Sustainability Appraisal Main Modifications Report

Ended on the 5 May 2021
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Chapter 9 - Reasons for Choosing the Plan and Monitoring

Reasons for Choosing the Plan

9.1 A statement has been prepared by CBC in accordance with the requirements of Regulation 16 of the Environmental Assessment of Plans and Programmes Regulations 2004 (see green box below). This statement outlines how environmental considerations have been integrated into the Local Plan, how the Sustainability Appraisal has been taken into account, how consultation responses have been taken into account and the reasons for choosing the Local Plan policies in light of alternative options. Information about the measures that will be taken to monitor the effects of the Local Plan is set out in the next section.

How environmental and sustainability considerations have been integrated into the Central Bedfordshire Local Plan

The Sustainability Appraisal has been conducted in such a way that it meets the requirements of the Strategic Environment Assessment Regulations and UK Government guidance on the preparation of Sustainability Appraisals. As required by the Regulations, the Sustainability Appraisal has been developed through an iterative process and has informed decision making at every stage of developing the Central Bedfordshire Local Plan.

The initial informative stage of the Sustainability Appraisal was the Scoping process. The Scoping process was undertaken in October 2016 and incorporated a Strategic Environmental Assessment, Health Impact Assessment and Equalities Assessment and included a review of other relevant plans, programmes and strategies that have an influence on sustainability and provide the policy context for the Local Plan. It identified the scope and level of detail of the information to be included within the Sustainability Appraisal Report. It also set the context, objectives and approach of the assessment as well as identifying the relevant environmental, economic and social issues and objectives.

How the Sustainability Appraisal has been taken into account

The distribution of growth across Central Bedfordshire as well as policies and strategic sites have been subject to Sustainability Appraisal throughout the plan-making process, along with reasonable alternative options. Each policy and proposal has been assessed against the social, environmental and economic objectives in the SA Framework in order to establish the likely positive and negative effects, both minor and significant. The results of the appraisals were used to inform the decision making process and establish appropriate options to take forward within the Plan.

A Supplementary SA was undertaken following the initial Examination Hearings into the Central Bedfordshire Local Plan. The Supplementary SA considered additional reasonable alternatives in relation the strategic residential-led allocations as well as the reasonable alternatives for strategic employment sites and other strategic options. The reasons for discounting alternative strategic options are set out in detail in Chapter 5 of the Supplementary SA.

The Local Plan, the SA and representations upon them have been subject to comprehensive and detailed examination by independent Inspectors appointed by the Secretary of State. The examination, coupled with updated evidence, has led to a series of proposed modifications to the Local Plan, which have also been subject to SA and are the subject of this stage of consultation.

How the results of consultation have been taken into account

The SEA Directive requires that opinions expressed by consultees be taken into account during the development of a plan before the plan is adopted. The Sustainability Appraisal and the Supplementary Sustainability Appraisal were consulted on alongside consultation on the draft Plan and additional information at each relevant stage. All comments and representations were taken into account as part of the plan-making process.

The reasons for choosing the Central Bedfordshire Local Plan (Regulation 19), in light of reasonable alternatives considered

The Local Plan sets the vision and strategic objectives of the place that Central Bedfordshire will become by 2035 based upon a spatial approach:

  • Building on our existing and emerging economic strengths;
  • Delivering homes in sustainable locations across the whole of Central Bedfordshire, including within the Green Belt, through extensions to villages and market towns as well as strategic urban extensions and new villages;
  • Maximising opportunities for intensification and redevelopment within our towns;
  • Enhancing and protecting the environment, landscape, countryside and local heritage; and
  • Delivering housing needs within the Luton HMA arising from Luton close to where the need arises.

The spatial approach within the Plan has been developed with the aim of delivering the spatial vision, informed by a range of technical evidence-based studies as well as the Sustainability Appraisal. Strategically the Central Bedfordshire Local Plan sets out to address identified cross-boundary issues with neighbouring authorities as well as with statutory partners and infrastructure providers. Statements of Common Ground, Memoranda of Understanding or Position Statements have been agreed with all Statutory partners and all except one of our twelve neighbouring District, Borough and County Councils.

Level of growth

The Plan identifies the strategy to meet the objectively assessed housing needs of Central Bedfordshire as identified through the Strategic Housing Market Area Assessment (SHMA), as well as the unmet housing needs arising from Luton. The local plan housing target of 39,350 new homes therefore comprises 32,000 homes to 2035 to meet Central Bedfordshire needs and 7,350 new homes to meet Luton's unmet housing needs. The housing target set out within the plan will be delivered through a combination of strategic allocations ranging between 1,500 to 5,000 new homes as well as a number of small and medium allocations sustainably distributed across Central Bedfordshire. Sufficient capacity has been built in to the plan to allow for contingency if it is required.

The plan also identifies the need for approximately 24,000 net additional jobs within the plan period to 2035. These jobs will be delivered through the mixed use strategic allocations as well as through sites that have been saved from previous Development Plans for the area.

In addition to the 24,000 jobs, the plan makes provision for three strategic employment allocations to meet wider strategic warehousing and distribution opportunities. These allocations will therefore deliver additional jobs and wider economic benefits to Central Bedfordshire and its residents.


In considering the spatial distribution of growth across Central Bedfordshire, the Council has been very mindful of the varying local character of the area as well as the need to consider designations such as the Chilterns AONB and the Green Belt.

Four Areas were identified early on in the plan-making process which reflect the different characteristics across Central Bedfordshire, drawing on spatial, settlement, environmental and infrastructure features. The capacity of the four areas based on their features, as well as other technical evidence, informed the broad distribution of growth across Central Bedfordshire before refining it down through a more detailed site assessment process. The four areas identified are:

  • The South Area (close to Luton, extending west to Leighton Linslade and north to Flitwick)
  • The A1 Corridor (Arlesey, Biggleswade, Sandy and north towards Tempsford)
  • The East-West Axis (M1 through Marston Valley to Wixams)
  • The Central Area (small towns and villages from Ampthill to Moggerhanger).

The spatial distribution of growth set out in this Plan also seeks to secure a balance to growth in the strategic transport corridor areas, as well as ensuring that other market towns and rural communities benefit from appropriate growth taking into consideration growth that has come forward across Central Bedfordshire outside of the local plan process.

The new development and growth locations have been identified with consideration to consultation responses, the availability and deliverability of sites, the identified spatial distribution pattern set out within the plan, the sensitivities and constraints of the area (e.g. flood zones, Green Belt and landscape designations etc) and the infrastructure capacity and opportunities (e.g. schools etc). Sites judged to perform best overall against the site assessment criteria and evidence base outcomes have been proposed in the Plan.

Any alternative sites have been discounted as they have not achieved the assessment criteria set out by the Council.

Other key policy objectives and issues

The various stages of developing the Sustainability Appraisal have provided an iterative and rational method for refining the options considered throughout the Local Plan process. Based on the overarching strategic objectives and informed through the supporting evidence and the Sustainability Appraisal, the Central Bedfordshire Local Plan seeks to ensure the delivery of appropriate housing and enable sustainable economic growth whilst enhancing and protecting the natural and local environment. The Sustainability Appraisal and the Supplementary Sustainability Appraisal published during the preparation of the plan have shown that reasonable and alternative options have been considered and evaluated.

Measures that are to be taken to monitor the significant environmental effects of the implementation of the plan

A monitoring framework is included in the Local Plan which has been carefully compiled to ensure the policies are monitored effectively. This enables the significant effects of implementing the Local Plan sites and policies to be assessed and considered. It helps to ensure that any unforeseen adverse effects can be identified, and remedial action taken if required.


9.2 The SEA Regulations require that "the responsible authority shall monitor the significant environmental effects of the implementation of each plan or programme with the purpose of identifying unforeseen adverse effects at an early stage and being able to undertake appropriate remedial action" and that the environmental report should provide information on "a description of the measures envisaged concerning monitoring". Monitoring proposals should be designed to provide information that can be used to highlight specific issues and significant effects, and which could help decision-making.

9.3 Monitoring should be focused on the significant sustainability effects that may give rise to irreversible damage (with a view to identifying trends before such damage is caused) and the significant effects where there is uncertainty in the SA and where monitoring would enable preventative or mitigation measures to be taken. In line with a precautionary approach, all of the SA Objectives for Central Bedfordshire's Local Plan have been included in the monitoring framework.

9.4 Table 9.1 overleaf sets out a number of suggested indicators for monitoring the potential sustainability effects of the Local Plan. Where possible, this draws from the data collected for the Central Bedfordshire Council Monitoring Report[39] (produced annually) and from the monitoring indicators in CBC's Local Plan Policy Monitoring Framework. Other monitoring indicators are also suggested.

9.5 The data used for monitoring in many cases will be provided by outside bodies. Information collected by other organisations (e.g. the Environment Agency) can also be used as a source of indicators. It is therefore recommended that CBC continues the dialogue with statutory environmental consultees and other stakeholders that has already been commenced, and works with them to agree the relevant sustainability effects to be monitored and to obtain information that is appropriate, up to date and reliable.

Table 9.1: Proposed monitoring framework

SA Objective


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

  • Total new homes completed in reporting year.
  • Completion of development on allocations.
  • Number of completed dwellings with a breakdown of housing type/tenure mix.
  • Gross affordable housing completions.
  • Number of approved Gypsy and Traveller pitches.
  • Number of permitted homes compliant with Nationally Described Space Standards.
  • Number of self and custom build plots permitted.

  1. To maintain and enhance community and settlement identities.

  • Net gain/loss of outdoor sport, leisure and open space.
  • Number of applications resulting in a loss of Important Open Space.
  • Number of community facilities lost through demolition, conversions or redevelopment.
  • Crime rates per 1,000 people.
  • Number of homes delivered on windfall sites within Settlement Envelopes and in settlements inset from the Green Belt.

  1. To improve accessibility to services and facilities.[40]

  • Net gain/loss of outdoor sport, leisure and open space.
  • Number of applications for change of use or re-development of shops or pubs in minor service centres or villages.
  • Number of schools that are at capacity/surplus.
  • Planning obligation monies received in the monitoring year.

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

  • Net gain/loss of B2/B8 and E(g) employment floorspace on small and medium allocated sites.
  • Town centre vacancy rates.
  • Number of permissions for tourism related development.
  • Employment rate for people aged 16-64.
  • Number of people claiming Jobseeker's Allowance.

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

  • Net gain/loss of accessible green space.
  • Percentage of residents that consider their health to be good.
  • Performance against relevant indices of multiple deprivation indicators.
  • Obesity rates in adults and children.
  • Access to doctors' surgeries and average wait times for appointments.
  • Residents opinion on availability of open space/leisure facilities.
  • Life expectancy.
  • Number of net additional local food growing opportunities, including allotment pitches.
  • Hectares of accessible green space per 1,000 population.

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

  • Peak traffic flow.
  • Travel times.
  • Total financial contributions secured to improve interchange infrastructure.
  • Car ownership.
  • Data from the air quality monitors within the AQMA.

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

  • Kilometres of cycle route completed.
  • Percentage of new residential development within 30 minutes public transport time of a GP, hospital, primary and secondary school, employment and a major health centre.
  • Length of public rights of way provided/lost as a result of development.
  • Percentage of trips to work, school, leisure using public transport, walking and cycling.
  • Number of applications approved for 80 dwellings of more that have a transport plan or travel plan
  • Public transport punctuality and efficiency.

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

  • Number of applications approved for sustainable energy development schemes.
  • Renewable energy generating developments granted.
  • Number of non-residential completions that achieved BREEAM Excellent.
  • Number of applications approved that provide car charging points.
  • CO2 emissions reductions per capita.
  • New installed renewable energy capacity.
  • Total energy consumption.

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

  • Water availability/consumption ratios.
  • Ecological/chemical status of water bodies.
  • Water use per household.
  • Water pollution incidents recorded by the Environment Agency.
  • Percentage of new development incorporating water efficiency measures.
  • Number of development applications permitted contrary to the EA and Anglian Water advice.

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

  • Percentage of developments permitted including elements of SuDS.
  • Number of applications permitted contrary to the Environment Agency advice. Amount of housing and employment land delivered within Flood Zones 2 and 3.

  1. To protect and conserve soil.

  • Proportion of new dwellings built on brownfield land.
  • Agricultural land (Grades 1, 2, 3a) lost to development on non-allocated sites.
  • Area of contaminated land remediated.

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

  • Number of designations by type as of 2019.
  • Changes in areas biodiversity importance – County Wildlife Sites (CWS).
  • The percentage of tree cover in the Forest of Marston Vale.
  • Number of applications with a condition for enhancing biodiversity.
  • Percentage of SSSIs in a favourable or unfavourable condition.
  • Number and hectares of Local Nature Reserves, Local Wildlife Sites, Ancient Woodland and Priority Habitats.
  • Number of applications with a condition for nature conservation.
  • Hectares of biodiversity habitat delivered through strategic site allocations.
  • Quantity of green infrastructure gains/lost through planning permissions.

  1. Protect and enhance the landscape and townscape.

  • Number of major applications approved within the AONB boundary.
  • Creation of the Forest of Marston Vale.
  • Total number of Tree Preservation Orders (TPOs) and TPOs lost as a result of development.
  • Percentage of development built on brownfield sites/previously developed land.
  • Quantity of green infrastructure gains/lost through planning permissions.
  • Number of landscape enhancement schemes secured.

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

  • Number of new and reviewed Conservation Areas.
  • Number of heritage assets on the Heritage at Risk Register.
  • Number of planning applications approved contrary to Historic England and/or Conservation Officer advice.
  • Number of designated and non-designated heritage assets.

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

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