Sustainability Appraisal Main Modifications Report

Introduction

4.1 This chapter describes the SA work that has been undertaken throughout the preparation of the Local Plan in relation to the spatial strategy options.

4.2 Appendix C presents an audit trail of the strategic options that have been considered at each stage of plan making, and this should be referred to alongside this chapter. The options assessment process is described in detail within the sections below, along with a summary of the SA findings for each group of options.

Areas for Development Growth

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

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

4.4 These areas were not intended as four alternatives, but rather as distinct areas to help guide plan-making. The four areas were appraised in the Regulation 18 SA Report (June 2017), and the SA findings were presented again in the Regulation 19 SA Report (December 2017) and in the Supplementary SA Report (May 2020).

4.5 The characteristics of these areas are described in Table 4.1 overleaf and they are mapped in Figure 4.1 at the end of this chapter.

4.6 No further SA work has been carried out in relation to Areas A-D since the options were originally appraised. The SA findings for the four areas are summarised in Table 4.2 below and are described beneath the table.

Table 4.1: Characteristics of Areas A-D

Table 4.2: SA findings for areas A-D

Summary of SA Findings

4.7 At this strategic level of assessment, there was considerable uncertainty in the SA findings since the likely effects depend upon the scale, nature and location of proposed development within each Area, as well as the possibilities for implementing mitigation measures.

SA Objective 1: To ensure that the housing needs of all residents and communities are met

4.8 Areas A, B and C are likely to have significant positive effects on SA Objective 1. All four Areas could provide an appropriate mix of types of housing but this is more likely to be deliverable through the medium to larger-scale growth that could be delivered in Areas A, B and C. Positive effects in Area D would be minor as growth potential there is small-medium scale.

SA Objective 2: To maintain and enhance community and settlement identities

4.9 Development in Area A could have significant negative effects on the first part of SA Objective 2, as a result of the loss of Green Belt land and the potential for coalescence of existing settlements. Development in the other three Areas would avoid the Green Belt, so minor positive effects were identified. All four Areas have the potential for either positive or negative effects on the second part of this SA Objective (integration and the identity of a settlement or community). Effects will depend upon the sensitivity of the settlement/community and the scale and design of the development.

SA Objective 3: To improve accessibility to services and facilities

4.10 All four Areas are likely to have minor positive effects on SA Objective 3. Although large development sites (including new villages or extensions to settlements) have the potential to put strain on existing services, they also have the greater potential for positive effects through early, creative masterplanning with the scale and scope to provide sustainable community infrastructure thus mitigating potential negative effects and potentially benefitting the area.

SA Objective 4: To support the economy and ensure that there are suitable opportunities for employment

4.11 All four Areas are likely to have positive effects on SA Objective 4. Potential significant positive effects were identified for Area C which has close links to Milton Keynes and is well-connected with the improved A421, M1 and the planned upgrading for the East West Rail between Oxford and Cambridge. Area B also has the potential for significant positive effects due to the location of the A1 corridor through this area and the planned upgrading of the East West Rail. Area A offers strong opportunities to support and enhance the vitality and viability of Dunstable and Luton town centres.

SA Objective 5: To improve the health and wellbeing of communities and reduce inequalities

4.12 Area A could have a significant positive effect on SA Objective 5 as it includes areas of higher deprivation around Houghton Regis and Luton which new development could help to address. Health would also be benefited by green infrastructure (GI) provision which should be better addressed by the larger-scale development possible in Areas A-C. Since growth potential for Area D would be small-medium sized, there may be fewer opportunities for delivering GI enhancements.

SA Objective 6. To maintain and improve the existing highway network and reduce associated indirect impacts on air quality and greenhouse gas emissions

4.13 There is some potential for growth along the major transport corridor following the M1, A5 and the railway with likely negative effects in Area A but mitigation may be achieved by ensuring that new development is located where there is existing capacity, with potential neutral effects resulting. Minor negative effects are likely to result from Areas B, C and D as a result of increased pressure on the highways network in those areas. The A1 corridor running through Area B is a strategic location for the warehousing industry with good, fast access to the national/international road network and is important to maintain. Area C is well-connected with the improved A421, the M1 and the planned section upgrade for East West Rail between Oxford and Cambridge. There is the potential for major development, including new settlements, to contribute to further improvements and ensure the continuing capacity of the strategic road and rail networks; although there is uncertainty at this stage. Larger developments are more likely to be able to support funding for upgrading the strategic road network. The smaller-medium scale developments indicated for Area D are less likely to support the potential to upgrade roads.

SA Objective 7: To encourage a demonstrable modal shift to more sustainable forms of transport and reduce the need to travel

4.14 Area A is well-connected to the Midland Main railway line and smaller-medium sized developments at locations such as Ampthill, Flitwick, Westoning and Harlington, along well-connected public transport routes could encourage modal shift with positive effects. Larger scale developments with major opportunities to promote sustainable transport are only likely to be possible adjacent to Luton and to help meet the housing needs of Luton Borough. Larger scale developments indicated for Areas B and C have the scope for effective design and implementation of sustainable transport modes – cycling and walking – with the potential for significant positive effects. Smaller-medium scale development indicated for Area D limits possibilities with likely neutral effects.

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

SA Objective 9: To minimise the demand for water and maintain or improve water quality

4.15 All development has the potential for high energy and water efficiencies but generally, the scale and scope of the larger developments, especially new villages/settlements, offers potential possibilities for exemplar design and construction.

SA Objective 10: To reduce the risk of flooding from all sources

4.16 The Regulation 19 SA report noted that a Development Management Policy on Flood Risk was being drafted for the Local Plan in line with Government guidance. This will provide mitigation measures. Larger developments can have the scale and scope to provide creative design and potentially contribute to resolving existing flood risk issues. No differences were identified in the SA between Areas A-D for these SA Objectives.

SA Objective 11: To protect and conserve soil

4.17 Minor negative effects were identified for all four Areas. All development will take land and the soil resource will be lost with permanent negative effects. However, it is possible to avoid the best and most versatile agricultural land.

SA Objective 12: To protect, enhance and manage biodiversity & geodiversity

4.18 The Regulation 19 SA report noted that Development Management Policies on Green Infrastructure, Enhancing Ecological Networks and Nature Conservation were being drafted for the Local Plan and these will help to avoid important assets to avoid negative effects on this SA Objective. The SA did not identify variations in the likely effects on biodiversity and geodiversity of development in the four Areas as these will depend on the specific location of developments.

SA Objective 13: To protect and enhance the landscape and townscape

4.19 All development has the potential for negative effects on landscape and townscape. The SA noted that Development Management Policies on Landscape Character and Value are being drafted for the Local Plan and these should reduce the extent of negative effects. No differences were identified in the SA between Areas A-D for these SA Objectives.

SA Objective 14. To ensure the protection and enhancement of heritage assets, the historic environment and its setting

4.20 The Regulation 19 SA report noted that a Development Management Policy on the Historic Environment was being drafted for the Local Plan and that this will help to avoid important assets to avoid negative effects on this SA Objective. The SA did not identify variations in the likely effects of development on the historic environment in the four Areas as these will depend on the specific location of developments.

Summary and Conclusions

4.21 Area C performed the best of the four Areas in the SA, with four potential significant positive effects identified. The next best performing was Area B, with three potential significant positive effects, followed by Areas A and D with two and zero likely significant positive effects identified respectively.

4.22 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. Conversely, development in Area C could be larger-scale, and would have good potential in terms of employment and the economy due to the focus in that area of research and development activities. The area is also well-connected in transport terms. The Green Belt in Area A is a significant constraint and that was the only Area which had a potential significant negative effect associated with it.

Approaches to Distributing Development Growth

4.23 Seven options for approaches to distributing development growth were originally identified at the Regulation 18 stage. These are not necessarily alternatives, but rather approaches that might be suitable and sustainable depending upon the likely effects for each of the four Areas for Development Growth. The SA findings (along with those for the Areas for Development Growth) informed consideration of possible scenarios for growth and the overall growth strategy.

4.24 The options for approaches to distributing development growth were developed during late 2016 and were subject to SA with the findings being first presented in the Regulation 18 SA Report (June 2017). The findings were again presented in the Regulation 19 SA Report (December 2017).

4.25 A number of changes were then made to the suite of options as part of the preparation of the Supplementary SA Report (May 2020), which superseded the SA work undertaken prior to that stage. These changes were made in response to points raised by the Inspectors (EXAM69) and sought to ensure that the options represent appropriate high-level alternative options for the spatial distribution of development.

4.26 Table 4.3 below summarises the changes that were made to the options for approaches to distributing development growth. These changes were made to ensure the distribution options are more reflective of the range of schemes being considered as alternative options. The changes also ensure there are distinct differences between the options. Previously options 4 and 6, for example, could have been one and the same. In the revised options, a distinction is made between growth around existing road networks, and growth that is based around sustainable transport networks. These could have significantly different sustainability effects.

4.27 The combined SA matrix that had been prepared previously for the seven original options was revised to reflect these changes and the findings (as previously presented in the May 2020 Supplementary SA Report) are summarised in Table 4.4 overleaf and described beneath the table.

Table 4.3: Approaches to distributing development growth

Table 4.4: Summary of likely sustainability effects of options for distribution of development growth

SA Objective 1: To ensure that the housing needs of all residents and communities are met

4.28 It is expected that all six options would have positive effects on SA Objective 1. It is likely that that the scale of individual new developments that would occur under Option 1 (smaller new settlements), Option 2 (larger new settlements), Option 4 (growth along the strategic road network), Option 5 (growth around sustainable transport hubs), and 6 (urban extensions), is most likely to support the delivery of sufficient housing to meet the identified needs of all communities within the Plan area and/or housing needs outside the Plan area. Therefore, the positive effects likely for these options are significant. Option 3 (village extensions) would provide for smaller-scale housing development so would have a minor positive effect.

SA Objective 2: To maintain and enhance community and settlement identities

4.29 Where options would deliver entirely new settlements (Options 1 (smaller new settlements) and 2 (larger new settlements)) it is expected that development could incorporate positive masterplanning to promote thriving and inclusive communities. Minor positive effects are therefore likely for those options in relation to SA Objective 2. However, the positive effect for Option 1 is mixed with a minor negative effect as it may be more difficult to deliver a wide range of services and facilities within a smaller new development, which may make it more difficult to create an independent new settlement with a strong identity.

4.30 Option 6 (urban extensions) has the potential to integrate positively with existing communities where existing social networks may have more resilience to change. Minor positive effects are therefore also expected for that option in relation to SA Objective 2 although this is uncertain and will depend on the level of existing services and facilities at the settlements to be extended.

4.31 Option 3 (village extensions) could have a minor negative effect, as extensions to smaller settlements may be less suited to accommodate new growth considering the limited level of service provision and the potential for community networks to be overburdened by relatively high levels of growth. However, this is mixed with a potential minor positive effect as new development could help to strengthen the viability of existing villages and support their services.

4.32 The effects of Options 4 (growth around strategic roads) and 5 (growth around sustainable transport hubs) are uncertain and will depend on the scale and precise location of growth.

SA Objective 3: To improve accessibility to services and facilities

4.33 Option 2 (larger new settlements) and Option 6 (urban extensions) could have significant positive effects in relation to SA Objective 3. The scale of growth at larger new larger settlements (Option 2) is likely to provide the critical mass to support the delivery of substantial new services and facilities and to support improvements to existing services, although it is noted that there may be a reasonably long lead in time for large new settlements. Smaller new settlements (Option 1) are likely to provide fewer new services and therefore the positive effect expected is minor. A similar contrast is noted between Options 3 and 6.

4.34 Option 3 (village extensions) would be likely to provide new residents with access to a more limited range of existing services and facilities compared to Option 6 (urban extensions). Village extensions may also be less likely to deliver new services, although all new development could have the potential to make some improvements and it is noted that existing village residents would be able to make use of any new or enhanced services provided.

4.35 Minor positive effects are also expected for Option 4 (growth around strategic roads) and Option 5 (growth around sustainable transport hubs) given that many of the larger settlements where access to services is strongest are along the strategic road network and by sustainable transport hubs. The minor positive effects expected for Option 4 are combined with minor negative effects, however, given that providing new growth around the strategic road network is less beneficial in terms of accessibility for residents who do not have a car.

SA Objective 4: To support the economy and ensure that there are suitable opportunities for employment

4.36 Locating development at or adjacent to the existing larger settlements and as large-scale new settlements would help to support more sustainable employment growth. These areas can be masterplanned to provide the required infrastructure and floorspace for employment development, or may already benefit from existing employment development. Therefore, significant positive effects are expected for Option 2 (larger new settlements) and Option 6 (urban extensions) in relation to SA Objective 4.

4.37 Option 1 (smaller new settlements) is likely to involve a more limited level of employment growth, and so could have a minor positive effect on SA Objective 4. It is noted that Option 1 covers a scale of development from 1,500-5,000 homes, and effects may be more positive where developments are at the larger end of that scale. The positive effects expected for both Options 1 and 2 are, however, combined with potential minor negative effects as new settlements may be less likely to provide good access to the existing key employment sites in Central Bedfordshire in comparison to development that occurs as an extension to an existing larger settlement.

4.38 Option 5 (growth around sustainable transport hubs) would provide access to employment sites as well as additional employment opportunities in the neighbouring areas of Bedford, Milton Keynes and Luton via sustainable transport links and therefore significant positive effects are expected for this option.

4.39 The opportunity for growth in the warehousing sector is most directly addressed through Option 4 (growth around strategic roads) as employment development of this type generally requires easy access to the strategic road network. As such, a positive effect is expected for this option. This is likely to be minor considering the limited range of job provision and diversification of the local economy that growth of this nature is likely to support. Option 3 (village extensions) is considered to perform least favourably in relation to SA Objective 4.

4.40 The more limited scale of growth at village extensions is less likely to allow for the delivery of significant new employment opportunities. These locations are also less likely to be well-related to the existing key employment sites in Central Bedfordshire, many of which are located in close proximity to the major service centres. Therefore, an overall minor negative effect is expected for Option 3.

SA Objective 5: To improve the health and wellbeing of communities and reduce inequalities

4.41 It is likely that all of the options have the potential to deliver development which incorporates green infrastructure (GI) and opportunities for recreation. Therefore, all options are expected to have positive effects in relation to SA Objective 5.

4.42 The larger scale of development associated with Option 2 (larger new settlements) means that there may be increased opportunities for incorporating improvements to GI and recreation provision and significant positive effects are therefore expected for that option. The smaller scale of development associated with Options 1 (smaller new settlements) and 6 (urban extensions) means that a minor positive effect is likely as while there are still likely to be good opportunities for GI provision, these may be more limited in comparison.

4.43 Option 4 (growth around strategic roads), Option 5 (growth around sustainable transport hubs) and Option 6 (urban extensions) have the potential to deliver development at or in close proximity to communities with higher levels of deprivation, at Houghton Regis and the edge of Luton. This could help support an uplift in indicators relating to deprivation, including health deprivation and disability through the provision of new community infrastructure. Furthermore, it is expected that delivering growth in close proximity to sustainable transport hubs (Option 5) could result in an increase in travel by active modes; therefore a significant positive effect is likely for that option. However, the effects are uncertain depending on location – in particular under Option 4, development may take place anywhere around the strategic road network, so not necessarily near to areas with higher deprivation.

SA Objective 6: To maintain and improve the existing highway network and reduce associated indirect impacts on air quality and greenhouse gas emissions

SA Objective 7: To encourage a demonstrable modal shift to more sustainable forms of transport and reduce the need to travel

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

4.44 There are many interlinkages between these three SA Objectives, so they are addressed together.

4.45 It is likely that new settlements can be designed to address negative effects on the existing transport networks and contribute to resolving existing problems, for example by incorporating new infrastructure including sustainable transport links. New settlements (Options 1 and 2) and larger urban extensions (Option 6) may also provide opportunities for incorporating renewable energy infrastructure. Larger new settlements (Option 2) would provide the critical mass to incorporate more in the way of new services and facilities and infrastructure, thereby also reducing the need for residents to travel longer distances on a regular basis.

4.46 The scale of growth that would occur through Option 2 (larger new settlements) means that positive effects are likely in relation to all three of these SA Objectives. The effects identified for Option 5 (growth around sustainable transport hubs) are also expected to be particularly positive for these objectives given that this option would most directly support the use of sustainable transport links.

4.47 Options 3 and 4 are expected to perform least favourably in relation to these three SA Objectives. Option 3 (village extensions) is likely to result in higher levels of car use. While providing growth along the strategic road network (Option 4) could potentially result in some development at the larger settlements, this option is considered least likely to support modal shift. Significant negative effects have therefore been recorded for this option in relation to SA Objectives 7 and 8. It is also noted that delivering new development around the strategic road network would place demands on its capacity and therefore a minor negative effect is expected for this option in relation to SA Objective 6.

SA Objective 9: To minimise the demand for water and maintain or improve water quality

SA Objective 10: To reduce the risk of flooding from all sources

4.48 The likely effects of the options on these SA Objectives will be largely determined by the specific location of development – for example its proximity to areas where there are known wastewater treatment capacity issues or areas at risk from surface water or groundwater flooding (such as Biggleswade, Dunstable, Flitwick, Houghton Regis and Leighton Buzzard which all have areas at risk from surface water flooding). As such, uncertain effects are expected for all options in relation to both these SA Objectives. However, where development is of a larger scale there may be increased potential to incorporate exemplar design and construction including local water reuse/recycling schemes. Therefore, the uncertain effects identified for Option 1 (smaller new settlements), 2 (larger new settlements) and 6 (urban extensions) in relation to SA Objective 9 are potentially minor positive.

SA Objective 11: To protect and conserve soil

4.49 All of the options would result in predominantly greenfield land take so all would have negative effects on SA Objective 11. However, it is likely that the smaller areas of higher value agricultural soils in Central Bedfordshire may be able to be avoided as development is delivered and therefore the negative effects identified are likely to be minor.

4.50 Option 1 (smaller new settlements), Option 2 (larger new settlements) and Option 6 (urban extensions) may provide better opportunities to achieve GI improvements and therefore minor positive effect are also expected for those three options.

SA Objective 12: To protect, enhance and manage biodiversity & geodiversity

SA Objective 14: To ensure the protection and enhancement of heritage assets, the historic environment and its setting

4.51 Effects relating to SA Objectives 12 and 14 will be influenced by the specific location of the new development which is unknown under each option. Therefore, uncertain effects are recorded for all of the options. Central Bedfordshire does not contain any internationally designated sites; however it contains and lies in close proximity to numerous national and local biodiversity designations, as well as numerous heritage assets, which may be adversely affected as new development is delivered and occupied. The design of new development offers the potential for mitigation to be achieved; however at this stage the effects remain uncertain.

SA Objective 13: To protect and enhance the landscape and townscape

4.52 Considering the predominantly rural character of much of Central Bedfordshire, and the proximity to the Chilterns AONB, new development has the potential for adverse effects on the landscape character. A number of existing settlements have been identified as having specific sensitivity to change. As such negative effects are expected for all options in relation to SA Objective 13.

4.53 Under Option 3 (village extensions) the negative effects could be significant given that effects may be more pronounced and harder to mitigate where development occurs at smaller villages.

4.54 Option 6 (urban extensions) may result in negative effects on the established townscape of larger settlements and could be most likely to result in development occurring by Luton, Houghton Regis and Dunstable for example which all lie partially within the setting of the Chilterns AONB. This option could therefore also have a significant negative effect although in all cases the effects are uncertain until the specific location and design of developments are known.

Summary and Conclusions

4.55 Many of the effects identified in relation to the six options are uncertain because they will depend on the specific location of development. For example, a large new settlement located in an area of high flood risk close to the AONB would have very different effects to one located in a less sensitive location. However, overall Options 2 (larger new settlements) and 5 (growth around sustainable transport hubs) are expected to have the highest number of significant positive effects against the SA Objectives.

4.56 The larger scale of development that would result from Option 2 means that there should be particularly good opportunities for the provision of services and facilities, employment opportunities, green infrastructure and sustainable transport infrastructure as part of the new development. Where specific thresholds for the provision of facilities such as schools exist, they are most likely to be met under this option. However, it is noted that lead in times may be long for a larger new settlement meaning that some of the positive effects would be seen over the medium-long term.

4.57 New developments should be more self-contained and more easily able to establish their own character. Option 1 (smaller new settlements) does not perform as well as Option 2 because smaller new settlements would not provide as good opportunities for creating a relatively self-contained settlement with a wide range of services, facilities and employment opportunities.

4.58 Option 5 (growth around sustainable transport hubs) performs particularly well in relation to the air quality, climate change and sustainable transport SA Objectives because of the ability to reduce levels of car use, and the accessibility to services, facilities and jobs for people without access to a car also contributes to the good performance of that option. In comparison,

4.59 Option 4 (growth around strategic roads) performs relatively poorly in the SA as it would be likely to facilitate high levels of car use amongst residents, with the associated impacts on air quality and greenhouse gas emissions.

4.60 Smaller developments that would occur under Option 3 (village extensions) would be likely to have much less in the way of on-site service provision compared to other options and levels of car use may be higher as residents need to travel to access jobs, services and facilities elsewhere. That option performs least well against the SA Objectives.

4.61 Option 6 (urban extensions) performs better than Option 3 (village extensions) in the SA as development on the edge of larger urban areas would provide residents with easier access, particularly via sustainable modes of transport, to services, facilities and employment opportunities.

4.62 Overall, the best performing options are Option 2 (larger new settlements), Option 5 (growth around sustainable transport hubs), and Option 6 (urban extensions), and the poorest performing are Option 3 (village extensions) and Option 4 (growth around strategic roads). Option 1 (smaller new settlements) falls in the middle of these two groups of options in terms of the likely sustainability effects.

Growth Scenario Options – Housing

4.63 In the Regulation 18 SA Report, five growth scenarios for housing were developed with potential growth locations in each of the four areas A-D and applying the opportunities for each of the approaches to distributing growth, aiming to minimise negative effects and maximise positive effects. The options appraised were:

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

4.64 The SA findings for these options were repeated in the Regulation 19 SA Report.

4.65 These five options are very specific, listing the strategic locations for development that would be included in each scenario and giving a total housing figure, each of which varies from the Objectively Assessed Need (OAN). Under this approach there are numerous other possible combinations of development locations that could also considered as alternative scenarios; therefore when the Supplementary SA Report was prepared in May 2020 in response to points raised by the Inspectors about the SA (EXAM69), these options were revisited. This process involved considering firstly how much development there should be, separately from the question of where it should be (through the appraisal of site options). The SA findings for the above five scenarios were therefore superseded by the Supplementary SA work and are not repeated in this report.

4.66 The Pre-Submission (Regulation 19) Local Plan (January 2018) included a housing target for Central Bedfordshire of 39,350 new homes between 2015 and 2035. This was comprised of 32,000 homes to meet Central Bedfordshire's OAN over that period, plus 7,350 homes to meet the unmet need arising from Luton. Because the Local Plan housing target is based on the OAN, it is not considered by CBC that there are reasonable alternative options for the amount of housing to be delivered through the Local Plan, which should be subject to SA.

4.67 A lower housing target would not meet the OAN and, given that there is sufficient land available in Central Bedfordshire to provide the identified housing requirement, this is therefore not a reasonable approach. There is no requirement to deliver new homes over and above the OAN figure. The Plan already seeks to go beyond CBC's OAN, to deliver homes to meet the unmet needs of Luton Borough. Bearing in mind CBC has also committed to an early partial review, meaning that the housing target will be reviewed again in the near future, CBC believes it is appropriate to plan to meet the identified OAN at this stage and then to determine a longer-term housing target within the early partial review. As such, no higher than OAN option has been tested.

4.68 Alternative options for the quantum of housing development to be delivered through the Local Plan were therefore not considered in the Supplementary SA (May 2020).

Growth Scenario Options – Employment

4.69 Two growth scenarios for employment were developed and appraised in the Regulation 18 SA. These options were:

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

4.70 The SA findings for these scenarios were repeated in the Regulation 19 SA Report.

4.71 As with the options for the housing growth scenarios, these options were revisited as part of preparing the Supplementary SA Report (May 2020) and it was again decided to separate the question of how much employment development there should be from the question of where it should be (through the SA of site options). The work undertaken on the employment strategy options as part of the Supplementary SA is described below.

Options Relating to Strategic Warehousing Provision

4.72 As alluded to in the Inspectors' post-hearing letter to CBC (EXAM69), there are alternative overall strategies for employment growth which could include whether or not to cater for the 'footloose' demand in the logistics and distribution sector. Therefore, SA work was carried out and presented in the Supplementary SA Report (May 2020) in relation to the following options:

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

4.73 A new combined SA matrix was prepared to appraise these options. The appraisal of these options focussed on the likely 'in principle' sustainability effects of providing or not providing land to meet some of the footloose regional requirement for strategic warehousing. Because this footloose regional demand had at this time not been quantified, there was no evidence on which to base a set of more detailed alternative options considering specific amounts of such development that could be provided within Central Bedfordshire. Instead, the appraisal focused on the principles of providing this type of development or not and reflected the uncertainty about how much there might be. The SA findings for the reasonable alternative employment site options would then inform CBC's decision making about whether particular sites should be allocated to contribute to this need.

4.74 Since the Supplementary SA Report was prepared, an Employment Land Update Note (EXAM109) has been published. This identified strong demand for strategic warehousing in Central Bedfordshire. It concluded that the 140ha allocated in the Local Plan as submitted is sufficient to meet demand at least until such time as the Local Plan is reviewed, and beyond if the market for strategic warehousing 'cools' from its current position.

Options for Meeting Local Employment Needs

4.75 In terms of the quantum of employment land to be provided to meet the Objectively Assessed (local) Need, the evidence^[17] shows that a minimum of 24,000 jobs will be required over the Local Plan period. It is not considered by CBCto be a reasonable option to allocate land for fewer than 24,000 new jobs because there are sufficient available sites within Central Bedfordshire and so there is no justification for planning not to meet the identified need for jobs. The option of providing additional employment land is considered in relation to the provision of sites for footloose strategic warehousing, as described above.

SA Findings for the Employment Strategy Options

4.76 The SA findings for the two employment strategy options (originally presented in the Supplementary SA Report) are summarised below.

4.77 The effects of Option 2 are expected to be negligible (0) in relation to all but one of the SA Objectives, as the option would not involve any development taking place (the appraisal focuses just on the effects of not providing land for footloose strategic warehousing - it is not an appraisal of the employment land being provided in the Local Plan to meet local needs).

4.78 The effects of Option 1 on the SA Objectives are more varied. Potential negative effects have been identified in relation to several of the environmental SA Objectives including SA Objective 12: Biodiversity and Geodiversity, SA Objective 13: Landscape and SA Objective 14: Historic Environment, due to the presence of sensitive features and other constraints such as designated sites, listed buildings, scheduled monuments and the Chilterns AONB within the A1 and M1 corridors where strategic warehousing sites are expected to be located. The negative effects on the landscape and historic environment could be considered to be potentially significant because of the value of sensitive features and their proximity to those areas, and because strategic warehousing can be of a large scale and in some instances may feature prominently in the landscape, as well as requiring supporting infrastructure. However, in all cases these effects are uncertain until the specific location and design of sites is known and it is recognised that it may be possible to mitigate effects, for example through appropriate design.

4.79 Option 1 could also have minor negative effects on SA Objective 9: Water Resources and Quality, SA Objective 10: Flood Risk and SA Objective 11: Soils, as there are waterbodies, Source Protection Zones, areas of high flood risk and high quality agricultural land within the A1 and M1 corridors, all of which could be adversely affected by the development of strategic warehousing sites. Again, the potential minor negative effects are uncertain until the specific location of sites is known. Effects on flood risk may also be able to be mitigated through appropriate design, for example the incorporation of SuDS and the implementation of appropriate construction and operational practices onsite.

4.80 The effects of Option 1 on SA Objective 6: Highways and Air Quality could be significantly negative, as there are known to be areas within the A1 and M1 corridors already affected by congestion and poor air quality, which could be compounded by HGV movements. While it may be possible to incorporate mitigation such as the provision of new bus services, most employees are likely to travel to these types of sites via car; therefore potential minor negative effects are also identified in relation to SA Objective 7: Sustainable Transport and SA Objective 5: Health and Equality. However, the effects on SA Objective 5 are mixed overall as a potential minor positive effect is also identified due to the fact that providing additional employment opportunities at strategic warehousing sites would benefit the local economy and so should help to address economic inequalities within Central Bedfordshire.

4.81 The effects of Option 1 on SA Objective 3: Services and Facilities and SA Objective 4: Employment could also be positive as the provision of new strategic warehousing sites would increase employment opportunities locally (as well as for people living outside of Central Bedfordshire) and, depending on where sites are located, people may have good access to services and facilities at nearby towns.

4.82 Option 2 would have a minor negative effect on SA Objective 4: Employment because there is widely acknowledged regional demand for footloose logistics warehousing sites associated with the strategic transport network. Given Central Bedfordshire's location on the strategic transport network, it is well-placed to contribute towards meeting a proportion of this demand. If the Council were not to make any provision for such footloose warehousing through the Local Plan, this would have a minor negative effect on support for the regional and local economy and would also reduce the number and range of job opportunities that would otherwise be made available. It is considered to be a minor rather than significant negative effect as this type of development could potentially be provided elsewhere along the strategic transport network in this part of the country, thereby meeting demand.

Summary and Conclusions

4.83 As noted previously, Option 2 would have negligible effects on all but one of the SA Objectives, with the exception being a minor negative effect against SA Objective 4: Employment due to the lost opportunity to contribute towards regional and local economic development and associated jobs.

4.84 The effects of Option 1 are generally positive in relation to the social and economic SA Objectives, as warehousing sites would provide employment opportunities and potentially help to address inequalities.

4.85 However, the effects of Option 1 on the environmental SA Objectives are generally negative. Because strategic warehousing developments are usually large in scale, they can be prominent features in the landscape and any adverse effects on the landscape and cultural heritage, in particular, may be difficult to mitigate.

4.86 The nature of these developments also means that they are likely to be located close to the main roads, with many employees likely to travel to work via car with the associated impacts on air quality and greenhouse gas emissions. However, the negative effects are uncertain until the location and design of sites are known, and mitigation proposals are detailed. As the effects at this strategic level of assessment are so uncertain, it is difficult to conclude whether the social and economic benefits of warehouse sites could outweigh the potential negative effects.

Figure 4.1: Areas for Development Growth (A-D)