Sustainability Appraisal Main Modifications Report: Non Technical Summary

Introduction

1.1 This Sustainability Appraisal Report: Non-Technical Summary relates to the Central Bedfordshire Local Plan, which is being prepared by Central Bedfordshire Council. The Local Plan sets out the long-term vision for Central Bedfordshire up to 2035 as well as detailed policies to achieve that vision.

1.2 Plans and strategies such as the Central Bedfordshire Local Plan are subject to a process called Sustainability Appraisal (SA), which assesses the likely effects of the plan on social, economic, and environmental issues. This Non-Technical Summary relates to the full SA Report for the Central Bedfordshire Local Plan: Main Modifications which is being published for consultation from March 2021.

The Central Bedfordshire Local Plan: Main Modifications

1.3 Central Bedfordshire Council submitted the Local Plan for Examination in April 2018. It sets out an overall vision for Central Bedfordshire, supported by 13 strategic objectives. Strategic policies set out the main elements of the strategy, including strategic allocations for large-scale housing and employment development. Allocations for small and medium development sites are made separately. A further 64 core and development management policies are then set out within sections of the Local Plan addressing topics such as housing, employment and economy, climate change and sustainability and the historic environment.

1.4 The Main Modifications to the Local Plan which are now being consulted upon propose various changes to the submitted version of the Local Plan, including the deletion of a small number of policies and some changes to policy wording.

Stages of the Sustainability Appraisal

1.5 Central Bedfordshire Council is required by law to carry out Sustainability Appraisal and Strategic Environmental Assessment (SEA) of the Local Plan, and it has appointed LUC to undertake the most recent stage of this process on its behalf. The Government recommends that these two legal requirements are met through one integrated process, referred to as Sustainability Appraisal (or SA).

1.6 The purpose of SA is to promote sustainable development by better integrating sustainability considerations into the preparation of plans. It should be seen as an important part of good plan making, involving ongoing iterations to identify and report on the likely social, economic and environmental effects of the plan and the extent to which it is expected to achieve sustainable development.

1.7 SA must be carried out in accordance with Government guidance and (as an integrated SA and SEA process is being undertaken) must meet the requirements of the European Strategic Environmental Assessment Directive^[1]. The approach that has been taken to the SA of the Central Bedfordshire Local Plan is described below. The SA has been undertaken in stages alongside the preparation of the Local Plan in order to provide sustainability guidance as the plan has been developed.

Stage A: Setting the context and objectives, establishing the baseline and deciding on scope

1.8 The SA process began in 2016 with the production of a Scoping Report. The Scoping Report determined what the SA should cover by reviewing a wide range of relevant policy documents (including international, national and local policies) and by examining data to help identify what the key sustainability issues are in Central Bedfordshire as well as likely future trends.

1.9 The Scoping stage also involved the development of the SA framework - this is a set of SA objectives against which Local Plan proposals were assessed. Two versions of the SA framework were developed - the strategic SA framework was used to test strategic options such as different options for distributing new development. The second version, the sites SA framework, was designed to enable the appraisal of site options that are location-specific. The use of the sites SA framework helped to ensure that different site options were appraised consistently. The SA objectives are presented further ahead in this Non-Technical Summary. Details of the decision-aiding questions that sit alongside each headline SA objectives, as well as the criteria and assumptions used in the sites SA framework, can be found in the full SA Report.

Stage B: Developing and refining alternatives and assessing their effects

1.10 Developing options for a plan is an iterative process which usually involves a number of consultations with stakeholders and the public. The SA process can help to identify where there may be other 'reasonable alternatives' to the options being considered for the policies and site allocations to be included in a plan. The reasonable alternative options that have been considered for the Central Bedfordshire Local Plan have included alternative policy approaches as well as potential sites for new housing and employment development, as described further ahead in this Non-Technical Summary.

SA Stage C: Preparing the Sustainability Appraisal report

1.11 The full SA report and this Non-Technical Summary describe the process that has been undertaken to date in carrying out the SA of the Central Bedfordshire Local Plan. They set out the findings of the appraisal of options and policies, highlighting any likely significant effects (both positive and negative, and taking into account the likely secondary, cumulative, synergistic, short, medium and long-term and permanent and temporary effects). The reasons for selecting or rejecting options during the preparation of the Local Plan are also described.

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

1.12 Central Bedfordshire Council is inviting comments on the proposed Main Modifications to the submitted Local Plan and the full SA Report to which this Non-Technical Summary relates. The documents are being published on the Council's website for consultation from March 2021.

1.13 Detailed information about earlier stages of consultation on the Local Plan and the accompanying SA Reports can be found in Chapter 2 in the full SA Report.

Stage E: Monitoring the significant effects of implementing the Local Plan

1.14 Detailed proposals for monitoring the sustainability effects of the Local Plan are set out Chapter 9 of the full SA report and are summarised further ahead in this Non-Technical Summary.

Policy Context

1.15 In order to establish a clear scope for the SA of the Central Bedfordshire Local Plan, it is necessary to review and develop an understanding of the wide range of policies, plans and programmes that are relevant. This includes international, national, regional and local-level policies, plans and strategies.

1.16 The review of relevant plans, policies and programmes that was originally presented in the 2016 SA Scoping Report has been updated and is presented in Appendix B of the full SA Report.

Baseline Information and Key Sustainability Issues

1.17 To make judgements about how the emerging Local Plan will progress or hinder sustainable development, it is essential to understand the economic, environmental and social circumstances in the plan area today and their likely evolution in the future. The SA Scoping Report (October 2016) described the baseline conditions for the plan area, structured around various themes. It has now been updated and is presented in Appendix A in the full SA Report. At the end of each topic section there is a summary of the key sustainability issues and their likely evolution without the Local Plan. Examples of the key sustainability issues identified include:

• High levels of out-commuting to surrounding areas including Luton, Milton Keynes and Bedford.
• Balancing the need for new development with the retention of a predominantly rural landscape character with important ridges, large areas of flat land, far-reaching views and high levels of tranquillity.
• Poor access to services and facilities in some areas of Central Bedfordshire, particularly in rural settlements.

Methodology and SA Framework

1.18 As described above, the review of relevant plans, policies and programmes and the collation of baseline data helped to identify key sustainability issues for Central Bedfordshire. These key sustainability issues fed into the identification of a set of SA objectives which are the main tool used at each stage of the SA for assessing the likely effects of the options and draft policies in the Local Plan. The SA objectives used for the appraisal of the Central Bedfordshire Local Plan are presented in Table 1. The SA objectives are grouped in relation to a number of sustainability 'themes', as shown in the first column of the table.

Table 1: SA Framework

Use of the SA Framework

1.19 Within the assessment matrices showing the potential sustainability effects of the Local Plan policies, symbols and colour-coding have been used against each SA objective to show whether an effect is likely to be positive or negative, minor or significant, or uncertain as follows:

Table 2: SA significance key

Difficulties Encountered

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

1.20 There was a need to appraise a large number of site options consistently. In order to address this issue, detailed criteria relating to each of the SA objectives were developed and applied during the appraisal of site options.

Sustainability Appraisal Findings for the Spatial Strategy Options

Areas for Development Growth

1.20 Four areas (A-D) were identified early on in the plan making process, 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

1.21 The characteristics of these areas are described in detail and mapped in Chapter 4 in the full SA Report. These areas were not intended as alternatives, but rather as distinct areas to help guide plan-making. The four areas were appraised in the Initial SA Report (June 2017), and the SA findings were repeated in later SA reports.

1.22 The SA findings for the four areas are summarised in Table 3 below. 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.

1.23 Area C performed the best against the SA objectives. The next best performing was Area B, followed by Areas A and D. This means that focusing development in the East/West Corridor of Central Bedfordshire is most likely to achieve sustainable development, followed by the East/A1 Corridor and then the South & West/M1 Corridor and Central Section of Central Bedfordshire.

Table 3: SA findings for Areas A-D

Approaches to distributing development growth

1.24 Seven options for approaches to distributing development growth were originally identified prior to the preparation of the Draft Local Plan. A number of changes were 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 sought to ensure that the options represent appropriate high-level alternatives for the spatial distribution of development. Full details of the changes that were made to the options for approaches to distributing development growth can be found in Chapter 5 in the full SA Report.

1.25 The SA findings for the revised options are summarised in Table 4 below. Many of the effects identified in relation to the six options are uncertain because they will depend on the specific location of development. 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.

Table 4: Approaches to distributing development growth

Growth scenario options – housing

1.26 In the Initial (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.

1.27 When the Supplementary SA Report was prepared in May 2020 in response to points raised about the SA by the Inspectors appointed by the Secretary of State to examine the Local Plan, these options were revisited. This process involved considering how much development there should be separately from the question of where it should be (through the appraisal of site options).

1.28 The Pre-Submission Local Plan (January 2018) included a housing target for Central Bedfordshire of 39,350 new homes between 2015 and 2035. This was made up of 32,000 homes to meet Central Bedfordshire's Objectively Assessed Need over that period, plus 7,350 homes to meet the unmet need arising from Luton. Since the Local Plan housing target is based on the Objectively Assessed Need, Central Bedfordshire Council considered that there are no reasonable alternative options for the amount of housing to be delivered through the Local Plan. For example, a lower housing target would not meet the Objectively Assessed Need and, given that there is enough land available in Central Bedfordshire to provide the identified housing requirement, this would not be a reasonable approach.

Growth scenario options – employment

1.29 Two growth scenarios for employment were developed and appraised in the Initial (Regulation 18) SA. 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).

Options relating to strategic warehousing provision

1.30 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, the following options were appraised in the Supplementary SA Report (May 2020):

• 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.

1.31 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. 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.

1.32 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.

1.33 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.

Options for meeting local employment needs

1.34 The evidence shows that a minimum of 24,000 jobs will be required over the Local Plan period. It is not considered by Central Bedfordshire Council to be a reasonable option to allocate land for fewer than 24,000 new jobs because there are enough 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.

Sustainability Appraisal Findings for the Strategic Housing Site Options

1.35 SA work relating to alternative options for the strategic housing site allocations to be made in the Local Plan was carried out and reported on at the Regulation 18 and Regulation 19 stages of plan making.

1.36 A review was undertaken as part of the Supplementary SA (May 2020) to determine whether the strategic housing sites appraised previously still remained the reasonable alternative options. As a result of this, a number of changes were made to the list of reasonable alternatives (these are detailed inAppendix C in the full SA Report). That appendix also provides information about the Council's reasons for selecting or rejecting each strategic housing site option for inclusion in the Local Plan as proposed to be modified.

1.37 Table 5 overleaf presents a summary of the SA findings for the 19 strategic residential site options. 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.

1.38 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.

1.39 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.

Table 5: Summary of SA findings for the residential site options

Sustainability Appraisal Findings for the Strategic Employment Site Options

1.40 In addition to three strategic employment site options that had been appraised at earlier stages in the plan-making process, a further 13 reasonable alternative employment site options were also appraised in the Supplementary SA (May 2020).

1.41 The audit trail of employment site options in Appendix C in the full SA Report lists the 16 reasonable alternative options that have been subject to SA and 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.

1.42 A summary of the SA findings for the 16 employment site options, as previously presented in the Supplementary SA Report (May 2020) is presented in Table 6. 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).

1.43 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.

Table 6: Summary of SA findings for employment site options

Sustainability Appraisal Findings for the Small and Medium Site Options

1.44 Reasonable alternative options for small and medium site allocations to be made in the Local Plan were identified through a Call for Sites by Central Bedfordshire Council. All sites that were considered by the Council to be suitable, available and achievable were subject to SA. The detailed SA findings for each small-medium site option are presented in Table 6.1 in the full SA Report. The site options are clustered by settlement which allows consideration to be given to potential cumulative effects. In summary:

• Many of the site options will result in the loss of the best and most versatile agricultural land with significant negative effects that are permanent and cumulative. However, other options are able to progress previously developed land with significant positive effects for SA objective 11: Soils.
• Those site options located in the Green Belt recorded significant negative effects against SA objective 2: Communities if they were in areas that contribute strongly to Green Belt objectives and minor negative if they are in areas that only contribute weakly. The Council has carefully selected those options in the Green Belt for those settlements that have not been able to benefit from development previously and to ensure that cumulative effects are not significant.
• Some of the site options were found to have minor negative effects with regard to SA objective 3: Access to Services; accordingly, limited development was proposed for these settlements to mitigate for cumulative effects. Minor negative effects were indicated for all the site options with regard to SA objective 6: Highways and Air Quality – but with uncertainty as the likely effects depend upon the options selected for each settlement.
• Some options were found to have likely minor negative effects on SA objective 13: Landscape; mitigation measures will be required through screening/design for those sites allocated. Similarly, some options are in Conservation Areas with the potential for negative effects on SA objective 14: Heritage.
• The effects of most options were minor positive with regard to SA objective 12: Biodiversity; further studies and mitigation measures may be needed for those options with uncertain negative effects that are progressed as allocations. However, the Development Management policies should ensure that these potential negative effects will be mitigated.

1.45 Generally, the options indicated positive effects for SA objectives 1: Housing and 2: Communities, 10: Flood Risk Management, and 12: Biodiversity. Neutral effects were indicated for SA objectives 8: Energy and Climate Change and 9: Water - and usually for SA objective 14: Heritage since important assets were avoided through the Sites Assessment Method.

1.46 Appendix D in the full SA Report sets out the Council's reasons for selecting or rejecting each small-medium site option as an allocation in the Local Plan as proposed to be modified.

Sustainability Appraisal Findings for the Local Plan as Proposed to be Modified

1.47 Chapter 7 in the full SA Report presents the SA findings for each component of the Local Plan as proposed to be modified, including the Vision and Strategic Objectives, Strategic Site Allocation Policies, Small and Medium Site Allocations, Strategic Policies (excluding strategic site allocations) and Development Management policies. Each policy has been appraised against the 14 SA objectives in the SA framework and the likely effects have been described, focussing in particular on the likely significant effects.

1.48 This Non-Technical Summary describes the likely cumulative effects of the Local Plan as proposed to be modified. The effects are described below in relation to each of the sustainability themes (Table 1 earlier in this document shows which themes relate to which of the SA objectives).

Cumulative Effects

Communities, Economy and Employment

1.49 The Local Plan (taking into account proposed modifications) will have cumulative significant positive effects on the themes of Communities and Economy and Employment, as a result of the large-scale housing and employment development that is proposed to meet the identified needs. While there could be cumulative negative effects on SA objective 2: Communities (part of the Communities theme) as a result of impacts on the identities of existing settlements, the selection of small-medium sites has aimed to ensure that new development can be integrated well and any negative effects minimised.

1.50 Where necessary, site-specific requirements are made in policy HA1 to ensure a visual and physical separation between existing and new development. Development management policies and specific requirements in the strategic site allocation policies will ensure a good mix of housing types and the delivery of services and facilities alongside new housing development to avoid existing facilities being over-stretched.

Health

1.51 Cumulative positive effects on the theme of Health are also likely. The provision of good quality homes, supporting services and facilities, and local employment will all have inter-related positive effects on health, while the Local Plan as proposed to be modified also makes good provision for improved access to open space and green infrastructure, both through the requirements in site specific policies and through relevant Development Management policies.

Highways and Air Quality

1.52 While the Local Plan as proposed to be modified allocates large-scale development which could have cumulative negative effects on the theme of Highways and Air Quality, the strategic allocations include specific policy requirements to ensure that the necessary improvements to the highway network are made.

1.53 The Local Plan as proposed to be modified also makes significant provision for improvements to the sustainable transport network. It focusses development in town extensions and new villages that are of a scope and size that they can establish sustainable transport networks of cycling and walking routes, linking with improved public transport and optimising opportunities such as the East West Rail Link. In combination with relevant Development Management policies, this should encourage use of public transport, cycling and walking routes, with positive effects on SA objective 7: Sustainable Transport (part of the Highways and Air Quality theme) in the longer-term.

Energy and Climate Change

1.54 While large-scale development could have cumulative negative effects on the theme of Energy and Climate Change, this is mitigated through strong Development Management policies relating to climate change, combined with the focus on strategic developments - this means that they are of a size and scope that can accommodate exemplar sustainable design including requirements for energy and water management.

Water Resources, Water Quality and Flood Risk

1.55 Similarly, in relation to the theme of Water Resources, Quality, and Flood Risk, the focus of the Local Plan on strategic developments means that they are of a size and scope that can accommodate exemplar sustainable design, including policy requirement that seeks to aim for water neutrality. The location of the strategic developments has avoided risk to water quality and flood management with likely neutral effects on this theme overall. There are also a number of relevant Development Management policies within the Local Plan as proposed to be modified, which provide further mitigation.

Soils and Land

1.56 Most new development will involve loss of the best and most versatile agricultural land – Central Bedfordshire is characterised by its rural nature and agricultural use – with significant cumulative negative effects on the theme of Soils and Land that would be permanent. However, Central Bedfordshire Council has sought to mitigate the effects by allocating town extensions that are adjacent to the existing urban form, and the smaller non-strategic sites are distributed throughout the area in settlements and proportionate to the existing services and facilities. The strategic employment allocations also include redevelopment of previously developed land.

Biodiversity

1.57 The large-scale development proposed through the Local Plan could have cumulative negative effects on the theme of Biodiversity; however where necessary, policy requirements draw attention to any need to separate uses to avoid conflicts and avoid negative effects. Development Management policies ensure that biodiversity is protected and enhanced for net gain, while site-specific requirements ensure that biodiversity at all levels of importance from national to local is protected and enhanced.

Landscape and Townscape

1.58 The potential for cumulative negative effects on the theme of Landscape and Townscape through impacts on visual amenity and landscape character was recognised at an early stage of plan-making and assessment. The town extensions and new villages are of a scale and scope that can ensure high quality design and landscaping through creative masterplanning at an early stage to minimise and potential negative effects. All the strategic development sites are required to have masterplanning, phasing and design codes that will have to be approved by the Council. The smaller non-strategic sites have been selected to minimise negative effects and integrate with existing settlements throughout the Central Bedfordshire area such that cumulative negative effects should be minimised.

1.59 The SA had indicated potential negative effects for the area north of Luton and adjacent to the Chilterns Area of Outstanding Natural Beauty. By proposing allocation adjacent to the urban area of Luton and carefully realigning Green Belt boundaries to protect local biodiversity and landscape character, and supported by Policy SP4: Development in the Green Belt, the Plan reduces potential negative effects. This suggests that the significant negative effects will be mitigated to at least minor negative with the potential for neutral effects in the longer-term as enhancements become established.

Historic Environment

1.60 The proposed allocations have generally avoided potential effects on the Historic Environment theme. Where there are particular issues for Listed Buildings or archaeological potential, site-specific policy requirements ensure that there is protection of the heritage asset. This, supported by Development Management policies, will ensure that there are neutral effects on the historic environment, including cumulative effects.

Reasons for Choosing the Plan and Monitoring

1.61 Chapter 9 in the full SA Report presents a statement which has been prepared by Central Bedfordshire Council outlining how environmental considerations have been integrated into the Local Plan, how the SA 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.

1.62 The SEA Regulations require that monitoring is undertaken in relation to the significant effects of implementing the Plan in question. Table 9.1 in the full SA Report sets out suggested indicators for monitoring the potential significant sustainability effects of implementing the Central Bedfordshire Local Plan.

Next Steps

1.63 The full SA Report and this Non-Technical Summary will be published alongside the schedule of proposed Main Modifications on the Council's website for consultation from March 2021. The Inspectors will then consider the representations raised and will report on the modified Local Plan's soundness. If the Local Plan is found to be 'sound', it can be formally adopted by Central Bedfordshire Council.

LUC
March 2021

^[1] SEA Directive 2001/42/EC