Representation by Central Bedfordshire Council (Central Bedfordshire Council)
- Date submitted
- 23 June 2023
- Submitted by
- Local authorities
Introduction Based on the information currently available Central Bedfordshire Council object/raise concerns to the proposed development as it is considered that the proposal would have a significant impact on residents and businesses within Central Bedfordshire. The Relevant Representation for Central Bedfordshire Council should be read in conjunction with the Council’s Principal Areas of Disagreement Summary Statement (PADSS). Highway Matters Having reviewed the submitted information, the Council is of the view that the proposed development would have an impact on the strategic and local highway network. It is considered that there are shortcomings in the assessments that have been undertaken. There are concerns relating to the modelling assumptions, in respect of core scenario, mode share and inclusion of assumed schemes, despite uncertainty over their delivery (notably M1 Smart Motorways and East of Luton Highways Schemes), and the relationship between the levels of modelling undertaken (Strategic, Microsimulation, and Local). As the modelling is deemed insufficient there is concern that an appropriate assessment of the likely impact and suitability of the mitigation cannot be appropriately assessed. Notwithstanding, there are areas outside of the red line boundary where, even with the current modelling, the Council is of the view that the impacts are such that mitigation is necessary but none is proposed. Insufficient detail is provided in respect to the junction modelling, mitigation and safety audits relating to works to the junctions included in the red line boundary. Inappropriate and inconsiderate airport related parking is an issue in Central Bedfordshire and offsite parking impact is a significant concern, which could be exacerbated if mode share targets are not achieved, resulting in increased pressure for long term parking provision in Central Bedfordshire. There is a general concern that parking assumptions have been underplayed. In addition, there is concern regarding the robustness of the Framework Travel Plan, and a number of the assumptions feeding into the public transport provision for the development, with related concerns with regards to the Green Controlled Growth Framework. The Council requests an issue specific hearing on transport and highway issues. Design, landscape and visual impact The Council considers that the proposed development, during construction and operational phases, by virtue of its scale and extent of operations would impact on the surrounding landscape including public footpaths, designated landscapes, which are valued for scenic quality, cultural heritage and recreational routes. Careful consideration needs to be given to the mitigation measures and how they would impact on the use of public footpaths, the quality of designated landscapes and cultural heritage. There is lack of detail and clarity within the assessment. Impact on historic environment and archaeology The Council considers that the proposed development due to its scale and massing and close proximity to heritage assets of archaeological significance, has the potential for harm to the significance of the Luton Hoo Registered Park and Garden and setting of the Luton Hoo mansion, and also Someries Castle. There is lack of detail and clarity within the assessments. The Council requests an issue specific hearing on the historic environment and archaeology. Noise Impacts The Council is very concerned about the noise impacts associated with the increase in passenger numbers and the resultant increase in aircraft movements. There are issues regarding the assessment which does not comply with UK aviation noise policy or emerging policy, which is important when considering timeframes into the future. There are other issues with the assessment, such as baseline data, which will be discussed in more detail at the Written Representation stage. Additionally, further discussion is required on the proposed noise mitigation measures and the Green Controlled Growth framework. The Council requests an issue specific hearing on noise. Health Impacts The Council is very concerned about the impact of the development on public health and wellbeing, which is influenced by air quality, noise, climate change, green house gas emissions, highways and reduced tranquillity and negative impacts on open spaces. There is lack of detail and clarity within the assessments. Climate Change and Greenhouse Gases There is concern that the proposed development, resulting from airport operations and surface access would impact on objectives for reducing climate change and greenhouse gas emissions. Air Quality There is concern regarding air quality and the impact of increased pollutant concentration levels that may affect human health and suitability of mitigation measures. Mitigation Measures A series of mitigation measures, controls and enforcement, including the operation of Green Controlled Growth have been put forward to ensure that the benefits of growth are shared with the local community. The level of information is insufficient to understand the effectiveness of these measures and the extent to which benefits will be realised by Central Bedfordshire residents and businesses. Development Consent Order and the Requirements The Council considers that there will be a need for negotiation on the matters set out in the draft DCO. There is concern regarding the provision, requirements, timescales and drafting of the DCO. These matters will be commented on in detail at Written Representations stage and it is likely that the requirements will develop through the process. S106 Agreement No S106 agreement has been submitted. Paragraph 5.8 of the Planning Statement indicates details the Heads of Terms. In the absence of a S106 agreement, the Council consider that there might be other matters that should be included in the obligation, which might arise as representations progress. Summary There are other topic areas that the Applicant has identified in its application documents, but these have not been commented on as they have lesser impact upon Central Bedfordshire. Central Bedfordshire Council consider that there are issues and shortcomings in the submitted information. Therefore, the proposal cannot be supported due to concerns regarding the likely impact on the communities that live and work in the local area, which could be adversely affected by the proposed development.