a Landscape and Visual Impact Assessment, which is set out in detail within the PDDA. This highlights the potential adverse impacts that could arise from the development of different options within the site and highlights the revisions that would be required to the configuration and layout to show how mitigation measures could be used effectively.

6.5.25. The PDDA continues to identify a number of landscape and visual design principles that have been identified to show how the proposed scheme can be enhanced in landscape terms and reduce the visual impact:

• The retention of Category A and B trees and existing woodland located to the west, just outside the proposed site allocation;
• The need to maintain hedgerows where feasible, and trees that have biodiversity potential;
• The need to protected species (e.g. badgers) as there are several setts on site/bats/ great crested newts due to the ponds in proximity and ditches;
• The provision of a landscape amenity area and ecological park with water feature;
• Character features including a natural woodland edge extending from the existing area of woodland;
• Landscape planting using native species;
• A primary green link, centred on the Biggleswade Green Wheel, with improved surfacing connecting to a number of secondary green links which separate the 4 separate phases of development;
• Landscape focal points at the entrance to the scheme;
• Boulevard planting along the estate roads and amenity planting along pedestrian routes and around areas of car parking; and
• A landscape buffer between the A1 to screen views of the proposed development.

6.5.26. In addition, the PDDA identifies a number of design measures relating to the future buildings that will occupy the site, in terms of scale, massing and treatment of elevations. The design principles identified are:

• Consideration of roof profiles (flat, curved or pitched), colours / materials and opportunity for photovoltaics;
• Strategy for the location, size and height of the proposed buildings to carefully reflect the topography of the site;
• An in-principle requirement to locate the buildings with the larger floorplates and likely requirements for higher eaves heights (and therefore overall building heights) on the lower lying land where there is a reduced level of visual impact and where landscape mitigation measures can be more easily introduced; and

6.5.27. An in-principle requirement to ensure that the scheme can accommodate the larger buildings which for operational reasons require eaves heights of between 18 – 19m and ridge heights which will be typically up to 3 or 4metres higher. This will produce overall building heights of between 21m – 23m. The details of the above would be reflected within the Policy and the details of the principles outlined would be agreed with the Council during the planning application process.

6.5.28. In relation to attracting workers from further afield and not applying a jobs uplift to the overall plan housing requirement, as previously identified, the ELR (ED C08) identified the need for footloose warehousing and distribution sites to be located adjacent to the strategic transport network, and that this would enable such sites to be more accessible to future employees from further afield.

6.5.29. Siting on major roads, strategic sites such as Holme Farm are by their very nature highly accessible sites and as warehouses often operate in shifts, commuting is often off-peak and with fewer travel restrictions, the labour catchment is larger than it would be for non-strategic uses.

6.5.30. It is therefore considered that whilst the workforce is likely to drawn from Central Bedfordshire, the location of the site on the A1 could also provide employment opportunities for those who live outside Central Bedfordshire within neighbouring areas.

6.5.31. Examination Note EXAM 33 'Population, Housing & Employment' (July 2019) explains the relationship between Jobs and available workforce and how this balances with the planned housing growth within Central Bedfordshire. This concludes that there is no requirement to uplift the housing requirement for Central Bedfordshire based upon the proposals for meeting strategic warehousing needs within the area.

Post Examination Modification

6.5.32. Modifications will be proposed to the boundary of Policy SE3 and the site area increased slightly to provide a more appropriate and logical boundary to the proposed allocation and in order to accommodate a new footbridge across the A1 to Stratton Park as well as additional environmental enhancements, planting and landscaping.

INSERTED:The land designated for Holme Farm, as identified on the DELETED:Proposal INSERTED:Policies Map, willINSERTED:provide new employment floorspace.

INSERTED:Development proposals will be permitted where they:

1. provide DELETED:for up to DELETED:60 INSERTED:77 hectares of new employment land INSERTED:to accommodate strategic warehousing and local employment opportunities, comprising INSERTED:approximately 25ha of mixed B1, B2 B8 uses and another 30ha of B8 strategic floorspace; 15ha for landscaping, environmental enhancements and sustainable access; and up to 8ha for a petrol filling station and service uses, to include a shop that will enable the purchase of goods and refreshments by those employed at the new allocation;

2. deliver necessary improvements to the A1 and A1 roundabout providing appropriate access to the site;
3. provide INSERTED:a new footbridge over the A1 providing access to the services and facilities within the Stratton Park employment and retail area opposite;
4. provide appropriate landscaping and contribute to the GI network, specifically in relation to the Biggleswade Green Wheel, INSERTED:including improvements to existing footpaths within the allocation providing greater pedestrian and cycle access between Biggleswade and the site via Windermere Drive;
5. provide opportunities for sustainable transport links to be determined through a Transport Assessment, INSERTED:including the provision of shuttle buses to serve the new development from the train station at regular intervals during the working week as well as during the weekend;
6. deliver INSERTED:strategic measures to reduce flood risk including the use of SUDS to attenuate and discharge surface water run-off at reduced rates and at least at a rate no greater than if the site were undeveloped and to reduce existing downstream risk. This may include consideration of off-site solutions;
7. INSERTED:do not prejudice the operation of the neighbouring wind farm; and
8. Protect INSERTED:mature woodland located within the site from development and enhance it by appropriate, sensitive landscaping.

6.6. RAF Henlow

Overview

6.6.1. The Inspectors raised concerns around postponing a decision on the future of RAF Henlow, risking the site becoming vacant with no positive strategy for its reuse.

Response to EXAM 69

6.6.2. This site was initially included within the plan as an allocation for 85ha for specialist high-technology, science, research and development uses. This was to meet site particular requirements that two proposed occupiers specifically required and which at the time, were considered by the proposed occupiers, to be foreseeably unavailable elsewhere. A further 45ha was proposed for a mixed-use, visitor-economy and residential scheme.

6.6.3. As the local plan progressed towards Submission, unfortunately due to circumstances beyond the Councils' control, the two occupiers withdrew their interest in the site, and it was no longer considered viable for its intended use. During the Hearing Sessions, it was therefore proposed that the allocation be removed from the plan, to be considered as part of the planned partial plan review when a new, recently introduced residential-led scheme could be considered in greater detail alongside the required appropriate evidence base.

Supplementary SA

6.6.4. Whilst the RAF Henlow site was included within the local plan for specialist employment uses, the site was originally submitted to the Council through the Call for Sites (2016) for consideration as a residential led mixed-use site.

6.6.5. As such, it was considered that the site should be included within the Supplementary SA as a reasonable alternative. As the site was considered within the Regulation 18 Stage Sustainability Appraisal for the delivery of 1,000 new homes, as part of a residential-led mixed use scheme, for consistency, this is the level of growth that has been considered within the Supplementary SA.

SA Findings

6.6.6. Having considered the site at Henlow, the Supplementary SA identifies that the proposed site would perform positively in relation to three SA Objectives. These include SA objective 1: to ensure that the housing needs of all residents and communities are met, as it is expected that all sites would benefit a range of residents given that Local Plan policy on Housing Mix requires new development to provide an appropriate mix of housing types, tenures and sizes; SA objective 3: to improve accessibility to services and facilities as the site could support the delivery of new services and facilities within Central Bedfordshire which would help meet the needs of both new and existing residents; and SA objective 5: to improve the health and wellbeing of communities and reduce inequalities, as the proposed site would fall within, or is in close proximity to, areas of the strategic green infrastructure network which could help to support the incorporation of multi-functional green infrastructure as new development occurs.

6.6.7. However, the SA also identifies that development of this site would have negative impacts in relation to SA Objective 11, to Protect and Conserve Soil; and SA Objective 14; to ensure the protection and enhancement of heritage assets, the historic environment and its setting.

6.6.8. In relation to SA Objective 11, the Supplementary SA identifies that whilst much of the land within the Henlow site is within the non-agricultural classification, there is some Grade 2 best and most versatile agricultural land within the site boundaries to the north as well as some Grade 3 agricultural land (sub-grade 3a or 3b not known) to the north west. Potential significant negative effects are therefore identified in relation to the first part of the SA Objective, although it is also states that there is an element of uncertainty attached to this until specific proposals for the sites come forward, and because the available data does not distinguish between Grade 3a and Grade 3b land (only Grade 3a land and above is considered to be high quality).

6.6.9. RAF Henlow is, however, expected to have a minor positive effect in relation to the second element of SA Objective 11, as while the site contains mostly greenfield land, it has a history of uses which could result in land contamination. Therefore, development of this site could help promote the remediation of contaminated land in Central Bedfordshire to the benefit of soil quality. It is also identified that development at RAF Henlow would also likely result in the reuse of some previously developed land.

6.6.10. In relation to SA Objective 14, the site at Henlow is identified within the Supplementary SA as containing designated heritage assets. It states that development at this site is considered to have potential for particular harm on these heritage assets or their respective settings and that therefore, a significant negative effect on this objective is expected.

6.6.11. Whilst overall, the site at Henlow performed well against the SA Objectives, the site is not proposed to be taken forward as an allocation within the local plan at this time. The reasons for this are set out below.

6.6.12. In addition to the above findings in relation to the SA Objectives, the Supplementary SA also identifies that the Henlow site is located within Area D – one of the four areas identified across Central Bedfordshire, recognising the areas individual characteristics.

6.6.13. Area D is the central section of Central Bedfordshire and is considered to be the most rural in nature and lest well-connected. In relation to Area D, the Supplementary SA identifies:

Area D performed poorest of all the Areas in the SA, as the area offers the potential only for smaller-scale development which would not deliver, or provide access to, as wide a range of services, facilities and infrastructure.

The appraisal of Area D showed that it is generally a less sustainable location for development compared to Areas A-C due to the limited potential for large-scale development. The appraisal of alternative approaches to development growth reinforced this, showing that smaller new settlements or village extensions provide less good opportunities for incorporating services, facilities and job opportunities and therefore do not tend to result in the more self-contained settlements resulting from larger new developments. Area D is also less well-connected than the other areas in transport terms.

6.6.14. At the current time, the site is still in active use as an Airbase and is not proposed to be vacated / decommissioned until at least 2023 at the earliest. Whilst the site promotors have recently identified the potential for a residential-led scheme to come forward in the future, no specific scheme has been formerly submitted to the Council and the Council does not have the confidence at the current time, that any meaningful level of development will be achievable within the plan period due to a significant number of constraints both within and adjoining the site. The Council, therefore, does not consider the site could be allocated at this time.

6.6.15. The local Parish Council consider elements of the existing uses in terms of buildings and infrastructure to be of significant local and historical value and have expressed grave concerns over the impact of their loss, not only in relation to their historic value but also in terms of the impact such losses would have on the character and form of Henlow. The Parish Council has very strong views regarding the retention, reuse and enhancement of several buildings and structures within the current airbase as well as the retention of the character and layout of the existing uses. This view is also reflected within the Historic England publication (2003) 'Historic Limitary Aviation Sites Conservation Guidance' which identifies that:

The five general service sheds at Henlow comprise the most complete ensemble of hangar buildings on any British site for the period up to 1923. The domestic site retains an extensive group of married quarters, built in the Garden City tradition, and barracks and office buildings that date to 1933-5. These display a unique architectural treatment for a military air base.

6.6.16. Both the Council and the Local Parish Council also wish to retain the airfield within the current airbase as an open space and potentially as an active airfield. The airfield is of significant local historical importance as well as being of environmental value. These attributes would have been maintained had the initial allocation been taken forward within the plan due to the nature of the intended use of the site.

6.6.17. In addition to the above, it is considered that there is insufficient evidence to date which would enable a viable development to take place at a reasonable scale so as to help meet the residential growth aspirations of the Council, without having a significantly detrimental impact upon an important, existing employer which is immediately adjacent to the site. The nature of the employer's business and the requirement for safety areas surrounding them, would severely limit the growth potential of the site as well as place strict transport and traffic restrictions on the immediate road network, impacting upon the accessibility and movement of any future residents and occupiers.

6.6.18. Whist the Council is supportive of growth across Central Bedfordshire, it would not wish such growth to be to the detriment of existing occupiers or to result in a long-established, valued employers having to relocate or leave Central Bedfordshire, resulting in a negative impact upon the local economy.

6.6.19. Whilst some limited technical evidence has been produced by the site promoters, the high-level transport modelling that has been provided identifies that some limited development may be able to be accommodated within the site without detrimentally impacting upon the neighbouring business and the local road network, but no evidence has been provided to indicate the cumulative transport impact and subsequently required mitigation, if at all possible, on the A507 and A600 of further growth within RAF Henlow alongside that which will arise following the delivery of sites that are proposed for allocation within the plan as well as those sites that will come forward in close proximity to the site within North Hertfordshire.

6.6.20. The Council is of the view that there is limited information available about the amount of growth that could be accommodated within the site as well as the cumulative impact of the site on the local area given the scale of growth already proposed. As previously noted above, at the current time, the Council does not consider RAF Henlow as an option for allocation at this time.

6.6.21. Whilst it is considered that there is insufficient evidence at this time to support an allocation within the current plan, the council is keen to ensure that future opportunities are not missed and as such will continue to work with the site promoters and Homes England to support potential future development proposals, to be considered within the planned partial review of the local plan.

Post Examination Modification

6.6.22. A modification has been proposed to remove the current proposed allocation from the plan.