Sustainability Appraisal Scoping Report

Published 20 July 2021



1. Introduction
2. The Oxford-Cambridge Arc
3. Why we are doing a sustainability appraisal
4. Strategic Context
5. Scoping of Key Effects
6. How we will carry out the assessment
7. How we will communicate the results
8. Your views


1.     Introduction

What is a sustainability appraisal?

1.1         Sustainable Development can be defined as meeting the needs of the present without compromising the ability of future generations to meet their own needs. To ensure that sustainability is at the heart of the Oxford-Cambridge Arc Spatial Framework, we are undertaking a Sustainability Appraisal (SA) that will inform and underpin its development. The SA will address environmental, social and economic factors so that we can best consider the wider impacts of policies as they are developed within the Spatial Framework.

1.2         We are taking an innovative approach to the SA to not only assess the impacts of draft policies but to embed sustainability into the development of policies and the creation of the Spatial Framework. The approach we are taking is set out in more detail in Chapter 6.


Purpose of this report

1.3         This report summarises the scoping stage of the SA of the Oxford-Cambridge Arc Spatial Framework. The purpose of the scoping stage is to focus the SA on the environmental, social and economic issues which are relevant to the Spatial Framework from the earliest phase of development of its policy opportunities. The assessment will focus on those effects that are likely to be significant, whether positive or negative.

1.4         We want to hear your views on the key issues and opportunities that should be the focus of the appraisal.  Chapter 8 sets out some questions we would like your feedback on through this consultation exercise to help us shape the next stage of the SA. We will use your views to shape and influence the scope of the assessment we will carry out at the next stage of the SA. 


2.     The Oxford-Cambridge Arc

What is the Oxford-Cambridge Arc?

2.1         The Oxford-Cambridge Arc (‘the Arc’) sits at the heart of England and is defined by the area that spans the five ceremonial counties of Oxfordshire, Buckinghamshire, Bedfordshire, Northamptonshire and Cambridgeshire (as shown in Figure 2.1). This forms a geographical ‘Arc’, which provides a place to live for approximately 3.7 million residents and supports over 2 million jobs. We are developing a Spatial Framework for the area, which will take a strategic approach to planning for growth and infrastructure over the long term.

Map of the Oxford-Cambridge Arc area showing key administrative boundaries including: Ceremonial Counties; City Councils; Combined Authorities; District Councils; and Unitary Authority areas.


Figure 2.1 – The Oxford-Cambridge Arc

Why is a Spatial Framework needed and what will it achieve?

2.2         Infrastructure underpins economic growth, and across the Arc inadequate infrastructure in housing, transport, utilities and digital platforms is a key constraint for the area. We have identified that by taking a strategic approach across the Arc, there is the opportunity to address these inadequacies and deliver new well-planned infrastructure which integrates natural capital, whilst supporting economic and population growth. There is also potential to support new large scale, publicly accessible green infrastructure, with benefits for health and wellbeing, as well as nature recovery and biodiversity net gain, amongst others.

2.3         The government wants to support sustainable economic growth in the Oxford-Cambridge Arc, so we are developing a Spatial Framework to plan for that growth – to 2050 and beyond. The Spatial Framework will form national planning policy and national transport policy for the area set out in Figure 2.1, which covers the ceremonial counties of Oxfordshire, Buckinghamshire, Bedfordshire, Northamptonshire and Cambridgeshire. At a strategic scale, this will coordinate and focus investment in the area and shape future local planning decisions on:

  • how land is used;
  • how the environment is protected and enhanced;
  • where and what type of new development happens; and
  • what infrastructure is provided. 

2.4         We are developing a long-term Spatial Framework for the Oxford-Cambridge Arc so that we can plan for growth in a more sustainable and strategic way. We believe that the Spatial Framework will allow us to plan for growth in a way that:

  • makes the area a better place to live and work for all;
  • leaves a long-term legacy by protecting and enhancing the Arc’s built and natural environment and beautiful places; and
  • helps combat and build resilience to climate change.

2.5         The strategic approach to growth for the Arc will be set out in a draft Spatial Framework, which we hope will be published for consultation in autumn 2022.


3.     Why we are doing a sustainability appraisal

Strategic Environmental Assessment and Sustainability Appraisal

3.1         Strategic Environmental Assessment (SEA) is a process that aims to integrate environmental and sustainability considerations into strategic decision-making (see: Therivel, R. (2010) Strategic Environmental Assessment in Action, 2nd Edition. London: Earthscan) and is a legal requirement for certain plans and programmes under the Environmental Assessment of Plans and Programmes Regulations 2004. Sustainability Appraisal aims to address environmental issues (by incorporating environmental assessments) alongside social and economic issues to inform decision-making.

3.2         To ensure sustainability is embedded into the development of the Spatial Framework, an SA is being undertaken which will include a strategic environmental assessment for the purposes of the 2004 Regulations. This will be informed by other statutory assessments and regimes, such as a habitats regulation assessment pursuant to the Conservation of Habitats and Species Regulations 2017 requirements (see Chapter 6 below).

3.3         The SA stages intended for the Spatial Framework are set out in Figure 3.1 below and are further explained in Table 3.1.

The Sustainability Assessment stages intended for the Spatial Framework, including the Vision Statement, Options Document, Draft Spatial Framework and Final Spatial Framework. 

Figure 3.1 – Spatial Framework development stages


Table 3.1 – The SA process to be followed for the Spatial Framework

Key Stage

Description and outputs required

1. Scoping

The scoping stage involves setting the scope of the assessment. It ensures that the SA is focussed on relevant issues that could influence or be influenced by the plan being developed.

This scoping report has been produced to consult on the scope of environmental, social and economic issues to be included in the SA.

2. Options Stage

This SA stage will involve the appraisal of options and sustainability issues. This will be documented in an SA ‘Issues and Options’ report which will be issued for consultation, outlining the shortlisted options for full assessment.

3. Assessment

The assessment phase influences the development of the Spatial Framework and assesses the effects of the draft Spatial Framework. It identifies the potential significant sustainability effects along with mitigation measures. Cumulative effects within the plan, and with other plans, programmes and policies will be assessed. Proposals for monitoring the effects identified will be outlined.

An SA Environmental Report (and an accompanying SA Environmental Report Non-Technical Summary) will be produced to document this process for consultation. The Environmental Report will be published alongside the draft Spatial Framework.

4. Adoption

Following adoption of the final Spatial Framework, a report will be produced that outlines how SA and consultation have influenced the development of the published Spatial Framework.

A post-adoption statement will also be prepared and published to give notice of the adoption of the Spatial Framework, in accordance with the requirements of the Environmental Assessment of Plans and Programme Regulations 2004.

5. Monitoring

Implementation and monitoring of the Spatial Framework.


3.4         Chapter 6 sets out more information on our approach to the SA to influence the policies and plan development, our SA themes, and how we will carry out the assessment.


Consulting on the scope of the SA

3.5         We have prepared this report to seek your views on the scope of the SA. It will help us to understand which environmental, social and economic effects of the plan are considered to be relevant and/ or of concern. It may also provide us with more information that we should take into consideration.

3.6         We are consulting with statutory stakeholders, interest groups and the community across the Arc on our environmental, social and economic baseline and the issues and opportunities we have identified to be the focus of the next stage of our assessment.

3.7         Chapter 8 sets out some questions we would like your feedback on through this consultation exercise to help us shape the next stage of the SA.


4.     Strategic Context


4.1         This section describes the current environmental, social and economic context of the Oxford – Cambridge Arc, and is informed by a detailed review of environmental, social and economic issues, opportunities and challenges as well as a review of relevant plans, policies and programmes, which can be found in the Annex accompanying this report. A list of the information sources used to produce the strategic context can be found at the end of the Annex.

4.2         The context covered in this section is focused on the Arc; however, the Spatial Framework could result in effects outside of this area. Relevant transboundary effects (if any) will be considered during the assessment of the Spatial Framework and recorded as part of this process.


Environmental assets in the Arc

4.3         The Arc has a diverse landscape, and is predominately characterised by its low-lying land, particularly through the centre of the Arc across to the Fens in the eastern extent. Some areas of raised land can be found in the Chilterns and Cotswolds around the western and southern extents. There are three nationally important landscapes within the Arc, designated as Areas of Outstanding Natural Beauty (AONB): The Chilterns, The North Wessex and Downs, and the Cotswolds, totalling 10% of the Arc’s land cover.

4.4         The rich loamy and clayey soils and high soil fertility of the Arc support large areas of the highest quality agricultural land, particularly around the eastern and western extents. Agriculture therefore plays a dominant role in the land use across the Arc with around 54% of land being classed as cultivated / disturbed land and 20% classed as improved grassland (land used for grazing). The Cambridge, Oxford and London Area Greenbelts are also located within the study area and are a means of protecting rural space. Figure 4.1 provides an overview of the landscape and land use within the Arc.

Map showing three AONBs, eight urban centres and areas of green belt, principally around Oxford, Luton and Cambridge.

Figure 4.1 – AONBs, main urban centres, areas of Greenbelt and distribution of agricultural land across the Arc

4.5         Land use change and urban expansions could present key challenges and pressures for the landscape in the Arc, including soils and their quality, particularly as a result of new settlements and development along new and existing transport corridors. There is an opportunity to create an enhanced ‘sense of place’ and improve the quality of life across the Arc, providing landscapes and townscapes which support increased access to blue and green infrastructure, allowing people to make healthier choices, whilst also supporting nature recovery and economic growth.

4.6         Across the Arc, there are areas of significant cultural heritage and part of its character and attractiveness is derived from the quality of the historic environment. There are numerous historic settings, where the landscapes, land use characteristics and distinctive built environment assets come together to create a strong sense of heritage and ‘place’. Nationally important and protected historic features are widespread across the Arc.

4.7         There are over 200 scheduled monuments and other areas of archaeological significance or potential; many of these are associated with the river corridors in the Arc where access to watercourses and good agricultural conditions favoured early settlement. There are over 7,000 listed buildings across the Arc of which approximately 1,700 are Grade I. Approximately, 50 Registered Parks and Gardens are located within the Arc, mainly associated with stately homes or landscaped parks and gardens. There is also a notable cluster of concentration of Civil War battlefields at the north-western extent of the Arc. There are approximately 150 Conservation Areas throughout the area, recognising and protecting these historic characteristics. The concentration of the listed buildings, scheduled monuments, conservation areas, and registered parks and gardens are shown in Figure 4.2.

Concentration of heritage assets across the Arc. The map shows concentrations of heritage assets around Oxford, Oxfordshire and Cambridge.

Figure 4.2 – Concentration of heritage assets across the Arc

4.8         Oxford features an architectural history that spans nearly 1,000 years with the skyline of domes, spires and towers that are enjoyed in views from the surrounding villages and hills of the Thames valley. The one UNESCO World Heritage Site in the Arc, Blenheim Palace, is located near Oxford. Cambridge’s historic and natural environment defines the character and setting of the city, with the exceptional concentration of collegiate buildings around the River Cam. Other notable towns within the Arc include Milton Keynes, a leading example of post-war architecture and place-making. Peterborough is an ancient settlement stretching back to prehistoric times, with the structures and street patterns, boundary walls, buried archaeological remains and other features of the city evident.

4.9         Improving the sense of place for existing communities coupled with enhancing economic benefits, for example the role of Oxford and Cambridge in supporting the tourism economy, provide opportunities to achieve multiple benefits. The existing protected heritage features, landscapes, and clusters of high value designations in rural areas and river corridors in Oxfordshire (River Thames) and Cambridgeshire (Fens and River Cam) provide constraints to future development.

4.10       The water environment is a key aspect of the Arc with over 5,700 km of rivers and streams, and nearly 350 river waterbody catchments designated under The Water Environment (Water Framework Directive) Regulations 2017 (S.I. 2017/407) to protect water sources and their dependent ecosystems. Over 100 of these waterbodies have a status of poor or bad, with the majority being affected by wastewater discharges. Low flows in rivers are a key concern, making them more vulnerable to the effects of pollution, with improvement in wastewater treatment capacity highlighted as a key enabler to prevent deterioration in water quality. The Arc also contains the headwaters of several major river systems and a number of chalk streams are found in the south of the Arc. Chalk streams are rare habitats and about 85% of the world’s chalk streams are in the south and southeast of England. The high ecological and conservation value, and good water quality of chalk streams make them an important consideration in planning future development within the Arc.

4.11      The Arc is home to areas of significant natural heritage with internationally important wetlands, ancient woodlands and meadows that support unique biodiversity. There is a diverse selection of priority habitats (Figure 4.3) with deciduous woodland being the most common priority habitat with approximately 56,000 ha (60% of the priority habitat cover). The Arc also has approximately 31,000 ha of ancient woodland. There are numerous international statutory designated nature conservation sites within the Arc totalling over 12,000 ha. Internationally designated sites in the Arc include 14 Special Areas of Conservation (SAC), three Special Protection Areas (SPA) and six Ramsar sites. The largest Ramsar site of the Arc, the Ouse Washes, is one of the most important areas of lowland wet grassland in Britain. The area contains one of the UK’s most extensive networks of wetland habitats and is important for a number of rare species, especially birds and aquatic invertebrates. There are also just under 500 nationally designated sites, including around 340 SSSI, and around 20 National Nature Reserve sites.

Priority Habitats across the Arc. There is a diverse selection of priority habitats with deciduous woodland being the most common priority habitat (60%), with coastal and floodplain habitat along the major rivers in the Arc.

Figure 4.3 – Priority habitats across the Arc

4.12      Across the UK, the average species abundance of terrestrial and freshwater species has fallen by 13% since 1970 with steeper rates of decline seen in the last 10 years. Agriculture has been the leading cause of net biodiversity loss over recent decades and the resulting intensification of land management is continuing to add pressures now. Agriculture is also the dominant source of nitrate in water with high nitrate concentrations contributing to nutrient enrichment which can adversely affect surface water habitats such as rivers and lakes and sensitive terrestrial habitats and ecosystems. Given the Arc is a key agricultural area, this is of particular relevance, although farmers and landowners are being encouraged to adopt more sustainable practices through the new Agricultural Act 2020 to recover and restore biodiversity losses, and contribute to the UK Government’s 25 Year Environment Plan.

4.13      Increasing population and development has also led to habitat fragmentation and species disturbance, and as sites become smaller, they become more vulnerable to pressures, and are therefore more likely to result in biodiversity loss. For example, only 47% of the area covered by habitats designated as SSSI are considered to be in a favourable condition. Climate change also represents a threat to biodiversity. The loss of biodiversity from increased development will continue if appropriate considerations are not integrated into future development plans.

4.14      There is an opportunity to guide the location of new development away from sensitive areas for biodiversity. New development can be used to integrate biodiversity into design and place-making. Requirements to achieve biodiversity net gain through all new development can increase habitat connectivity and increase the provision of green infrastructure with wider benefits for health and wellbeing, and climate resilience.

4.15      Environmental net gain goes beyond biodiversity net gain and is outlined as a key commitment in the UK Government’s 25 Year Environment Plan. The Plan states that development should seek to result in net environmental gain through returning neglected or degraded land to health, and restoring or creating habitats for wildlife. Environmental net gain principles do not apply to all environmental assets in the same way. The historic environment, for example, is a non-renewable resource and new assets cannot be created to contribute to net gain in the same way as the natural environment. However, some historic and archaeological assets can be made subject to restoration and improvement works designed to leave them in a better physical state than beforehand, improve their historical and cultural value, ecosystem services and the benefits they deliver.

4.16      Natural capital are the stocks of our natural assets which include ecosystems, species, freshwater, air, soil, minerals, land and seas. Value is generated by these natural capital stocks and is delivered directly or indirectly through a range of services, referred to as ecosystem services. The Arc has a range of natural capital assets, from woodlands to wetlands, which provide a significant number of services including climate and flood regulation, recreational provision and water supply, thereby delivering benefits and adding value to the area. The estimated total natural capital asset value in the Arc over 100 years is £72 billion. As shown in Figure 4.4, the value of services flowing from the natural capital assets in the Arc every year is estimated at £2.3 billion. Integrating natural capital approaches or considerations into the Spatial Framework will likely lead to more efficient decision-making, resulting in better outcomes for the environment and people.

Example outputs from the Local Natural Capital Plan. The value of the natural assets of the Arc is approximately £2.3 billion.
Example outputs from the Local Natural Capital Plan. £2.68 billion is the estimated annual value in the Arc flowing from ecosystem services.

Figure 4.4 – Example outputs from Oxford-Cambridge Arc Local Natural Capital Plan

Living and working in the Arc

4.17      The main population centres are across the core of the Arc, including Oxford, Bicester, Milton Keynes, Bedford and Cambridge as well as Luton and Peterborough in the north and south. The Arc has a total population of approximately 3.7 million people; this has grown from approximately 2.8 million in 1991 and is expected to increase to close to 4 million by 2043. The population in the Arc is supported by a steady flow of national (internal) and international migration where 80% of the inflows into the area are from other places in the UK. The areas experiencing the largest increases in population from international migration are Northampton, Luton and Oxford. The current and projected age profile of the Arc population is shown in Figures 4.5 and 4.6.

The current age profile of the Arc is consistent with the age profile of England.

 Figure 4.5 – Current age profile of the Arc population (2019 mid-year estimates from ONS data were used for population profiles)

Population projections show numbers in older age groups rising, and numbers in younger age groups falling to 2043. 

Figure 4.6 – Projected age profile of the Arc population (2018 based population estimates from ONS data were used as the base year for the population projections.)

4.18      Of the people that make up the Arc, the proportion identifying their ethnicity as white is slightly above the England average.  Across the Arc, the areas of relative deprivation broadly follow another arc, running from Luton through Bedford, Northampton, Kettering, Corby, Peterborough and the Fenlands. Health and wellbeing indicators follow a similar pattern with variations across the Arc in terms of life expectancy, healthy lifestyles and mental health. For example, there is a difference in life expectancy of almost two years between some parts of the Arc, demonstrating that existing health inequalities are present.

4.19      Housing affordability is one of the key issues in the Arc, where the supply of new homes in the main settlements has not kept up with demand. Cambridge, Oxford, Chiltern and South Buckinghamshire are examples where affordability ratios are so high that home ownership is not a realistic prospect for many residents. The areas where housing is affordable have seen population growth, for example in Corby, Milton Keynes and Peterborough. The mismatch between economic centres and residential centres results in a shortage of local skilled labour; one of the main constraints to economic growth.

4.20      One of the drivers of increased demand for housing is economic prosperity. The Arc has been one of England's fastest-growing economic areas over the last 20 years. Economic output increased from £81 billion in 2000 to £108 billion in 2018, with the economy growing at a faster rate within this period, than any other region in England, excluding the East of England and London.

4.21      The Arc experienced this growth due to highly specialised and productive sectors, and high employment rates. Those employed work across various knowledge-based industries and services such as education, health, business, professional, scientific, and technical services. Some of these knowledge-based industries operate together as economic clusters (for example, life sciences, advanced manufacturing, space and aviation) which contribute significantly to the UK economy and have the potential to become global innovation hubs that can attract further inward investment and create jobs in the region. The wholesale and retail sector accounts for the largest share of the Arc's workforce, employing 13% of its workforce as of 2019.

4.22      A highly skilled labour force supports the Arc's industries and sectors; 41% of the Arc's resident population hold qualifications at degree level or equivalent; gross median resident earnings are higher than the national average. There are shortages in vocational and applied skills, which increasingly are in demand. Median house prices are higher than the national average, with the lack of affordable housing leading to residents settling further away from economic centres, limiting the pool of labour available to the local employers, and increasing workplace commuting and migration. There is an opportunity to increase the supply of new homes to help tackle housing affordability and locate workers closer to places of work. Place-making is a key objective for the Spatial Framework and offers the opportunity to create healthy and sustainable communities.


Infrastructure supporting the Arc

4.23      Infrastructure underpins economic growth, and across the Arc inadequate infrastructure is a key constraint. As such, investment in housing, transport, utility and digital infrastructure will be critical to realising the Arc’s full potential, whilst helping to ensure sustainable growth and resilience to current and future stresses.

4.24      Car-based transport is the primary transport mode within the Arc. Approximately three-quarters of residents commute to work by car and typically travel between five and ten kilometres to reach their final destination. Most car journeys are within the immediate employment catchments and therefore commuting patterns tend to be localised. The Arc is generally well served by the Strategic Road Network (SRN). The M11, A1(M), M1 and M40 pass through the area in a north/south orientation, resulting in good overall connection into London and the M25, towards the Midlands, and to the North. Connectivity in the east-west direction is poor with large sections of single carriageway, both on primary and secondary roads. As with the road network, north-south infrastructure also prevails in rail infrastructure, with limited links available east to west. Key rail links passing through the area include the Great Western, West Coast, East Coast, West Anglia and Midland Mainlines. Across the Arc, there are a total of 94 rail stations, although only 17 are considered to have high frequency services with more than eight trains per hour.

4.25      To address the transport challenges currently faced by the Arc, and to accommodate planned growth, a series of projects at both strategic and local scales have been proposed to begin resolving the congestion issues, and the lack of east-west connectivity within the Arc. This includes proposals for upgrades to the strategic road network, the development of the East West Rail Corridor between Oxford and Cambridge, and improvements to local transport provision including proposals for rapid transit/ metro systems in Oxford, Cambridge and Milton Keynes.

4.26      The movement of goods and freight is a key aspect of the Arc and will be critical to the development of the area. Major distribution corridors include the M1 with nationally significant logistics hubs located around Milton Keynes, Northampton and Wellingborough, where the Arc crosses the “Golden Triangle” of national distribution hubs. The A14 and A34 also see significant traffic flows for freight as they provide important access to ports on the east coast. Rail freight has an important role to play in the Arc with rail terminals located across the area. Forecasts for rail freight indicate potential for increased demand across the UK and proposals such as East West Rail could (if successfully brought forward) support the unlocking of this demand and mode shift of freight from road to rail.

4.27      Current road traffic in urban centres and on the strategic road network is the primary source of harmful emissions leading to air quality problems within the Arc. Exposure to air pollution represents one of the most significant environmental threats to health in the UK, with thousands of deaths a year being attributed to long-term exposure. Air Quality Management Areas (AQMAs) are declared where local authorities consider that national air quality objectives are not likely to be achieved. There are over 50 AQMAs across the Arc, as shown in Figure 4.7; the principal locations are:

  • in central Oxford, plus Marcham and Abingdon on the A415 (Oxfordshire);
  • the M40 and M25 through Buckinghamshire plus the main roads into High Wycombe (Buckinghamshire);
  • several roads into the centre of Northampton plus the M1 to the south of Northampton (Northamptonshire);
  • central Bedford, central Luton plus the M1 through Leagrave (Bedfordshire); and
  • central Cambridge, sections of the A14 and Huntingdon plus Wisbech (Cambridgeshire).
Air Quality Management Areas in the Arc. The map shows the distribution of designated Air Quality Management Areas.

Figure 4.7 – Air Quality Management Areas in the Arc

4.28      Residential development close to major roads already affects the health of those living nearby. The location of future development within the Arc can be informed by these existing sensitive routes, and other areas where major roads are close to residential areas (for example, A34, the A14 and the A1(M)). One of the challenges associated with future development is to balance the requirement for good access to transport infrastructure, whilst avoiding, or at the very least not contributing further to, areas of existing pollution. Within urban centres, focus remains on efforts to reduce local traffic emissions. Urban planning can also seek to improve access to sustainable modes of transport, as well as recognising the role of housing density and wider streets in creating space between pollution sources and people, and the role of nature in air purification. Planning can also enable behaviour change to reduce motor vehicle use and promote active travel modes such as walking and cycling. Increases in flexible working policies, business practices and significant improvements in digital infrastructure, particularly in the light of the COVID-19 pandemic, reduces the need to travel and therefore presents a key opportunity.

4.29      In terms of energy utility infrastructure, spatial variations in gas capacity exist across the Arc with some areas significantly constrained, and others able to support future development such as Milton Keynes and Cambridgeshire. Plans from the UK Government to stop new household gas connections after 2025, may reduce gas demand in the Arc and will likely lead to an increase in electricity demand. There is limited spare capacity in electrical distribution and transmission networks, with significant constraints in some areas, for example to the west of Milton Keynes and east of Cambridge. The opportunity to develop low-carbon infrastructure provides the foundations for maximising affordable energy and clean growth.

4.30      Water is supplied to customers in the Arc by four main water companies: Anglian Water, Cambridge Water, Thames Water and Affinity Water. Water companies are expecting that there will be no surplus capacity once existing committed development (to 2040) is built and serviced. Although initiatives are underway to reduce water demand from existing users, the availability and ability to supply water will be a significant constraint in planning the scale and location of future development within the Arc.

4.31      Resilient, reliable and secure digital networks and infrastructure are continuing to grow in importance for supporting economic growth and providing social and wellbeing benefits, particularly during the COVID-19 pandemic. Broadband speeds typically differ across the Arc with higher speeds in urban areas compared to rural areas. Data demand is also projected to increase within the Arc.

4.32      The UK is also committed to moving towards a circular economy to optimise resource use, create new opportunities for growth and reduce environmental pressures of production and consumption. The Spatial Framework presents an opportunity to integrate and promote circular economy approaches, working with key stakeholders across the Arc, to contribute to this transition. National policy priorities also focus on reducing waste to landfill, including eliminating food waste from landfill by 2030, eliminating avoidable plastic waste over the next 25 years, eliminating all kinds of avoidable waste by 2050 and doubling resource productivity by 2050.

4.33      Waste management and disposal capacity across the Arc is sufficient for current and projected populations, with each county having recycling, composting, waste transfer and landfill facilities. However, a significant proportion of waste still goes to landfill. An approximate total of 1.4 million tonnes of waste was collected in the Arc in 2019/20 which accounts for 6% of the total local authority waste collected in England in the same year. Around 51% of this waste was sent to landfill and the remaining was sent for recycling, composting or reuse.

4.34      There is an opportunity to support an ambitious and long-term approach to improving regional or even national waste management capacity. Strategic scale growth would bring with it the potential to deliver new Energy from Waste plants that deliver combined heat and power. It may also be that concentrations of new growth aligned with highest standards of waste separation leads to the potential to deliver next-generation recycling facilities.


Changing climate

4.35      Climate change is a global challenge and can have significant implications for the environmental,  and economic aspects of the Arc that are described above. Action is needed at all levels to mitigate and manage the effects, primarily through reducing contributions to greenhouse gases (GHG) emissions and increasing resilience to climate risks and hazards. As the country heads towards net zero target economic and housing potential of the Arc, some additional carbon emissions are likely and therefore challenges remain, when considering impacts and ambitions, in identifying where opportunities might exist at local and regional level to reduce emissions from existing sources (e.g. housing, industry, transport, etc.) and maximise the opportunities provided by existing natural resources and carbon sinks.  economic and housing potential of the Arc, some additional carbon emissions are likely and therefore challenges remain, when considering impacts and ambitions, in identifying where opportunities might exist at local and regional level to reduce emissions from existing sources (e.g. housing, industry, transport, etc.) and maximise the opportunities provided by existing natural resources and carbon sinks. 

4.36      The GHG emissions for the area covered by the Arc are shown in Figure 4.8. The Spatial Framework has the opportunity to lead in its approach to contributing to the national transition to net zero. This can be achieved by setting a framework for reducing embodied and operational carbon emissions through well-designed and appropriately placed development, increasing the provision of carbon sinks, providing sustainable and active transport infrastructure, encouraging behaviour change, and supporting the growth of the green economy.

Carbon emissions in the Arc. In 2018, approximately 17,000 kilotonnes of carbon dioxide was emitted in the Arc, with the transport sector contributing the majority of the total emissions.

Figure 4.8 – Carbon emissions in the Arc

4.37      The climate is changing; the latest UK climate projections (UKCP18) show milder, wetter winters and hotter, drier summers along with an increase in the frequency and intensity of extreme events are to be expected. The UKCP18 climate projections for the Arc are presented in Figure 4.9. 

Mean temperature changes range from 5.2 to 5.8 degrees in the summer and 3.5 to 3.6 degrees in the winter. Mean precipitation changes range from 20% to 27% drier in the summer and 35% to 41% wetter in the winter.

Figure 4.9 – Projected climate change in the Arc

4.38      A key risk posed by climate change for the Arc includes flooding from more extreme precipitation events. Areas at greater risk of flooding are The Fens / Fenlands in the north east of the Arc, along the River Great Ouse, River Nene and the River Thames, especially along the southern borders of Oxfordshire and Buckinghamshire, and the western boundary of the Arc. As well as avoiding existing areas liable to flooding, future development will need to avoid generating run-off that may increase the risk of downstream flooding. River catchment management, changes in land management practices and nature-based solutions can help provide flood management, alongside enhancing natural water systems, public realm and ecological value. There is also risk of droughts with recent events affecting the Arc during 2011 to 2012 and 2017 to 2019. Heatwaves during summer months, and an increase in the urban heat island effect, where built-up and dense urban areas absorb and retain heat, creating increased air temperatures relative to the surrounding rural areas are also key climate related risks.

4.39      Climate risks can be actively managed across the Arc through a framework that demands the integration of resilience into the design of new and existing places, spaces and infrastructure, and the avoidance of development in areas of high flood risk, increasing water efficiency, incorporating green infrastructure into new development, and supporting nature recovery. Without mitigation, all of these risks can significantly affect the health and wellbeing of the population, biodiversity and the natural environment, and the economy.

5.     Scoping of Key Effects


5.1         This section sets out the proposed scope of the SA, focusing on the relevant environmental, social and economic issues and opportunities that could influence or be influenced by the development and implementation of the Spatial Framework. The scope of the assessment has been determined by reviewing the baseline conditions identified in Chapter 4 (Strategic Context) and Annex A. In addition, relevant plans policies and programmes (Annex B) have been used to identify the potential impact the Spatial Framework may have on the environmental, social and economic aspects of the Arc.

5.2         At this stage, the scope of the assessment reflects the strategic nature of the Spatial Framework Vision and therefore identifies the high-level issues and opportunities relevant to each sustainability theme. As the Spatial Framework evolves, so will the SA and the level of detail associated with the scope of the assessment. The approach to assessing those themes that are within the scope of the SA is set out in Chapter 6.

5.3         It should be noted that the SA will not consider, or address, all the likely impacts associated with all project/ development level activities in the Arc area that might be envisaged or anticipated by developers as a result of the options and opportunities presented in the draft Spatial Framework. Such detail is likely to be beyond the scope of this strategic assessment; however, any such impacts are highly likely to be within the scope of other statutory and non-statutory project level assessments, such as Environmental Impact Assessment (EIA) (implemented through the Town and Country Planning (Environmental Impact Assessment) Regulations 2017), and will need to be considered as appropriate. 


Proposed scope of the assessment

5.4         Given the wide range of issues that are addressed within the Spatial Framework, the document has the potential to influence many aspects of how people live, work, travel and experience the natural landscapes within the Arc. Table 5.1 identifies the issues and opportunities that have been scoped into the assessment; these are a reflection of the diverse aspects of the environment, economy and society that the Spatial Framework has the opportunity to guide. 

Table 5.1 – Proposed scope of the assessment

SA Theme

Scoped In?

Spatial Framework Issues

Spatial Framework Opportunities

Land use and landscape



Notable changes to the visual identity of the area, including National Character Areas and AONBs

The loss of soil and its quality from increased development with implications for food production, biodiversity, flood management, water quality and carbon storage

Many parts of the Arc’s natural environment are relatively inaccessible to the public

Protect and enhance landscape character

 Provide a ‘sense of place’ and belonging for existing and new communities

Recover and restore soils

Ensure soils are protected from contamination and use brownfield sites

Protect the highest quality agricultural land from disturbance and loss

Land use planning to be influenced by natural capital approaches

Historic Environment




Heritage assets and archaeology at risk from inappropriate development, which could affect their international renown or attractiveness

Views and vistas to heritage assets are at risk from increased development pressures

Pressure of development on the archaeology and settings of heritage assets

Enhance the setting of heritage assets

Encourage public awareness through promoting heritage sites and transport links to sites

Conserve and enhance the historic landscape character






A predicted increase in the population to mid-2040s

Ageing and more diverse population

The corridor of relative deprivation from Luton through Bedford, Northampton, Kettering, Corby, Peterborough and the Fenlands relating particularly to affordable home ownership and job security

Evidence of inequalities, including health inequality across the Arc

Increase the supply of new homes, help tackle housing affordability, and locate workers closer to places of work

Provide social facilities (including educational and healthcare facilities) to meet the evolving needs of the existing and expanded communities

Contribute to improved health and wellbeing for those living and working in the Arc

Reduce the Arc’s inequalities




The loss and fragmentation of locally, nationally and internationally designated ecological habitats

Consequences for species abundance and diversity due to loss and fragmentation of habitats and disturbance




Protect, recover, and restore the diversity of habitats and species

Slow/ halt biodiversity losses and declines and support nature recovery

Promote and achieve biodiversity net gain, integrating biodiversity considerations into new infrastructure and development

Increase biodiversity connectivity of sites and habitat restoration

Connect people with nature and improving access to greenspace

Integrate a natural capital approach to influence decision making and achieve better outcomes

Grow the value of the Arc’s natural capital





Increased demand and pressure on water resources and wastewater treatment due to population and economic growth in the Arc

Risk of flooding to new or existing resources, considering future climate projections

Contamination or exacerbation of existing contamination of the water environment from development

Ensure the protection, improvement and sustainable use of all waterbodies

Reduce per capita water consumption

Plan for and deliver additional water resources to support new development and growth

Consideration of water efficiency improvements in existing housing across the Arc

Reduce flood risk and increase resilience to flooding (including measures at a catchment scale)

Encourage a nature-based approach to managing flood risk

Reduce or control water pollution

Improve water quality in all waterbodies

Air Quality




Harmful emissions from road traffic sources (NOx, PM10 and PM2.5) in urban centres and on the strategic road network that are the primary sources of air quality problems within the Arc, impacting those who live and work in these locations

Growth in transport, and the associated infrastructure will continue to contribute significantly to emissions in the Arc, particularly road vehicles


Encourage sustainable and active modes of transport by improving connectivity across the main urban centres

Reduce the need to travel, and car dependency, through promoting active and sustainable transport

Plan for the infrastructure required to support the transition to low and zero emission vehicles, thereby contributing to the government’s commitments on ending the sale of new conventional petrol and diesel cars and vans by 2030

Support the government in reducing the annual average level of PM2.5 in ambient air

The role of nature in land use planning to improve air quality

Climate Change




Increased emissions due to development and growth in the Arc, presenting a challenge in light of national net zero by 2050 commitment

Transport will continue to contribute significantly to emissions in the Arc, particularly road vehicles

Current and future climate change projections risk affecting health and wellbeing, the environment and the economy in the Arc

Lead the approach to local/ regional contribution to the national transition to net zero by 2050 by reducing embodied and operational carbon emissions across the Arc

Ensure the framework demands that climate risks are actively and consistently managed across the Arc and resilience is integrated into new and existing places, spaces and infrastructure

Avoid development in areas at high risk of flooding

Increase the provision of green infrastructure and nature recovery to improve resilience to climate change through sequestration of carbon    




Increase in road congestion across the Arc due to growth and development, particularly if car-based transport continues to be the primary mode of travel

High car usage and dependency

Poor east-west connectivity in all modes of public transport across the Arc

Proposed development needs to be planned in conjunction to public transport improvements

Proposed development needs to be planned in conjunction with freight movements to and within the Arc


Improve connectivity for east-west journeys

Improve access to key services and locations and improve the health and safety of the network

Reduce road congestion and car dependency by encouraging the use of public and active modes of travel

Reduce the need to travel

Ensure transport links are reliable and accessible for all, particularly public transport 

Promote active and sustainable modes of travel and connectivity around transport hubs, to provide an alternative to car use

Ensure the transport network supports and enables economic growth in the Arc

Optimise freight movements to and within the Arc and promotion of sustainable modes of freight movement





Inadequate infrastructure in sectors such as utilities and digital across the Arc, acting as a constraint to growth

Development pressures on existing transport and utility infrastructure

The rate of house building will not meet the continued demand across the Arc


Deliver well planned and co-ordinated transport, housing, digital and utility infrastructure - including sustainable drainage -   within the Arc which integrates a natural capital approach, and supports the net zero transition, whilst supporting economic and population growth

Increase the provision of large scale and publicly accessible green and blue infrastructure

Resources and Waste




Increase in waste, particularly from construction materials as well as increases in household waste due to population growth

Although waste management and disposal capacity across the Arc is sufficient for current and future populations, a significant proportion of waste is still sent to landfill and will likely continue to increase with population growth  

Safeguarded mineral resources are available within the Arc (sand and gravel, brick clay, limestone, chalk, building and roofing stone, and industrial (silica) sands) but it will be necessary to calculate, if the Arc is self-sustaining

Contribute to the transition to a circular economy to optimise resource use, create new opportunities for growth and reduce environmental pressures of production and consumption

If the SF includes provisions for waste management, contribute to waste reduction targets and increase recycling rates, reducing the amount sent to landfill

If the SF includes provisions for waste management, improve waste management capacity

If the SF includes provisions for waste management, deliver energy from waste plants which generate combined heat and power




Demand for labour exceeds supply in some locations, increasing workplace commuting and migration

High housing costs has led residents to settle further away from its economic centres, limiting the labour pool available to local employers and therefore the labour market may not support the economic opportunity

Limited availability of the commercial spaces required to accommodate business growth across the Arc

Infrastructure across the Arc is a constraint to future economic growth

Increase the Arc’s economic output (Gross Value Added (GVA)) and generate new jobs

Address inequalities across the Arc to achieve equality of opportunities for economic growth

Potential for existing business clusters to become global innovation hubs to attract further inward investment, promote skills development and create jobs

Focus on the strategic opportunities for growth and environmental improvement across local administrative boundaries

A more integrated approach to planning for new transport infrastructure alongside new development to support and enable economic growth


6.     How we will carry out the assessment


6.1         This chapter presents the approach that will be used to influence the development of the Spatial Framework in order to achieve improved sustainability outcomes, and to identify and evaluate the residual environmental, social and economic effects that are likely to arise during implementation. 

6.2         Upon completion of this Sustainability Appraisal scoping phase, including the associated consultation, the process of developing the options and policies that will shape the future development of the Arc will commence. The SA will be embedded within this process to improve the outcomes for those receptors scoped into the assessment. 

6.3         Where any residual effects are considered to be significant, appropriate measures to mitigate these effects will be proposed. Further, a monitoring programme focussing on the measurement of the long-term effects of the implementation of the Spatial Framework will be outlined.


The approach to SA

6.4         The potential for a plan of this nature to result in significant positive or negative environmental, social and economic impacts is high due to the scale of development proposed, and the associated land use change. In addition, given the key sustainability issues and targets that are at the heart of the Spatial Framework’s objectives (e.g. targets under the Climate Change Act 2008 and policies under the 25 Year Environment Plan), there are significant sustainability challenges to address. The fundamental purpose of the SA is to embed sustainability within the Spatial Framework, rather than produce a report; therefore, integrating the assessment with the development of the plan provides the best opportunity to influence its content and evolution.

6.5         In contrast to ‘traditional’ objectives led approaches to SA - where plan makers and environmental assessment specialists typically work independently - the Spatial Framework team will be accountable for how the sustainability issues are addressed and will be supported by a dedicated Sustainability Adviser. This role will entail championing sustainability and will provide expert advice throughout the evolution of the Spatial Framework. The role will also be responsible for assembling the evidence that shows how the sustainability issues have been taken into account and will assess the residual impacts.

6.6         Consistent with the approach outlined above, this assessment will challenge the Spatial Framework team to demonstrate how sustainability has been incorporated into the overall management of the various stages that will be involved in developing the Spatial Framework. In order to evaluate the team’s performance in this area, a bespoke ‘Sustainability Leadership’ theme will supplement those identified in Chapter 5.

6.7         Resilience has also been introduced as a further bespoke theme and will seek to understand how the Spatial Framework will deliver in terms of adaptability for future needs in the face of a changing climate, changing working patterns, the need to decouple development from carbon emissions, and promote resource efficiency / the principles of a circular economy.


Assessment Framework

6.8         The proposed approach involves the development of assessment criteria that, rather than being used to assess the draft Spatial Framework, are used to measure how sustainability is being taken into account in its development. The criteria will be applied by those developing the Spatial Framework policies, supported by the Sustainability Adviser, to influence its development and to embed the incorporation of sustainability considerations.

6.9         The specific requirements of the assessment criteria will challenge the Spatial Framework to be able to demonstrate:

  • that an issue was considered at an early stage and there was an understanding of the current baseline and trends;
  • how the assessment issue formed part of the basis for developing the spatial framework or how it has been incorporated into it;
  • the alternatives considered during the development of the Spatial Framework;
  • the anticipated effects of the Spatial Framework in relation to the assessment issue; and
  • the steps taken to ensure plans implementing the Spatial Framework adopt the measures required to deliver on beneficial sustainability outcomes.

6.10      The final content of the sustainability criteria will be influenced by this scoping exercise; however, based on the requirements of the 2004 Regulations (on strategic environmental assessments), key issues currently being considered following the review of policies plans and programmes, and the review of baseline conditions, are set out in Table 6.1.

Table 6.1 – Proposed sustainability themes

Sustainability Themes


Sustainability leadership

How sustainability was considered in the management and direction of the Spatial Framework.


Consideration of strategic risks, resource efficiency and future needs.


Consideration of the impact of existing communities and planning for future occupants, their health and wellbeing. Accounting for equality in the development of new communities and infrastructure, access to the environment and social infrastructure.


Protection of existing sites and corridors of biodiversity value, and incorporation of net gain and supporting the recovery and resilience of biodiversity.

Air quality

Impact of the Spatial Framework on air quality.

Climate change

Performance in contributing to the net zero carbon emissions by 2050 target; adaptation to the effects of climate change, with specific reference to flood risk.

Historic environment

Protection of existing heritage and anticipated change resulting from the Spatial Framework.


Water resource provision and management; changes and benefits to the water environment.

Land use and landscape

Effects on existing land use and likely change; protection of existing valued landscapes and anticipated effects on landscape character


Consideration of transport and movement; provision of new infrastructure, the impact on existing transport networks and associated sustainability effects.


Impact on existing infrastructure (e.g. utilities, digital networks and communications) and the likely resulting change to infrastructure provision.

Resources & Waste

The efficient use of materials and energy throughout the planning, design, and delivery of the Spatial Framework.


Consideration of labour pool availability and the skills required to support economic growth, the impact of infrastructure constraining economic growth, and the exploration of opportunities to further inward investment, promote skills development and create jobs.


Assessing significance

6.11      Whilst the primary purpose of the assessment criteria is to steer the consideration of sustainability in the development of the Spatial Framework, they will also form the basis of the assessment of the potential effects of the draft plan. The assessment will focus on the potential effects considered to be significant at the scale of the Arc, based on the following criteria:

  • effects that are widespread across the Arc or a significant proportion of it (e.g. two or more counties);
  • local effects that are of a large enough scale to be considered significant for the Arc or where the effects will be experienced across a much wider area (e.g. this could result from plans for new settlements, industrial areas or a large area of habitat creation);
  • effects that are likely to result in a demonstrable change in the health of the environment, population and communities, including socio-economic outcomes; and
  • effects of a small scale, although within a sensitive location (such as statutory designations) and considered significant for the Arc.

6.12      The assessment of the effects of the Spatial Framework will include an understanding of the cumulative impacts within the Spatial Framework together with other existing or reasonably certain anticipated connected plans, programmes and strategic projects e.g. connected Nationally Significant Infrastructure Projects (NSIPs), such as (if successfully brought forward) the proposals for East West Rail (although NSIPs may not be the totality of what will be considered). Potential effects arising from interrelationships between themes will also be assessed.


Approach to alternatives

6.13      The purpose of the SA is to influence and assess the effects of the Spatial Framework.  Therefore, the approach to alternatives will be to address the strategic alternatives within the development of the Spatial Framework. These will be set out in an ‘Issues and Options’ report that we hope to publish in spring 2022. This will be accompanied by a high-level sustainability appraisal of the options.


Incorporating other related assessments

Habitats Regulations Assessment

6.14      The Conservation of Habitats and Species Regulations 2017 (as amended) sets out specific assessment requirements for plans or projects that may affect the integrity of internationally designated sites of nature conservation interest, i.e. Special Protection Areas; Special Areas of Conservation; and sites designated under the Ramsar Convention (Annex C). The SA will be informed by a Habitats Regulations Assessment pursuant to the requirements of the 2017 Regulations. The purpose of this will be to facilitate the development of the Spatial Framework in such a way that, as far as possible, it avoids any effects on the integrity of these internationally designated sites. However, a separate Habitats Regulations Assessment report will be drawn up to demonstrate how the requirements of the Regulations have been met where required. This will be published in parallel to the SA Environmental Report; we hope to publish these in autumn 2022.

Water Environment (Water Framework Directive) Regulations Assessment

6.15      The Water Environment (Water Framework Directive) (England and Wales) Regulations 2017 (as retained and as amended) set out a framework for the protection of surface waters, transitional waters (e.g. estuaries), coastal waters and groundwater (Annex D). The environmental objectives of the Regulations principally relate to the improvement of water bodies through the development and implementation of plans to recover failing water bodies to a good condition, or better. 

6.16      The 2017 Regulations set out requirements to:

  • implement measures to prevent the deterioration of the status of all bodies of surface and groundwater; and
  • protect, enhance, and restore all water bodies, with the aim of achieving good status (or potential) by 2021 or 2027, for water bodies currently failing to achieve this status or potential.

6.17      The requirements of the Regulations together with the opportunities to deliver the improvements set out in the River Basin Management Plans will form the basis of the assessment criteria for the water environment, and therefore will be incorporated into the SA.

Equality Impact Assessment                   

6.18      The Public Sector Equality Duty came in to force in April 2011 under Section 149 of the Equality Act 2010. Those subject to the equality duty must, in the fulfilment of their respective duties, demonstrate due regard to the need to:

  • eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act;
  • advance equality of opportunity between people who share a protected characteristic and those who do not; and
  • foster good relations between people who share a protected characteristic and those who do not.

6.19      The requirements of the Act will form part of the basis for the assessment criteria that addresses the effects on communities. The purpose is to facilitate the development of the Spatial Framework in a way that fosters the values expressed by the legislation, rather than doing a ‘retrospective check’ after the Framework has been developed. 

6.20      Nevertheless, the specific requirement on those subject to the duty to give due regard to any equalities and discrimination impacts will be met as appropriate.

Health Impact Assessment

6.21      Health Impact Assessment (HIA) has been developed as a tool to identify the potential health impacts of a plan or project, the outputs of which facilitate the development of recommendations to maximise positive impacts and minimise negative impacts, while maintaining overall focus on addressing health inequalities.

6.22      The National Planning Policy Framework (NPPF) requires planning policies and decisions to “enable and support healthy lifestyles, especially where this would address identified local health and wellbeing needs”. Therefore, a HIA will be undertaken in accordance with the various HIA guidance outlined within ‘Health Impact Assessment in Spatial Planning’. The purpose of this assessment will be to facilitate the development of the Spatial Framework in such a way that, as far as possible, it avoids negative impacts on health within the Arc.


7.     How we will communicate the results

7.1         Your views on the proposed scope of the assessment, summarised in this report, will be used to influence and shape the detailed assessment criteria that will be applied to the next stage of the Sustainability Appraisal.

7.2         The next step in our approach will be to apply the assessment criteria to the development phase of the Spatial Framework options. This process will be documented in the ‘Issues and Options’ report which we intend to publish for consultation in spring 2022. 

7.3         Comments received on the ‘Issues and Options’ report will be used to identify the preferred options, and these will be taken forward for detailed assessment. The outcome of this process will be presented in the SA Environmental Report, alongside the draft Spatial Framework, which we hope will be published for consultation in autumn 2022.

7.4         The Environmental Report will set out the results of the assessment and will:

  • provide information on the current condition of the environmental, social and economic factors that the Spatial Framework could affect;
  • outline how the plans and programmes we have reviewed could affect the Spatial Framework;
  • provide evidence on how we have integrated the SA with the development of the Spatial Framework and how it has influenced the outcomes;
  • set out the strategic options that we have evaluated, and the reasons for the selection of the proposed approach;
  • set out the environmental, social and economic effects of the draft Spatial Framework;
  • suggest additional mitigation or management actions to further improve the sustainable outcomes; and
  • provide a description of the monitoring proposed to identify any unforeseen adverse effects.


8. Your views

8.1     We would very much welcome your comments and views on the proposed scope of the SA of the Spatial Framework. In order to focus consideration on key elements of the SA, we have provided a number of questions for your consideration below; however, we would also welcome any other information or comments you may be able to provide which will improve the way in which our assessment is undertaken.


1. To what extent do you agree with the key strategic issues and opportunities in the proposed scope for the Sustainability Appraisal of the Spatial Framework?
[Strongly disagree/ Disagree/ Neutral/ Agree/ Strongly agree]

2. Are there any other strategic issues and/or opportunities that need to be considered in the appraisal?

3. Are you aware of any additional strategic data that we should take into account as part of the sustainability appraisal?
4. Are you aware of any additional plans or programmes you think will be important to consider within the sustainability appraisal?
5. To what extent do you agree with our approach to the SA?
[Strongly disagree/ Disagree/ Neutral/ Agree/ Strongly agree]


8.2     We will be consulting on the scope of our assessment, alongside the draft Vision for the Spatial Framework, for a period of 12 weeks commencing 20 July 2021, and ending 12 October 2021.

8.3     You can respond by using our online platform, which we strongly encourage you use. Using the online platform greatly assists our analysis of the responses, enabling more efficient and effective consideration of issues raised. If you are responding in writing, please make it clear which question or questions you are responding to. Written responses should be sent to:

Oxford-Cambridge Arc Unit
Fry Building,
2 Marsham Street,