Sustainability Appraisal Main Modifications Report

5.1 This chapter presents the SA findings for the reasonable alternative strategic residential and employment site options.

5.2 Thirty eight strategic growth options for residential development were identified at the Regulation 18 stage, with nine of these being considered by CBC to be reasonable alternative options for the purposes of SA. These nine options, as well as four options involving growth in the villages in each of areas A-D, were appraised and the findings were presented in the Regulation 18 SA Report.

5.3 The Regulation 18 SA Report also included an appraisal of three alternative strategic employment sites to contribute to the regional footloose demand that had been identified:

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

5.4 At the Regulation 19 stage, further work was undertaken to identify and investigate potential site options for allocation. Each option for the strategic major development sites was subject to detailed SA and the findings were presented in the Regulation 19 SA Report.

5.5 In a letter to the Council following initial Examination hearings (EXAM69) the Inspectors queried potential inconsistencies between the SA findings for certain site options and some of the other assessment work carried out by the Council.

5.6 Therefore, as part of the Supplementary SA work published in May 2020, a review was undertaken of the appraisal criteria that were used to inform the appraisal of sites against each SA Objective and consideration was given to whether any changes to the criteria should be made. The review did not identify any fundamental gaps in the evidence used to inform the SA which could have led to the identified inconsistencies and did not result in any changes to the appraisal criteria used.

5.7 In order to ensure that the SA is consistent with other evidence, the appraisal work for strategic sites that was undertaken previously was reviewed and any areas of inconsistency identified were addressed in the Supplementary SA report (May 2020).

5.8 A review was also undertaken as part of the Supplementary SA to determine whether the strategic sites appraised previously still remained the reasonable alternative options (see the audit trail of options in Appendix C). As a result of this review, a number of changes were made to the list of reasonable alternatives including the addition of some further reasonable alternative options based on the Inspectors' comments following the initial Examination hearings (EXAM69) about there being potential discrepancies between the capacities considered for certain sites.

5.9 The changes made to the suite of reasonable alternative strategic housing site options are detailed in Appendix C and the updated SA findings for these options (originally presented in the Supplementary SA Report (May 2020)) are summarised further ahead in this chapter.

5.10 A further 13 reasonable alternative employment site options were also appraised in the Supplementary SA (May 2020). These sites had passed the strategic site assessment stage in the Strategic Employment Site Assessment Technical Document^[18] and so are considered to be reasonable alternative options for the purposes of SA; however they were previously omitted from the SA process on the basis that they had been assessed in more detail in the Strategic Employment Site Assessment Technical Document and discounted for not meeting specific criteria that CBC considered necessary and appropriate for the delivery of strategic, stand-alone warehousing and distribution uses. Whilst an assessment of all but one of these sites was carried out, which included sustainability criteria, they should have been included in the SA and assessed consistently against the SA Objectives. One site was also omitted in error. An updated summary of the SA findings for all 16 strategic employment site options (as previously presented in the May 2020 Supplementary SA Report) is provided further ahead in this chapter.

SA Findings for the Strategic Housing Site Options

5.11 The audit trail of residential site options in Appendix C (see Table C.5) lists the 19 reasonable alternative options that have been subject to SA. These sites are mapped in Figure 5.1 at the end of this chapter. As described above, not all of these options had been subject to SA prior to the Supplementary SA Report in May 2020 – several of the site options were identified by CBC following a review of whether alternative boundaries or capacities should be considered for certain sites (where this is the case, these comprise reasonable alternative options which should be appraised individually).

5.12 Table C.5 in Appendix C also sets out the Council's reasons for selecting or rejecting each strategic housing site option for inclusion in the Local Plan as proposed to be modified.

5.13 Table 5.1 overleaf presents a summary of the SA findings for the 19 residential site options. The likely sustainability effects of these sites are summarised below the table.

Table 5.1: Summary of SA findings for the residential site options

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

5.14 All 19 sites are being considered primarily for residential use. It is expected that all sites would benefit a range of residents given that Local Plan policy on Housing Mix requires new development to provide an appropriate mix of housing types, tenures and sizes. Site options in close proximity to Luton (i.e. Luton North Options 1-3 and Luton West Options 1-3) would help contribute to the unmet housing need of Luton Borough within that Housing Market Area (HMA). All 19 sites are expected to have significant positive effects in relation to SA Objective 1.

5.15 It should be noted that the options which would provide lower levels of housing (i.e. Arlesey Option 3, Luton North Option 2 and Luton West Option 1) are also expected to support the lowest levels of affordable housing provision.

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

5.16 As shown in Table 2.1 in Chapter 2, there are two elements to the appraisal of options against this SA Objective – the first relating to the site's position in relation to the Green Belt and the second relating to the effects on community and settlement identities.

5.17 The six sites in closest proximity to Luton (Luton North Options 1-3 and Luton West Options 1-3) all contain land that is within the Green Belt. Significant negative effects are therefore expected for these sites in relation to the first element of this SA Objective^[19]. Significant negative effects are also expected for Houghton Regis North which contains Green Belt land. The remaining 12 sites are outside of the Green Belt and therefore neutral effects are expected for the first part of this SA Objective.

5.18 Three sites are expected to have a significant negative effect in relation to the second element of this SA Objective. Development at Marston Moretaine North (Marston Thrift) or at Marston Moretaine South (Marston Vale) could contribute to coalescence between a number of smaller settlements (including Marston Moretaine, Lower Shelton and Cranfield) as well impacts on the identities of these settlements. Similarly, development at Tempsford South and Tempsford Airfield could contribute to coalescence with the settlements of Everton and Sandy with Tempsford.

5.19 Fourteen of the residential sites are expected to have minor negative effects in relation to the character of nearby settlements. For 11 of these sites^[20] the minor negative effects are more certain considering that there could be a contribution to settlement coalescence. For three sites (Aspley Guise; Houghton Regis North; and North and North East Sandy) the minor negative effects are uncertain. The negative effects identified for Aspley Guise and North and North East Sandy relate to the potential difficulty to integrate new development as a result of the presence of a railway line or strategic road which might create severance between the new development and existing settlements. Uncertainty is identified given that this issue may be able to be resolved when specific proposals come forward. At Houghton Regis North, the potential negative effect is associated with the potential for coalescence to occur with Luton to the east and Chalton to the north; however there is uncertainty because of the presence of the A5 which means that there is a defensible barrier between Houghton Regis and Chalton.

5.20 Only two sites (Biggleswade East Phase 1 and Henlow Airfield and Camp) are expected to have a positive effect in relation to the second part of SA Objective 2.

5.21 It is considered likely that development directly to the east of Biggleswade (Phase 1) could integrate well with the existing settlement and contribute to the identity of the existing community. For Biggleswade East Phase 2, a minor negative effect has been recorded in relation to this part of SA Objective. That site would represent a strategic increase in housing development within the existing countryside further to the east of the town meaning there could be detrimental impacts on settlement character. The Phase 2 site option could also negatively affect the rural and separated nature of the villages of Sutton and Dunton.

5.22 Development at Henlow Airfield and Camp would take in land which is currently developed and would not result in a major extension of the current settlement boundary. As such, benefits may occur in terms of settlement identity and a minor positive effect is expected in relation to the second part of SA Objective 2.

SA Objective 3: To improve accessibility to services and facilities

5.23 All of the residential site options are likely to support the delivery of new services and facilities in Central Bedfordshire. This will help meet the needs of new residents as homes are occupied and could also benefit existing residents. All of the site options are located in close proximity to existing services and facilities at settlements within Central Bedfordshire or within neighbouring Districts, including at Luton (sites Luton North Options 1-3 and Luton West Options 1-3) and Milton Keynes (Aspley Guise). Significant positive effects are therefore expected for all 19 site options effects in relation to SA Objective 3.

5.24 Where potential issues relating to access have been identified, particularly the suitability or accessibility of existing local services and facilities or the provision of new services and facilities to support growth, the potential positive effect is uncertain. This is the case for six site options. At Henlow Airfield and Camp the nearby service provision is relatively limited and the development of the site may result in the loss of the existing onsite services. Development at Marston Moretaine North (Marston Thrift) is not of a scale to provide a new secondary school and nearby facilities have been identified as having existing capacity pressures. For Luton West Options 1-3 the accessibility of existing services and facilities within Luton from the site will be dependent in part upon the delivery of new infrastructure to support access across the M1. At North and North East Sandy, the uncertainty is associated with the potential for development of the site to result in competition with the town centre of Sandy.

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

5.25 As described in Table 2.1 in Chapter 2, there are two elements to the appraisal of options against this SA Objective – the first relating to the provision of employment opportunities and the second to the vitality/viability of town centres.

5.26 All of the site options are being considered primarily to accommodate new housing and for the sites where employment land is not proposed alongside the housing, the potential for making a contribution to the local economy beyond the construction phase is likely to be limited to non-B uses such as employment in retail units and schools and, indirectly, to the provision of homes for working age people.

5.27 However, new employment land is to be provided as part of the development of 12 of the site options^[21]. For two of the site options (Luton North Option 1) and Marston Moretaine South (Marston Vale) this would be more than 10ha; therefore significant positive effects are likely in relation to the first part of this SA Objective for those site options. A further 10 site options^[22] are likely to have a minor positive effect as they will provide employment land, but less than 10ha. For Biggleswade East Phase 2 and North and North East Sandy, the quantum of the employment land to be provided is unknown. Therefore, the positive effects identified for these sites are uncertain. Uncertain minor positive effects are also identified for the North and North East Sandy site given that the site promoter has indicated that an unknown amount of employment land could be provided at the site.

5.28 For the seven remaining sites^[23] no employment land is expected to be provided as part of the development. Therefore, neutral effects are expected in relation to the first part of SA Objective 4.

5.29 The second element of this SA Objective relates to the potential for the site options to support the viability of town centres. As described in relation to SA Objective 3, all of the site options being considered are relatively well-related to existing settlements within Central Bedfordshire and, in some cases, in neighbouring districts. All 19 sites are therefore expected to have minor positive effects in relation to the second element of SA Objective 4. However, the potential positive effects are uncertain for Luton West Options 1-3 and Marston Moretaine North (Marston Thrift) as access on foot from these sites to the nearby centres may be limited due to the presence of the strategic road network.

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

5.30 As described in Table 2.1 in Chapter 2, there are two elements to the appraisal of options against this SA Objective – the first relating to regeneration/deprivation and equality, and the second to green infrastructure for health and wellbeing.

5.31 Ten of the 19 site options^[24] are not located within or in close proximity to areas of higher deprivation. These sites are therefore expected to have neutral effects in relation to the first element of SA Objective 5. Only one site (Houghton Regis North) takes in land which is within an area of higher deprivation. This site is expected to have significant positive effects in relation to the first element of SA Objective 5, given that new development may directly help to deliver regeneration in that area. Minor positive effects are expected for the remaining eight site options^[25] which are in close proximity to, but not within, areas of higher deprivation.

5.32 All sites would fall within or are in close proximity to areas of the strategic green infrastructure network and therefore could help to support the incorporation of multi-functional green infrastructure as new development occurs. Significant positive effects are therefore expected for all 19 site options in relation to the second part of SA Objective 5.

5.33 It should be noted that compared to Arlesey Option 1, Arlesey Options 2 and 3 have less certainty in relation to the delivery of the new country park as the land for its provision would fall outside of the site boundary under those two options. A new country park, if delivered, would benefit new and existing residents in the surrounding area in terms of access to open space. The provision of a country park would also strengthen the significant positive effect expected for the Arlesey Option 1 site in relation to the second part of SA Objective 5 in the long term.

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

5.34 All new residential development in Central Bedfordshire is likely to result in increased traffic generation. Access to the strategic road network and sustainable transport links is provided from most of the site options and many options would be supported by new highways improvements. Mitigation relating to traffic generation is provided through draft Local Plan policies relating to Strategic Transport Improvements, Mitigation of Transport Impacts on the Network, Connectivity and Accessibility, Development and Public Transport Interchanges and Low Emission Vehicles.

5.35 Of the 19 site options, six (Luton North Options 1-3; Marston Moretaine North (Marston Thrift); Marston Moretaine South (Marston Vale)); and Tempsford South and Tempsford Airfield are expected to have minor negative effects in relation to SA Objective 6 due to the potential for increased road stress and congestion resulting from development which would require the provision of new infrastructure and/or lead to indirect contributions to increases in existing air pollution within AQMAs. These effects are uncertain, however, dependent upon the potential for mitigation to be achieved and recognising the good level of access to the strategic road network and/or sustainable transport links from these sites.

5.36 Six sites are expected to have significant negative effects in relation to this SA Objective. This includes two sites (Houghton Regis North and North and North East Sandy) which are in particularly close proximity to AQMAs where the existing air quality issues could be exacerbated. It also includes three site options by Luton (Luton West Options 1-3). It is likely that the three Luton West Options could lead to the aggravation of air pollution within the three AQMAs in Luton as well as one in Dunstable. These three options would also require access to Junction 10 of the M1 which is likely to adversely affect traffic flows on the local and strategic road network. A significant negative effect has also been identified for Henlow Airfield and Camp considering the constraints on the number of vehicle movements on the A600 which would be one of the main points of access to this site.

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

5.37 All of the site options are expected to have positive effects in relation to SA Objective 7. The positive effects for Marston Moretaine South (Marston Vale) and Aspley Guise are likely to be significant given that these sites are within walking distance of railway stations as well as bus stops which benefit from frequent services. Marston Moretaine South (Marston Vale) is in close proximity to two railway stations at Lidlington and Millbrook respectively, while the site at Aspley Guise is in close proximity to Aspley Guise railway station.

5.38 Minor positive effects are expected for the remaining 17 site options as they would provide access to some sustainable transport links but are not in close proximity to both railway links and frequent bus services. It is noted that while parts of the site at North and North East Sandy lie in close proximity to the railway station at Sandy, the large size of the site means that some parts would be quite a distance from the station. Furthermore, the railway line acts to separate the north east of the site from the railway station and other services and facilities within Sandy.

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

5.39 As described above in relation to SA Objective 7, all 19 residential site options would provide a good level of access to sustainable transport links, so increases in transport-related greenhouse gas emissions resulting from development could be minimised. Mitigation provided through local planning policy (draft Local Plan policy Connectivity and Accessibility) is expected to further promote the aim of minimising greenhouse gas emissions. Minor positive effects are therefore expected for all sites in relation to SA Objective 8.

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

5.40 Land within the boundaries of all of the residential site options falls within either the Upper Lea catchment (Luton North Options 1-3 and Luton West Options 1-3) or the Upper Bedford and Ouse catchment (all remaining sites). Climate change is likely to contribute to water supply stress in the coming years in Central Bedfordshire.

5.41 Information from the Water Cycle Study Stage 2^[26] indicates that Bedford, Biggleswade, Clifton, Marston Moretaine, Shillington and Tempsford are all forecast to exceed their permitted dry weather flow as a result of planned growth during the Local Plan period. These settlements all lie within the Upper Bedford and Ouse catchment area. Continued liaison between Central Bedfordshire Council and the Water Companies, as well as between developers and Water Companies, is essential to ensure that additional wastewater treatment works (WwTW) capacity is also in place in time to accommodate the planned growth, and that there will be no detriment to service to customers or to the environment. It is expected that this liaison on the investment required to limit the potential for adverse impacts on WwTW capacity will address this issue. Therefore, likely but currently uncertain neutral effects are identified for all residential site options in relation to SA Objective 9.

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

5.42 The majority (17) of the residential site options are on land which is mostly not at risk of flooding from overflowing rivers. These 17 site options are therefore expected to have neutral effects in relation to SA Objective 10. Only Biggleswade East Phases 1 and 2 contain more substantial areas of land which fall within Flood Zone 2 and Flood Zone 3. Minor negative effects are therefore expected for these two site options in relation to SA Objective 10.

SA Objective 11: To protect and conserve soil

5.43 As described in Table 2.1 in Chapter 2, there are two elements to the appraisal of options against this SA Objective – the first relating to greenfield and agricultural land quality and the second to previously developed land.

5.44 All 19 residential site options contain large areas of greenfield land including sizeable areas of Grade 1, Grade 2 or Grade 3 agricultural soils. Therefore, potential significant negative effects are identified in relation to the first part of this SA Objective. An element of uncertainty is attached until specific proposals for the sites come forward, and because the available data does not distinguish between Grade 3a and Grade 3b land (only Grade 3a land and above is considered to be the best and most versatile agricultural land).

5.45 Henlow Airfield and Camp; Marston Moretaine South (Marston Vale); and Tempsford South and Tempsford Airfield are the only sites that are expected to have a minor positive effect in relation to the second element of SA Objective 11. While these sites contain mostly greenfield land, all have a history of uses which could result in land contamination. Development at these locations could therefore help promote the remediation of contaminated land in Central Bedfordshire. Development at the Henlow Airfield and Camp site would also likely result in the reuse of some previously developed land.

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

5.46 One significant positive effect is identified on SA Objective 12, in relation to Arlesey (Option 1). This option provides for the delivery of a new country park within the site boundaries which would help to mitigate the potential for increased recreational pressure on biodiversity sites nearby and would improve habitat connectivity in the area. Arlesey Options 2 and 3 provide less certainty for the delivery of the country park than Arlesey Option 1, as these two options would not incorporate the new country park within their boundaries. Minor positive effects are therefore associated with those two options. In all three cases, likely effects are mixed as the development proposed could also have minor negative effects on biodiversity assets in the area.

5.47 Only one of the residential site options (Luton West Option 3) could have a significant negative effect on biodiversity. This site is located in relatively close proximity to Blow's Down SSSI at which increases in recreational use and noise and light pollution may cause harm. Furthermore, the site contains two County Wildlife Sites (CWSs). The other site options considered for Luton West (Options 1 and 2) are expected to have minor negative effects in relation to this SA Objective. These sites lie further away from the SSSI and contain fewer CWSs. Luton West Option 1 does not contain any CWSs but is adjacent to three, while Luton West Option 2 contains Badgerdell Wood CWS. For all three of these options, substantial new open space is to be incorporated. This is likely to go some way to help mitigate recreational pressures on nearby biodiversity sites and could also help to promote habitat connectivity in the area. Therefore, the negative effects are recorded in combination with minor positive effects.

5.48 Henlow Airfield and Camp; Luton North Options 1-3; Marston Moretaine North (Marston Thrift); Marston Moretaine South (Marston Vale); Tempsford South and Tempsford Airfield; Wixams South; Houghton Regis North; and North and North East Sandy are also expected to have mixed effects in relation to this SA Objective.

5.49 The Luton North Options all lie in close proximity to designated biodiversity sites but the potential for improvements to the local biodiversity network including the provision of ecological corridors or stepping stones has also been identified. Similarly, Tempsford South and Tempsford Airfield is near to a number of nationally designated sites; however the site is expected to deliver a significant amount of accessible open space which may reduce pressure on nearby biodiversity sites.

5.50 At Marston Moretaine North the close proximity of biodiversity designations means that there is potential for habitat disturbance, but there is also potential for improved connectivity between the nearby SSSI, Local Nature Reserve (LNR) and CWSs. This is also the case at Marston Moretaine South and Wixams South where the nearby CWSs lie within or in close proximity to the biodiversity network and in close proximity to the Greensand Ridge Nature Improvement Area, meaning there is potential for improvements to ecological connectivity on a strategic scale.

5.51 The Henlow Airfield and Camp site currently lies in an area with limited connection to the biodiversity network meaning that new ecological corridors could be of particular benefit to wildlife in this area. The site is in close proximity to local biodiversity designations meaning that habitat disturbance might result as development occurs and is occupied and therefore an overall mixed effect is recorded for this site option in relation to SA Objective 12. The Houghton Regis North and North and North East Sandy sites are both to provide substantial amounts of new open space to help limit the potential for increased recreational pressures on nearby biodiversity sites, which could also support habitat connectivity in the area.

5.52 The three remaining site options (Aspley Guise, Biggleswade East Phase 1 and Biggleswade East Phase 2) are expected to have minor negative effects alone in relation to this SA Objective. These sites contain or are in close proximity to areas of Priority Habitat or CWSs which may mean that habitat fragmentation or disturbance results as development is delivered and occupied.

5.53 Local planning policy would help to provide mitigation as far as is possible in relation to impacts on wildlife in the plan area. This is of particular relevance where development could have adverse effects relating to habitat loss and fragmentation. Draft policies on Nature Conservation and Enhancing Ecological Networks, for example, require that new developments contribute positively to local biodiversity and ensure that designated sites are protected.

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

5.54 The Chilterns AONB lies within Central Bedfordshire near the boundary with Luton, in close proximity to Dunstable and Houghton Regis. Significant negative effects are expected where development might result in harm to the setting and special character of this designated landscape. This includes a number of the site options in close proximity to the boundary with Luton Borough (Luton North Option 1 and Luton West Options 2 and 3). The boundaries for the other Luton site options (Luton North Option 2-3 and Luton West Option 1) have been drawn to be considerate of the topography and landscape sensitivities of the area, so as to limit the potential for adverse impacts on the AONB. Therefore, for those site options, the negative effects recorded are minor.

5.55 Only two further site options (Tempsford South and Tempsford Airfield and North and North East Sandy) are expected to have minor negative effects alone in relation to SA Objective 13. Development at these sites has the potential to impact upon the sensitivities of the landscape character area in which they lie.

5.56 The three site options at Arlesey are expected to have mixed (minor positive and minor negative) effects on landscape character. This land has been identified in the site assessment work as having low/medium landscape sensitivity and there is potential for development to be integrated well within the local landscape. Development at this location could, however, result in detrimental impacts on the existing open nature of surrounding arable farmland.

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

5.57 Only three sites (Biggleswade East Phase 2; Henlow Airfield and Camp; and Tempsford South and Tempsford Airfield) contain designated heritage assets. Development at these site options is considered to have potential for particular harm on these heritage assets or their respective settings. Therefore, a significant negative effect on this objective is expected.

5.58 Thirteen of the 19 site options^[27] are expected to have minor negative effects in relation to SA Objective 14. These sites do not contain designated heritage assets but all lie in close proximity to such features meaning there is potential for impacts upon their settings.

5.59 Neutral effects are expected for the remaining three site options^[28]. These sites are located a substantial distance away from the closest heritage assets and/or there is existing development present between the site and the identified assets meaning the potential for effects on their setting is minimal.

5.60 The effects for all of the site options are uncertain, however, until specific proposals are set out for each site. It is noted that the sites all contain at least one Archaeological Notification Area and development could allow for the investigation and recording of heritage assets of archaeological significance. These processes could promote a better understanding of local assets dependent upon how they are eventually undertaken.

Summary and Conclusions

5.61 The likely sustainability effects of the 19 residential site options are not particularly varied in terms of the number of likely significant positive and negative effects identified. The most significant positive effects associated with a single residential site option is five, which is the case for Marston Moretaine South (Marston Vale). There are only two potential significant negative effects associated with that site, so overall it performs best against the SA Objectives. Looking across the SA Objectives, the other sites that perform relatively well are Arlesey (in particular Option 1), Aspley Guise, Biggleswade East Phase 1, and Wixams South.

5.62 The three Luton West options perform the least well, with three significant negative effects associated with Option 1, four with Option 2 and five with Option 3. The Luton North options perform slightly better, but not as well as many of the other options. Luton North Option 1 also has three significant negative effects but these are counterbalanced by four significant positive effects. The other two Luton North options have two significant negative and three significant positive effects each. Tempsford South and Tempsford Airfield performs similarly to the Luton options, with three significant negative effects.

5.63 Henlow Airfield and Camp and Houghton Regis North also have three significant effects, but these each have three significant positive effects. As a result these two options perform in the middle of all the options, along with Marston Moretaine North (Marston Thrift) and Biggleswade East Phase 2.

Growth Locations for Development Growth – Employment

5.64 The audit trail of employment site options in Appendix C (see Table C.6) lists the 16 reasonable alternative options that have been subject to SA. The locations of these site options are mapped in Figure 5.2 at the end of this chapter.

5.65  Table C.5 in Appendix C also sets out the Council's reasons for selecting or rejecting each strategic employment site option for inclusion in the Local Plan as proposed to be modified.

5.66  Table 5.2 below presents a summary of the SA findings for the 16 employment site options, as previously presented in the Supplementary SA Report (May 2020). The likely sustainability effects of these sites are summarised below the table.

Table 5.2: Summary of SA findings for employment site options

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

5.67  All of these site options are being considered for standalone, strategic employment uses and none would contribute to housing supply in Central Bedfordshire. Therefore, all 16 sites are expected to have neutral effects in relation to SA Objective 1.

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

5.68 As described in Table 2.1 in Chapter 2, there are two elements to the appraisal of options against this SA Objective – the first relating to the site's position in relation to the Green Belt and the second relating to the effects on community and settlement identities.

5.69  Three sites (Sundon Rail Freight Interchange; Land East of Junction 11A and North of Vauxhall Plant; and Checkley Wood Garden Village) all lie within the Green Belt and therefore are expected to have significant negative effects in relation to the first element of this SA Objective^[29]. The remaining 13 sites do not take in Green Belt land and therefore neutral effects are expected.

5.70 Of the three sites identified as having significant negative effects in relation to the potential loss of Green Belt land, two of them (Land East of Junction 11A and North of Vauxhall Plant; and Checkley Wood Garden Village) are also expected to have minor negative effect in relation to the character of nearby settlements. Land East of Junction 11A and North of Vauxhall Plant could have adverse effects on the identity of the hamlet directly adjacent to junction 11a (understood to be part of Chalton), while Checkley Wood Garden Village has the potential to contribute to the perception of coalescence between the settlements of Leighton Buzzard, Heath and Reach and Hockliffe.

5.71 Minor negative effects are also expected in relation to the second element of SA Objective 2 (community and settlement identities) for Land West of the A1, Biggleswade; West Sunderland Farm; and Aspley Guise Triangle/Milton Keynes South East Opportunity Area. These are sites at which there may be difficulties integrating with existing nearby settlements with potential for impacts on existing character and settlement identity. Only one site (Land at Marston Moretaine and Lower Shelton) is expected to have a significant negative effect in relation to the second element of this SA Objective. Development at this site would reduce the open space between Marston Moretaine and Cranfield and would also contribute to coalescence between Lower Shelton and Marston Moretaine.

5.72 Land at Wharley Farm is the only site which is expected to have a minor positive effect in relation to either element of SA Objective 2. Given the current uses which surround the site (university buildings focussing on science, technology and engineering), employment development could complement existing development.

SA Objective 3: To improve accessibility to services and facilities

5.73 The scale of development to be provided at each site is likely to mean that services and facilities can be provided on site to satisfy the needs of the employees, for example places to purchase and eat lunch. Given that these sites are proposed for employment development, it is expected that the need to access services and facilities on a regular basis would be more limited than from residential sites. All 16 site options are therefore expected to have neutral effects in relation to SA Objective 3.

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

5.74 As described in Table 2.1 in Chapter 2, there are two elements to the appraisal of options against this SA Objective – the first relating to the provision of employment opportunities and the second to the vitality/viability of town centres.

5.75 All of the employment site options are being considered to accommodate a strategic level of employment development (i.e. at least 10ha of employment land). Considering the high number of employment opportunities each site option is likely to support, all 16 options are expected to have significant positive effects in relation to first element of SA Objective 4.

5.76 The second element of this SA Objective relates to the potential for the site options to support the viability of town centres. For nine of the site options uncertain effects have been recorded. These site options are not located in close proximity to any town centres. Six site options are located in close proximity to one of the principal or secondary town centres of Central Bedfordshire and therefore could help to promote the viability of these locations. Significant positive effects have therefore been recorded in relation to the second element of this SA Objective for those sites. The two remaining site options (Land East of Junction 11A and North of Vauxhall Plant and Aspley Guise Triangle/Milton Keynes South East Opportunity Area) are not located within close proximity to any of the principal or secondary town centres in Central Bedfordshire. However, development at these locations could help to support the town centres of Luton and Milton Keynes respectively, with the potential for cross boundary effects to result. Therefore, minor positive effects have been recorded for those sites.

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

5.77 As described in Table 2.1 in Chapter 2, there are two elements to the appraisal of options against this SA Objective – the first relating to regeneration/deprivation and equality, and the second to green infrastructure for health and wellbeing.

5.78 The majority (14) of the 16 site options are not located within or in close proximity to a more deprived area as defined using data from the Indices of Multiple Deprivation. These fourteen sites are therefore expected to have neutral effects in relation to the first element of SA Objective 5 - promoting regeneration or renewal in areas of higher deprivation. Only two sites (Sundon Rail Freight Interchange and Land adjacent to Popes Farm) are expected to have minor positive effects in relation to this SA Objective. These sites lie in close proximity to more deprived areas in the North of Luton and Sandy respectively.

5.79 Development at the majority (14) of the employment site options would fall within or in close proximity to areas of the strategic green infrastructure network. Supporting improved links to the strategic green infrastructure network could provide employees at the sites with access to open space and recreational areas. Significant positive effects are therefore expected for these 14 site options in relation to the second part of SA Objective 5. The remaining two sites (Land at Wharley Farm and Cranfield University Campus and Airfield) do not lie in close proximity to the strategic green infrastructure network although it may be possible for development to support new green infrastructure provision. Minor positive effects have therefore been recorded in relation to the second element of SA Objective 5 for those two site options.

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

5.80  It is expected that at all new employment site options would result in increased traffic generation. Many of the site options provide access to the strategic road network, sustainable transport links and/or would be supported by new highways improvements. Furthermore, mitigation relating to traffic generation is provided through draft Local Plan policies relating to Strategic Transport Improvements, Mitigation of Transport Impacts on the Network, Connectivity and Accessibility, Development and Public Transport Interchanges and Low Emission Vehicles.

5.81  Of the 16 site options, 13 are expected to have minor negative effects in relation to SA Objective 6 considering the potential for increased numbers of journeys making use of surrounding roads. These effects are uncertain, however, dependent upon the potential for mitigation to be achieved and recognising the good level of access to the strategic road network and/or sustainable transport links from these sites. Sundon RFI is likely to have a mixed effect overall on this SA Objective, as the proposed use of the site as a rail freight interchange should contribute to taking heavy goods vehicles off the road.

5.82 Minor negative effects have been identified in relation to SA Objective 6 for Land at Marston Moretaine and Lower Shelton due to the current high level of congestion in close proximity to this site. The negative effects expected for the sites Land adjacent to Popes Farm; and Land East of Junction 11A and North of Vauxhall Plant are likely to be significant. Development at these locations could intensify existing air quality issues at the AQMAs declared along the A1 in Sandy and along the M1 at Luton respectively.

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

5.83  Fifteen out of the 16 site options are expected to have positive effects in relation to SA Objective 7. These positive effects are likely to be significant for three site options (Sundon Rail Freight Interchange; Land West of the A1, Biggleswade; and Land at Ridgmont (M1 Junction 13)) as they are in close proximity to railway stations as well as bus stops which benefit from frequent services. These links could be used by employees travelling to and from the sites. The proximity of certain sites to existing urban areas and therefore concentrations of sources of potential employees, such as Land West of the A1, Biggleswade which is within close proximity of Biggleswade, also contributes to the positive effects identified. Where sites are close to existing urban areas there will be more scope for reducing the need to travel as a higher number of employees may be able to travel shorter distances to work. This may also be more likely to be via sustainable modes of transport, including walking and cycling. The proposed use of Sundon RFI as a rail freight interchange also contributes to the positive effect identified as it would help to take freight traffic off the roads. Twelve further site options would provide access to some sustainable transport links but are not in close proximity to both railway and frequent bus links, so would have minor positive effects.

5.84  Only Checkley Wood Garden Village is not in close proximity to a railway station or bus stop. A county cycle path and numerous footpaths cross this site which may provide some opportunities for employees to make use of more sustainable modes of transport but the use of such opportunities are likely to be limited. Minor negative effects are therefore expected in relation to SA Objective 7 for this site option.

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

5.85  As described above in relation to SA Objective 7, 15 of the 16 employment site options would provide a good level of access to sustainable transport links. Development at these sites is therefore also expected to help minimise increases in greenhouse gas emissions in Central Bedfordshire as development is delivered. Mitigation provided through local planning policy (draft Local Plan policy Connectivity and Accessibility) is expected to further promote the aim of minimising greenhouse gas emissions. Minor positive effects are therefore expected for these 15 sites in relation to SA Objective 8.

5.86 The remaining site (Checkley Wood Garden Village) is relatively isolated from existing sustainable transport links and so the potential to achieve reductions in greenhouse gas emissions is expected to be limited. Negligible effects are therefore expected in relation to SA Objective 8 for this site.

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

5.87 All of the employment site options are located within either the Upper Lea catchment (Sundon Rail Freight Interchange; and Land East of Junction 11A and North of Vauxhall Plant) or the Upper Bedford and Ouse catchment (all remaining sites). One of the most likely effects of climate change to impact upon Central Bedfordshire will be increased stress on water resources.

5.88 Information from the Water Cycle Study Stage 2^[30] indicates that Bedford, Biggleswade, Clifton, Marston Moretaine, Shillington and Tempsford are all forecast to exceed their permitted dry weather flow as a result of planned growth during the Local Plan period. These settlements all lie within the Upper Bedford and Ouse catchment area. Continued liaison between Central Bedfordshire Council and the Water Companies, as well as between developers and Water Companies, is essential to ensure that additional wastewater treatment works (WwTW) capacity is in place in time to accommodate the planned growth, and that there will no detriment to service to customers or to the environment. It is expected that this liaison on the investment required can help to limit the potential for adverse impacts on WwTW capacity. Therefore, neutral effects are expected for all employment site options in relation to SA Objective 9. However, this is uncertain until specific proposals come forward.

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

5.89 All but one of the employment site options is located on land which is mostly not at risk of flooding from overflowing rivers. Neutral effects are therefore expected for these 15 sites in relation to SA Objective 10. Only Land adjacent to Popes Farm contains a substantial area (40% of the site) which falls within Flood Zone 2 and Flood Zone 3. Minor negative effects are therefore expected for this site in relation to SA Objective 10.

SA Objective 11: To protect and conserve soil

5.90 As described in Table 2.1 in Chapter 2, there are two elements to the appraisal of options against this SA Objective – the first relating to greenfield and agricultural land quality and the second to previously developed land.

5.91 Fifteen of the 16 employment site options contain large areas of greenfield land and so could have negative effects in relation to the first part of SA Objective 11. These sites all contain substantial areas of Grade 1, Grade 2 or Grade 3 agricultural soils. Therefore, the negative effect expected in relation to the first element of SA Objective 11 is likely to be significant. Given that the effects will be informed in part by site level surveys, an element of uncertainty is attached to the effects recorded.

5.92 Cranfield University Campus and Airfield contains only a small proportion of greenfield land with 90% of the land within its boundaries previously developed. Neutral effects are therefore expected for this site option in relation to the first element of SA Objective 11. As development at this site would help to promote the use of brownfield land in Central Bedfordshire, significant positive effects are expected in relation to the second element of SA Objective 11. This site was previously used as an airfield and development of the site may also support the remediation of contaminated land.

5.93 Only Checkley Wood Garden Village is also expected to have significant positive effects in relation to the second element of this SA Objective. While this site contains areas of Grade 3 agricultural soils there are also areas of the site which have been used as quarries and other associated land uses. Development of the site is likely to present opportunities for the use of brownfield land and to support the remediation of contaminated land in Central Bedfordshire. The remaining sites contain negligible amounts of brownfield land and therefore neutral effects are expected in relation to the second element of SA Objective 11.

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

5.94 None of the employment site options are within or in close proximity to an international biodiversity designation and therefore significant negative effects are not expected. A negative effect is expected in relation to SA Objective 12 for four sites (Sundon Rail Freight Interchange; Land at Marston Moretaine and Lower Shelton; Land East of Junction 11A and North of Vauxhall Plant; and Checkley Wood Garden Village), given that the sites contain or are in close proximity to SSSIs. For these sites, increases in noise and light pollution and/or recreational pressures could adversely impact the nationally designated sites nearby. These adverse impacts are weighed against the potential to achieve mitigation or enhancements at a site level and therefore the negative effects recorded are expected to be minor.

5.95 For the remaining 12 sites, the potential for habitat enhancements has been identified in relation to a Nature Improvement Area, the GI network and/or biodiversity network. Minor positive effects have therefore been recorded in relation to SA Objective 12 for 14 of these sites. The exception to this is Sundon Rail Freight Interchange. Overall, this is expected to have neutral effects in relation to SA Objective 12. Opportunities for enhancements to the biodiversity network have been identified for this site; however the site is in close proximity to Sundon Chalk Quarry SSSI and a number of County Wildlife Sites. Considering the relatively high number of biodiversity designations which are close to this site, the potential for light and noise pollution, increases in recreational pressures and increases in atmospheric pollutants could act to negate the potential benefits of development for biodiversity.

5.96 Where development could have adverse effects on habitats it is expected that local planning policy would help to provide mitigation as far as is possible. For example, draft policies Nature Conservation and Enhancing Ecological Networks require development to contribute positively to local biodiversity and the protection of designated sites.

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

5.97 Only one site (Sundon Rail Freight Interchange) is located within close proximity of the Chilterns AONB. Development at this location might have adverse impacts on the setting and special character of this designated landscape. It is recognised that there is some existing development between the location and the AONB, which gives some degree of buffering. However, considering the importance of the designated AONB landscape and the potential for adverse impacts on its setting resulting from increased urbanisation in the area, overall significant negative effects are expected for this site in relation to SA Objective 13.

5.98 Aspley Guise Triangle/Milton Keynes South East Opportunity Area; Checkley Wood Garden Village; West Sunderland Farm; and Land at Hitchin Road, Shefford are also expected to have significant negative effects in relation to SA Objective 13. For these sites Aspley Guise Triangle/Milton Keynes South East Opportunity Area; and Checkley Wood Garden Village the Council site assessment work has determined that development would be unacceptable in landscape terms. For the remaining two sites particularly limited scope for development has been identified considering the sensitivity of the landscape character. One further site (Land at Bedford Road, Husborne Crawley) is expected to have significant negative effects in relation to this SA Objective. This site lies within the vale landscape of the Aspley Triangle which has been assessed through as having moderate – high landscape sensitivity.

5.99 Land adjacent to Popes Farm has been identified as having landscape sensitivities which are likely to mean that the scope for development is limited. However, it is considered likely that development could be acceptable at this site in terms of landscape character if mitigation measures are implemented. Therefore, overall neutral effects are expected for this site option in relation to SA Objective 13.

5.100 The Council's site assessment work has not identified specific landscape sensitivities which might otherwise limit the potential for the nine^[31] remaining site options. It is expected that development at these locations could help respond positively to the landscape strategies of the relevant landscape character areas. Therefore, minor positive effects are identified for these nine site options.

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

5.101 Only one of the 16 site options is expected to have significant negative effects in relation to SA Objective 14 - West Sunderland Farm, which is adjacent to Sutton Conservation Area. It also contains the Newton Bury moated site scheduled monument and lies within the setting of two other scheduled monuments. Site assessment work by the Council indicates that development at the site has potential to result in substantial harm to the settings of these scheduled monuments and overall is considered to be unsuitable in terms of potential impacts on the historic environment.

5.102 Minor negative effects are expected for a further six site options. These sites are in close proximity to heritage assets and therefore development may have impacts upon their respective settings. However, the design of new development and Local Plan policy (Built Heritage) may help mitigate the potential for adverse effects. Neutral effects are expected for the remaining nine site options. These are sites where the closest heritage assets to the site are located a substantial distance away and/or are already set among existing development meaning the potential for effects on their setting is reduced.

5.103 The overall effects for 13 of the site options are uncertain. These sites contain at least one Archaeological Notification Area, and so development could involve investigating and recording heritage assets of archaeological significance. At such there is potential for better understanding of local assets dependent upon how this process is eventually undertaken.

Summary and Conclusions

5.104 The likely sustainability effects of the 16 employment site options are not particularly varied in terms of the number of likely significant positive and negative effects identified. The most significant positive effects associated with a single employment site option is four, which is the case for two sites (Sundon Rail Freight Interchange and Land West of the A1, Biggleswade). However, Sundon Rail Freight Interchange, along with three other sites (Land East of Junction 11A and North of Vauxhall Plant; West Sunderland Farm and Checkley Wood Garden Village) also has the largest number of significant negative effects associated with any one site (three).

5.105 Looking across all the SA Objectives, the employment sites that perform most strongly are Cranfield University Campus and Airfield, Land West of the A1, Biggleswade, Land at Ridgmont (M1 Junction 13), New Spring Farm, Biggleswade, and Land East of M1, South of Broughton Road. The employment sites that perform least well are Checkley Wood Garden Village, Land East of Junction 11A and North of Vauxhall Plant, Land at Marston Moretaine and Lower Shelton, West Sunderland Farm, and Aspley Guise Triangle/Milton Keynes South East Opportunity Area. The other employment sites fall between these two groups of sites.

Figure 5.1: Location of residential site options

Figure 5.2: Location of employment site options