Sustainability Appraisal Main Modifications Report

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Chapter 2 - Methodology

Introduction

2.1 SA is an iterative process that aims to provide a high level of protection for the environment and to promote sustainable development in plan-making. The role of SA is to inform the Council as the planning authority; the SA findings do not form the sole basis for decision-making – this is informed also by other studies, feasibility and feedback comments from consultation. SA is a criteria-based assessment process with objectives aligned with the issues for sustainable development that are relevant to the plan and the characteristics of the plan area.

2.2 The sections below describe the approach that has been taken to the SA of the Central Bedfordshire Local Plan to date.

SA Stage A: Scoping

2.3 In January 2016 independent consultants Enfusion Ltd. were commissioned by CBC to undertake the SA of the Local Plan. The first stage was to carry out the Scoping process. Relevant plans and programmes were reviewed and baseline information was collated and analysed to ensure that key issues, problems and opportunities for the plan area were identified.

2.4 The Scoping stage also involved the development of the SA framework. This provides the basis by which the sustainability effects of the Local Plan can be described and evaluated and options compared. It includes a number of objectives with associated decision-making criteria, that are relevant to the objectives of the Local Plan and sustainable development in Central Bedfordshire. These objectives were identified at the Scoping stage from the information collated in the review of plans and programmes, baseline analysis, identification of sustainability issues, and Scoping workshops that were held with Council officers and key stakeholders.

2.5 Two versions of the SA framework (strategic and sites) were developed. The strategic SA framework is presented in Table 2.2 below and was used to test strategic options emerging from plan-making, including the growth scenarios for distributing new development. The strategic SA framework was then refined to make it more relevant and effective for the consideration of site options that are location-specific – the sites SA framework is presented in Table 2.3. It sets out the standards and thresholds that have been used to determine the nature and significance of effects against SA Objectives, including any assumptions to be made or uncertainties that exist. Enfusion worked closely with CBC to develop these standards and thresholds to determine the nature and significance of effects against each SA Objective. This helped to ensure that a consistent appraisal of reasonable alternative site options is carried out.

2.6 The categories of significance used within both SA frameworks are as set out in the key below (Table 2.1).

2.7 The tasks undertaken during the Scoping stage of the SA were presented in the draft SA Scoping Report (June 2016) which was published for consultation. After the responses received were reviewed and addressed, the final SA Scoping Report (October 2016) was published. As a result of consultation comments received, some refinements were made to the decision-aiding questions supporting the SA Objectives in the SA framework (these are reflected in Table 2.2).

2.8 The policy review and the analysis of baseline information and key sustainability issues have been repeated and updated in the SA reports prepared since then, including most recently in Chapter 3 of this report.

Table 2.1: SA significance key

Categories of Significance of Effects

Symbol

Meaning

Sustainability Effect

++

Significant positive

Proposed development encouraged as would resolve existing sustainability problem

+

Minor positive

No sustainability constraints and proposed development acceptable

0

Neutral

Neutral effect

?

Uncertain

Uncertain or unknown effects

-

Minor negative

Potential sustainability issues: mitigation and/or negotiation possible

--

Significant negative

Problematical and improbable because of known sustainability issues; mitigation likely to be difficult and/or expensive

SA Objectives 2, 4, 5, 9 & 11 consider more than one sub-topic such that more than more than one significant effect may be predicted with two symbols:

  • No. 2 Communities – first symbol refers to in/out of Green Belt; second symbol refers to community & settlement identities.
  • No. 4 Employment – first symbol refers to employment support; second symbol refers to vitality/viability of town centres.
  • No. 5 Health & Equality – first symbol refers to regeneration/deprivation & equality; second symbol refers to green infrastructure for health & well-being.
  • No. 9 Water – first symbol refers to water resources; second symbol relates to water quality.
  • No. 11 Soil & Land – first symbol refers to greenfield & agricultural land qualities; second symbol relates previously developed land.


Table 2.2: Strategic SA Framework

Topic

SA Objectives

Decision Aiding Questions

Communities

SEA Directive Topic(s): Population and Human Health

NPPF Paragraphs: 47-78[6]

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

  • Does the option provide sufficient housing to meet the identified needs of all communities within the Plan area?
  • Does the option provide an appropriate mix of types of housing to meet the identified needs of all communities within the Plan area?
  • Does the option offer the opportunity to help meet housing needs arising from outside the Plan area?

  1. To maintain and enhance community and settlement identities.

  • Is the option likely to have an effect on the identity of any communities or settlements? For example, will development lead to coalescence?
  • Will development result in the loss of Green Belt land?
  • Can development effectively integrate within the existing settlement pattern?
  • Are there any opportunities to enhance the identity of a community or settlement?

  1. To improve accessibility to services and facilities[7].

  • Does the option ensure that a sufficient level of services/facilities will be delivered to meet the identified needs of all communities within the Plan area, or will development result in a net gain in the level of services/facilities?

Economy and Employment

SEA Directive Topic(s): Population and Human Health

NPPF Paragraphs: 18-22

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

  • Does the option provide sufficient high quality employment land to meet the identified needs of all communities within the Plan area?
  • Are there a range of types of employment land being proposed?
  • Does the option provide sufficient safeguarding for existing employment land in the Plan area?
  • Does the option offer the opportunity to support and enhance the vitality and viability of Town Centres, in particular Dunstable Town Centre?
  • Would the option result in the loss of any existing strategic employment opportunities?
  • Does the option regenerate or provide employment opportunities in areas that are currently experiencing high rates of unemployment?
  • Does the options provide opportunities to enhance the provision of education and training facilities?

Health and Equalities

SEA Directive Topic(s): Population and Human Health

NPPF Paragraphs: 69-78

  1. To improve the health and wellbeing of communities and reduce inequalities.

  • Does the option offer the potential for investment, regeneration or renewal in areas of higher deprivation?
  • Does the option offer opportunities for protected or special groups of the community, including the ageing?
  • Does the option result in the loss of any significant areas of green infrastructure, open space or recreation for people?
  • Will the option result in a net gain in green infrastructure, open space and recreational areas for people, or improve the quality of these provisions across the Plan area?

Transport and Movement

SEA Directive Topic(s): Population and Human Health

Economy and Employment

NPPF Paragraphs: 29-41

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

  • Is the option likely to increase levels of traffic, and is this in an area already experiencing congestion issues?
  • Does the option offer an opportunity to enhance or improve the existing network?
  • Does the option support or enhance local ambitions for transport?

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

  • Does the option offer an opportunity to improve access to and quality of sustainable transport modes for all communities, to allow sustainable movement not only within Central Bedfordshire but into the surrounding areas?
  • Does the option offer an opportunity to support the delivery of proposed transport infrastructure, such as the East West Rail Link?
  • Does the option support or enhance local ambitions for transport?

Air Quality

SEA Directive Topic(s): Air

NPPF Paragraphs: 109-125

Air quality within Central Bedfordshire is closely linked to road traffic. This is demonstrated by the designation of the three AQMAs which cover areas where the road network is currently congested.

Given the close relationship between traffic and air quality, it is not considered necessary to have a separate SA Objective specifically relating to air quality. For example, positive effects against SA Objectives 6 and 7 are likely to result in a positive indirect effect on air quality; equally, negative effects are likely to result in negative indirect effects on air quality. Mitigation provided through Local Plan policies and at the project level to reduce traffic impacts, such as improving access to sustainable transport modes will also help to mitigate impacts on air quality.

Energy and Climate Change[8]

SEA Directive Topic(s): Climatic Factors

NPPF Paragraphs: 93-104

  1. To maximise the potential for energy efficiency, reduce greenhouse gas emission and ensure that the built and natural environment and its communities can withstand the effects of climate change.

  • Does the option offer an opportunity to improve access to and quality of sustainable transport modes for all communities, to allow sustainable movement not only within Central Bedfordshire but into the surrounding areas?
  • Does the option offer an opportunity to support the delivery of proposed transport infrastructure, such as the East West Rail Link?
  • Does the option support or enhance local ambitions for transport?

Water: Resources, Quality and Flooding

SEA Directive Topic(s): Water

NPPF Paragraphs: 99-125

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

  • Is the option likely to have an effect on water resources?
  • Is the option likely to have an effect on water quality?

  1. To reduce the risk of flooding from all sources.

  • Does the option direct development towards lower flood risk areas?[9]
  • Are there any opportunities to significantly reduce flood risk?
  • Does the option safeguard land to manage flood risk?
  • Does the option promote the use of sustainable drainage systems?

Soil and Land

SEA Directive Topic(s): Soil

NPPF Paragraphs: 79-92, 109-125

  1. To protect and conserve soil.

  • Is the option likely to result in the loss of greenfield land?[10]
  • Is the option likely to result in the loss of agricultural land, in particular best and most versatile agricultural land?[11]
  • Does the option provide an opportunity for the reuse or regeneration of previously developed land?

Biodiversity and Geodiversity

SEA Directive Topic(s): Biodiversity, Flora and Fauna

NPPF Paragraphs: 109-125

  1. To protect, enhance and manage biodiversity & geodiversity.

  • Is the option likely to have an effect on any nationally or locally designated sites?
  • Could the option result in the loss or fragmentation of important GI for biodiversity or ecological corridors as identified in the Nature Conservation Strategy (2015)?
  • Are there any opportunities to enhance biodiversity & geodiversity, or provide a net gain?

Landscape and Townscape

SEA Directive Topic(s): Landscape

NPPF Paragraphs: 109-125

  1. Protect and enhance the landscape and townscape.

  • Is the option likely to have an effect on a nationally or locally designated landscape, townscape or its setting?
  • Is the option likely to have an effect on the overall rural landscape character?
  • Is there an opportunity to regenerate previously developed land or restore derelict sites such as disused market gardens, former quarries or pits?[12]

The Historic Environment

SEA Directive Topic(s): Cultural Heritage

NPPF Paragraphs: 126-141

  1. To ensure the protection and enhancement of the historic environment and its setting.

  • Is the option likely to have an effect on a nationally or locally designated heritage asset and/or their settings?
  • Is the option likely to have an effect on any important or protected non-designated heritage assets and/or their setting or any potential archaeology?
  • Are there any opportunities for enhancement of the historic environment and its setting?

Minerals and Waste

SEA Directive Topic(s): Material Assets

NPPF Paragraphs: 5, 142-149

The adopted Minerals and Waste Local Plan sets out the strategic allocations for mineral extraction and for waste management development in the Plan area (Bedford Borough, Central Bedfordshire and Luton Borough) together with strategic policies which will guide the ongoing supply of minerals and development of waste management facilities. The adopted Minerals and Waste Local Plan was subject to SA.

At this stage, it is not considered that there are any significant sustainability issues within Central Bedfordshire in relation to Minerals and Waste. While development proposed through the Central Bedfordshire Local Plan will affect this topic, it is considered that these effects are unlikely to be of significance. This topic is unlikely to play a significant role in the identification and refinement of alternatives. Taking the above into account, this topic has therefore been scoped out of the SA process for the Local Plan.

It is important to note that the Waste and Minerals Plan is in the process of being reviewed and as part of that process further SA work will be carried out. As part of the iterative and ongoing SA process, should any significant issues or effects arise that need to be considered through the SA process for the local plan then they will be taken into account.


Table 2.3: Sites SA Framework

Topic

SA Objective

Significance criteria, including any assumptions, uncertainties, standards and thresholds for SA of Site Options

Communities

SEA Directive Topic(s): Population and Human Health

NPPF Paragraphs: 47-78

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

SA Objective 1 primarily relates to the provision of an appropriate quantity and quality of housing to meet the needs of all residents and communities in Plan area.

The SA assumes that development at any of the site options could be delivered to a high quality and could provide an appropriate mix of housing types and tenures.

The nature and significance of the effects against this SA Objective will relate to the potential capacity of the site to accommodate residential development.

Evidence base:

The Council's site assessment process, in particular the proposed use and estimated housing capacity of the site, will inform the assessment of effects against this SA Objective.

++

The site option has the potential to provide a significant amount of new housing (500 dwellings or more)

+

The site option has the potential to provide a significant amount of new housing (500 dwellings or more)

0

The site option has the potential to provide a significant amount of new housing (500 dwellings or more)

?

There is an element of uncertainty as the capacity of the site option for housing development is unknown.

-

Not applicable.

--

Not applicable.

  1. To maintain and enhance community and settlement identities

SA Objective 2 primarily relates to the nature and character of settlements that give them distinct and individual identities, and retaining and enhancing these identities whilst accommodating growth needs.

Evidence base:

The Council's site assessment process will inform the assessment of effects against this SA Objective. In particular criteria 13, 18, 19, & 24 of the Council's Site Assessment Framework for Housing Sites; criteria 11, 16, 17 & 19 of the Council's Site Assessment Framework for Employment Sites and criteria 11, 16, 17 of the Council's Site Assessment Framework for Gypsy and Traveller Sites.

++

The site option relates well to an existing settlement (within settlement envelope or bordered by settlement on 3 sides) Evidence suggests that development at the site option could significantly enhance the identity of the settlement, with the potential for major positive effects.

+

Development at the site option may positively contribute to the identity of settlements, for example through the regeneration of previously developed land that is currently detracting from the character of the settlement.

0

Development at the site option will not contribute towards coalescence and is unlikely to affect the overall character of the settlement. Potential for a residual neutral effect.

?

There is an element of uncertainty, most likely until lower level assessments have been carried out.

-

Development at the site option is likely to contribute towards coalescence and / or erode settlement identity.

--

The site option is located within the Green Belt, or development at the site option will directly lead to coalescence.

  1. To improve accessibility to services and facilities.

SA Objective 3 relates to the ability of communities to sustainably access the services and facilities they require to meet their needs.

The SA assumes that any proposal for development can make appropriate and timely provision or contributions for necessary supporting infrastructure, including community facilities and services.

The nature and significance of the effects against this SA Objective will relate to the distance of the site from existing services/ facilities.

The Council considers key facilities/services to include schools (primary and secondary), GP surgery/medical centre & retail provision (Town Centre/ Local Centre).

The SA assumes that larger strategic development options have greater potential for enhancements to existing provisions.

However, this will not have an impact on the nature and significance of the effect against this SA Objective. This will be a consideration through the Council's wider site assessment process.

Evidence base:

The settlement audit and Council's site assessment process will be used to inform the assessment of effects against this SA Objective. Reasonable walking distance informed by the Department for Transport (2007) Manual for Streets. Barriers to movement informed by the Council's Site Assessment Framework for Housing criterion 6.

++

The site option is located within reasonable walking distance (within 800m) of all key services and facilities.

+

The site option is located within reasonable walking distance (within 800m) of most of the key services and facilities.

0

A neutral effect is not considered possible.

?

There is an element of uncertainty, most likely until lower level assessments have been carried out through planning applications.

-

The site option is located beyond reasonable walking distance (over 800m) of most of the key services and facilities.

--

The site option is located beyond reasonable walking distance (over 800m) of all key services and facilities.

Economy and Employment

SEA Directive Topic(s): Population and Human Health

NPPF Paragraphs: 18-22

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

SA Objective 4 relates to the provision and loss of employment land within the Plan area.

The nature and significance of the effects against this SA Objective will relate to the capacity of the site to accommodate employment land, and the potential for development to lead to the loss of existing employment.

For the purposes of the SA an employment site is considered strategic if it is equal to or above 10ha, which is the threshold used in the Council's call for sites.

For the purposes of this appraisal, the loss of agricultural land is not considered of significance for the economy at a Plan level, as the sectors contribution is less than 1% (Agriculture, Forestry and Fishing accounts for 0.7%)[13]. The cumulative loss of agricultural land however, is a significant factor that will be assessed within the full SA Report.

Evidence base:

The Employment Land Review and the Councils estimated capacity of site options, and assessment of site options will inform the assessment of effects against this SA Objective.

++

Potential for the site option to accommodate a strategic level of employment development (equal to or more than 10ha).

+

Potential for the site option to accommodate employment development (less than 10ha).

0

If no employment is being proposed as part of development, as it is a housing site option, then it is considered to have a neutral effect against this SA Objective.

?

There is an element of uncertainty as the capacity of the site option for employment development is unknown.

-

Development at the site option may result in a net loss of existing employment.

--

Not applicable.

Health and Equalities

SEA Directive Topic(s): Population and Human Health

NPPF Paragraphs: 69-78

  1. To improve the health and wellbeing of communities and reduce inequalities.

SA Objective 5 relates to the built environment's contribution to healthy and active lifestyles, and any disparities in provisions across the Plan area.

The nature and significance of the effects against this SA Objective will relate to the provision of development in deprived areas[14] and access to existing open/recreational space and sports/leisure facilities.

The SA assumes that any proposal for development can make appropriate and timely provision or contributions for necessary supporting infrastructure, including health, and green infrastructure. The SA further assumes that any new provisions can be delivered to the aspirational quality standards.

The appraisal narrative will note if there are any potential issues at site options with regard to the compatibility of surrounding land uses. It will also identify where mitigation may overcome any identified potential negative effects.

Evidence base:

Reasonable walking distance is informed by the Central Bedfordshire Leisure Strategy (2014). The strategy identifies a range of different accessibility standards for different typologies of space, however for the purposes of this SA, the most common distance used (480m) has been utilised in the analysis. Map layers of open and recreational space will be provided by Central Bedfordshire Council and data analysis within ArcGIS will inform the assessment of effects against this SA Objective. The settlement audit and Council's site assessment process will also help to inform the SA.

++

The site has good access to existing open/recreational space or sports/leisure facilities (480m), and will deliver new development in an area of higher depravation.

+

The site has good access to existing open/recreational space or sports/leisure facilities (480m) or will deliver new development within or in close proximity to an area of higher deprivation.

0

A neutral effect is not considered possible.

?

An element of uncertainty exists until lower level assessments have been carried out

-

The site is beyond reasonable walking distance (480m) to existing open/recreational space or sports/leisure facilities.

Or

Development would result in a net loss of existing open/recreational space, and / or sports/leisure facilities on site.

--

Development at the site option would result in a net loss of open/recreational space, and / or sports/leisure facilities, and is located beyond reasonable walking distance (480m) to further open/recreational space or sports/leisure facilities.

Transport and Movement

SEA Directive Topic(s): Population and Human Health

NPPF Paragraphs: 29-41

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

SA Objective 6 relates to the capacity of the highways network to accommodate new development, which can have indirect effects on air quality and greenhouse gas emissions.

The nature and significance of effects against this SA Objective will relate to the potential traffic impacts of development at the site options.

The SA assumes that appropriate access can be provided for any of the site options; however, if the evidence suggests that access may be a significant issue then this will be noted within the summary appraisal narrative.

Evidence base:

Available evidence, including traffic modelling, further detail through existing planning applications, the Council's site assessment process and input from Council Officers will also inform the assessment of effects against this SA Objective.

++

Development at the site option has the potential to significantly enhance the highways network, which will reduce levels of traffic in an area that is experiencing congestion issues.

+

Development at the site option has the potential to enhance the highways network, which will reduce levels of traffic.

0

The site option is well located in respect of the road network and vehicle movements. Whilst development at the site has the potential to increase traffic, there is suitable mitigation available to reduce negative effects with the potential for a residual neutral effect.

?

There is an element of uncertainty, most likely until lower level assessments have been carried out.

-

Development has the potential to increase traffic in the surrounding road network and the site is not well located in respect of the road network and vehicle movements. Mitigation available, potential for a residual minor negative effect.

--

Development will increase the levels of traffic in an area that is already experiencing congestion issues, and the site is not well located in respect of the road network and vehicle movements. Mitigation difficult and/or expensive, potential for a residual major negative effect.

  1. To encourage a demonstrable modal shift to more sustainable forms of transport and reduce the need to travel.

The nature and significance of the effects against this SA Objective will primarily relate to existing access to sustainable transport modes (train, bus, walking and cycle routes).

For the purposes of the SA Primary/ Secondary Pedestrian Routes and Primary/Secondary/Inter Urban Cycle Routes are considered to be of greater significance than routes below them in the pedestrian and cycle network hierarchies set out in the Walking and Cycling Strategies published in 2011.

A key aspect of encouraging walking and cycling is that routes need to be direct and accessible. Taking this into account, for the purposes of the SA a reasonable distance to these key walking and cycling routes is considered to be within 100m.

Distances will be measured using a buffer zone of the set reasonable walking distance calculated from the site boundary within ArcGIS. It is recognised however that the distance by buffer zone is not the only aspect to consider in accessibility, and as such the narrative will note if potential barriers to movement, or poor quality infrastructure is likely to restrict the potential use of the mode.

The SA assumes that development at any of the site options could potentially provide or contribute to improved sustainable modes of transport.

The SA assumes that larger strategic development options have greater potential for enhancements to existing infrastructure and services/provisions.

Evidence base:

 Local Transport Plan 2011 - 2026

 Walking Strategy (2011)

 Cycling Strategy (2011)

 Local Area Transport Plans

 Council GIS shapefiles

Reasonable walking distances informed by the Council's site assessment criteria.

Barriers to movement informed by the Council's Site Assessment Framework for Housing criterion 6.

++

The site option is within reasonable walking distance to a train station (800m) and bus stop (400m) with a frequent service (every half hour) and is also within a reasonable distance (100m) to either a key pedestrian or cycling route.

+

The site option is within reasonable walking distance to either a train station (800m) or bus stop (400m) with a frequent service (every half hour) and is within a reasonable distance (100m) to either a key pedestrian or cycling route.

0

A neutral effect is not considered possible.

?

There is an element of uncertainty, for example the quality of the route is questionable or unknown, most likely until lower level assessments have been completed.

-

The site option is not within reasonable walking distance to either a train station (800m) or bus stop (400m) with a frequent service (every half hour) but is within a reasonable distance (100m) to either a key pedestrian or cycling route.

--

The site option is not within reasonable walking distance to either a train station (800m) or bus stop (400m) with a frequent service (every half hour) and is not within a reasonable distance (100m) to either a key pedestrian or cycling route.

Air Quality

SEA Directive Topic(s): Air

NPPF Paragraphs: 109-125

Air quality within Central Bedfordshire is closely linked to road traffic. This is demonstrated by the designation of the 3 AQMAs which cover areas where the road network is currently congested.

Given the close relationship between traffic and air quality, it is not considered necessary to have a separate SA Objective specifically relating to air quality. For example, positive effects against SA Objectives 6 and 7 are likely to result in a positive indirect effect on air quality; equally, negative effects are likely to result in negative indirect effects on air quality. Mitigation provided through Local Plan policies and at the project level to reduce traffic impacts, such as improving access to sustainable transport modes will also help to mitigate impacts on air quality.

Energy and Climate Change

SEA Directive Topic(s): Climatic Factors

NPPF Paragraphs: 93-104

  1. To maximise the potential for energy efficiency, reduce greenhouse gas emissions and ensure that the built environment and its communities can withstand the effects of climate change

The potential indirect effects of development on emissions of greenhouse gases from road traffic is assessed under the Transport and Movement topic. The SA assumes that all new development can meet policy targets for energy efficiency, using sustainable construction methods and could promote building form and layout that aids adaptation. It should be noted that further aspects of climate change, e.g. flooding, green infrastructure and landscapes, are assessed under the topics relating to Water: Resources, Quality and Flooding; Health and Equalities; and Landscape and Townscape.

It is therefore assumed that all site options have the potential for neutral effect against SA Objective 8, and this SA Objective will not be a key differentiator between site options.

Water: Resources, Quality and Flooding

SEA Directive Topic(s): Water

NPPF Paragraphs: 99-125

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

SA Objective 9 relates to the water efficiency of new development, and its potential effects on water quality.

The SA assumes that development at any of the sites can incorporate aspirational water efficiency measures and that any proposal can make appropriate and timely provision for necessary supporting infrastructure, including waste water treatment.

The appraisal summary narrative will note if water intensive development is being proposed at the site option.

Evidence base:

The Water Cycle Study will be used to inform the assessment of effects against this SA Objective.

++

Evidence from the Water Cycle Study suggests that development at the site option will lead to significant positive effects on water quality.

+

Evidence from the Water Cycle Study suggests that development at the site option will lead to positive effects on water quality.

0

Evidence from the Water Cycle Study suggests that development at the site option is unlikely to lead to any significant effects on water quality, or that appropriate mitigation is in place to reduce negative effects with the potential for a residual neutral effect.

?

There is an element of uncertainty, most likely until lower level assessments have been carried out.

-

Evidence from the Water Cycle Study suggests that development at the site option will lead to minor negative effects on water quality.

--

Evidence from the Water Cycle Study suggests that development at the site option will lead to major negative effects on water quality.

  1. To reduce the risk of flooding from all sources.

SA Objective 10 relates to existing areas of flood risk within the Plan area.

The nature and significance of effects against this SA Objective will therefore relate to whether a site option is located within an area of flood risk (from all sources) or has the potential to reduce flood risk.

The SA assumes that development at any of the site options has the potential to incorporate Sustainable Drainage systems.

Evidence base:

The Environment Agency Flood Map for Planning and Risk of Flooding from Surface Water and the Council's SFRA will be used to inform the assessment of effects against this SA Objective.

++

The site option is not located within an area of flood risk and there is evidence that development at the site option could offer an opportunity to potentially reduce flood risk.

+

The site option is not located within an area of flood risk and is not at risk of surface water flooding.

0

The site option is located partially within an area of flood risk, or at risk of surface water flooding in parts of the site. However, development could avoid this area, or suitable mitigation is available, with the potential for a residual neutral effect.

?

There is an element of uncertainty until more detailed lower level surveys and assessments have been carried out.

-

The site option is located partially within an area of flood risk, or at risk of surface water flooding in parts of the site. The areas of flood risk would be difficult to avoid, and mitigation is likely to be expensive/ difficult.

--

The site option is located wholly within an area of flood risk or at risk of surface water flooding across the entire site.

Soil and Land

SEA Directive Topic(s): Soil

NPPF Paragraphs: 79-92, 109-125

  1. To protect and conserve soil

SA Objective 11 relates to soil and land quality.

The nature and significance of the effect will relate to the land type and potential loss of best and most versatile agricultural land.

Evidence base:

The Council's site assessment process, in particular criterion 25 of the Council's Site Assessment Framework for Housing Sites; criterion 20 of the Council's Site Assessment Framework for Employment Sites and criterion 20 of the Council's Site Assessment Framework for Gypsy and Traveller Sites.

Council shapefiles, DEFRA Magic Map application, as well as information available from planning applications where available, will be used to inform the assessment of effects against this SA Objective.

++

The site is entirely brownfield and will not result in the loss of any greenfield or agricultural land, and/or development at the site will remediate contaminated land.

+

The majority of the site is brownfield land and will not result in the loss of best and most versatile agricultural land.

0

A neutral effect is not considered possible.

?

An element of uncertainty exists for all sites until more detailed lower level surveys and assessment have been carried out through planning applications.

-

The majority of the site is greenfield and does not contain any best and most versatile agricultural land.

--

Development at the site option could result in the loss of best and most versatile agricultural land.

Biodiversity and Geodiversity

SEA Directive Topic(s): Biodiversity, Flora and Fauna

NPPF Paragraphs: 109-125

  1. To protect, enhance and manage biodiversity & geodiversity.

SA Objective 12 relates to existing identified biodiversity and geodiversity assets, and ecological corridors that provide strategic connectivity for biodiversity.

The nature and significance of effects against this SA Objective will primarily relate to potential effects on biodiversity.

Is the site within, adjacent to, or in close proximity (200m) to any nationally designated biodiversity (NNRs) or located within an identified Impact Risk Zone (SSSI)?

Is the site within, adjacent to, or in close proximity (200m) to any biodiversity sites designated as being of local importance (Local Wildlife Site, Local Nature Reserve)?

Would development at the site result in the loss or fragmentation of important habitats or GI for biodiversity as identified in the Nature Conservation Strategy (2015)?

It is recognised that when considering the potential for effects on designated biodiversity, distance in itself is not a definitive guide to the likelihood or severity of an impact. The appraisal commentary will try to note any key environmental pathways that could result in development potentially having a negative effect on designated biodiversity that may be some distance away.

The capacity of the site to accommodate housing and employment development will also influence the judgements made in terms of the nature and significance of effects against this SA Objective.

Are there opportunities to enhance biodiversity? Possibly improve connectivity, green/blue infrastructure or enhance an important habitat?

For the purposes of this SA an important habitat is considered to encompass Priority Habitats, Ancient Woodland, wetlands and carbon stores such as peatland.

Evidence base:

DEFRA Magic Map application, analysis of ArcGIS map layers CBC Officer input and the Nature Conservation Strategy will inform the assessment of effects against this SA Objective.

++

Development at the site option will deliver biodiversity gains, or improve ecological corridors/connections to strategic GI, or development will address a significant existing sustainability issue relating to biodiversity.

+

Development will not lead to the loss of an important habitat, species, trees and hedgerows or lead to fragmentation of ecological corridors identified in the Nature Conservation Strategy (2015) and there are potential opportunities to enhance biodiversity.

0

Development at the site is not likely to have negative effects on any nationally or locally designated biodiversity or contribute towards a severance of green and blue infrastructure or impede the migration of biodiversity. Potential for a neutral effect.

Or

Development at the site has the potential for negative effects on sites designated as being of local importance. Mitigation possible, potential for a residual neutral effect.

?

Element of uncertainty exists until more detailed lower level surveys and assessments have been carried out.

-

Development at the site option has the potential for negative effects on sites designated as being of local importance or Priority Species, or will lead to the loss of important habitats, or fragmentation/severance of the connectivity of ecological corridors as identified in the Nature Conservation Strategy (2015).

Or

Development at the site has the potential for negative effects on nationally designated sites. Mitigation possible, potential for a minor residual negative effect.

--

Development at the site has the potential for negative effects on an internationally or nationally designated site. Mitigation difficult and / or expensive, potential for a major residual negative effect.

Landscape and Townscape

SEA Directive Topic(s): Landscape

NPPF Paragraphs: 109-125

  1. Protect and enhance the landscape and townscape.

SA Objective 13 relates to valued landscapes and townscapes, as well as features and assets that contribute to landscape and townscape character.

The nature and significance of the effects against this SA Objective will relate to the sensitivity of the landscape or townscape.

The capacity of the site to accommodate housing and employment development will also influence the judgements made in terms of the nature and significance of effects against this SA Objective.

It is considered that there is an element of uncertainty for all sites until more detailed lower level surveys and assessments have been carried out through planning applications.

The SA assumes that any trees protected by Tree Preservation Orders within a site option will be retained, unless there is evidence to suggest that this is not the case.

Evidence base:

Council's site assessment process - in particular in particular criteria 17 & 38 of the Council's Site Assessment Framework for Housing Sites; criteria 15 & 30 of the Council's Site Assessment Framework for Employment Sites and criteria 15 & 32 of the Council's Site Assessment Framework for Gypsy and Traveller Sites - will inform the assessment of effects against this SA Objective.

++

Development significantly enhances the landscape or removes a significant eyesore and/or would regenerate previously developed land and buildings (PDL) that is currently having a major negative effect on the landscape/ townscape.

+

Development would remove an eyesore, or enhance the landscape and/or would regenerate PDL that is currently having a minor negative effect on the landscape/ townscape, or the site is identified as of low landscape sensitivity.

0

A neutral effect is not considered possible.

?

Element of uncertainty exists until more detailed lower level assessments have been carried out.

-

The site option has medium sensitivity in landscape terms or is within the setting of the AONB or is located within a village or landscape setting where the landscape or townscape character is identified within the Landscape Character Assessment (2016) as vulnerable to the impacts of development.

--

The site option has medium to high or high sensitivity in landscape terms and/ or is within the AONB.

Mitigation is likely to be difficult/ expensive. Potential for major residual negative effect.

The Historic Environment

SEA Directive Topic(s): Cultural Heritage

NPPF Paragraphs: 126-141

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

The nature and significance of the effects in this instance will relate to designated heritage assets (Scheduled Monuments, Listed Buildings, Conservation Areas, Registered Parks and Gardens, and Areas of Archaeological Potential & Importance) and their setting. Any important non-designated heritage assets will be noted within the appraisal commentary.

Are there any designated heritage assets or their setting, which could be affected within or adjacent to the site?

Are there any opportunities to enhance heritage assets, such as: securing appropriate new uses for unused Listed Buildings; the removal of an eyesore could have a positive effect on the setting of designated assets; improved access and signage?

Consider the nature and significance of the effects identified against the topic Landscapes and Townscapes in terms of the setting of designated heritage assets.

The capacity of the site to accommodate housing and employment development will also influence the judgements made in terms of the nature and significance of effects against this SA Objective.

It is considered that there is an element of uncertainty for all sites until more detailed lower level surveys and assessments have been carried out.

Evidence base:

DEFRA Magic Map application, the National Heritage List for England, analysis of ArcGIS map layers and Central Bedfordshire Council Officer input will inform the assessment of effects against this SA Objective.

++

Development at the site option has the potential for a major positive effect on the significance of a designated heritage assets and / or its setting.

+

Development at the site option has the potential for minor positive effects as it may secure appropriate new uses for unused Listed Buildings and / or enhance the setting of, or access / signage to designated assets.

0

Development at the site option will have no significant effect. This may be because there are no heritage assets within the influence of proposed development, or that mitigation measures are considered to reduce negative effects with the potential for a residual neutral effect.

?

Element of uncertainty for all sites until more detailed lower level surveys and assessments have been carried out.

-

Development has the potential for a residual minor negative effect on a Conservation Area, Scheduled Monument, Listed Building, Registered Historic Parks and Gardens and/ or their setting.

--

Development has the potential for a residual major negative effect on a Conservation Area, Scheduled Monument, Listed Building, Registered Historic Parks and Gardens and/ or their setting. Mitigation is likely to be difficult/ expensive.

Potential for major residual negative effect.

Minerals and Waste

SEA Directive Topic(s): Material Assets

NPPF Paragraphs: 5, 142-149

The adopted Minerals and Waste Local Plan sets out the strategic allocations for mineral extraction and for waste management development in the Plan area (Bedford Borough, Central Bedfordshire and Luton Borough) together with strategic policies which will guide the ongoing supply of minerals and development of waste management facilities. The adopted Minerals and Waste Local Plan was subject to SA.

At this stage, it is not considered that there are any significant sustainability issues within Central Bedfordshire in relation to Minerals and Waste. While development proposed through the Central Bedfordshire Local Plan will affect this topic, it is considered that these effects are unlikely to be of significance. This topic is unlikely to play a significant role in the identification and refinement of site options and is not a significant constraint to development.


SA Stage B: Developing and refining options and assessing effects

2.9 Developing options for a plan is an iterative process, usually involving a number of consultations with the public and stakeholders. Consultation responses and the SA can help to identify where there may be other 'reasonable alternatives' to the options being considered for a plan.

2.10 Regulation 12 (2) of the SEA Regulations requires that:

"The (environmental or SA) report must identify, describe and evaluate the likely significant effects on the environment of-

(a) implementing the plan or programme; and

(b) reasonable alternatives, taking into account the objectives and the geographical scope of the plan or programme."

2.11 Any alternatives considered for the plan need to be 'reasonable'. This implies that alternatives that are not reasonable do not need to be subject to appraisal. Examples of unreasonable alternatives could include policy options that do not meet the objectives of the plan or national policy (e.g. the National Planning Policy Framework) or site options that are unavailable or undeliverable.

2.12 Extant SEA guidance[15] sets out an approach and methods for developing and assessing alternatives. This includes acknowledgement of a hierarchy of alternatives that are relevant and proportionate to the tiering of plan-making. Alternatives considered at the early stages of plan-making need not be elaborated in too much detail so that the "big issues" are kept clear; only the main differences between alternatives need to be documented i.e. the assessment should be proportionate to the level and scope of decision-making for the plan preparation. The hierarchy of alternatives may be summarised in the following diagram.

Figure 2.2: Hierarchy of alternative in SA/SEA and options in plan-making

Figure 2.2

Assessment of Options in Plan-Making

2.13 Development planning issues, such as how much, what kind of development and where, are considered within the requirements of legislation and policy together with the characteristics of the plan area and the views of its communities. Potential options for resolving such issues are identified by Councils through various studies, such as population projections and housing need, community strategies, infrastructure capacities, and environmental constraints analysis – and through consultation with the regulators, the public, businesses, service providers, and the voluntary sector.

2.14 At the earlier and higher levels of strategic planning, options assessment is proportionate and may have a criteria-based approach and/or expert judgment; the focus is on the key differences between possibilities for scale, distribution and quality of development. At that early stage, the options presented may constitute a range of potential measures (which could variously and/or collectively constitute a policy) rather than a clear spatial expression of quantity and quality. Each option is not mutually exclusive and elements of each may be further developed into a preferred option. As a plan evolves, there may be further consideration of options that have developed by taking the preferred elements from earlier options. Thus, the options for plan-making change and develop as responses from consultation are considered and further studies are undertaken.

2.15 At the later and lower levels of development planning for site allocations, options assessment tends to be more specific, often focused on criteria and thresholds, such as land availability, accessibility to services, and impacts on local landscape - and particularly informed by technical studies such as the Strategic Housing Market Assessment (SHMA), the Strategic Housing Land Availability Assessment (SHLAA), and Strategic Flood Risk Assessment (SFRA). There is a hierarchy of options assessment with sites that are not viable or deliverable or might have adverse effects on protected environmental assets rejected at an early stage.

2.16 The role of the SA is to inform the Council in its selection and assessment of options as SA is carried out in relation to the reasonable alternatives (options) identified through the plan-making process. The findings of the SA can help with refining and further developing these options in an iterative and ongoing way. The SA findings do not form the sole basis for decision making – this is informed also from planning and other studies, feasibility, and consultation feedback.

2.17 This section provides an overview of how options have been developed and appraised throughout the preparation of the Local Plan, and further detail is provided in relation to specific groups of options within Chapters 4-6.

Options for Accommodating Growth in the Central Bedfordshire Area

2.18 Different options for accommodating growth have been considered since early on in the development of the Central Bedfordshire Local Plan. Between September and October 2016 the public was invited to comment on the 'Shaping Central Bedfordshire' consultation. This included consideration of four main areas (A-D) for development growth (these are mapped at the end of Chapter 4 of this report, see Figure 4.1). The comments received were considered when developing the next stage of options assessment, which included approaches to distributing development and the consideration of five alternative scenarios for the distribution of growth, the drafting of the spatial strategy, and options for growth locations for both housing and employment. These options were subject to Regulation 18 consultation from June 2017 and the comments received were considered by CBC as it identified the preferred strategic approach and the potential site options set out in the Regulation 19 consultation.

2.19 The strategic SAs of the Areas A-D (A: South & West/M1 Corridor; B: East/A1 Corridor; C: East/West Corridor; D: Central Section) and the approaches to distributing new growth were undertaken at an early stage of plan-making when other studies had yet to be completed. As may be expected at this high level of appraisal, assumptions were made, including regarding the mitigation for negative effects that would be provided by the emerging Development Management policies. There was some uncertainty about the significance of effects; however significant effects were indicated where they were considered likely and the initial findings from these strategic SAs, together with the initial strategic SA findings of the growth location options, informed the development of the scenarios for growth, the spatial strategy and policies.

2.20 After the Local Plan had been submitted to Government and initial Examination hearings had been held, the Inspectors wrote to CBC (EXAM69) raising queries about some aspects of the SA work completed to date. As a result, CBC commissioned independent consultants (LUC) to carry out supplementary SA work in relation to the strategic options for the Local Plan. This involved revisiting the initial options for approaches for distributing development and the overall housing and employment strategies, as well as the strategic housing and employment site options. The findings of the Supplementary SA were published in May 2020 (EXAM115) and have helped to inform the Main Modifications that are now proposed to be made to the submitted Local Plan.

Options for Strategic and Small-Medium Site Allocations

2.21 Emerging options for the proposed Strategic Allocations (housing and employment) and Broad Locational areas (to identify areas for future growth after the Plan period ends in 2035) were subject to SA from an early stage in the plan making process. The Initial (Regulation 18) SA Report did not include consideration of any proposed site allocations because the Regulation 18 draft Local Plan did not include possibilities for site allocations but rather consulted on the proposed Spatial Strategy and potential approach with strategic growth locations in Areas A-D. The Regulation 18 SA Report therefore presented the SA findings for reasonable alternative broad locational options. Specific site options were considered at the next (Regulation 19) stage of plan-making.

2.22 As described above, the Supplementary SA Report prepared in May 2020 revisited the strategic site options for the Local Plan and appraised a number of additional reasonable alternative options. The findings of that SA work (detailed in Chapter 5 of this report) have contributed to the preparation of the proposed Main Modifications.

2.23 The options identified as reasonable alternatives for small-medium site allocations were subject to SA and the findings reported in the Regulation 19 SA Report. No further work on those site options was carried out as part of the Supplementary SA.

The Do-Nothing Scenario

2.24 It may be noted that "doing nothing" is not a reasonable alternative for the Local Plan since the Council has a duty to plan positively for objectively identified needs for housing and employment land.

Duty to Cooperate

2.25 A feature of plan-making for CBC is to consider any reasonable options for accommodating growth for unmet housing need from adjacent Councils. This was acknowledged as a particular characteristic for the CBC area and the strategic SA framework (see Table 2.2) includes a sub-objective/decision-aiding question "Does the option offer the opportunity to help meet the housing needs arising from outside the Plan area"? Accordingly, this aspect of considering meeting unmet need from outside the Plan area has been tested through SA.              

SA Stage C: Preparing the Sustainability Appraisal Report

2.26 This SA Report describes the process that has been undertaken to date in carrying out the SA of the Central Bedfordshire Local Plan. It sets out the findings of the appraisal of reasonable alternative options throughout the plan making process, as well as the SA findings for the Local Plan as proposed to be modified, highlighting any likely significant effects (both positive and negative and taking into account the likely secondary, cumulative, synergistic, short, medium and long-term and permanent and temporary effects). It also outlines the Council's reasons for selecting or rejecting certain options during the preparation of the Local Plan.

SA Stage D: Consultation on the Local Plan and the SA Report

2.27 The SEA Regulations require early and effective public consultation. The Central Bedfordshire Local Plan has been subject to consultation throughout its development as described below.

2.28 The SA Scoping Report was subject to consultation in summer 2016, including formal consultation with the SEA statutory bodies (Historic England, the Environment Agency and Natural England). Comments received on the SA scoping were taken into consideration and addressed in the final SA Scoping Report (October 2016). For example, some of the comments received resulted in changes being made to the decision-aiding questions supporting the SA Objectives in the SA framework. Full details of how each response was addressed were set out in Appendix II of the final Scoping Report.

2.29 The Initial SA Report accompanied the Draft (Regulation 18) Local Plan for consultation at the end of June 2017 for eight weeks. Comments made during the consultation were taken into consideration and informed the preparation of the Pre-Submission (Regulation 19) Local Plan and SA Report. Consultation comments received in relation to the Initial (Regulation 18) SA Report were detailed in Appendix IX of the Regulation 19 SA Report, along with a response to each. Many of the comments related more to the content of the Local Plan itself and only referred to the SA in the context of making wider comments about Local Plan policies. Comments were also received in relation to the evidence base used for the SA and the specific appraisal findings, particularly where consultees were promoting or opposing a certain location for development.

2.30 The SA Report for the Draft Pre-Submission Local Plan (December 2017) accompanied the Local Plan for Regulation 19 consultation between January and February 2018. Many of the consultation responses received in relation to the SA Report focussed on the appraisal of specific sites that had been selected or rejected for allocation, including a large number of comments from site owners and promoters.

2.31 After the Local Plan was submitted to the Secretary of State for independent examination and initial examination hearings were held, CBC commissioned LUC to prepare a Supplementary SA Report to revisit the appraisal of strategic options for the Local Plan. That report (EXAM115) was published for consultation between June and August 2020. As at the Regulation 19 stage, many of the consultation responses received focussed on specific sites that had or had not been allocated in the Local Plan, as well as some comments on the methodology used for the supplementary SA and whether it did indeed address the points raised by the Inspectors.

2.32 CBC is now inviting comments on the proposed Main Modifications and this SA Report. Both documents are being published on the Council's website for consultation from March 2021.

2.33 Thus, consultation has been carried out in an iterative way, as an important element of the SA/SEA process.

SA Stage E: Monitoring implementation of the Local Plan

2.34 Recommendations for monitoring the likely significant social, environmental and economic effects of implementing the Central Bedfordshire Local Plan are presented in Chapter 9.

Difficulties Encountered

2.35 It is a requirement of the SEA Regulations that consideration is given to any data limitations or other difficulties that are encountered during the SA process.

2.36 During the appraisal of the strategic options, the fact that options had not yet been worked up in detail (comprising only high-level policy approaches) meant that at times it was difficult to assess in detail the likely effects of the options on each SA Objective. Once draft policies are worked up in more detail it is possible to draw more certain conclusions about their likely effects.

2.37 There was a need to appraise a large number of site options consistently. In order to address this issue, detailed criteria relating to each of the SA Objectives were developed and applied during the appraisal of site options (as shown in Table 2.3 previously). The Supplementary SA undertaken by LUC sought to interpret and apply the detailed criteria developed by Enfusion at the Scoping stage in the same way in order to ensure consistency throughout the SA process.

[6] References to the NPPF throughout this table and Table 2.3 below refer to the 2012 version, under which the Central Bedfordshire Local Plan is being examined.

[7] This relates to the provision of services and facilities, both existing, and what could potentially be provided as part of new development. Consistent with the settlement audit this includes community facilities (Place of worship, public library, village hall/community centre/social club), health facilities (GP/ Health centre (Primary Health Care), Dentist, Pharmacy), educational facilities (pre-school/nursery, lower school, middle school, upper school, Colleges/Academies, Universities)), financial (bank/building society), groceries (superstore, convenience store, newsagents), other retail (petrol station/garage, post office) and hospitality (restaurant/café/takeaway, public house with and without food).

[8] Please note that flooding is dealt with separately under the Water: Resources, Quality and Flooding topic.

[9] For the purposes of this SA, a flood risk area relates to an area located within Flood Risk Zones 2 and / or 3, or an area at risk of flooding from surface water.

[10] For the purposes of this assessment, greenfield land includes agricultural land graded 3b-5.

[11] For the purposes of this assessment, best and most versatile agricultural land relates to agricultural land graded 1-3a.

[12] This relates to regeneration that may lead to positive effects on landscape character rather than land and soils.

[13] Office for National Statistics - 2011 Census.

[14] DCLG Indices of Deprivation - Lower Super Output Areas (LSOAs) in the most deprived 10 to 30% in England 2015; Parkside (601 and 602), Dunstable Manshead (594), Houghton Hall (580), Tithe Farm (619), Houghton Hall / Tithe Farm (618), Sandy (433), Leighton Buzzard North (605 and 609), Flitwick (400), Dunstable Northfields (596), Dunstable Central / Dunstable Northfields (568) and Caddington (562).

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