Sustainability Appraisal of the Luton Local Plan Sustainability Report on the Draft Local Plan Client: Luton Borough Council Report No.: UE-130 Draft Luton LP SA Report_7_140603 Version: 7 Status: Final Date: June 2014 Author: NP/SP Checked: SP Approved: NP Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603 Contents Non-Technical Summary i About Sustainability Appraisal i About Draft Luton Local Plan i Purpose and Context of the Sustainability Report i The Sustainability Appraisal Scoping Stage ii Appraisal of Strategic Alternatives ii Assessment of Alternative Options iii Likely Significant Effects of the Draft Local Plan iii Recommendations iii Monitoring iii Next Steps iv Consultation Arrangements iv 1 Introduction 1 1.1 Purpose of this Report 1 1.2 The Luton Local Plan 1 1.3 The Study Area 2 1.4 The Wider Sub-region 5 1.5 Sustainable Development 6 2 Methodology 9 2.1 Integrated Sustainability Appraisal 9 2.2 Habitats Regulations Assessment 10 2.3 Stages of Sustainability Appraisal 10 2.4 Approach to the Assessment 10 2.5 Limitations to the Sustainability Appraisal 14 3 Scoping 17 3.1 Scoping Report 17 3.2 Scoping Consultation and Review 17 3.3 Policy, Plan and Programme Review 18 Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603 3.4 Gathering Baseline Data 18 3.5 Key Sustainability Issues 19 3.6 The Sustainability Appraisal Framework 19 4 Current and Future Characteristics of the Area and Existing Sustainability Issues 27 4.1 Introduction 27 4.2 Summary of Baseline Conditions and Likely Evolution in Absence of the Plan 27 4.3 Key Sustainability Issues 34 5 Testing Objectives, Identifying Alternatives 37 5.1 Vision and Objectives of the Draft Local Plan 37 5.2 Assessing the Plan’s Objectives against the SA Objectives 39 5.3 Identifying Reasonable Alternatives 39 6 Assessment of Alternative Options 45 6.1 Assessment of Strategic Alternatives 45 6.2 Assessment of Sites for Allocation 58 7 Assessment of Draft Local Plan 61 7.1 High Level Assessment of Policies 61 7.2 Detailed Assessment Matrices 61 7.3 Appraisal Commentary by SA Objective 62 7.4 Cumulative Effects Assessment 74 8 Mitigation and Monitoring 79 8.1 Summary of Mitigation 79 8.2 Requirements for Monitoring 82 8.3 Preliminary Monitoring Proposals 82 9 Summary and Consultation Arrangements 85 9.1 Summary and Next Steps 85 9.2 Consultation Arrangements 86 Appendix A: Annex 1 of the SEA Directive A Appendix B: Site Assessment Criteria C Appendix C: Scoping Consultation Responses E Appendix D: PPP Review F Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603 Appendix E: Baseline Data G Appendix F: Site Assessments and High Level Assessment for Long List H Appendix G: Site Assessments and High Level Assessment for Short List J Appendix H: Justification for Preferred Sites L Appendix I: High Level Assessment of Policies N Appendix J: Detailed Assessment Matrices P Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603 List of Tables and Figures Table 2.1: SA/SEA stages and those addressed in this report 11 Table 2.2: Significance matrix 14 Table 3.1: Summary of Policy, Plan and Programme Review 21 Table 3.2: Sustainability Appraisal Objectives 26 Table 4.1: Key sustainability issues for the Luton Local Plan 34 Table 5.1: Local Plan Objectives 38 Table 5.2: Compatibility assessment between plan objectives and SA Objectives 39 Table 6.1: Appraisal of Strategic Alternatives: Residential target and location of unmet need 47 Table 6.2: Appraisal of Strategic Alternatives: Employment development target 48 Table 6.3: Appraisal of Strategic Alternatives: Release of employment sites 49 Table 6.4: Appraisal of Strategic Alternatives: Converting TC employment sites to residential 50 Table 6.5: Appraisal of Strategic Alternatives: Housing density 51 Table 6.6: Appraisal of Strategic Alternatives: Land south of Stockwood Park 52 Table 6.7: Appraisal of Strategic Alternatives: Butterfield Park 54 Table 6.8: Appraisal of Strategic Alternatives: Century Park 55 Table 6.9: Appraisal of Strategic Alternatives: Napier Park 56 Table 6.10: Appraisal of Strategic Alternatives: Power Court 57 Table 7.1: Scale of Significance: Biodiversity & Landscape - Strategic Allocations 63 Table 7.2: Scale of Significance: Green Infrastructure - Strategic Allocations 64 Table 7.3: Scale of Significance: Air, water, soil - Strategic Allocations 65 Table 7.4: Scale of Significance: Flood risk - Strategic Allocations 66 Table 7.5: Scale of Significance: Carbon emissions - Strategic Allocations 67 Table 7.6: Scale of Significance: Resource efficiency - Strategic Allocations 68 Table 7.7: Scale of Significance: Heritage assets - Strategic Allocations 68 Table 7.8: Scale of Significance: Poverty & social inclusion - Strategic Allocations 69 Table 7.9: Scale of Significance: Crime - Strategic Allocations 70 Table 7.10: Scale of Significance: Health - Strategic Allocations 71 Table 7.11: Scale of Significance: Housing - Strategic Allocations 71 Table 7.12: Scale of Significance: Vitality of centres – Strategic Allocations 72 Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603 Table 7.13: Scale of Significance: Transport & accessibility - Strategic Allocations 73 Table 7.14: Scale of Significance: Employment, learning & skills - Strategic Allocations 74 Table 7.15: Cumulative, synergistic and indirect effects 74 Table 8.1: Summary of proposed mitigation 79 Table 8.2: Proposed monitoring framework 82 Figure 1.1: Luton Local Plan Key Diagram 3 Figure 1.2: Five Guiding Principles of the UK Sustainable Development Strategy, Securing the Future (2005) 7 Abbreviations AGLV Area of Great Landscape Value ALC Agricultural Land Classification ALLI Area of Local Landscape Importance AONB Area of Outstanding Natural Beauty AQMA Air Quality Management Area CEMP Construction Environmental Management Plan CHP Combined Heat and Power CO2 Carbon dioxide CWS Country Wildlife Site DAM Detailed Assessment Matrix Dph Dwellings per hectare DWS District Wildlife Site FZ Flood Zone GI Green Infrastructure Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603 Abbreviations (cont.) HLA High Level Assessment HRA Habitats Regulations Assessment l/p/d Litres per person per day LVIA Landscape and Visual Impact Assessment NPPF National Planning Policy Framework NVQ National Vocations Qualification PDL Previously Developed Land PPP Policy, plan or programme SA Sustainability Appraisal SAM Scheduled Ancient Monument SEA Strategic Environmental Assessment SNCI Site of Nature Conservation Importance SPZ Source Protection Zone SSSI Site of Special Scientific Interest SuDS Sustainable Drainage System TPO Tree Preservation Order Sustainability Report on the Draft Luton Local Plan June 2014 Non-Technical Summary UE-130 Draft Luton LP SA Report_7_140603 Non-Technical Summary About Sustainability Appraisal A Sustainability Appraisal (SA) is being carried out alongside the development of the Draft Luton Local Plan 2011-2031. Local Planning Authorities such as Luton Borough Council use SA to assess plans against a set of sustainability objectives developed in consultation with local stakeholders and communities. This assessment helps the Council to identify the relative environmental, social and economic performance of possible strategic, policy and site options, and to evaluate which of these may be more sustainable. SA is a statutory process incorporating the requirements of the European Union Strategic Environmental Assessment Directive. About Draft Luton Local Plan The Draft Luton Local Plan sets out a proposed set of policies, development allocations and actions to meet the environmental, social and economic challenges facing the borough over the 20 year period from 2011. When adopted it will provide a strategy for the distribution and level of development and supporting infrastructure, a set of proposals to meet that strategy, policies against which to assess planning applications, and proposals for monitoring the success of the plan. Purpose and Context of the Sustainability Report The purpose of this Sustainability Report is to: Identify, describe and evaluate the likely significant effects of the Local Plan and its reasonable alternatives; and Provide an early and effective opportunity for statutory consultees, interested parties and the public to offer views on any aspect of the SA process which has been carried out to date. The Sustainability Report contains: An outline of the contents and main objectives of the Local Plan and its relationship with other plans, programmes and strategies; Relevant aspects of the current state of the environment and key sustainability issues for the borough; The SA Framework against which the Local Plan has been assessed; An appraisal of alternative strategic directions that the Local Plan could reasonably take; i Sustainability Report on the Draft Luton Local Plan June 2014 Non-Technical Summary UE-130 Draft Luton LP SA Report_7_140603 An assessment of alternative options for meeting Local Plan strategy; An explanation of the likely significant effects of the Draft Local Plan in sustainability terms; The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects which may arise as a result of the Local Plan; A description of the measures envisaged concerning monitoring; and The next steps for the SA. The Sustainability Appraisal Scoping Stage An SA Scoping Report was prepared by the Council and submitted to stakeholders for consultation in October 2012. This set out the intended scope and level of detail to be included in the Sustainability Report and included a plan, programme and strategy review, an evidence base for the assessment, key issues and environmental challenges to address, and an SA Framework of appraisal objectives against which the Local Plan could be assessed. Following consultation on the Scoping Report, the information presented in the document was updated to take account of the responses received.