Sundon Rail Freight Interchange - Alternative Site Assessment [EXAM 107/107A]

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Comment

Sundon Rail Freight Interchange - Alternative Site Assessment [EXAM 107/107A]

Representation ID: 14421

Received: 03/08/2020

Respondent: Harlington Parish Council

Agent: Martin Small

Representation:

A01
P07
Loss of Green Belt due to RFI and M1/A6 Link Road, assessment of RFI does not take into account project traffic movements, impact from visual, noise and light pollution, impact on AONB, remove RFI and warehousing from the plan.

Full text:

I am submitting these objections on behalf of Harlington Parish Council. The Parish Council met 6th July to consider the issues raised by the additional documents and responses prepared.
The seriousness, depth and range of the Parish Council’s concerns do not lend themselves to the online consultation response format.

I note that the on-line system requires comments on the legality, soundness and co-operation for the Local Plan before seeking 100 word comments,

The parish council did not consider the issues of legality or whether the required level of cooperation had been achieved via these additional documents – however there were serious concerns expressed over the way that the Council’s own application for the M1 / A6 link was self-approved, and the response by Luton Borough Council to this approach must bring into question the cross-border co-operation.

The Parish Council does not consider the Local Plan in its current form – with the additional documents, to be sound. The documents are selective in the material changes, the housing needs are now considerably out of date and do not reflect likely scenarios regarding projected economic downturn, and the Plan has not demonstrated that reasonable alternatives have been considered nor the required exceptional circumstances met to justify proposals to develop areas of the green belt and the AONB.

The seriousness, depth and range of the Parish Council’s objections exceeded the limitations of the on-line system hence they are submitted in this format

Object

Sundon Rail Freight Interchange - Alternative Site Assessment [EXAM 107/107A]

Representation ID: 14548

Received: 12/08/2020

Respondent: Cllr Silvia Collins

Representation:

A01
P07
traffic impacts from RFI, development in Green Belt is unjustified, impact on landscape, biodiversity and local character.

Full text:

Objections to Sundon RFI
Objections to HAS20

PLEASE SEE ATTACHMENTS

Comment

Sundon Rail Freight Interchange - Alternative Site Assessment [EXAM 107/107A]

Representation ID: 14568

Received: 12/08/2020

Respondent: Historic England

Representation:

A02
P02
Historic England are disappointed to see the wording agreed in the Statement of Common Ground has not been included in the proposed policy wording for Sundon Rail Freight Interchange. Please reinstate.

Full text:

See attachment

Attachments:

Object

Sundon Rail Freight Interchange - Alternative Site Assessment [EXAM 107/107A]

Representation ID: 14741

Received: 12/08/2020

Respondent: Dr John Reynolds

Representation:

A02
P07
Object to RFI, contrary to sustainable transport, impact on road network, environmental impacts.

Full text:

As a resident of sundon road, I would like to object to the proposed RFI interchange on the following points:

size of RFI
proximity to 3 larger strategic RFIs
does not support sustainable transport,
detrimental impact from increasing no. of access vechicles
adverse impact on the wider transport network
destruction to Chiltern way footpath
ecological impact
night time noise
air and light pollution
interference and disruption to rail passenger traffic
no local transport model referenced
an additional 8,400 vehicles per day accessing junction 11A and or using local roads
Does not meet objective 5 of improving the health and wellbeing of communities
proximity to a SSSI site an area of Priority Habitat and a Country Wildlife Site (CWS)
cutting the green belt into 2 separate unconnected blocks,
cutting of 320 mature Poplar trees.

Comment

Sundon Rail Freight Interchange - Alternative Site Assessment [EXAM 107/107A]

Representation ID: 14803

Received: 12/08/2020

Respondent: Chiltern Society

Representation:

A02
P07
Extent of Green Belt release for RFI should reduced.

Full text:

Thank you for inviting further comments on the additional
ocuments submitted to the Local Plan Examination. The Chiltern Society’s comments are as follows.

Sundon Rail Freight Interchange
The Society is satisfied with the additional evidence provided to justify the choice of the Sundon site over
other options within the District. We are satisfied that the proposed facility will help to encourage the movement of freight by rail, thereby seeking to reduce road transport and contributing to addressing climate change.

We accept that the low-lying part of the site adjacent to the M1 junction and the Midland Mainline lends itself very well to an interchange and a case could be made for
exceptional circumstances to amend the Green Belt boundary accordingly. However, in our view, the land take from the Green Belt should be restricted to that required for the interchange itself and should not include the much larger site on raised ground which is proposed for additional warehousing units. This area is open land within the Green Belt which borders an SSSI and County Wildlife Site. We would have liked the report to consider alternative locations for the proposed warehousing, possibly separating it from the Rail Freight Interchange.
We are not convinced that exceptional circumstances exist for taking the whole site out of the Green Belt. We, therefore, sustain our objection in this respect.

Land North of Luton
The Society previously objected to the scale of development proposed in the Green Belt and the setting of the Chilterns AONB. The proposed Option C1 proposes a scheme that is much more acceptable than Option A. The removal of the eastern bowl from development and the incorporation of significant green infrastructure would help to address impacts on the setting of the AONB and retain significant areas of openness in the Green Belt.

We were disappointed that the planning application for the bypass was approved by the Council because it was indicated at the original hearings that the bypass would be discussed further at a later date. No additional evidence on alternatives was provided before the planning application was improved. It is essential that the final site layout includes landscaping proposals, based on the Landscape and Visual Impact Assessment, to secure substantial mitigation measures and biodiversity and landscape gain.

We still remain opposed to the scale of new development proposed in the Green Belt around Luton. We are pleased that the sustainability appraisal was extended to look at alternative sites elsewhere to consider whether the North of Luton site was the most sustainable option. Whilst all options for North of Luton would have significant negative impacts on the Green Belt, Option C1 would have less of a landscape impact, particularly on the AONB around Warden and Galley Hills. We would not support the compromise Option B as it would still allow significant development in the setting of the AONB to the east.

We hope that you can take these comments on board in your consideration of the Examination.

Attachments: