Sustainability Appraisal

Showing comments and forms 1 to 29 of 29

Comment

Technical Reports

Representation ID: 303

Received: 27/07/2017

Respondent: Mr Graham Goodall

Representation:

Built development must not destroy or harm important sites for wildlife. County Wildlife Sites (CWS) must be managed appropriately on an annual basis, including those owned by CBC. CBC appears to not have sufficient funding to manage its CWS; this is wrong! Funding MUST be found; eg. thousands of pounds were spent on the Biggleswade Green Wheel. New development offers opportunities to raise money for nature conservation and should be included in local Green Spaces plans. However, green spaces do NOT deliver for wildlife if they have open public access, cycling and dog walking, which not benefit wildlife.

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Built development must not destroy or harm important sites for wildlife. County Wildlife Sites (CWS) must be managed appropriately on an annual basis, including those owned by CBC. CBC appears to not have sufficient funding to manage its CWS; this is wrong! Funding MUST be found; eg. thousands of pounds were spent on the Biggleswade Green Wheel. New development offers opportunities to raise money for nature conservation and should be included in local Green Spaces plans. However, green spaces do NOT deliver for wildlife if they have open public access, cycling and dog walking, which not benefit wildlife.

Comment

Technical Reports

Representation ID: 1204

Received: 18/08/2017

Respondent: Harpenden Town Council

Representation:

Expectation that the SA will consider the chosen Spatial Strategy carefully against reasonable alternatives and one such reasonable alternative should comprise directing all strategic development away from the Green Belt, using more greenfield land in north of CBC near planned transport infrastructure. The assertion that more development in the north would be unsustainable needs to be robustly evidenced at Reg 19 stage, in order to be considered a sound approach, along with robust consideration of all major sites against reasonable alternative options as a separate but related exercise.

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Object

Technical Reports

Representation ID: 1558

Received: 29/08/2017

Respondent: Villages Focus Group

Representation:

We object that Sustainable Housing for G&T/Showpeople was not conducted, or referred apart from a single line-item reference on a list for technical documents (1.9). This document called 'Gypsy and Traveller Accommodation Assessment' (GTAA) is, on closer inspection, based on poor research outcomes and limited criteria-based evidence. If this data base is not improved and a clear sustainability framework compliant with national policy added so as to able to practically apply the policies, then presumably these (especially sound evidence) will be too late to include at presubmission given the short timeline proposed for a successful Local Plan submission,

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Since CBC's withdrawal of the preceding Gypsy and Traveller Plan (GTLP), this local authority has had 3 years to gather valid housing evidence for G&T/Showpeople. Given the GTLP now is incorporated under this one draft local plan, it is curious that there were no evidence or details presented in the sustainability appraisal on sustainability of G&T/Showpeople housing which has its own national policy and unique housing needs as emphasised in the 'Planning policy for traveller sites' (PPTS 2015). There are no references in the main sustainability appraisal nor in the associated non-technical summary. The latter highlights the omission by the table on Page xxiii/Section 52 under Development Management Policies: "The emerging Policies were tested through SA at an early stage of plan-making in autumn 2016. Interrelationships between topics and cumulative effects were considered by assessing the policy chapters against SA themes as follows..." However no relevant G&T/Showpeople policy is included despite the indirect reference to "higher deprivation" in area A which matches the location of over half of G&T and the majority of Showpeople in Central Bedfordshire. The only repeated mention of G&T in the sustainability appraisal is one technical document, the Gypsy and Traveller Accommodation Assessment (GTAA) which in itself is problematic due to the quality of the evidence. Only a third of all G&T housed in the district were able to be located by the CBC-hired consultants so that the proposed numbers for 5 year G&T housing does not appear transparent or referenced to withstand either Inspector or public scrutiny. The oversight can only lead to further unsound planning, lack of sustainability and poorly based evidence which currently has made the G&T/Showpeople an escalating planning issue that is requiring a proposed costly and extraordinary intervention by CBC.

Support

Technical Reports

Representation ID: 3559

Received: 29/08/2017

Respondent: Eaton Bray Parish Council

Representation:

Agree

Full text:

Agree

Object

Technical Reports

Representation ID: 3805

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Please see attached

Full text:

Please see attached

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Comment

Technical Reports

Representation ID: 4509

Received: 16/08/2017

Respondent: Historic England

Representation:

Comments of on evidence:
With regards to the Sustainability Appraisal, the relevant SA objective relating to the historic environment has not been properly provided as the sentence cuts out mid-way. This is likely to be a formatting error but should be rectified for clarity.
As outlined in our comments above, we have concerns with some of the policies and do not agree that the SA objectives are being achieved by the policies of the draft Plan and that they may produce some negative effects.

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Comment

Technical Reports

Representation ID: 5053

Received: 29/08/2017

Respondent: Mr Rawdon Crozier

Agent: mr james mcmurdo

Representation:

please refer to document attached

Full text:

please refer to document attached

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Support

Technical Reports

Representation ID: 5087

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Please see attached Covering Letter in regard to Slip End

Sustainability Appraisal - Confirms positive attributes to Slip End, opportunities for limited allocations.

Full text:

Please see attached

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Support

Technical Reports

Representation ID: 5093

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

please see attached letter regarding the Sustainability Appraisal and how its comments relates to Slip End,
This in relation to:

Support the justification for extensions to the village of Slip End that would be sustainable,
Support expansions as part of a collective of settlement in the Green Belt receiving allocations,
Support the conclusion that Slip End is a large village

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Please see attached

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Object

Technical Reports

Representation ID: 5339

Received: 23/08/2017

Respondent: Linden Homes

Agent: Marrons Planning

Representation:

Cranfield East in the Sustainability Appraisal has been dismissed as not sustainable on the grounds of concern about landscape/topography, and capacity of education facilities (page 80).
In relation to landscape, the supporting evidence presented in the North Central Bedfordshire Growth Options Study confirms that Cranfield East is not a designated landscape, nor is it a locally sensitive landscape (page 33).

it is noted from the Study that Cranfield East is identified as the option having the least number of secondary constraints and scores highly in all other areas. Its dismissal within the Sustainability Appraisal does not accord with this evidence.

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It is noted that some of the proposed growth locations are within the Green Belt.
In order to demonstrate exceptional circumstances necessary to redraw the boundary of the Green Belt, the Council will need to demonstrate (amongst other things) that it has taken account of the need to promote sustainable patterns of development within the District (paragraph 84 of the Framework), and considered all other reasonable options for meeting the identified requirements (paragraph 1.39 of the Housing White Paper).
It is accepted that housing growth at Cranfield would promote a sustainable pattern of development given the range of employment (including the University and Technology Park), services and facilities that exist within the settlement, and given its proximity to Milton Keynes, the A421 and M1 corridors, and the planned section upgrade for East West Rail. It is therefore a reasonable option for the Council to consider when deciding how to meet the identified need, and one which should be carefully assessed before considering the removal of land within the Green Belt.
Any re-drawing of the Green Belt boundary in Central Bedfordshire could not be found sound unless it has been demonstrated that growth at Cranfield would not represent sustainable development in accordance with the Framework.
Land promoted by Linden Homes lies to the east of Cranfield and is identified on the attached plan. It comprises all of ALP109 (edged blue), and also part of the wider area assessed as NLP104 (edged red).
This land forms part of a wider area referred to as Cranfield East in the Sustainability Appraisal that has been dismissed as not sustainable on the grounds of concern about landscape/topography, and capacity of education facilities (page 80).
In relation to landscape, the supporting evidence presented in the North Central Bedfordshire Growth Options Study confirms that Cranfield East is not a designated landscape, nor is it a locally sensitive landscape (page 33). In fact, it is noted from the Study that Cranfield East is identified as the option having the least number of secondary constraints and scores highly in all other areas. Its dismissal within the Sustainability Appraisal does not accord with this evidence.
The Site Assessments for this area find that development of areas ALP109 and NLP104 would impact on the setting of Cranfield when viewed across the Marston Vale due to its topography (page 73), although it is noted that the impacts in relation to ALP109 could be mitigated to address landscape impact. Whilst it is not disputed that development would have an impact on the landscape, it is not evidenced that this impact will have a significant adverse effect or have any greater impact than development elsewhere within the District around existing settlements or within the open countryside.
The Site Assessment does not appear to have been informed by a Landscape and Visual Impact Assessment, and such an assessment would enable a more informed judgement to be made as to the suitability and capacity of this area taking into consideration appropriate mitigation. It would also provide an opportunity to consider what compensatory measures might be able to be delivered by the landowners in this area that could enhance the wider landscape and ecological value of the Marston Vale to compensate for any residual impacts, for example creating new green infrastructure and areas for leisure as referenced in paragraph 7.6.13 of the Draft Plan and within the Initial Settlements Capacity Study for Cranfield (page 5). Such an assessment would be an important piece of evidence.
In respect of education, the Site Assessment states that land for a new lower school has been provided, but that the middle school is at capacity (page 72). The Local Plan is required to plan positively for the development and infrastructure required in the area, with strategic policies to deliver the provision of infrastructure necessary to serve development (paragraphs 156 and 157 of the Framework, and a test of soundness). Land cannot be held to be inappropriate for development based on a failure of the Plan to make provision for necessary infrastructure in the surrounding area, and there is no evidence that facilities for educating children generated by development at Cranfield could not be accommodated within or around Cranfield (at existing schools or at new locations), or in the surrounding settlements.
Although not identified within the Sustainability Appraisal, the Initial Settlements Capacity Study for Cranfield also identifies a potential constraint on capacity related to existing community facilities (page 5). It is not clear which facilities it is referring to, however, the Assessment identifies the absence of recreational facilities, such as allotments, facilities for young people, urban parks and formal large recreation areas. As with education, the evidence base has identified an issue that the Draft Plan at present fails to plan positively to address. As noted above, the allocation of land at Cranfield East could provide an opportunity to address this under provision and provide new facilities for the settlement.
Cranfield East should not therefore be discounted by the Council as unsustainable without further consideration being given to how these two issues (landscape and education) might properly be addressed through the preparation of the Plan, and prior to the Regulation 19 consultation, in order that this area might be considered as a small or medium scale site.
Furthermore, given the Council are considering removing substantial areas of land from the Green Belt, it is imperative that the Council fully consider and test all parts of Cranfield East before dismissing this as an option.
In this respect, Linden Homes will provide further evidence to the Council to demonstrate that any potential harm arising from the development of ALP109 (East End Farm) can be mitigated through good design. Linden Homes are strongly of the view that this land should come forward as a small or medium scale site for inclusion as an allocation in the Regulation 19 version of the Draft Plan, and that further consideration should be given to the potential of the wider area of land (NLP104) to come forward in the longer term.

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Comment

Technical Reports

Representation ID: 6241

Received: 25/08/2017

Respondent: O&H Properties

Agent: David Lock Associates

Representation:

O&H offer comments on the Sustainability Appraisal (SA) in relation to this section of the Local Plan document, these are detailed further in the schedule
at Part 3 of this report. see attachment

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Comment

Technical Reports

Representation ID: 6487

Received: 29/08/2017

Respondent: Natural England

Representation:

As a requirement of the Habitats Directive [transposed through the Conservation (of Habitats and Species) Regulations 2010 (as amended) (the Habitats Regulations)] the assessment of a plan is a process that should be undertaken during the preparation of the plan, preferably from the earliest stages, so that the assessment influences the evolution of the plan. It is important, and a requirement of the SEA Directive, that reference is made to the HRA findings within the Sustainability Report. see attachment

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Comment

Technical Reports

Representation ID: 6488

Received: 29/08/2017

Respondent: Natural England

Representation:

The SA report provides an overview, rather than a detailed assessment, of the effects of the Central Bedfordshire Draft Local Plan on sustainability objectives. The SA objectives, assessment methodology and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment Regulations. However, as stated above, the statutory requirement for the assessment to take into consideration the findings of HRA will need to be addressed. see attachment

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Comment

Technical Reports

Representation ID: 6544

Received: 25/08/2017

Respondent: CPRE

Representation:

The Council's Sustainability Appraisal is driven and thus fundamentally flawed, by the need to accommodate the high growth figures and housing numbers.
As stated earlier we believe these figures are way in excess of what CBC should be planning for in the future and therefore what needs to be accommodated within the Local Plan.

This study seeks to justify developing in the Green belt through a list of nebulous, unquantified positives, namely:
see attachment

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Comment

Technical Reports

Representation ID: 6564

Received: 29/08/2017

Respondent: Willis Dawson

Agent: HD Town Planning

Representation:

From this it is then noted that the Sustainability Appraisal (SA) investigates growth in four areas (identified as A-D) with five possible scenarios having a minimum additional net housing capacity of 20,000 dwellings (Paragraph 5.1.3). It concludes that the SA supports growth in Area A (Paragraph 5.1.4) and specifically rejects the Scenario which has no growth in Area A (Scenario 4) on the basis that it will have a negative effect on the needs and health of the community as well as on Luton (including the most deprived areas). see attachment

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Comment

Technical Reports

Representation ID: 6590

Received: 29/08/2017

Respondent: O&H Properties

Agent: David Lock Associates

Representation:

The scope of the SA is limited to testing scenarios for new strategic
growth with the potential to be included within the emerging Local Plan as new
allocations. O&H agree that it is sensible to test with 'headroom' between the 500
homes identified for Land South of Wixams (as well as the 650 proposed in the current planning application) and the 1,000 tested for SA. However, O&H are concerned that the SA has not fully tested the sustainability of new allocations in addition to the existing allocation of 1,000+ dwellings established by Policy MA3 of the Site Allocations DPD. attachment

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  • O&H (777.89 KB)

Comment

Technical Reports

Representation ID: 6632

Received: 29/08/2017

Respondent: Willis Dawson

Agent: Pegasus Group

Representation:

With regard to growth in Area A paragraph 31 identifies the positive effects of
growth as;
* offering opportunities with new development which Gren Belt designation
restricts
* providing infrastructure around Houghton Regis and Luton with positive
effects for these areas with higher deprivation
* Support provision of housing for Luton HMA
* Key transport corridors provide employment benefits for the area
* Good access to open space, recreation and green infrastructure to the benefit of new and existing communities
see attachment

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Support

Technical Reports

Representation ID: 6689

Received: 29/08/2017

Respondent: R and A Farms

Agent: Savills

Representation:

supports the conclusions in Strategic Employment Site Assessment Technical Document and Sustainability Appraisal that their site (NLP244) is most suited to achieve the employment development aspirations of the Council at J13
see attachment

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Savills is instructed by R and A Farms to submit these representations to Central Bedfordshire Council (CBC) regarding the Draft Local Plan (DLP). The representations follow on from R and A Farms previous response to the Council's Call for Sites in 2016.
R and A Farms is a major landholder in the area. The holdings include 43 hectares of land to the north of the A507 (site plan attached) at J13 of the M1. It benefits from the ability to connect to the A507 and thereby take advantage of the strategic road network. The land ownership also extends north-west to the railway providing the opportunity for connections to Ridgmont Railway Station.
To the west is Prologis Marston Gate, a well established logistics park with high profile occupiers including Amazon. Prologis has a strong record in delivering high quality logistics park with supporting facilities and is engaged as development partner by R and A Farms. Separate, complementary, representations illustrating how the R and Farms site could be successfully and sustainably developed and the potential economic benefits are being submitted to the CBC by Prologis. This would form a logical and deliverable extension to the Prologis Marston Gate development.
The Draft Local Plan
The National Planning Policy Framework (NPPP) includes a presumption in favour of sustainable development. In order to achieve this, Local Plans should positively seek opportunities to meet the development needs of the area and should be based on objectively assessed needs allowing sufficient flexibility to adapt to change1. The first of the Core Planning Principles to deliver sustainable development is the need to build a strong, competitive economy which secures economic growth and creates jobs2. Local Plans should therefore set out an economic strategy that promotes sustainable economic growth and identify strategic sites that will help deliver the strategy.
In line with paragraph 182 of the NPPF, local plans must be prepared on the basis of sound evidence. R and A Farms welcome and endorse the conclusions of the Strategic Employment Site Assessment Technical Document and Sustainability Assessment that support the site's suitability for development and allocation through the Local Plan. Again, we would emphasise that the site is available, suitable, achievable and deliverable.
As noted, above, R and A Farms submitted their site for consideration under the previous Call for Sites. Sites promoted through this exercise for employment use are identified and considered in the supporting Strategic
Employment Site Assessment Technical Document issued alongside the DLP. It is helpful to note that:
* para 2.2.1 - recognises the suitability of CBC district to deliver footloose warehousing and distribution employment
* para 2.2.2 - notes that the Call for Sites was undertaken to help identify potential sites to address the "lack of strategic scale, high quality sites that r well located to the strategic transportation network that are capable of meeting this specific need"
The Assessment undertakes a thorough assessment of the submitted sites and identifies three options that could deliver strategic employment sites.
The R and A Farms site is identified as Site ref NLP 244. The Assessment identifies the site as meeting the criteria necessary for it to be considered as suitable to be a strategic employment sites and that the J13 location makes it an excellent location. We agree with the assessment that there are no overriding constraints to development.
The site also performs strongly in the comparative assessment for the identification of Preferred Options for Strategic Development being one of only three of the fifteen sites assessed considered to be best placed to deliver the Council's development aspirations. We also endorse the Sustainability Appraisal assessment on the potential impact of the site (Table 5.13) and the conclusions Section 10 supports growth within Area C (within which the site is located) and will have a positive effect on both housing and employment.
Spatial Strategy Approach and Policy SP1 - Growth Strategy
The Spatial Strategy Approach outlined in the DLP includes the need to deliver a minimum of 24,000-30,000 new jobs over the plan period. These figures are stated at para 7.1.3 as being 24,000 jobs to be created by growing existing key employment locations and sectors plus, in addition, 6,000 jobs to meet "footloose" strategic warehousing on three major strategic employment sites. These sites are considered to be most appropriately located along strategic transportation corridors and not tied to a particular location (footnote 7) Four Growth Locations are identified. This includes Area C - East West which is identified as having the ability to deliver large sites in the Marston Vale and close to Milton Keynes.
R and A Farms strongly support the identification at para 7.6.14 and in Policy SP1 -Growth Strategy of the M1 J13 location for around 40 hectares of strategic employment land. The extent of this proposal aligns with the area of the R and A landholding. For clarity and certainty, R and A Farms request that in the next version of the Local Plan, their landholding is clearly identified as the specific allocation to meet this requirement both in the policy and on the Proposals Map. The development of the site would represent a logical extension to the Prologis Marston Gate development, benefits from access to the Strategic Road network and provides an opportunity to contribute towards enhancing the use of Ridgmont Station. When allocating the sites within the policy, it should also be made clear that ancillary uses/facilities that would support the development for B class uses would also be acceptable within the development.
Policy EMP1 - Strategic Warehousing and Logistics
The policy provides for the consideration of additional strategic warehousing and logistics developments over and above those allocations identified in Policy SP1 and identifies criteria against which proposals will be assessed. As worded, such development would only be viewed as acceptable when all of the criteria within the policy are met. The second criteria identified is:
"The allocations identified within Policy SP1 are built and occupied"
R and A Farms welcomes the primacy given to the allocations to be identified through Policy SP1 but considers that this emphasises the need for the relevant allocations to be specifically included in Policy SP1 and identified on the Proposals Map.

Policy EMP2 - Employment Sites and Uses
The policy provides a presumption in favour of Use B Classes across the portfolio of employment land within the District.
R and A Farms consider that the proposals for their site at Junction 13 will help deliver additional B class uses and welcome the presumption in favour of such uses. However, for clarity Policy SP1 will provide full policy support for the development of the strategic employment sites for these uses.
The reading of the Policy EMP2 leads to the assumption that it relates solely to the existing portfolio of employment sites and is designed to protect and encourage B class uses within them and to provide for alternative employment uses within them when appropriate evidence is provided. If this is the case, we consider that the policy should be clarified to state that it relates to the existing portfolio of employment land.
Conclusions
R and A Farms:
* support the Spatial Strategy for Growth, especially Area C
* support Policy SP1 and the identification of M1 Junction 13 as a suitable location for a strategic employment area
* consider Policy SP1 and Proposals Map should be amended to identify specific sites. Their landholding at M1 Junction 13 is the most sustainable and suitable site to deliver the employment objective at J13, is achievable and capable of early delivery and should be specifically allocated both in the policy and the Proposals Map. Its development would represent a logical extension to the extension to the existing development at Prologis Marston Gate.
* consider that Policy SP1 should also include provision for suitable supporting ancillary uses/facilities within the strategic employment sites
* supports the conclusions in Strategic Employment Site Assessment Technical Document and Sustainability Appraisal that their site (NLP244) is most suited to achieve the employment development aspirations of the Council at J13
* consider that clarity should be included in Policy EMP2 that it relates to the existing portfolio of employment land R and A Farms look forward to continue to work proactively with CBC to achieve the successful allocation and delivery of strategic employment on their land. I would be grateful if you keep us informed on the progress of the Local Plan.
Should you have queries relating to this letter, please do not hesitate to contact me using the details above.

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Comment

Technical Reports

Representation ID: 6732

Received: 29/08/2017

Respondent: Mrs Diane Elder

Agent: Strutt & Parker

Representation:

We strongly support the acknowledgement within the Spatial Strategy Approach that recognizes the importance of the duty to cooperate with neighbouring local planning authorities. In the case of Luton, it is clear that given the tightly drawn administrative boundaries surrounding the Borough mean that it will not be possible for Luton to deliver all its growth within its boundaries. Furthermore, Luton is surrounded by an important hinterland, which is linked to Luton for many of its employment, retail and leisure needs. see attachment

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Comment

Technical Reports

Representation ID: 6775

Received: 29/08/2017

Respondent: Wynne Family

Agent: Strutt & Parker

Representation:

The Sustainability Appraisal, which underpins the Central Bedfordshire Local Plan 2035 has been used to support the strategy supports growth in Areas A, B and C as having positive effects on housing delivery and employment. We support focusing development in these locations, and believe particular emphasis should be given to sites in locations close to or not major transport corridors. see attachment

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Comment

Technical Reports

Representation ID: 6830

Received: 29/08/2017

Respondent: Hayfield Consortium

Agent: Savills

Representation:

The Consortium agrees with the assessment for major positive effects in relation to delivery of housing.

see attachment

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Comment

Technical Reports

Representation ID: 6919

Received: 29/08/2017

Respondent: Bedfordshire Local Nature Partnership

Representation:

The Sustainability Appraisal identifies key environmental issues that do not appear to have solutions proposed anywhere in the Plan. These include the potential loss of Green Infrastructure as well as the new provision of areas of open space and recreational areas for people; a need to reduce excess weight in adults, which is ranked significantly worse than the England average; increased pressure on water resources in an area of low rainfall (while it is acknowledged that Central Beds fall within the Upper & Bedford Ouse Catchment, the U&BO Catchment Partnership has not been consulted on the Local Plan).

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Bedfordshire Local Nature Partnership comments on the draft Central Bedfordshire Council Local Plan
Local Nature Partnerships (LNPs) have been established across England. The purpose of the Bedfordshire Local Nature Partnership is to ensure the natural environment is valued and integral to local decision making to deliver benefits for wildlife, people, landscape, heritage, and the local economy. The Bedfordshire LNP covers the geographical area of Bedfordshire, including the boroughs of Luton, Bedford and Central Bedfordshire.
We would like to thank you for engaging us in the Local Plan process. The LNP is covered by the Duty to Co-operate and we aim to ensure the natural environment and the benefits it brings to people and wildlife are fully considered and accounted for in decision-making. Please do continue to engage us in the plan-making process to ensure that the issues we have identified can be resolved in a positive and constructive way.
Our comments follow.
Bedfordshire LNP Response:
Key points:
 The level of anticipated growth is unprecedented and in significant potential conflict with stated desires of maintaining local character and the protection of the natural environment and services it provides. There is a need to ensure that the natural environment is properly recognised, protected and enhanced through the Local Plan.
 The Draft Plan does not truly reflect the value of the natural environment to Central Bedfordshire, either in terms of the natural capital/ecosystem services it provides, or the underpinning of the economy of the area. CBC's own Environmental Framework (p.12) quotes a business survey of 2014 where Central Bedfordshire's businesses rated 'a nice area / surroundings / environment' as the third most positive thing about a Central Bedfordshire location. The environment is generally presented as a constraint throughout the document, yet its value means that it is also very much a key driver and opportunity.
 The Sustainability Appraisal identifies key environmental issues that do not appear to have solutions proposed anywhere in the Plan. These include the potential loss of Green Infrastructure as well as the new provision of areas of open space and recreational areas for people; a need to reduce excess weight in adults, which is ranked significantly worse than the England average; increased pressure on water resources in an area of low rainfall (while it is acknowledged that Central Beds fall within the Upper & Bedford Ouse Catchment, the U&BO Catchment Partnership has not been consulted on the Local Plan).
 A significant amount of the proposed growth is in locations that will have substantial impacts on the Chilterns AONB and Greensand Ridge NIA, either directly upon their landscape and setting, or indirectly in terms of increased visitor pressure upon these areas.
 Much seems to be dependent upon strategic transport developments such as the Oxford-Cambridge Expressway and East-West Rail. However, the potential alignments of these are not confirmed and the Draft Plan seems to imply the E-W rail route is already chosen to the east beyond Bedford - which it has not been.
 While the Biodiversity and Green Infrastructure policies are strong, their essence does not pervade the Draft Plan and they are therefore isolated. The Draft Plan must have a stronger approach to the natural environment, building in its protection and enhancement throughout the Plan, and embedding the principle of "net environmental gain". CBC should consider developing a new Central-Bedfordshire-wide GI Plan to enable a greater embedding of GI principles, priorities and opportunities into the Local Plan. GI loss needs to be minimised and mitigated for; and new GI provisions need to be within a 'strategically planned and managed network' in locations appropriate to proposed development.
 The Bedfordshire LNP is leading a consortium of LNPs from across the Oxford-MK-Cambridge Growth Corridor on the production of a 'Natural Capital Investment Plan' (NCIP), to be produced later in 2017/18. We would be happy to share the results of this study and work that informs it, where appropriate and where timescales permit, to assist in the further development of the Local Plan

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Comment

Technical Reports

Representation ID: 6926

Received: 29/08/2017

Respondent: Gladman Developments Limited

Representation:

Gladman previously responded to the SA Scoping Report, which was published for consultation in September 2016. Clearly, the SA that accompanies this consultation is not at the stage where the comparative assessment of individual sites for residential allocation has been undertaken and we would therefore highlight the importance of the need for a comprehensive exercise to support the pre-submission version of the Local Plan. We look forward to reviewing the SA that accompanies the version of the Plan that is published under Regulation 19 in due course.

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Comment

Technical Reports

Representation ID: 7132

Received: 29/08/2017

Respondent: Evans and Sons

Agent: Fisher German

Representation:

The Sustainability Appraisal supports growth in Areas AB and C as having "positive effects" on housing delivery and employment. The capacity for Upper Shelton/Area C in which the site are located is well demonstrated within the draft plan. see attachment

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Comment

Technical Reports

Representation ID: 7148

Received: 29/08/2017

Respondent: Denison Investments

Agent: Arrow Planning

Representation:

They also welcome the findings of the Sustainability Appraisal, namely
that the benefit of releasing land from the Green Belt outweighs the harm.
Development in these Green Belt locations is vital to ensuring the vitality
and future regeneration of towns and villages surrounded by the Green
Belt. Without growth in these locations, local housing need will go unmet,
resulting in a loss of residents and workers to other settlements
potentially outside of Central Bedfordshire. see attachment

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Comment

Technical Reports

Representation ID: 7324

Received: 25/08/2017

Respondent: O&H Properties

Agent: David Lock Associates

Representation:

Overall, we consider that a comprehensive approach to the SA has been undertaken, ensuring that a good
balance and range of growth scenarios are tested. It provides a good starting point for determining an
appropriate growth strategy. However, we consider that there are a number of key points to raise in relation to
the SA that could directly impact upon the growth strategy in the Local Plan:
see attachment

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Comment

Technical Reports

Representation ID: 7361

Received: 29/08/2017

Respondent: Natural England

Representation:

Policy CC5: Sustainable Drainage
Natural England welcomes recognition of the multi-functional benefits of SuDS including flood control, improved water quality, recreational and amenity benefits and wildlife enhancement. We advise that potential risks to water-dependent designated sites, through changes in water quality / quantity, should be recognised. The SA will need to assess this issue against proposed site allocations and any mitigation measures will need to be secured through relevant allocation policies.

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Comment

Technical Reports

Representation ID: 7362

Received: 29/08/2017

Respondent: Natural England

Representation:

Policy CC6: Water Quality
We support this policy and requirement for relevant proposals to be accompanied by a Water Framework Directive assessment and to contribute positively to the water environment and its ecology. However, this appears to be deferring the sustainability assessment of proposals to the project stage. In our view this poses a potential risk to designated sites and the deliverability of development which should be minimised by assessing water quality effects and deliverability of measures to address adverse effects through the SA (informed by an up to date Water Cycle Strategy). see attachment

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Object

Technical Reports

Representation ID: 7369

Received: 29/08/2017

Respondent: Landowners & IM Properties

Agent: Barton Willmore

Representation:

The SA fails to consider potential secondary effects which is a requirement of the SEA
regulations.
* There is no consideration of how the uncertain and unknown effects of the Plan will be monitored which is key to understanding the impacts of the draft Local Plan.
* The approach to assessing mitigation is inadequate and inconsistently applied across the appraised sites. Our Site has been unfairly discounted from the SA process on the basis that landscape impacts of the development cannot be mitigated against. see attachment page 12

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