IM Properties Plc, in Respect of Land at Junction 12 of the M1 (I.E

Local Plans Central Bedfordshire Council Priory House Monks Walk Chicksands Bedfordshire SG17 5TQ

Our Ref: 25282/A3/SH/bc

12th August 2020

Dear Sir/Madam, CENTRAL BEDFORDSHIRE LOCAL PLAN EXAMINATION

ADDITIONAL EVIDENCE CONSULTATION

These representations to the additional evidence consultation are made on behalf of our Client, IM Properties Plc, in respect of Land at Junction 12 of the M1 (i.e. Toddington Park), which they are promoting for strategic employment development, predominantly Class B8.

These representations set out that:

• Given a quantified demand for land for strategic warehousing in Central Bedfordshire as 320- 425 hectares over the remaining Plan period, the options considered for the Strategic Employment Strategy should have considered options with a greater number of jobs/sites.

• There is a continuing disconnect between the Council’s own evidence base, which now quantifies the demand for land for strategic warehousing in Central Bedfordshire as 320-425 hectares over the remaining Plan period, and the approach of the Plan, which seeks to further reduce supply to 105 hectares. That is, a 3.75-5 year supply, with no buffer in the event that the allocated sites are delayed or do not come forward at all. Given this, there is a clear need to allocate at least one more site for strategic warehousing.

• The diminished supply of land for strategic warehousing results in a diminished yield in potential jobs generated. At best 105 hectares may generate 3,868 jobs and at worst 2,211 25282/A3/SH/bc -2- 12th August 2020

jobs. This adds weight to the need to allocate at least one more site for strategic warehousing.

• The additional allocation/s should be along the M1 corridor, the primary market for strategic warehousing, with demand on the A1 corridor driven by a scarcity of sites along the M1.

• The additional evidence seeks to limit supply and retrospectively justify the allocations.

• Land at Junction 12, as demonstrated in an independent assessment, performs well against the Sustainability Appraisal objectives, and as least as well as the allocated sites. As such, Land at Junction 12 is a sustainable reasonable alternative to be selected for inclusion as a site allocation within the Local Plan.

• The allocation of Land at Junction 12 of the M1, a 224 acre (90.7 hectare) site that can provide 2.4 million square feet (around 227,000 square metres) of floorspace and around 2,300 jobs in the operational phase, has distinct benefits. It is located along the M1 corridor with direct access to the upgraded Junction 12 already in place enabling early delivery; it is close to Harlington Rail Station providing opportunities for sustainable travel; it is advantageously positioned within proximity to Sundon RFI providing a potential opportunity for rail connectivity for the transportation of goods; and it makes a lesser contribution to the Green Belt than Sundon RFI and can brought forward without resulting in unacceptable landscape impact.

• Land at Junction 12 is a suitable site. It is available now and IM Properties are committed to early delivery.

Background

IM Properties have engaged throughout the Local Plan process, including submission of representations at the Regulation 18 and Regulation 19 consultation stages, and participating in the Examination hearings sessions held between May and July 2019. It is IM Properties’ case that the Local Plan does not make sufficient allocations for strategic employment development, in particular along the M1 corridor, and that Land at Junction 12 has been discounted as a potential site following an incorrect assessment in the Strategic Employment Site Assessment Technical Document, prepared by PBA (now Stantec) July 2017 (Ref: F02).

Following the close of the Examination hearing sessions, the Inspectors raised concerns with the legal compliance and soundness of the submitted Local Plan in a letter dated the 30th September 2019 (Ref: EXAM 69). The Inspectors’ concerns include that the Sustainability Appraisal (SA) does not adequately consider alternative strategies for employment growth or the alternative sites available, and that there are discrepancies in the scoring of sites, which undermines its robustness as an objective assessment. Related to this, the Inspectors’ raise concerns about the soundness of the three strategic employment allocations – that is, Sundon Rail Freight Interchange (RFI) (Policy SE1), Marston Gate Expansion (Policy SE2), and Holme Farm, Biggleswade (Policy SE3).

The additional evidence submitted by Central Bedfordshire Council (the Council) seeks to address the concerns raised by the Inspectors in their letter of the 30 th September 2019. The additional evidence includes:

• Sustainability Appraisal of the Central Bedfordshire Local Plan Supplementary Report, prepared by LUC (Ref: EXAM 115/115B) (‘the Supplementary SA’);

• Employment Technical Paper prepared by the Council (Ref: EXAM 112);

• Employment Land Update, prepared by Stantec (Ref: EXAM 109); and

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• Sundon Rail Freight Interchange Alternative Sites Assessment, prepared by Lichfields (Ref: EXAM 107) (‘the Sundon RFI ASA’).

It is our view that the additional evidence does not address the concerns raised by the Inspectors in their letter of the 30th September 2019, or IM Properties concerns as raised in earlier submissions made to the Local Plan consultation and Examination. IM Properties’ earlier submissions are before the Inspectors and are not repeated here. These representations respond to the additional evidence, focused on the strategic employment strategy and site options, and are supported by the following documents:

• Strategic Warehousing Allocations: Jobs Generated, provided at Appendix 1;

• Toddington Park, Land East of Junction 12, M1: Independent Sustainability Appraisal, provided at Appendix 2; and

• Toddington Park: A Landscape and Visual Comparative Sites Study, provided at Appendix 3.

Strategic Employment Strategy Options

The Supplementary SA includes entirely new appraisal work in relation to strategic employment strategy options. Whilst the original SA appraised two growth scenarios based on the allocations in the Local Plan, with and without Sundon RFI, the Supplementary SA considers whether or not to provide sites to meet some of the footloose regional demand for strategic warehousing. As such, IM Properties’ concern that an option with a greater number of sites/jobs is not addressed.

At paragraph 2.26, the Supplementary SA states that: “Because this footloose regional demand has not been quantified, there is no evidence on which to base a set of more detailed alternative options considering specific amounts of such development that could be provided within Central Bedfordshire.”

The Supplementary SA confirms that it takes account of updated evidence, including the Functional Economic Market Assessment and Employment Land Review, prepared by PBA and dated July 2017 (Ref: C08). This does not quantify how much additional land for strategic warehousing is required over the plan period, but states, at paragraph 5.106, that “ …very simply the strength of the national market and the footloose nature means that demand is largely infinite …”.

However, this is not the latest evidence. This is set out in the Employment Land Update, prepared by Stantec May 2020, and which forms part of the additional evidence. This quantifies the demand for land for large warehouses in Central Bedfordshire as 320-425 hectares over a 15-year period (i.e. the remaining Plan period).

It is our view that the Supplementary SA should have taken account of the latest evidence as set out in the Employment Land Update, and given this quantifies footloose regional demand for strategic warehousing it should have tested alternative options with a greater numbers of sites/jobs. In the absence of this the Plan is not:

• Positively prepared, as the strategic employment strategy does not seek to meet objectively assessed development; or

• Justified, as it is not demonstrated that the strategic employment strategy is the most appropriate strategy when considered against the reasonable alternatives based on proportionate evidence.

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Strategic Warehousing Land Supply

The Employment Technical Paper, at paragraph 5.4.6, sets out that the Plan strategy currently addresses the strong demand for warehousing within Central Bedfordshire by “… allocating up to 140ha of land for strategic warehousing on sites considered to be qualitatively suitable.”

The Growth Strategy (Policy SP1) allocates 140 hectares of land as strategic employment areas, of which strategic warehousing is a part. Taking account of the site-specific allocation policies, a maximum of 127 hectares is allocated for strategic warehousing. However, the Draft Suggested Main Modifications Arising from Additional Evidence (Ref: EXAM 117), as detailed in the Employment Technical Paper, reduce the supply further to a maximum of 105 hectares. The supply position , by allocated site, is set out in the table below.

Growth Strategy Site Specific Draft Suggested (Policy SP1) Allocation Policies Main Modifications from Additional Evidence

M1 Junction 11a - Strategic Employment B8 warehousing and No change – Sundon Rail Freight Area - 45ha distribution uses – approximately 40ha Interchange approximately 40ha

(Policy SE1)

M1 Junction 13 - Strategic Employment Employment land No change – up to Marston Gate Area - 35ha including B8 35ha Expansion warehousing and associated uses – up to (Policy SE2) 35ha

A1 Corridor – Strategic Employment B2 and B8 floorspace Change – 30ha of B8 Biggleswade South/ Area - 60ha including strategic strategic floorspace Holme Farm, warehousing - up to Biggleswade 52ha

(Policy SE3)

TOTALS 140ha 127ha 105ha

Furthermore, if Sundon RFI focuses on meeting the demand of occupiers with a rail requirement, this will further diminish overall supply for general strategic warehousing. Indeed, as raised later in these representations, given the emphasis on sustainable transport in terms of freight to justify the Sundon RFI allocation, Policy SE1 should restrict the employment uses to occupiers with a rail requirement.

In light of the above, there is a disconnect between the Council’s own evidence base which now quantifies the demand for land for large warehouses in Central Bedfordshire as 320-425 hectares over a 15-year period (i.e. the remaining Plan period) and the approach of the Plan which seeks to further reduce supply to 105 hectares – that is, a 3.75-5 year supply. Moreover, there is no buffer to improve the prospect of delivering the planned supply in the event that the allocated site s are delayed or do not come forward at all. For example, where sites, such as Sundon RFI, are dependent on the delivery of significant infrastructure this may impact on delivery timescales and/or viability. For these reasons, it is our view that for the Plan to be found sound there is a clear need to allocate at least one more site for strategic warehousing.

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Strategic Warehousing Jobs Generated

With a diminished supply of land for strategic warehousing there is a diminished yield in potential jobs generated, which adds weight to the need to allocate at least one more site for strategic warehousing.

The PBA Technical Note that supports the Council’s Matter 6 Statement sets out that the three sites allocated for strategic warehousing may generate around 5,700 jobs. This is based on development at 40% plot ratio and one worker per 95 square metres of built floorspace, which is in line with the 2015 HCA Employment Densities Guide. Applying the same assumptions to the now diminished supply of land for strategic warehousing results in the generation of a lower 4,421 jobs. The jobs generated by allocated site is set out in the table below.

135 hectares 105 hectares

(PBA Technical Note) (Draft Suggested Main Modifications from Additional Evidence)

Sundon RFI Area - 40ha Area - 40ha

Jobs - 1,700 Jobs – 1,684

Marston Gate Area - 35ha Area - 35ha Expansion Jobs - 1,500 Jobs – 1,474

Holme Farm, Area - 60ha Area - 30ha Biggleswade Jobs - 2,500 Jobs – 1,263

TOTAL JOBS 5,700 4,421

It is our view that the approach used in the PBA Technical Note overestimates the potential jobs generated. There are a number of factors which dictate the density of an individual development scheme, including site shape and topography, visual impact, and the need to accommodate infrastructure such as roads, attenuation and landscaping. However, evolving policy and occupier requirements have also generated the need to accommodate other factors, such as amenity, biodiversity and the growing demand from occupiers for increased yards and circulation areas (e.g. in the growing parcel sector where low density plots are the norm). Taking into account these factors, we consider plot ratios of between 20% and 35% may be more realistic. We have calculated jobs generated on a best-case scenario (35% plot ratio) and a worst-case scenario (20% plot ratio). These calculations are provided at Appendix 1 and summarised in the table below. At best 3,868 jobs may be generated and at worst 2,211 jobs.

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Best Case Worst Case

35% Plot Ratio 20% Plot Ratio

Sundon RFI Area - 40ha Area - 40ha

Jobs – 1,474 Jobs – 842

Marston Gate Area - 35ha Area - 35ha Expansion Jobs – 1,289 Jobs – 737

Holme Farm, Area - 30ha Area - 30ha Biggleswade Jobs – 1,105 Jobs – 632

TOTAL JOBS 3,868 2,211

Allocation of Land at Junction 12 could assist in meeting the shortfall in jobs that results from the diminished supply of strategic warehousing land. As set out in the Delivery Framework Document submitted with our Matter Statements (in advance of making verbal representations to the Examination hearings sessions held between May and July 2019), we estimate that the proposed development at Land at Junction 12, once operational, could generate around 2,300 jobs . This is based on a site area of 90.7 hectares and the Concept Masterplan within the Delivery Framework Document which achieves a plot ratio of 25%. Note that this excludes the proposed community woodland to the west of the M1, which is integral to the proposed development, and if included would result in an even lower plot ratio.

Partial Plan Review

The Employment Technical Paper acknowledges, at paragraph 5.4.6, that additional supply of land for strategic warehousing will be required but sets out that this can be addressed through the early Partial Plan Review. Section 5.5 of the Local Plan covers the Partial Plan Review and paragraph 5.5.4 sets out that the Council will start the Partial Review within six months of ado ption of the Plan.

We have concerns with reliance on an immediate review of the Plan to rectify the issue of a disconnect between the demand for and supply of land for strategic warehousing. We do not consider that the Plan should be found sound if it needs to be reviewed immediately on adoption as known needs should be addressed now rather than delayed for a future plan.

Notwithstanding this, should the Inspectors be minded to find the Plan sound subject to a Partial Plan Review then this should be a commitment set out in a policy. Taking account of the Procedure Guide for Local Plan Examinations, we request that the policy sets out the matters to be dealt with, including strategic warehousing, and the timescales for commencement of the review and for submission for Examination. The timescales should take into account that the limited supply of land for strategic warehousing will not support a delay in bringing a future plan forward.

Strategic Employment Site Options

The Supplementary SA includes entirely new appraisal work in relation to strategic employment site options, appraising an additional 13 sites alongside the three allocations of Sundon RFI, Marston Gate Expansion, and Holme Farm, Biggleswade.

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Site Assessment and Selection – SA Appraisal

The additional sites appraised in the Supplementary SA do not include Land at Junction 12 , and it is our view that the Supplementary SA should have assessed Land at Junction 12. The omission of Land at Junction 12 from the Supplementary SA’s appraisal highlights a significant lack of consistency in the additional evidence submitted, given the Sundon RFI ASA not only appraises, but also shortlists Land at Junction 12 as one of three locations with RFI potential.

The Supplementary SA confirms, at paragraph 2.32, that it assesses sites that passed the strategic site assessment stage in the Strategic Employment Site Assessment Technical Document (PBA, July 2017), together with one that was omitted in error (i.e. Land at New Spring Farm, Biggleswade ).

Land at Junction 12 ‘failed’ the strategic site assessment in the Strategic Employment Site Assessment Technical Document on grounds of Green Belt and landscape. However, our representations to both the Regulation 18 and Regulation 19 consultations raised significant concerns with the assessment of Land at Junction 12 within the Strategic Employment Site Assessment Technical Document, including a lack of consistency in the assessment of sites. As such, it is our view that Land at Junction 12 has been unfairly dismissed as a suitable and deliverable option for strategic employment growth and that the Strategic Employment Site Assessment Technical Document is not fit for purpose and should not be used as a tool to determine options.

Our earlier submissions requested that that Land at Junction 12 be properly assessed and considered as a reasonable alternative. However, the Council have never responded to this request. Our requests included, at the Regulation 18 consultation stage, submission of an independent appraisal of the Land at Junction 12 as a strategic employment growth option against the SA objectives. This appraisal has been reviewed and updated in the Toddington Park, Land East of Junction 12, M1: Independent Sustainability Appraisal provided at Appendix 2.

As demonstrated in the table below, Land at Junction performs well in the appraisal, and as least as well as the allocated sites. The conclusion reached from this is that Land at Junction 12 is a sustainable reasonable alternative to be selected for inclusion as a site allocation within the Local Plan.

SA Objective Land at Strategic Warehousing Allocations Junction 12 Sundon RFI Marston Gate Holme Farm, Expansion Bigglewade

1. Housing 0 0 0 0

2. Communities -- - 0 -- 0 0 0 -?

3. Services & 0 0 0 0 Facilities

4. Employment ++ ++ ++ ++ ++ ? ++ ++

5. Health & 0 ++ + ++ 0 ++ 0 ++ Equality

6. Highways & Air 0? +/-? -? -? Quality

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SA Objective Land at Strategic Warehousing Allocations Junction 12 Sundon RFI Marston Gate Holme Farm, Expansion Bigglewade

7. Sustainable ++ ++ ++ ++? Transport

8. Energy & +? +? +? +? Climate Change

9. Water 0 0 0? 0? Resources & Quality

10. Flood Risk 0 0 0 0

11. Soil -? 0 --? 0 --? 0? --? 0

12. Biodiversity & + -? +? +? Geodiversity

13. Landscape -? --? +? +?

14. Historic 0? 0 0? -? Environment

By omitting Land at Junction 12, the Supplementary SA does not appraise all reasonable alternatives. As such, the Plan is not justified as it is not demonstrated that the sites selected are the most appropriate.

Site Assessment and Selection – “Qualitatively Suitable”

The Employment Technical Paper, at paragraph 5.4.6, sets out that the Plan allocates sites for strategic warehousing that are considered to be “qualitatively suitable.”

However, despite the Employment Land Update quantifying demand for land for large warehouses in Central Bedfordshire as 320-425 hectares over the remaining Plan period and the Supplementary SA appraising 16 sites as reasonable alternative strategic employment sites, the allocations remain as Sundon RFI, Marston Gate Expansion and Holme Farm, Biggleswade, which together are now to deliver a diminished supply of land for strategic warehousing totalling a maximum of 105 hectares.

The Supplementary SA concludes, at paragraph 4.142, that: “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.” That is, it does not give a clear steer on preferred sites, and, to us, it is not clear how sites have been selected and discounted, in particular the weighting process applied.

The Supplementary SA, as set out at paragraph 4.143, found the employment sites that perform most strongly to be: 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. However, of these five sites only two are allocated – that is, Land at Ridgemont (M1 Junction 13) (i.e. Marston Gate Expansion) and Land West of the A1, Biggleswade (i.e. Holme Farm, Biggleswade).

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Whilst the sites identified as performing the least well do not go on to be allocated, Sundon RFI is allocated. Sundon RFI falls between the sites that perform most strongly and least well. The Supplementary SA notes, at paragraph 4.142, that Sundon RFI is one of two sites with the greatest number of significant positive effects, with the other site being Land West of the A1, Biggleswade (i.e. Holme Farm, Biggleswade) which is also allocated. However, the Supplementary SA goes on to note that Sundon RFI also has the largest number of significant negative effects, along with three other sites which are identified as performing least well and are not allocated.

The Employment Technical Paper, at paragraph 6.2.13, states that: “When planning balance is applied and factors such as the physical location and attributes of each location are taken in to consideration, the Supplementary SA reinforces the judgements made in relation to the sites identified to meet the strategic demand and supports the strategy set out within the plan.” However, it is our view, that the process seeks to retrospectively justify the allocations.

Land at Junction 12

The Employment Technical Paper, at 6.2.12 sets out that: “It has been established that there is a strong need and demand for strategic employment opportunities along the two strategic routes (M1 and A1) that pass through Central Bedfordshire and that there is currently a limited supply of land and sites to meet this demand.” However, taking account of the above, supply is limited by flawed and opaque site assessment and selection process.

Given the strong need and demand, there is a clear need to allocate at least one more site for strategic warehousing. It is our view that this should be along the M1 corridor. The Council’s Functional Economic Market Assessment and Employment Land Review, prepared by PBA May 2016 (Ref: C08), sets out that the M1 is the stronger performing market, with a secondary market on the A1. It is noted that the Employment Land Update states, at paragraph 3.2.15, that the A1 corridor has become “… increasingly attractive – joining the M1 as a location for large warehouses.” However, this is due to lack of supply along the M1, with the Property Market Update for Strategic Distribution Warehousing, prepared by Aspinall Verdi March 2020 and appended to the Employment Land Update, stating at paragraph 3.14, that “… agents have told us that as sites have become scarce along the M1 corridor the A1 corridor has become more attractive.”

The allocation of Land at Junction 12 of the M1, a 224 acre (90.7 hectare) site that can provide 2.4 million square feet (around 227,000 square metres) of floorspace and around 2,300 jobs in the operational phase, has distinct benefits.

The case for Land at Junction 12 is set out in the Delivery Framework Document (submitted with our Matter Statements) and is not repeated here, but attention is drawn to key benefits of:

• Location along the M1 corridor, where there is a critical lack of supply and where the Plan proposes to allocate only two sites, and with direct access to the upgraded Junction 12 already in place enabling early delivery. It is noted that being strategically located on the M1 corridor weighs in favour of Sundon RFI in the Supplementary SA. Furthermore, two of the best performing sites, Cranfield University Campus and Airfield and Land East of the M1, South of Broughton Road, were discounted in part for being less well connected to the strategic road network (Cranfield University Campus and Airfield) and having uncertainties in relation to access onto the M1 (Land East of the M1, South of Broughton Road).

• Proximity to Harlington Rail Station, which is less than one mile (1.6 kilometres) from Land at Junction 12, with rail services every 20-40 minutes weekdays and 60 minutes Saturday and Sundays from Bedford to Brighton via Luton and London. Proximity to the railway station at Ridgemont weighs in favour of Land at Ridgemont (M1 Junction 13) (i.e. Marston Gate Expansion) in the Supplementary SA, as it provides better opportunities for people to travel

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to and from by sustainable transport. Sustainable transport connections also weighed in favour of Sundon RFI.

• Advantageously positioned within proximity to Sundon RFI providing a potential opportuni ty for rail connectivity for the transportation of goods. Facilitating the bulk transfer of goods movement from road to rail weighs in favour of Sundon RFI in the Supplementary SA and given this, as noted above, Policy SE1 should restrict the employment uses on this site to occupiers with a rail requirement.

• Weak performance against Green Belt purposes (and an evidential need for strategic warehousing along the M1 corridor and development can be brought forward without resulting in unacceptable landscape impact. Whilst the Sundon RFI ASA discounts Land at Junction 12 as a credible alternative for an RFI on grounds of landscape impacts, it notes at paragraph 7.24 that a full landscape assessment has not been undertaken to inform the study of alternatives, and it draws on the assessment of Land at Junction 12 as set out in the Strategic Employment Site Assessment Technical Document. However, as set out above, we do not consider that this should be relied on. Furthermore, the Supplementary SA recognises that impacts may be mitigated and concludes as such in relation to the landscape impacts of Marston Gate Expansion, and a Landscape Mitigation Plan for Land at Junction 12 is set out in the Delivery Framework Document.

Supplementing the Delivery Framework Document, the Landscape and Visual Comparative Sites Study, provided at Appendix 3, compares sites for strategic warehousing along the M1 and A1 corridors and, for those site within the Green Belt, which are all on the M1 corridor, ranks them in relation to their relative contribution to Green Belt purposes. This shows that Land at Junction 12 makes the least contribution, performing better than Sundon RFI. The Study also ranks sites by their ability to contribute to a sustainable development pattern, factoring in the contribution that each makes to the purposes of the Green Belt and the landscape and visual opportunities and constraints present. In this respect Land at Junction 12 is fifth, behind: New Spring Farm, Biggleswade (Site J); Land East of M1, Broughton Road (Site A); Land at Ridgmont (M1 Junction 13) (i.e. Marston Gate Expansion) (Site E); and Land at Bedford Road, Husborne Crawley (Site C). Land at Ridgmont (M1 Junction 13) is an allocated site (i.e. Marston Gate Expansion). Of the other three sites, New Spring Farm, Biggleswade is on the A1 corridor, whereas the need for sites is greatest along the M1 corridor, and Land East of M1, Broughton Road and Land at Bedford Road, Husborne Crawley are disadvantaged as credible alternatives for strategic warehousing due to their size, with Appendix G to the Supplementary SA giving their respective site areas as 12.75 hectares and 14.49 hectares.

Conclusion

The additional evidence does not address the concerns raised by the Inspectors in their letter of the 30th September 2019, or IM Properties’ concerns as raised in earlier submissions made to the Local Plan consultation and Examination. It remains IM Properties’ case that the Local Plan does not make sufficient allocations for strategic employment development, with a continuing disconnect between the Council’s own evidence base, which shows significant demand for land for strategic warehousing in Central Bedfordshire, and the approach of the Plan, which further constrains supply. There is a clear need to allocate at least one more site for strategic warehousing, and consideration should be given to Land at Junction 12 as a reasonable alternative. Notwithstanding this, should the Inspectors be minded to find the Plan sound subject to a Partial Plan Review then this should be a commitment set out in a policy.

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We thank you for the opportunity to respond to the additional evidence consultation. If you require any clarification of the matters raised or any further information please do not hesitate to contact me.

Yours faithfully

MARK SITCH Senior Partner

Representations Barton Willmore obo IM Properties Appendices

APPENDIX 1

STRATEGIC WAREHOUSING ALLOCATIONS: JOBS GENERATED

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25282/A3/SH 12th August 2020

Strategic Warehousing Allocations: Jobs Generated

Best Case Scenario Calculations

Site Hectares Hectares - Resultant Jobs Site Density Buildings 1:95sqm Ratio sqm (actual 35% buildings excluding yards)

Sundon RFI 40 14 140,000 1,474

Marston Gate 35 12.25 122,500 1,289 Expansion

Holme Farm, 30 10.5 105,000 1,105 Biggleswade

TOTAL 105 36.75 367,500 3,868

Worst Case Scenario Calculations

Site Hectares Hectares - Resultant Jobs Site Density Buildings 1:95sqm Ratio sqm (actual 20% buildings excluding yards) Sundon RFI 40 8 80,000 842

Marston Gate 35 7 70,000 737 Expansion

Holme Farm, 30 6 60,000 632 Biggleswade

TOTAL 105 21 210,000 2,211

Page 1 of 1

Representations Barton Willmore obo IM Properties Appendices

APPENDIX 2

TODDINGTON PARK, LAND EAST OF JUNCTION 12, M1: INDEPENDENT SUSTAINABILITY APPRAISAL

25282/A3/SH/bc August 2020

Toddington Park, Land East of Junction 12, M1

Independent Sustainability Appraisal

August 2020

Toddington Park, Land East of Junction 12, M1

Independent Sustainability Appraisal

Prepared on Behalf of IM Properties Plc

Project Ref: 25282/A5/Reports/Environmental Planning Status: Draft for client Final for issue Issue/Rev: 01 02 Date: August 2020 August 2020 Prepared by: JM JM Checked by: LW LW

Barton Willmore LLP 7 Soho Square London W1D 3QB

Tel: 020 7446 6888

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP.

All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks.

Toddington Park, Land East of Junction 12, M1 Introduction

1.0 Introduction

1.1 This report includes a review of the appraisal of the sustainability credentials of the proposed Toddington Park on Land East of Junction 12 of the M1 motorway. The site has not been included for allocation or as an option for assessment against the Sustainability Appraisal (SA) Objectives within the SA Supplementary Report (May 2020)1, which has been prepared to support the draft Central Bedfordshire Local Plan 2015-2035 and is currently under consultation. The SA process must comply with the Environmental Assessment of Plans and Programmes Regulations 2004 (the Strategic Environmental Assessment (SEA) Regulations). Policies and proposed allocations within the Plan must be appraised in an objective manner, alongside reasonable alternatives. The Local Plan was submitted to government by Central Bedfordshire Council (CBC) in April 2018 and Examination hearing sessions took place between May and July 2019. Following the hearings, the Inspectors wrote a post-hearing letter to the Council which raised a number of points in relation to the SA work carried out to date. The purpose of the Supplementary SA report was to present the further work undertaken on the SA to address those points.

1.2 Toddington Park is being promoted for the development of a large-scale logistics park, in conjunction with comprehensive green infrastructure and landscaping. An independent appraisal of the site against the fourteen SA Objectives was previously undertaken as part of the Regulation 18 representations2, which were submitted in August 2017. This appraisal has been reviewed and updated by drawing on the current evidence base available for the site, including the Toddington Park Delivery Framework Document3, the concept masterplan, technical assessments and reports, and online sources of current baseline information. The updated site-specific appraisal is included at Appendix 1 and has been undertaken by Barton Willmore utilising the same matrix methodology and 14 SA Objectives used to consider the alternative site options within the SA Supplementary Report for inclusion within the draft Plan. The matrix assessment with a colour coded key is a method often used for the assessment of site options in SAs, to make the comparison of the positive and negative sustainability aspects of a site clear and consistent. The appraisal provides commentary on the score that we consider should be awarded for each SA Objective.

1 Sustainability Appraisal of the Central Bedfordshire Local Plan Supplementary Report, Land Use Consultants Ltd on behalf of Central Bedfordshire Council (May 2020) 2 Land East of Junction 12, M1, Representations to Central Bedfordshire Draft Local Plan – 2015 – 2035 Submitted on behalf of Landowners and IM Properties Plc, Barton Willmore (August 2017) 3 Investing in Central Bedfordshire – Delivering Logistics, Toddington Park Delivery Framework Document, Barton Willmore (December 2018)

25282/A5/Reports/Environmental Planning August 2020 Toddington Park, Land East of Junction 12, M1 Site Appraisal

2.0 Site Appraisal

Performance of Toddington Park, Land East of Junction 12, M1

2.1 Toddington Park performed well overall in the site appraisal against the 14 SA Objectives. The full appraisal is included at Appendix 1. The site was awarded a positive score (+ or ++) in 4 of the SA Objectives and a score of neutral (0) was awarded for 7 of the SA Objectives for which neutral impacts are anticipated or are unknown at this stage. Negative scores were awarded for 3 criteria. Note that some Objectives are split into two or three, so the results listed here are worst case.

2.2 The following sources of information were used as the evidence base for undertaking the site appraisal:

• Investing in Central Bedfordshire – Delivering Logistics, Toddington Park Delivery Framework Document, Barton Willmore (December 2018); • Economic Benefits Summary (Barton Willmore, December 2018); • Landscape and Visual Appraisal and Green Belt Review report, Barton Willmore (August 2017); • Land East of Junction 12/M1 Arboricultural Constraints and Opportunities, Tree Schedule and Tree Constraints Plan (Lockhart Garratt, July 2018); • M1 Junction 12 Extended Phase 1 Survey Report and Map (Lockhart Garrett, May 2018); • Transport Strategy (Vectos, February 2018); • Heritage Impact Assessment (Barton Willmore, February 2018); and • Noise Assessment for Old Park Farm, Harlington (Resound Acoustics, June 2018).

2.3 The development provides the opportunity to meet demand for large-scale logistics development along the southern M1 corridor, within a location with exceptional connectivity and access to potential labour. This will deliver economic benefits for Central Bedfordshire with the creation of around 2,300 full time equivalent jobs on-site during the operational phase and a further 464 jobs during construction. The site will improve access to rail connections, which could have positive impacts by using rail to transport freight instead of roads. The development will also provide the potential for bus services for employees travelling from Harlington rail station and the Dunstable to Luton guided busway, and the development of bespoke smart shared travel, which could reduce car use. This will include IT platforms designed to accentuate the increasing trend for the sharing of private cars (car sharing) and the use of shared cars provided by the development (car pooling). In addition, the development will create networks of pedestrian and cycling routes, which will have benefits for the health of employees.

25282/A5/Reports/Environmental Planning August 2020 Toddington Park, Land East of Junction 12, M1 Site Appraisal

2.4 The design of the development includes for significant provision of publicly accessible open space and the enhancement of key green infrastructure corridors, including the River Flit corridor with linked wetland and streamside features, which will focus on the creation of a network of high quality habitats to support biodiversity enhancement and connectivity. The site provides significant opportunity for new planting, including reinforcement of off-site boundary planting and the creation of approximately 23 hectares of the site as new woodland and associated habitats, with a further substantial area of off-site woodland of approximately 16 hectares to the west of the M1. The development will be integrated into the landscape without impacting the Chilterns Area of Outstanding Natural beauty (AONB) or views from surrounding areas. The development will be energy efficient and will include measures that will increase adaptation to climate change including the provision of Sustainable Drainage Systems (SuDS), which include an allowance for climate change, and detailed energy modelling to reduce the risk of overheating.

Summary of Site Appraisal

2.5 The independent site appraisal for Toddington Park, Land East of Junction 12, M1 (Appendix 1), has been updated to assess its performance against the fourteen SA Objectives used to consider the alternative site options within the Supplementary SA. This shows the scores that we think should be awarded. This is based on our knowledge of the site’s opportunities and our client’s commitment to delivery. This review suggests that the site should be included within the development options in the draft Central Bedfordshire Local Plan.

25282/A5/Reports/Environmental Planning August 2020 Toddington Park, Land East of Junction 12, M1 Conclusion

3.0 Conclusion

3.1 The conclusion reached within this report, based on the site appraisal in Appendix 1, is that the potential development site “Toddington Park, Land East of Junction 12, M1” is a sustainable reasonable alternative to be selected for inclusion as a site allocation within the Local Plan. The site scores well against the Council’s 14 SA Objectives and would lead to economic, social and environmental benefits not only at the site and borough levels but would present a catalyst for the continued investment, growth and success in logistics in Central Bedfordshire with enhancement of the green infrastructure network and the delivery of significant social benefits and associated long-term sustainability benefits.

25282/A5/Reports/Environmental Planning August 2020

APPENDIX 1: SITE APPRAISAL - TODDINGTON PARK, LAND EAST OF JUNCTION 12, M1

SITE APPRAISAL – TODDINGTON PARK, LAND EAST OF JUNCTION 12, M1

Categories of Significance of Effects Symbol Meaning Sustainability Effect + + Major Positive Proposed development encouraged as would resolve existing sustainability problem + Minor Positive No sustainability constraints and proposed development acceptable 0 Neutral Neutral effect ? Uncertain Uncertain or Unknown Effects - Minor Negative Potential sustainability issues: mitigation and/ or negotiation possible - - Major Negative Problematical and improbable because of known sustainability issues; mitigation likely to be difficult and/or expensive - + SA Objectives 2, 4, 5, 9 & 11 consider more than one sub-topic such that more than more than one significant effect may be predicted with two symbols. No 2 Communities – first symbol refers to in/out of Green Belt; second symbol refers to community & settlement identities No 4 Employment – first symbol refers to employment support; second symbol refers to vitality/viability of town centres No 5 Health & Equality – first symbol refers to regeneration/deprivation & equality; second symbol refers to Green Infrastructure for health & well-being No 9 Water – first symbol refers to water resources; second symbol r elates to water quality No 11 Soil & Land – first symbol refers to greenfield & agricultural land qualities; second symbol relates to previously developed land

2. Communities The employment growth option is located within the Green Belt. CBC’s Green Belt Study identifies the land as making a strategic contribution to the purposes - - - 0 To maintain and enhance community of Green Belt. Based on the conclusions of the Green Belt Study, the development therefore has the potential for major long-term negative effects. However, and settlement identities based on the findings of Barton Willmore’s Landscape and Visual Appraisal and Green Belt Review4 only a minor adverse effect is anticipated (further information is provided in the footnote below). Therefore, both outcomes have been recorded for this objective to reflect this. The development of the site for employment uses is unlikely to significantly affect settlement identity as it is not located within or adjacent to an existing settlement. There are potentially neutral effects on settlement identity.

The weak performance of the site against Green Belt purposes, and the evidenced need for large-scale logistics along the M1 provides a clear justification for its release from the Green Belt. The development can be brought forward without resulting in unacceptable harm to the setting of, and views to and from, the Chilterns AONB. The Landscape Mitigation Plan5 demonstrates how the landscape impacts on existing communities and settlements can be successfully mitigated through sensitive design. In addition, the development provides the opportunity to work with the Bedfordshire Local Nature Partnership and other key stakeholders to reinforce and enhance the landscape character of the area and ensure the proposed development reflects and contributes to sense of place and local distinctiveness. In addition, the development will deliver green infrastructure enhancements, providing a network of open space (much of which will be publicly accessible) and recreational amenities, and opportunities to create high quality green infrastructure linkages and restore sensitive habitats. Access provision will include a direct footpath/cycleway to and from Harlington (located approximately 800m to the east from the eastern boundary of the site) and a substantial area of accessible new woodland and associated habitats linking into the wider Public Rights of Way (PRoW) network.

The site can deliver for business, employees and community. The site promoter is committed to creating an environment that underpins the creation of a successful business community, integral to which are the needs and well-being of those who work there. The development will support a wider Social Value agenda, with local employment, use of local suppliers and engagement with community groups, schools and the third sector. Such initiatives will enhance the local communities of Toddington and Harlington and the surrounding area and could include:

4 The assessment of the effects of the employment growth option on the Green Belt is based on the Council’s Green Belt Study. However, this study is not considered to be robust. The Green Belt Study sets out that the vast majority of the site is overlapped by Parcel H3. However, Parcel H3 occupies a much greater swathe of land than the site and encompasses additional land to the north and west of Harlington. These areas of land within Parcel H3 are not associated with the site and are separated from the urbanising influences (both by distance and intervening topography) identified in the published character assessments and through our field survey. Therefore, in the Green Belt Study, the extent to which Parcel H3 is perceived as countryside is overstated concerning the area that is pertinent to the site. A finer grain of detail of assessment, as has been conducted in the Landscape and Visual Appraisal and Green Belt Review report (August 2017) is required to determine the site’s suitability for release from the Green Belt. On this basis, it is considered that the Development has the potential for minor long-term negative effects. 5 Investing in Central Bedfordshire – Delivering Logistics, Toddington Park Delivery Framework Document, Barton Willmore (December 2018)

• Furthering student awareness and exposure to the ‘world of work’ (and specifically the industrial and logistics sector), through business partnering and Industry Awareness Days; • The potential for third sector enterprises to engage with the project (for example through procurement of services); • Exploring how the wider community can utilise space within the development (including the new 16 hectare woodland) where it does not compromise the operational requirements of the site or financial viability; • Engagement with the local community to ensure the long-term operation of the site does not adversely impact on the nearby community; and • Creation of a Community Fund to support local charities, groups and other formally constituted local organisations.

3. Services & Facilities The scale of employment growth means that sufficient services are likely to be provided at the site itself. Employees are less likely to travel off-site for services. 0 To improve accessibility to services Despite this, the site is in close proximity to the settlements of Toddington (located approximately 1.3km to the west from the western boundary of the site) and facilities and Harlington (located approximately 800m to the east from the eastern boundary of the site), which offer a range of services and facility provisions including shops, healthcare and pubs, as well as services on the M1.

Toddington Park has direct access to the M1 with immediate access off Junction 12. It is also advantageously positioned within proximity of the Rail Freight Interchange (RFI) proposed at Sundon, providing a potential opportunity for rail connectivity for the transportation of goods. The site is located approximately 800m to the west of Harlington Rail Station which is on the Midland Mainline Railway, and there is significant opportunity to provide integrated footpaths and cycleways to the Rail Station, Harlington village, and strategic employment development proposed at Sundon.

A hub facility will be provided for employees offering a range of activities and events and acting as a focal point for providing easy access to a range of sustainable transport modes and social interaction. The development will improve accessibility including a direct footpath / cycleway to and from Harlington and a substantial area of accessible new open space and woodland and associated habitats which will link into the wider PRoW network.

4. Employment The site would deliver new employment land and jobs to support the economy with the potential for major long-term positive effects. The site is adjacent to + + + + To support the economy and ensure a railway line and is in close proximity to Harlington railway station. It has potential for major long-term cumulative positive effects. Given the site’s location that there are suitable opportunities in proximity to the town centres of Luton, Houghton Regis and Dunstable, there is an opportunity for the site to have positive effects on these centres, as well for employment as on Harlington and Toddington, which are identified as ‘Minor Service Centres’ in the Draft Local Plan.

There is strong demand for high quality large-scale logistics development along the southern M1 corridor to meet the regional and national demand for warehousing development.

The southern M1 Corridor remains the major distribution corridor serving the south east, and the rest of the UK, but it now suffers from a critical shortage of deliverable land. The development will create a 90.7 hectare employment site at Toddington Park which will provide approximately 227,000 square metres of floorspace, with notable potential for accommodating larger footprint buildings, including one unit of at least 93,000 square metres of floorspace. There is a notable lack of supply across the region for this scale of building. The site has the potential to deliver 2,300 full time equivalent jobs during the operational phase and a further 464 jobs during construction, and generate an additional £5.8 million in business rates per annum for the district, and £109 million GVA per annum from direct employment and £43.7 million GVA from construction6. The site will provide the opportunity to attract and accommodate new businesses and operators into the area and will deliver exceptional economic benefits for Central Bedfordshire.

The site promoter is committed to continue to work with local businesses / stakeholders and local communities to deliver sustainable new business opportunities. The development has access to a very large pool of potential labour given its proximity to Luton, Harlington and Toddington, with 293,000 economically active residents living within 20 minutes’ drive of Junction 12. Access to labour from Toddington Park would also be possible through the nearby Harlington Rail Station, which is within a 15 minute journey to both Bedford and the Luton conurbation, itself within the 20-minute drive time catchment and a significant source of labour supply. The development will support local employment and in addition to providing new local jobs will also:

• Support new entrants and people returning to work; • Where possible support deprived communities; • Promote local jobs via local campaigns; • Align with local suppliers supporting indirect employment growth; and • Buy Local – Working with and through any lead contractor, will seek to maximise (where economically viable) the use of local suppliers and will put in place a procurement plan which identifies and communicates the opportunities for local suppliers and the sourcing of materials where possible.

6 Economic Benefits Summary, Barton Willmore (December 2018)

SA Objective Assessment of Effects Nature of the likely sustainability effect (including positive/negative, short - medium term (5-10 years)/long-term (10 - 20 years plus), permanent/temporary, secondary, cumulative and synergistic); Uncertainty 5. Health and Equality The site is not located in an area of higher deprivation and therefore significant effects are not anticipated. The creation of local employment opportunities 0 + + To improve the health and wellbeing may lead to positive indirect effects on health. The site contains the River Flit, old field boundaries, hedgerows, scrub and a County Wildlife Site is located of communities and reduce adjacent to the east of the site, on the opposite side of the railway line. Therefore, there is an opportunity to enhance the wildlife areas within the site for inequalities use by people and access to the off-site County Wildlife Site, particularly as two public rights of way transect the site. Access to nature is known to promote wellbeing.

The site is located within an area of substantial green infrastructure opportunity and will provide areas of publicly accessible open space. The development includes enhancements to the River Flit corridor, provision of a new community woodland, and connection to a wider network of green spaces, in particular Sundon Country Park and Sundon landfill and Sundon Chalk Pits to the east of the site.

The site will incorporate an extensive network of permitted public access routes linking into the wider PRoW network, to encourage healthy outdoor lifestyles and improve physical activity rates through walking and cycling. The development will be suitable for all user groups (elderly, mobility impaired and use of walking frames/scooters, parents with pushchairs). It is known that green space and the opportunity for exercise and recreation is of great benefits to physical and mental health. The location of employment land with substantial accessible green infrastructure that could be used by all on a daily basis, is likely to encourage more sustainable and healthy behaviour over the working week, which would be facilitated by the improvement of access to facilities. Whilst not possible to directly attribute the design to good mental health and lower levels of obesity, it is commonly known that making healthy choices and exercise easier for people increases positive outcomes.

A Noise Assessment7 has been undertaken and shows some adverse impacts, without mitigation, mainly relating to external vehicle noise as the dominant source. Mitigation measures will be considered at the detailed planning stage, which may include landscaped perimeter bunding and acoustic fencing to the service yards, to ensure that noise effects are not significant.

6. Highways and Air Quality The site is not located within or adjacent to an Air Quality Management Area. Impacts from noise and/or, air quality on residential receptors and other 0 ? To maintain and improve the existing neighbouring land uses would need to be considered and evaluated in a feasibility study. highway network and reduce associated indirect impacts on air The site is advantageously positioned on the Midland Mainline Railway and within proximity of the RFI proposed at Sundon, providing a potential opportunity quality and greenhouse gas emissions for rail connectivity for the transportation of goods. Harlington Rail Station is less than 1 mile (1.6 kilometres) from Toddington Park on foot with the potential for the provision of bus services for employees travelling from Harlington rail station and the Dunstable to Luton guided busway, and the development of bespoke smart shared travel, which could reduce car use. This will include IT platforms designed to accentuate the increasing trend for the sharing of private cars (car sharing) and the use of shared cars provided by the development (car pooling). The site has direct access to the M1 with immediate access off Junction 12. A Transport Strategy8 has been prepared for the site. Junction 12 is able to accommodate the level of employment growth proposed. Developer contributions from Toddington Park could help fund the strategically important A6-M1 link road.

Until transport modelling has been undertaken to determine whether there would be increased congestion in Luton and other surrounding settlements resulting from traffic generated by the site, the potential effect on highways is uncertain. Noise and air quality assessments undertaken at the planning application stage would determine the requirement for any mitigation measures that would be implemented to reduce effects. During the construction phase of the development, dust and emissions would be generated in association with plant and vehicles. Dust and emissions would be managed in accordance with standard best practice mitigation measures, implemented through a Construction Environmental Management Plan (CEMP), in accordance with all relevant legislation, and is not anticipated to generate significant adverse effects.

7. Sustainable Transport A Transport Strategy9 has been prepared for the site. The site is adjacent to the M1 and in close proximity to the RFI proposed at Sundon, providing a potential + + To encourage a demonstrable modal opportunity for rail connectivity for the transportation of goods, and Harlington train station (on the Midland Mainline which runs between London and shift and reduce the need to travel Sheffield), which is located approximately 800m to the east of the site. There is the potential to create a sustainable transport connection to the train station, Harlington village, and the strategic employment development proposed at Sundon, through new integrated footpaths and cycleways and a dedicated shuttle bus service on the existing network, and to encourage a modal shift, with employees using the railway line rather than cars, which would have positive effects.

As above, there are opportunities to enhance existing local bus services that will provide links to, for example, Harlington Rail Station and the Dunstable to Luton guided busway, and the development of bespoke smart shared travel. The creation of a potential hub facility within the development will act as a central access point to a range of transport modes. This facility will be an information point, providing details such as journey times and local cycle provision, and will – through ‘social sustainability’ – support initiatives such as car sharing. Additionally, a site-wide Travel Plan will be the umbrella document for each workplace to incorporate a package of measures and actions that will encourage safe, healthy and sustainable travel options.

7 Noise Assessment for Old Park Farm, Harlington, Resound Acoustics (June 2018) 8 Transport Strategy, Vectos (February 2018) 9 Transport Strategy, Vectos (February 2018)

SA Objective Assessment of Effects Nature of the likely sustainability effect (including positive/negative, short - medium term (5-10 years)/long-term (10 - 20 years plus), permanent/temporary, secondary, cumulative and synergistic); Uncertainty 8. Energy and Climate Change As set out above for SA Objective 7, there is the potential to establish a sustainable transport connection to the train station to encourage a modal shift, + ? To maximise the potential for energy which also provides the opportunity to reduce greenhouse gas emissions. Development at the site could comply with local planning policy which targets energy efficiency, reduce greenhouse gas efficiency and high quality design to reduce the effects of climate change. There is the potential for a minor positive effect. emissions and ensure that the built and natural environment and its The extensive areas of woodland planting will be designed to maximise their value for carbon sequestration in line with the Forestry Commission’s Woodland communities withstand the effects of Carbon Code. Landscape design will seek to provide shading and shelter to enhance the energy and sustainability of the development proposals. Where climate change appropriate water efficiency measures such as rainwater harvesting, and grey water recycling schemes will be integrated into the design.

The following commitments have been made as part of the development and will maximise the potential for energy efficiency, reduce greenhouse gas emissions and increase adaptation to climate change:

• The implementation of measures to adapt to climate change including the provision of SuDS, which include an allowance for climate change, and detailed energy modelling to reduce the risk of overheating; • Reducing the energy use of the development by approximately 20% over the current building regulations by using a range of energy efficiency and renewable energy technologies; • Ensuring all buildings achieve a BREEAM Very Good rating as a minimum, with a target of a BREEAM Excellent performance in relation to energy and water efficiency; • The specification of sustainable materials and where possible the use of modern methods of construction to reduce waste and the embodied carbon of development; • The use of water efficiency measures that will secure a 25% reduction in water use as a minimum; • Subject to occupier requirements, pilot schemes will inform appropriate low carbon renewable energy technologies; • The provision of passive and active Electric Vehicle (EV) charging points to encourage sustainable travel for employees and consideration of infrastructure for low emission freight vehicles; • Development in a sustainable location with a range of proposed access improvements, including a direct link to Harlington Rail Station, increased bus service frequency and improvement to the footbridge connection to the Sundon quarry site; • The development includes 39 hectares of green infrastructure, including a 16 hectare woodland to the west of the M1, enhancing on-site habitats and creating new habitats including new wetland areas as part of the sustainable drainage of the Site.

9. Water Resources and Quality The Water Cycle Study (July 2017) identifies that the site is located within the Upper Ouse and Bedford Ouse catchment. Abstraction for consumption is only 0 To minimise the demand for water available for up to 32% of the time and 25% of licences in the area are time limited and tied to a common end date of March 2028. Climate change is likely and maintain or improve water quality to have an impact on Central Bedfordshire in terms of a shortage of water resources10.

There are no strategic limitations on development growth as Water Companies have a statutory duty to supply water; however, capacity for providing additional supply varies and any new infrastructure requirements have to be aligned with Water Resources Management Plans. The addition of new employment land in this area is therefore considered to have the potential for cumulative effects on water resources but uncertainty until the scale and location is identified and the Water Cycle Study Phase 2 is undertaken. The River Flit which runs through the western part of the site is considered to be in a moderate overall water body class. Pollution from waste water is the most common reason for the majority of watercourses in the Plan not meeting a ‘good’ overall water body class. However, all waste water treatment works in the Water Cycle Study have some capacity within their existing permits to accommodate future development without causing a class of 10% deterioration. However, the available capacity in some settlements is quite small, reflecting the limited dilution potential available in the receiving water course. Some development may require waste water treatment works upgrades. The northern part of the site was historically used for landfill waste. Draft Local Plan policies require mitigation measures to be implemented to ensure at least neutral effects on water quality, so these could be implemented to prevent mobilisation of any contaminants from the site as well as manage waste water which could impact water quality.

Surface water run-off and foul water drainage will be managed on-site during the construction and operational phases. The onsite sewers are likely to be adopted by Anglian Water. As above, the use of water efficiency measures will secure a 25% reduction in water use as a minimum. Sustainable water management will reduce the quantity of water consumed and grey and green water solutions will reduce the need and usage of potable water.

10. Flood Risk Some western parts of the site are located in Flood Zones 2 and 3 (at a medium to high risk of flooding), corresponding with the location of the River Flit, 0 To reduce the risk of flooding from all with the rest of the site located in Flood Zone 1 (low risk of flooding). Standard, best practice mitigation measures in accordance with all relevant legislation sources could be implemented at the detailed design stage for parts of the site located in Flood Zones 2 and 3, such as raised finished floor levels and flood resilient construction of buildings, where required. The site is located in headwaters of River Flit and the discharge of surface water should not exacerbate flood risk downstream. Draft Local Plan policy requires development to maximise SuDS, where applicable. Likely neutral effects.

10 Central Bedfordshire Climate Change Adaptation Evidence Base Final Report, LDA Design (2012)

11. Soils The northern part of the site is used for motocross uses. Grade 3 agricultural land is located within the site, which would be lost to development. There is - ? 0 To protect and conserve soil uncertainty on whether the Grade 3 agricultural land comprises Grade 3a, which is considered to be best and most versatile (BMV) agricultural or Grade 3b, which is not BMV agricultural land. However, there is the potential for long-term minor negative effects. Given that the site contains landfill uses, there is potential for contamination. However, local planning policy aims to ensure that no significant effects on human health would be generated through mitigation and the site would be remediated, where required, which could have minor positive effects.

12. Biodiversity and Geodiversity In May 2018, an Extended Phase 1 Habitat Survey11 was undertaken on the site. An Arboricultural Constraints and Opportunities, Tree Schedule and Tree + To protect, enhance and manage Constraints Plan12 has also been prepared for the site. With the exception of the River Flit corridor and the veteran trees, the ecological habitats on the site biodiversity and geodiversity are of low to moderate value, with arable farming being the dominant land use. Initial species surveys have not highlighted any critical protected species issues.

The site does not include any nationally significant sites for biodiversity or geodiversity. There may be potential impacts on farmland species. A County Wildlife Site is located adjacent to the east of the site, on the opposite side of the railway line. Sundon Quarry Site of Special Scientific Interest (SSSI) is located approximately 200m to the east of the site Fancott Woods and Meadows SSSI is located approximately 730m to the south west of the site. Smithcombe, Sharpenhoe and Sundon Hills SSSI is located approximately 900m to the east of the site. Impacts on these ecological sites are expected to be limited as development separates them from the site. Development at the site provides an opportunity to provide an ecological corridor to the County Wildlife Site to the east of the site (with buffer zones implemented to protect sensitive areas of the County Wildlife Site, if required), as well as strengthen the existing biodiversity network in the surrounding area. The design of the key green infrastructure corridors, including the River Flit corridor with linked wetland and streamside features, will focus on the creation of a network of high quality habitats to support biodiversity enhancement and connectivity. Barriers to connectivity have been restricted to a single crossing point on each of the main corridors, which will be designed to minimise the number of points where development infrastructure will cross the principle Green Infrastructure corridors and provide strong linkages for biodiversity movement. The development will seek to create innovative ecological and public access links at the two principal crossing points. The site provides significant opportunity for new planting, including reinforcement of off-site boundary planting and the creation of approximately 23 hectares of the site as new woodland and associated habitats, with a further substantial area of off-site woodland of approximately 16 hectares to the west of the M1. Veteran Oak trees will be retained at the site entrance. There is the potential for a long-term minor positive effect on the local biodiversity network.

The green infrastructure network will be carefully designed to facilitate effective and sustainable future management, and a clear and deliverable holistic Landscape and Biodiversity Management Strategy will support any planning application. It is anticipated that following the initial development phase the green infrastructure network will be transferred into a management company structure that would be funded through the development.

13. Landscape The site varies in character between the lower-lying parts of the site and the more elevated part of the site. The elevated part of the site has a wide ranging - ? Protect and enhance the landscape visual envelope and is a feature in views towards the Chilterns AONB, while the lower-lying parts of the site are physically and visually contained by vegetation, and townscape landform and built elements, including the Midland Mainline railway and the M1 which also serve as physical and visual thresholds to development. Toddington Service Station also influences the site and further diminishes the sense of being within an area of countryside. Development of the site would result in an extension of the settled area, although within the lower-lying parts of the site this would be in the context of the M1 corridor which already features built elements and would be contained by vegetation and landform. Development of the elevated part of the site may be appropriate if built forms are appropriately sited to retain the visual connection with the hilltop village of Harlington and the Chilterns AONB, and integrated with comprehensive structural planting and sympathetic earthworks. Development could be effectively assimilated within the site if led by a robust landscape framework, including sympathetic earthworks treatment, as development of this area would not compromise the purposes and function of the remaining Green Belt and it provides the potential to deliver sustainably planned development that capitalises on its proximity to the M1 and Midland Mainline railway. While localised alterations to the elevated landform may result in adverse landscape impacts to the landform within the site, there is the potential to screen introduced development in views from the Chilterns AONB and protect its setting, while also resulting in a number of beneficial effects to the landscape resource that moderate any adverse impacts, such as by providing new green infrastructure linkages, new planting and enhancement of the River Flit corridor. These landscape opportunities as part of the landscape- led approach, would result in a net gain in woodland vegetation, habitat creation and ensure that the type of development proposed could be integrated into the landscape without significant or demonstrable adverse landscape impact. Planting species will be chosen to provide strong and viable connections with local character. Areas of woodland will be provided on higher ground to provide a green backdrop while also screening views of built development from the north and east within the Chilterns AONB and soften effects on long distance views, such as from Toddington. In addition, certain PRoW will be diverted to

11 M1 Junction 12 Extended Phase 1 Survey Report and Map, Lockhart Garrett (May 2018) 12 Land East of Junction 12/M1 Arboricultural Constraints and Opportunities, Tree Schedule and Tree Constraints Plan, Lockhart Garratt (July 2018)

14. Historic Environment A Heritage Impact Assessment15 has been undertaken for the site. The site does not include any nationally significant heritage assets. However, the Old Park 0 ? To ensure the protection and Farmhouse, a Grade II listed building is located adjacent to the west of the site. To the west of the site is Mill Farm, including Mill Farm and Mill Farmhouse, enhancement of heritage assets, the both Grade II listed buildings. Development could affect the setting of these heritage assets. Trees will provide screening and reinstate a previous landscape historic environment and its setting feature in the setting of Old Park Farmhouse. Furthermore, the masterplan includes a green infrastructure network travelling east-west, with trees to either side of the buildings to provide some visual screening, but with a more open central section to maintain a sense of openness in views as currently characteristic across the site. Veteran Oak trees will be retained at the site entrance and promoted to provide a unique, high quality and mature entrance to the site.

The site has multi-period archaeological potential but this would not prevent allocation providing appropriate mitigation is undertaken. The site lies within a landscape that is known to contain multi-period archaeological remains dating to the prehistoric, Roman and Saxon periods, some of which have been subject to small scale investigation in the past. Archaeological potential does not prevent allocation or development providing that an appropriate mitigation strategy in line with paragraph 141 of the NPPF was implemented. Any planning submission would need to be accompanied by the results of an intrusive archaeological field evaluation to satisfy par a 128 of the NPPF. Should the site be allocated, a contingency for archaeological works would be included in any proposal to prevent issues with viability. Any archaeological finds could be displayed in local museums. There is uncertainty until assessment work at the site has been undertaken but there is potential for minor positive effects.

13 Landscape and Visual Appraisal and Green Belt Review Barton Willmore (August 2017) 14 Investing in Central Bedfordshire – Delivering Logistics, Toddington Park Delivery Framework Document, Barton Willmore (December 2018) 15 Heritage Impact Assessment, Barton Willmore (February 2018)

Representations Barton Willmore obo IM Properties Appendices

APPENDIX 3

TODDINGTON PARK: A LANDSCAPE AND VISUAL COMPARATIVE SITES STUDY

25282/A3/SH/bc August 2020

Toddington Park: Landscape and Visual Comparative Sites Study

Prepared on behalf of IM Properties PLC

July 2020

Status: Final

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP.

All Barton Willmore stationery is produced using recycled or FSC paper and vegetation oil based inks.

CONTENTS

1.0 Introduction...... 1

2.0 Methodology ...... 4

3.0 Assessment of the Site ...... 9

4.0 Assessment of the Comparative Sites ...... 12

5.0 Conclusion ...... 255

ILLUSTRATIVE MATERIAL

Figure 1: Context Plan

Figure 2: Topography Plan

Landscape and Visual | Comparative Sites Study Introduction

1.0 INTRODUCTION

Overview

1.1 Barton Willmore Landscape Planning and Design (BWLPD) was commissioned by IM Properties PLC to undertake a Comparative Sites Study that includes consideration of the contribution that each 'comparative site' makes to the purposes of the Green Belt and their landscape and visual opportunities and constraints to accommodate logistics development. Each 'comparative site' has also been compared to the 'Site' at Toddington Park.

1.2 This Comparative Sites Study has been undertaken in the context of the Central Bedfordshire Local Plan Examination - Consultation on Additional Evidence, which is due to close on the 12th August 2020. Specifically, this Comparative Sites Study responds to the failings of the Sustainability Appraisal - Supplementary Report (EXAM 115/115B) and the Non-Technical Summary (EXAM 115A), and the Employment Technical Paper (EXAM 112). The Employment Technical Paper confirms at paragraph 5.2.3 that 'The Council is keen to ensure that the local economy is supported and enhanced through the supply of appropriate employment land across Central Bedfordshire that is of the right size and quality, and within the most advantageous locations, to meet the needs of current-day employers, attract new businesses to the area and encourage existing businesses to expand and grow.'

1.3 This Comparative Sites Study builds upon the previously submitted representations on the Local Plan Examination and in relation to the Site at Toddington Park and is intended to provide a broader range and consideration of alternative options than those set out in the Additional Evidence. EXAM 112 itself recognises that "further assessment of options should have been undertaken as part of the original Sustainability Appraisal", although EXAM 112 and EXAM 115/115B and 115A do not adequately consider the Site.

1.4 The 'comparative sites' have been drawn from the Employment Site Options set out in EXAM 115A and narrowed down to those in close proximity to the M1 and A1 major transport corridors which is considered to be a reasonable assumption in terms of within which the influence of large scale logistics distribution and its associated infrastructure would result in landscape and visual effects including:

Site A Broughton Road M1

Site B Aspley Guise M1

Site C Bedford Road M1

25282/A5/LV2020 1 July 2020 Landscape and Visual | Comparative Sites Study Introduction

Site D Winterwoods Farm M1

Site E Ridgmont (Marston Gate) M1

Site F Sundon RFI M1

Site G East of M1 M1 Junction 11A Site H Popes Farm A1

Site I West of A1, Biggleswade A1 (Holme Farm) Site J New Spring Farm, Biggleswade A1

1.5 For ease of reference, the locations of these comparative sites along with the Site at Toddington Park are illustrated on Figure 1: Context Plan.

1.6 In summary, the aims of this study are to:

• Appraise the Site and other comparative sites against the purposes of the Green Belt; • Determine the key landscape and visual attributes of the Site and other comparative sites, including consideration of their surroundings and function within the landscape and the nature and quality of existing views; • Identify high level opportunities and constraints to logistics development for the Site and comparative sites and their capacity to accommodate logistics development from a landscape and visual perspective; and • Rank the Site and comparative sites as to their suitability to be released form the Green Belt and their ability to deliver a sustainable pattern of logistics development fr om a landscape and visual perspective.

Study Area

1.7 As demonstrated in Figure 1: Context Plan, the study area encompasses the Central Bedfordshire administrative area, with the sites under examination linked to the M1 and A1 corridors, all lying between the main built-up areas of Luton to the south, Milton Keynes to the north-west, Bedford to the north and Letchworth to the south-east. Cambridge lies much further afield to the north-east, beyond the extents of Figure 1: Context Plan.

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1.8 The Green Belt area largely covers the landscape extending between and around Milton Keynes, Luton and Letchworth. A disparate section of the Chilterns AONB also occupies the landscape north of Luton and west of Letchworth.

1.9 The landscape of Central Bedfordshire varies, as depicted in Figure 2: Topography Plan, which comes about by the underlying geology of clay, chalk and greensand. In simplistic terms, much of the area consists of low lying clay vales that are flat or gently undulating, while a Greensand ridgeline extends across the core of the area, east-west, giving rise to greater topographical variation. Chalk hills and escarpment associated with the Chilterns AONB provide a sharp contrast to the vales in the southern part of Central Bedfordshire.

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2.0 METHODOLOGY

Overarching Approach

2.1 This section sets out the methodology that was used for undertaking this study, which was carried out in five phases:

• Phase 1: Summarise the existing landscape context of the wider area, including for a review of relevant policy and landscape character as appropriate; • Phase 2: Assess the contribution of the Site and the other areas to the purposes of the Green Belt (where relevant) as defined in the NPPF; • Phase 3: Appraise the Site and each of the comparative sites form a landscape and visual perspective, identifying high level opportunities and constraints to development, and their ability to accommodate logistics development; • Phase 4: Provide a brief comparison of the issues between the Site and the relevant comparative site; and • Phase 5: Combine the findings of Phase 1 to Phase 4 in order to rank the Site and other comparative sites as to their suitability to be released from the Green Belt and deliver a sustainable pattern of logistics development from a landscape and visual perspective.

Green Belt Review Methodology

Assessment against the purposes of the Green Belt

2.2 The Site and other areas were assessed against the first four of the purposes of the Green Belt as set out in Paragraph 134 of the NPPF, which are:

• "To check the unrestricted sprawl of large built-up areas; • To prevent neighbouring towns from merging in to one another; • To assist in safeguarding the countryside from encroachment; and • To preserve the setting and special character of historic towns…"

2.3 With respect to the fifth purpose of the Green Belt "to assist in urban regeneration by encouraging the recycling of derelict and other urban land", should the Site or other areas be brought forward for development, independently or in parallel, it would not prejudice derelict or other urban land being brought forward for urban regeneration. However, the principle of retaining land within the Green Belt holds true for all areas within the Green Belt, therefore the Site and the other areas are considered in this study to make the same contribution to this purpose of the Green Belt, and no additional specific assessment is undertaken.

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2.4 The NPPF endorses the permanence of Green Belts as an essential characteristic and stipulates in Paragraph 136 that "once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans".

2.5 The NPPF seeks to align Green Belt boundary reviews with sustainable patterns of development, as set out in Paragraph 138, with Local Planning Authorities encouraged to "consider the consequences for suitable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary".

2.6 In this regard, where a given area of land contributes poorly towards meeting the purposes of the Green Belt and its release would contribute positively to promoting a sustainable development pattern, this may be considered to constitute an 'exceptional circumstance' and the Green Belt boundary should be reviewed accordingly. The criteria used to asses s the contribution made to the first four purposes of the Green Belt is set out in Table 2.1.

Table 2.1: Purposes of the Green Belt - Assessment Criteria

Purpose Criteria

1. To check the Considerable: Development of the land would be strongly perceived as sprawl, unrestricted sprawl as it is not contained by robust physical features and/or would extend the of large built-up settlement pattern in an incoherent manner areas Some: Development of the land would be perceived as sprawl, as it is partially contained by robust physical features and/or would extend the settlement pattern in a moderately incoherent manner Limited: Development of the land would be perceived as sprawl to a limited degree, as it is largely contained by robust physical features and/or would extend the settlement pattern in a broadly coherent manner None: Development of the land would not be perceived as sprawl as it is well contained by robust physical features and/or is entirely set within the existing coherent settlement pattern

2. To prevent Considerable: Development would result in the physical unification of two (or neighbouring towns more) towns from merging Some: Development would substantially reduce the physical or perceived separation between towns Limited: Development would result in a limited reduction in the physical or perceived separation between towns None: Development would not physically or perceptually reduce the separation between towns

3. To assist in Considerable: No built or engineered forms present and perceived as safeguarding the inherently undeveloped and/or rural in character. Development would countryside from potentially result in a strong urbanising influence over the wider landscape encroachment Some: Built or engineered forms present but retaining a perception of being predominantly undeveloped and/or rural in character. Development would potentially result in a moderate urbanising influence over the wider landscape

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Purpose Criteria Limited: Built or engineered forms present and a minimal perception of being undeveloped and or rural in character. Development would potentially result in a limited urbanising influence over the wider landscape None: Built or engineered forms present and perceived as inherently developed and/or urban in character. Development would not result in urbanising influence over the wider landscape

4. To preserve the Considerable: Strong physical and/or visual and/or character connection with setting and special the historic part of a town. May be within or adjoining the historic part of a character of town historic towns Some: Partial physical and/or visual and/or character connection with the historic part of a town, whilst not adjacent to it Limited: Weak physical and/or visual and/or character connection with the historic part of a town None: No physical and/or visual and/or character connection with the historic part of a town

2.7 The NPPF states that the key characteristics of the Green Belt are "their openness and their permanence". In defining new boundaries to the Green Belt, it must be ensured that these characteristics are not diminished for the areas remaining within the Green Belt designation as a direct result of development.

2.8 An assessment is made of the openness of the Green Belt in the vicinity of the Site and to what extent its removal could have on the perception of openness in the remaining designated area.

2.9 In addition, the relationship of the Site to existing elements, such as built form, roads, railways and rivers, as well as visual barriers, such as ridgelines and areas of notable vegetation is set out. This assists in the assessment of the Site in relation to the existing Green Belt and consideration of potential development in relation to the openness of the remaining Green Belt and the permanence of Green Belt boundaries.

Landscape and Visual Appraisal Methodology

2.10 The landscape and visual appraisal is prepared with reference to the current best practice guidelines, as set out in the Landscape Institute and the Institute of Environmental Management and Assessment's 'Guidelines for Landscape and Visual Impact Assessment', Third Edition, 2013.

2.11 A desktop assessment of the area was undertaken, including an assessment of landscape character, landform, landscape features, policy and designations. This information was used as the initial basis against which to appraise the Site and the other areas.

2.12 A description of the existing land use of the area is provided and includes reference to existing areas of settlement, transport routes and vegetation cover, as well as local landscape

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designations, elements of cultural and heritage value, and local landmarks or tourist destinations. These factors combine to provide an understanding of landscape value and sensitivity and provide an indication of particular key views and viewpoints that are available to visual receptors.

2.13 To determine the extent of visual influence, a visual appraisal was undertaken of the Site and the other areas to consider the nature of existing views from publicly accessible viewpoints including roads, Public Rights of Way (PRoW) and public open space. Consideration was given to private views, however access to private properties was not obtained. Views were considered from all directions and from a range of distances. The ability of the Site and the other areas to accommodate logistics development is considered in terms of the following:

• Landscape Character: i.e. landform, vegetation cover, land use, scale and state of repair; • Landscape Value: i.e. national designations, local designations and sense of tranquillity or remoteness; and • Visual Influence: i.e. the extent and types of views available.

2.14 The appraisal of the Site and the other areas assists in the identification of opportunities and constraints that would assist in defining the boundaries for potential future sustainable development, and thus an amended Green Belt boundary.

Comparative Ranking

2.15 Emphasis is placed on the purposes of the Green Belt as opposed to the quality of the landscape when undertaking a Green Belt Review. However, the consideration of landscape and visual opportunities and constraints provides a greater understanding of, and aids in the identification of, appropriate sustainable locations for logistics development across Central Bedfordshire.

2.16 The ranking is undertaken on a qualitative basis and includes consideration of the contribution that the Site and other comparative sites make to the purposes of the Green Belt; the potential to accommodate logistics development from a landscape and visual perspective, which can maximise the opportunities available and respond positively to any constraints present that can realistically be delivered in a sustainably planned manner.

2.17 This study does not undertake a comprehensive consideration of potential cumulative impacts of the various schemes, as in our view that this would be premature, as the way in which the schemes could come forward are too broad with too many assumptions and open to interpretation that the findings could not be reasonably relied upon to give an accurate or fair account.

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2.18 However, this study does provide some indication of where there would be likely perception of multiple sites in combination.

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3.0 ASSESSMENT OF THE SITE

3.1 A detailed Landscape and Visual Appraisal and Green Belt Review in relation to the Site and its potential to accommodate logistics development was provided in the 2016 Call for Sites, the Draft Local Plan Regulation 18 consultation in 2017 and Regulation 19 consultation in 2018.

3.2 An Environmental Capital Enhancement Report was also provided as part of the 2018 Local Plan Regulation 19 consultation, which demonstrated the suitability of the Site to accommodate logistics development and the way in which the redevelopment of the Site could help unlock and directly contribute to the wider natural capital of the area.

3.3 Accordingly, this study should be read in conjunction with the aforementioned previously undertaken and submitted work. The intention of this section of the study is to provide an equitable means of comparison between the Site and other areas identified.

The Site

3.4 The Site lies between the M1 corridor (and Toddington Services) and the Midland Mainline Railway and comprises predominantly agricultural land utilised for sheep grazing in the northern part of the Site and generally arable use to the south. A moto-cross track is located on the north facing slopes of the elevated part of the Site and a clay pigeon shooting range on the south facing slopes of the elevated part of the Site, which have resulted in some re - profiling of the landform. Built forms within the Site are limited to temporary structures associated with the aforementioned non-agricultural uses, and the series of pylon towers that traverse the Site. The boundaries to the Site are generally well defined by dense hedgerows and treebelts.

Green Belt Review

• Purpose 1: Limited / Some; • Purpose 2: Limited / Some; • Purpose 3: Some; and • Purpose 4: Limited.

3.5 An explanation of how the above conclusions have been reached is set out below:

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Purpose Critique Contribution

To check the The Site does not directly adjoin a defined built-up area, Limited / Some unrestricted sprawl albeit Toddington Service Station adjoins the Site and is of large built-up washed over by the Green Belt. Nonetheless, the Site is areas generally contained by robust boundaries of permanence, including the Midland Mainline railway, the River Flit and the M1 which would contain development. The Site is also separated from Harlington by a swathe of agricultural land, beyond which the Midland Mainline railway restricts the sprawl of the built-up area. The western part of the Site beyond the M1 would not feature built forms, in accordance with the Design Strategy, and consequently this part of the Site would continue to check the unrestricted sprawl of large built-up areas.

To prevent nearby The Site lies within the context of the M1 corridor, which Limited / Some towns from merging traverses the landscape between the main built-up areas of into one another Harlington, Westoning, Toddington and Chalton, and existing built features including the Toddington Service Station which adjoins the Site. The M1 forms a physical and visual threshold to development, and any development of the Site would be perceived in the context of the existing built elements, including the infrastructure associated with the M1 and the Toddington Service Station and in this regard would not physically reduce the separation distance between the built-up areas. Furthermore, the Midland Mainline railway to the east of the Site forms a robust feature of permanence that effectively forms the western extent of Harlington and prevents coalescence between the main built-up areas. Nonetheless, development of the Site would result in an extension of the overall developed area within the settled gap between the main built-up areas. The western part of the Site beyond the M1 would not feature built forms, in accordance with the Design Strategy, and consequently this part of the Site would continue to prevent the coalescence of built-up areas.

To assist in The Site partly fulfils this purpose insofar that the majority Some safeguarding the of the land use is agricultural. However, the M1 and Midland countryside from Mainline railway exert their influence over the lower-lying encroachment parts of the Site, with intervisibility also obtained with Toddington Service Station. From the more elevated parts of the Site, whilst there is intervisibility with visual detractors in the panoramic views obtained, there is a sense of being within a partly rural landscape due to the visual connection with an expansive area of agricultural land, including the Greensand ridgeline and the Chilterns AONB. The western part of the Site beyond the M1 would not feature built forms, in accordance with the Design Strategy, and consequently this part of the Site would continue to safeguard the countryside from encroachment.

To preserve the There are no historic towns within the vicinity of the Site. Limited setting and special However, there are a number of areas of historical and character of historic conservation interest within the surrounding landscape, towns including listed buildings and the Toddington conservation area, within the setting of which the Site lies. The western part of the Site beyond the M1 would not feature built forms, in accordance with the Design Strategy, and consequently this part of the Site would continue to preserve the setting of areas of historical and conservation interest.

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Landscape and Visual Appraisal

3.6 The key landscape and visual attributes of the Site are:

• Landform: pronounced within immediately vicinity, characterised by localised hill in north and in the south more undulating in nature; • Landscape Character: NCA 88, NCA 110, LCA 5B and LCA 8A; • Land Use: agricultural (pastoral and arable), moto-cross track, and clay pigeon shooting range; • Enclosure: well contained by boundary vegetation although limited sense of enclosure from elevated aspects of the Site; • Scale: medium; • Representativeness: somewhat representative of the landscape adjoining the M1; • Designations: none, although within setting of Chilterns AONB; • Tranquillity / Remoteness: heavily influenced by audible intrusion from M1 and Midland Mainline railway and frequent visual detractors; • Cultural / Recreational Associations: traversed by Icknield Way Trail and two PRoW, with moto-cross and clay pigeon uses; • Scenic Beauty: not noteworthy, comprising common agricultural land; and • Visual Influence: moderate visual envelope due to prominent landform, albeit in context of visual detractors.

3.7 The key opportunities and constraints from a landscape and visual perspective include:

• Not within designated landscape although in the setting of the Chilterns AONB; • Within an area of urbanising influences; • Partially contained but partially elevated landscape; • Potential for restoration and enhancement of the River Flit and associated green infrastructure; and • Potential to enhance amenity experience travelling along Icknield Way, although need to incorporate this and existing vegetation and pylon towers within development . • The topographical variation between Site F and the Site, resulting in a degree of v isual and physical separation, would diminish the combined perception of Site F with the Site.

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4.0 ASSESSMENT OF THE COMPARATIVE SITES

Overview

4.1 The information presented within this section provides an assessment of each areas' contribution to the purposes of the Green Belt where relevant; and the high level opportunities and constraints and potential to accommodate residential development from a landscape and visual perspective in comparison to the Site. As previously set out, the following comparative sites are included within this study:

• Site A - Broughton Road; • Site B - Aspley Guise; • Site C - Bedford Road; • Site D - Winterwoods Farm; • Site E - Ridgmont; • Site F - Sundon RFI; • Site G - East of M1 Junction 11A; • Site H - Popes Farm; • Site I - West of A1, Biggleswade; and • Site J - New Spring Farm, Biggleswade.

Site A - Broughton Road

4.2 Site A occupies land either side of the M1 corridor on the eastern edge of Milton Keynes, in proximity to the suburb of Broughton and an existing area of logistics development. Site A is broadly flat, consisting of a group of arable fields bounded by low hedgerow vegetation and adjoining a minor road connecting Broughton with Salford.

Green Belt Review

4.3 Site A is not located within the Green Belt, therefore an assessment of the contribution that Site A makes towards the purposes of the Green Belt has accordingly not been undertaken as it is not applicable.

Landscape and Visual Appraisal

4.4 The key landscape and visual attributes of Site A - Broughton Road are:

• Landform: flat; • Landscape Character: NCA 88, LCA 5C; • Land Use: arable farmland;

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• Enclosure: generally low clipped hedgerow, meaning physical enclosure but not visual; • Scale: medium; • Representativeness: fairly representative of the Milton Keynes fringe; • Designations: not within a designated landscape; • Tranquillity / Remoteness: proximity to the M1, local highway and edge of urban area reduces perceived tranquillity and remoteness; • Cultural / Recreational Associations: not publicly accessible; • Scenic Beauty: limited due to influence of adjoining land uses, including M1 and logistics development; and • Visual Influence: moderate, being visible either side of M1 and overlooked by higher ground, albeit in context of visual detractors.

4.5 The key opportunities and constraints from a landscape and visual perspective include:

• Not within designated landscape; • Flat landscape requiring minimal cut-and-fill operations; • While moderate visual influence, seen in context of existing visual detractors including existing logistics uses.

Comparison to the Site and Ability to Accommodate Logistics Development

4.6 Not located in Green Belt or in the setting of the Chilterns AONB, which stands in the favour of Site A. However, by straddling both sides of the M1 corridor and being in proximity to the existing logistics development, this would increase the influence of this use.

Site B - Broughton Road

4.7 Site B occupies an extensive tract of land to the south-west of the M1 and lies between the A421 and the railway line, being in proximity to Aspley Guise railway station. Site B is generally flat, comprising a series of geometric but irregular shaped arable fields defined by sporadic vegetation and verges. Salford Road traverses Site B, while some built form is also present.

Green Belt Review

4.8 Site B is not located within the Green Belt, therefore an assessment of the contribution that Site B makes towards the purposes of the Green Belt has accordingly not been undertaken as it is not applicable. However, it is of note that Site B does adjoin the Green Belt.

Landscape and Visual Appraisal

4.9 The key landscape and visual attributes of Site B - Aspley Guise are:

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• Landform: broadly level; • Landscape Character: NCA 88, NCA 90 LCA 5C, LCA 6A; • Land Use: predominantly arable farmland, with some built form and traversed by minor road; • Enclosure: largely contained by hedgerow and tree vegetation; • Scale: small to medium; • Representativeness: representative of the area; • Designations: not within a designated landscape; • Tranquillity / Remoteness: audible intrusion from passing vehicles, albeit some sense of tranquillity due to perceived countryside location across extensive area with a moderate sense of remoteness; • Cultural / Recreational Associations: traversed by PRoW; • Scenic Beauty: some sense of scenic beauty insofar that it is perceived as countryside; and • Visual Influence: modest visual envelope despite the large scale, albeit overlooked by higher ground.

4.10 The key opportunities and constraints from a landscape and visual perspective include:

• Not within a designated landscape; • A good degree of enclosure despite the scale of the area, albeit overlooked by higher ground; • Ability to sympathetically tie-in with adjacent land uses; and • Any development will need to provide a positive response / experience for the PRoW that traverse the area. • Expanse of continuous low-lying topography would increase potential for cumulative perception of sites B-E.

Comparison to the Site and Ability to Accommodate Logistics Development

4.11 Not located in Green Belt or in the setting of the Chilterns AONB, which stands in the favour of Site B. However, its large size means that it may exert a strong influence over the landscape, while being separate from both Milton Keynes and Brogborough could sequentially intensify the influence of this use along a significant stretch of the M1, notably given the potential for the continuous low-lying topography to result in the combined perception of Sites B-E.

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Site C - Bedford Road

4.12 Site C comprises two small arable fields in proximity to Junction 13 of the M1, between the A421 and the railway line. Site C is flat and is bounded by hedgerow vegetation , with a small group of trees present in the south-eastern corner near Bedford Road.

Green Belt Review

4.13 Site C is not located within the Green Belt, therefore an assessment of the contribution that Site C makes towards the purposes of the Green Belt has accordingly not been undertaken as it is not applicable. However, it is of note that Site C does adjoin the Green Belt.

Landscape and Visual Appraisal

4.14 The key landscape and visual attributes of Site C - Bedford Road are:

• Landform: flat; • Landscape Character: NCA 88, LCA 5C, LCA 6A; • Land Use: arable farmland; • Enclosure: well-contained by field boundaries; • Scale: small; • Representativeness: representative of the area; • Designations: not within a designated landscape; • Tranquillity / Remoteness: audible intrusion from passing vehicles with limited sense of remoteness; • Cultural / Recreational Associations: traversed by a PRoW; • Scenic Beauty: not of noteworthy scenic beauty; and • Visual Influence: modest visual envelope, albeit overlooked by higher ground

4.15 The key opportunities and constraints from a landscape and visual perspective include:

• Not within a designated landscape; • Flat topography requiring minimal cut-and-fill operations, although small field structure likely to require removal of existing boundary features; • Well-contained area albeit overlooked by higher ground and development will need to respect PRoW traversing the Site; and • Disturbed landscape by A421, railway and M1.

Comparison to the Site and Ability to Accommodate Logistics Development

4.16 Not located in Green Belt or in the setting of the Chilterns AONB, which stands in the favour of Site C. However, its location in proximity to the Marston Gate distribution centre on the

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opposing side of the M1 could intensify the influence of this use in the landscape, notably given the potential for the continuous low-lying topography to result in the combined perception of Sites B-E.

Site D - Winterwoods Farm

4.17 Site D occupies an area of gently sloping/undulating land to the north of the M1 and Salford Road. The land use of Site D comprises two large scale arable fields (bounded by hedgerow vegetation) and the Winterwoods Farm complex in the centre. The eastern edge of Site D, along much of its length, is defined by a treebelt.

Green Belt Review

4.18 Site D is not located within the Green Belt, therefore an assessment of the contribution that Site D makes towards the purposes of the Green Belt has accordingly not been undertaken as it is not applicable.

Landscape and Visual Appraisal

4.19 The key landscape and visual attributes of Site D - Winterwoods Farm are:

• Landform: gently sloping/undulating; • Landscape Character: NCA 88, LCA 1A, LCA 5C; • Land Use: arable farmland and farm complex; • Enclosure: hedgerow and treebelt vegetation; • Scale: large; • Representativeness: representative of this countryside area; • Designations: not within a designated landscape; • Tranquillity / Remoteness: audible and visual presence of the M1, Cranfield Airfield and the edge of Milton Keynes; • Cultural / Recreational Associations: not publicly accessible; • Scenic Beauty: not of noteworthy scenic beauty; and • Visual Influence: somewhat contained.

4.20 The key opportunities and constraints from a landscape and visual perspective include:

• Not within designated landscape and in an area disturbed by M1, Cranfield Airfield and Milton Keynes; • Undulating land form may require extensive cut-and-fill; and • Somewhat contained although prolonged visibility from M1.

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Comparison to the Site and Ability to Accommodate Logistics Development

4.21 Not located in Green Belt or in the setting of the Chilterns AONB, which stands in the favour of Site D. However, its location in proximity to the Marston Gate distribution centre would intensify the influence of this use in the landscape, notably given the potential for the continuous low-lying topography to result in the combined perception of Sites B-E.

Site E - Ridgmont

4.22 Site E comprises three irregularly shaped arable fields that overlay sloping land and are bounded by low clipped hedgerows. Site E lies in proximity to Ridgmont train station, to the north of the M1 and the A507 and to the south-east of the existing Marston Gate Distribution Centre.

Green Belt Review

4.23 Site E is not located within the Green Belt, therefore an assessment of the contribution that Site E makes towards the purposes of the Green Belt has accordingly not been undertaken as it is not applicable.

Landscape and Visual Appraisal

4.24 The key landscape and visual attributes of Site E - Ridgemont are:

• Landform: gently sloping; • Landscape Character: NCA 88, LCA 5C, LCA 6A; • Land Use: arable farmland; • Enclosure: contained by low-clipped hedgerows; • Scale: medium; • Representativeness: representative of the landscape area; • Designations: not within a designated landscape; • Tranquillity / Remoteness: audible and visual presence of the M1, Cranfield Airfield, and Marston Gate; • Cultural / Recreational Associations: incorporates four PRoW, including the John Bunyan Trail and the Greensand Ridge Walk; • Scenic Beauty: not of noteworthy scenic beauty; and • Visual Influence: Extensive visual envelope owing to underlying topography of the Site and surrounding area and the limited physical containment.

4.25 The key opportunities and constraints from a landscape and visual perspective include:

• Not within designated landscape and in an area already disturbed by Marston Gate ;

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• Development of Site likely to be perceived as extension to an existing developed area rather than substantial intensification; • Any development will need to provide a positive response / experience for the PRoW that traverse the area; and • Extensive visual envelope, albeit seen in context of existing development.

Comparison to the Site and Ability to Accommodate Logistics Development

4.26 Not located in Green Belt or in the setting of the Chilterns AONB, which stands in the favour of Site E. Given that it is located adjacent to Marston Gate, and any development of Site E will be seen in conjunction with this development, there is the potential for this use to be perceived as an intensification of the influence of these uses in the landscape, notably given the potential for the continuous low-lying topography to result in the combined perception of Sites B-E, while development will also need to be respectful of the PRoW that traverse Site E .

Site F - Sundon RFI

4.27 Site F lies in proximity to Junction 11a of the M1 and the Midland Mainline railway to the north - west of the main built-up area of Luton. Site F occupies an area of elevated and sloping arable land (split into two fields) that is bounded by treebelt vegetation. Two sets of Pylon towers traverse the northern part of Site F, as does the Chiltern Way PRoW.

Green Belt Review

• Purpose 1: Considerable / Some – outward extension from defined settlement edge but largely contained by physical features; • Purpose 2: Limited / Some – physical reduction beyond perceived settlement edge; • Purpose 3: Some – pylon towers present but generally retaining undeveloped character; and • Purpose 4: None – no physical/visual/character connection with historic part of town.

Landscape and Visual Appraisal

4.28 The key landscape and visual attributes of Site F - Sundon RFI are:

• Landform: sloping elevated landscape; • Landscape Character: NCA 110, LCA 5B, LCA 10B; • Land Use: arable farmland; • Enclosure: well-contained by treebelt vegetation; • Scale: medium; • Representativeness: somewhat representative of the area;

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• Designations: not within a designated landscape but within the setting of the Chilterns AONB; • Tranquillity / Remoteness: strong audible intrusion from the M1 and the railway reduces level of tranquillity and perception of remoteness; • Cultural / Recreational Associations: traversed by the Chiltern Way PRoW; • Scenic Beauty: not of noteworthy scenic beauty and traversed by visual detractors of the pylon towers; and • Visual Influence: limited due to boundary containment, although any introduced built form likely to be break the treeline.

4.29 The key opportunities and constraints from a landscape and visual perspective include:

• Largely well-contained by existing vegetation framework, although built development likely to breach the treeline; • Elevated location; and • Within the setting of the Chilterns AONB.

Comparison to the Site and Ability to Accommodate Logistics Development

4.30 Like the Site, Site F lies within the Green Belt and in the setting of the Chilterns AONB – although Site F does make a greater contribution to the purposes of the Green Belt. Both areas feature pylon towers and any development in either is likely to be visible in views towards the AONB. However, development of Site F will introduce development in a new part of the landscape at a greater height in comparison to development in the Site, with development seen alongside the Toddington services. The topographical variation between Site F and the Site, resulting in a degree of visual and physical separation, would diminish the combined perception of Site F with the Site.

Site G - East of M1 Junction 11A

4.31 Site G encompasses an area of flat to gently sloping grassland to the north of the main built- up area of Luton. Although contained by treebelt vegetation there is intervisibility through to Site G from the surrounding road network while the urban edge of Luton is similarly visible to the south from within Site F. A PRoW skirts along the southern boundary.

Green Belt Review

• Purpose 1: Considerable – clear outward extension from defined settlement edge of main-built up area; • Purpose 2: Limited – while physical reduction in separate, perceived limit of Luton is arguably Sundon Road;

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• Purpose 3: Considerable / Some – no built form present, but strong sense of urban fringe; and • Purpose 4: None – no physical/visual/character connection with historic part of town.

Landscape and Visual Appraisal

4.32 The key landscape and visual attributes of Site G - East of M1 Junction 11A are:

• Landform: flat to gently sloping; • Landscape Character: NCA 110, LCA 10B; • Land Use: grassland; • Enclosure: contained by intermittent treebelt vegetation; • Scale: medium; • Representativeness: somewhat representative of the area; • Designations: not within a designated landscape but within the setting of the Chilterns AONB; • Tranquillity / Remoteness: audible intrusion from the M1, the railway and the urban edge of Luton and its activities; • Cultural / Recreational Associations: A PRoW extend along the periphery of the Site; • Scenic Beauty: not of noteworthy scenic beauty; and • Visual Influence: limited visual envelope albeit open views from adjacent residential properties and adjoining roads.

4.33 The key opportunities and constraints from a landscape and visual perspective include:

• Not within designated landscape albeit in settings of Chilterns AONB; • In proximity to similar uses on the urban edge of Luton; and • Broadly flat topography will likely require minimal cut-and-fill operations; and • Development to be sympathetic to visual amenity of adjacent PRoW and residences .

Comparison to the Site and Ability to Accommodate Logistics Development

4.34 Like the Site, Site G lies within the Green Belt and in the setting of the Chilterns AONB – although Site G does make a greater contribution to the purposes of the Green Belt. While the visual influence of Site G is undeniably reduced in comparison to the Site, Site G is overlooked by adjacent residential properties and development is likely to protrude above the containing vegetation.

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Site H - Popes Farm

4.35 Site H predominantly comprises an area of flat arable farmland that is in part bounded by treebelt vegetation and timber poste and wire fencing. Some small scale residential development is also present within Site H, fronting on to the A1 that adjoins the Site to the east.

Green Belt Review

4.36 Site H is not located within the Green Belt, therefore an assessment of the contribution that Site H makes towards the purposes of the Green Belt has accordingly not been undertaken as it is not applicable.

Landscape and Visual Appraisal

4.37 The key landscape and visual attributes of Site H - Popes Farm are:

• Landform: flat; • Landscape Character: NCA 88, LCA 4A; • Land Use: predominantly arable with some residential; • Enclosure: sporadic, some visually open boundaries, including along A1; • Scale: medium; • Representativeness: very representative of the area; • Designations: not within a designated landscape; • Tranquillity / Remoteness: audible and visual intrusion from busy A1 transport corridor and fringe uses around Sandy; • Cultural / Recreational Associations: traversed by multiple PRoW; • Scenic Beauty: not of noteworthy scenic beauty; and • Visual Influence: wide visual envelope owing to flat topography in the river plain of the River Ivel and limited enclosure, while being overlooked by higher ground surrounding flood plain.

4.38 The key opportunities and constraints from a landscape and visual perspective include:

• Not within designated landscape; • Flat topography will likely require minimal cut-and-fill operations; and • Extensive visual envelope with development likely to exert substantial visual influence .

Comparison to the Site and Ability to Accommodate Logistics Development

4.39 Although Site H benefits from the fact it does not lie within the Green Belt nor in the vicinity of the Chilterns AONB, it does lie within an open and flat landscape on the edge of the

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development of Sandy. As a consequence, development within Site H will likely have an extensive visual envelope and exert its influence over a wide area, while also fundamentally altering the character on approach to Sandy.

Site I - West of A1, Biggleswade

4.40 Site I occupies an expansive area of land to the west of the A1 and to the south of built-up area of Biggleswade. Site I primarily consists of a series of irregularly shaped arable and grass fields that are defined by a mixture of ditches, verges and sporadic shrub vegetation. A block of woodland is also present in the Site, as is a farm building. A railway line defines the western extent of the Site while a wind farm is present in the landscape to the immediate south.

Green Belt Review

4.41 Site I is not located within the Green Belt, therefore an assessment of the contribution t hat Site I makes towards the purposes of the Green Belt has accordingly not been undertaken as it is not applicable.

Landscape and Visual Appraisal

4.42 The key landscape and visual attributes of Site I - West of A1, Biggleswade are:

• Landform: flat; • Landscape Character: NCA 88, LCA 4B; • Land Use: predominantly arable and grassland; • Enclosure: poorly enclosed; • Scale: medium; • Representativeness: very representative of the area; • Designations: not within a designated landscape; • Tranquillity / Remoteness: limited sense of tranquillity or remoteness due to the presence of the A1 road corridor, the wind farm, and the urban edge; • Cultural / Recreational Associations: traversed by two PRoW; • Scenic Beauty: limited due to the presence of multiple visual detractors; and • Visual Influence: expansive, albeit seen in the context of existing development.

4.43 The key opportunities and constraints from a landscape and visual perspective include:

• Not within designated landscape; • Likely to have a substantial visual influence over wide area; and • Likely to present as an extension/intrusion of Biggleswade southwards towards the wind farm, removing any sense of transition.

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Comparison to the Site and Ability to Accommodate Logistics Development

4.44 Development within Site I will likely have a much more substantial visual envelope than that within the Site. Furthermore, will development in the Site at Toddington Park will be seen in conjunction with Toddington Services in a complementary manner, development of Site I is likely to be perceived as a strong erosion of character in the landscape to the south of Biggleswade.

Site J - New Spring Farm, Biggleswade

4.45 Site J lies to the east of the A1 and to the south of the built-up area of Biggleswade. Site J consists of two arable fields, the western of which is bounded by tree vegetation with the exception of the western boundary of the Site that is featureless and provides direct physical and visual permeability with the adjacent A1 corridor. The eastern parcel of land has undefined boundaries (save for a short section of treebelt vegetation). Existing logistics development adjoins Site J to the north.

Green Belt Review

4.46 Site J is not located within the Green Belt, therefore an assessment of the contribution that Site J makes towards the purposes of the Green Belt has accordingly not been undertaken as it is not applicable.

Landscape and Visual Appraisal

4.47 The key landscape and visual attributes of Site J - New Spring Farm, Biggleswade are:

• Landform: flat; • Landscape Character: NCA 88, LCA 4B; • Land Use: arable farmland; • Enclosure: some vegetation cover, albeit connection with A1; • Scale: medium; • Representativeness: typical of the area, albeit with greater vegetation cover; • Designations: not within a designated landscape; • Tranquillity / Remoteness: limited sense of tranquillity or remoteness due to the presence of the A1 road corridor and the urban edge; • Cultural / Recreational Associations: traversed by a PRoW; • Scenic Beauty: limited due to the presence of multiple visual detractors; and • Visual Influence: large, albeit seen in the context of existing development and slightly curtailed by tree vegetation.

4.48 The key opportunities and constraints from a landscape and visual perspective include:

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• Not within a designated landscape; • Situated in proximity to existing distribution / logistics development; and • Existing vegetation framework can help integrate introduced built form and consolidate it to a confined area.

Comparison to the Site and Ability to Accommodate Logistics Development

4.49 There are a number of parallels between the Site at Toddington Park and Site J. Site J benefits from the partial containment provided by dense vegetation in a similar manner to the Site at Toddington Park, while both also lie in the context of existing visual detrac tors / areas of built development, such that development can be readily consolidated to an area that is not perceived as a substantial intrusion that bleeds into the wider landscape. Both also have the capacity to incorporate landscape mitigation measures to successfully absorb development into the landscape and address visibility and character concerns.

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5.0 CONCLUSION

5.1 A Comparative Preliminary Landscape and Visual Appraisal and Green Belt Review has been undertaken in relation to the both the Site, at Toddington Park, and the other comparative sites as identified in this study, in relation to their ability to accommodate logistics development.

5.2 The NPPF endorses the permanence of Green Belts as an essential characteristics and stipulates in Paragraph 136 "Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans…".

5.3 Table 5.1 below provides the relative ranking of each site in relation to their contribution to the purposes of the Green Belt. Only those sites within the Green Belt are included within Table 5.1. For clarity, a rank of ‘1’ indicates that the area makes less of a contribution to the purposes of the Green Belt in comparison to a rank of ‘3’ which indicates that the area makes a greater contribution.

Table 5.1: Relative Contribution to the Purposes of the Green Belt

Rank Area Contribution Critique

1 The Site Does not adjoin built-up area and contained by strong defensible boundaries. Land at Junction 12

2 Site F: Outward extension into area of largely undeveloped character contained by physical features Sundon RFI

3 Site G: Clear outward extension from Luton and encroachment into countryside East of the M1 Junction 11A

5.4 From the above it is apparent that in purely Green Belt terms, the Site at Toddington Park should be considered the most preferable option for allocation. This reflects the findings of the Central Bedfordshire and Luton Green Belt Study (GBS) and the previous representations made with respect to the Site and the Local Plan Review.

5.5 As previously noted, the NPPF seeks to align Green Belt boundary reviews with sustainable patterns of development. Emphasis is placed on the purposes of the Green Belt as opposed to the quality of the landscape when undertaking a Green Belt Review. However, the consideration of landscape and visual opportunities and constraints provides a greater understanding of, and aids in the identification of, appropriate sustainable locations for logistics development across Central Bedfordshire.

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Table 5.2 below sets out the relative ranking of each sites' ability to contribute positively to a sustainable development pattern, factoring in the contribution that each site makes to the purposes of the Green Belt and the landscape and visual opportunities and constraints present. A rank of '1' indicates the most preferable location for logistics development, and a rank of '11' indicates the least preferable location for logistics development.

Table 5.2: Site Ranking

Ran Site Marke Rationale k t

1 Site J A1 Consolidated with existing similar development, logical confined extension Spring Farm, Biggleswade

2 Site A M1 Consolidated with existing similar development in wider expanse of Milton Keynes, logical Broughton Road confined extension albeit extends north-east of M1.

3 Site E M1 Consolidated with existing similar development, logical confined extension Ridgmont (Marston Gate)

4 Site C M1 Consolidated with existing similar development, albeit potential for intensification perception Bedford Road

5 The Site M1 Consolidated to area already disturbed by services but not encroaching

= Site D M1 Disturbed area, albeit prolonged visibility from M1 Winterwoods Farm

7 Site F M1 Result in perceptible northward sprawl of Luton Sundon RFI

8 Site B M1 Extensive tract result in sequential extension of Milton Keynes Aspley Guise

9 Site G M1 Result in noticeable northward sprawl of Luton East of M1 Junction 11A

10 Site H A1 Fundamentally alter character on approach to Sandy, extensive visual envelope Popes Farm

11 Site I A1 Fundamentally alter character in the landscape to the south of Biggleswade, extensive visual West of A1, Biggleswade envelope (Holme Farm)

5.6 In conclusion, it is apparent that logistics development could be effectively assimilated within the Site and that, of those Sites within the Green Belt, it is the most suited to said development. Accordingly, the Site is considered appropriate for release from the Green Belt and suitable for allocation from a landscape and visual perspective.

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ILLUSTRATIVE MATERIAL

FIGURE 1 –CONTEXT PLAN

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Landscape and Visual | Comparative Sites Study Illustrative Material

ILLUSTRATIVE MATERIAL

FIGURE 2 – TOPOGRAPHY PLAN

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