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Sustainability Appraisal of the Local Plan

Sustainability Report on the Draft Local Plan

Client: 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

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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

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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

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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 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: 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

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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

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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;

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 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. This concluded the first stage of the SA process.

Appraisal of Strategic Alternatives

Following the scoping stage, the SA team undertook an assessment of a number of strategic alternatives for the Local Plan. The following bullets summaries those strategic alternatives which were considered to be reasonable, and which were therefore subject to appraisal in the following chapters:

 A range of residential and employment development targets;

 Releasing employment sites for residential or mixed uses;

 Converting town centre employment sites to residential use;

 Housing density: high density throughout, low density throughout, or mix of densities with higher densities focused on centre hierarchy and Luton- busway;

 Land south of Stockwood Park: employment only, or employment with relocated Luton Town FC, or residential only, or mixed uses;

 Butterfield Park: employment only, residential only or mixed use;

 Century Park: employment only, residential only or mixed use;

 Napier Park: retail only, residential only or mixed use; and

 Power Court: retail only, residential only, mixed use or relocated Luton Town FC.

The findings of the assessment of strategic alternatives subsequently informed and influenced the development of early drafts of the Local Plan.

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Assessment of Alternative Options

The next stage was to assess alternative options for delivering the Local Plan’s overall strategy. A long list of 190 sites were considered as possible candidates for future development. This long list of sites was subject to two kinds of assessment.

Firstly each site was assessed against a range of site-specific criteria. The criteria aimed to examine the suitability of each site according to its relative accessibility, previous uses, and proximity to sources of, or sensitive receptors to pollution. A range of designated features were also addressed, including nearby heritage assets, important landscapes, nature conservation sites and areas of flood risk. Secondly, a high level assessment was made of each site’s relative sustainability performance against the SA Objectives. High level assessments were also carried out for the emerging Strategic Allocations and policies for the Local Plan.

Likely Significant Effects of the Draft Local Plan

The Council used the initial site assessments to select a shortlist of 31 sites which are proposed to be allocated for future development. The shortlist of sites were then taken forward for more detailed assessment, together with the Strategic Allocations and remaining policies for the Local Plan.

A summary of the potential effects of the Draft Local Plan, presented by SA Objective, is given at Chapter 7 of the main report. Overall, significant long-term positive sustainability effects are predicted to result from the Local Plan, particularly in relation to poverty and social inclusion, green infrastructure, healthy lifestyles, provision of housing, the vitality of centres, and employment learning and skills. Nonetheless, significant negative effects are also predicted, especially in relation to biodiversity, air, soil and water resources, and heritage assets, although many of these impacts are capable of being mitigated.

Recommendations

Whilst the Draft Local Plan as it stands brings a range of positive sustainability effects, a number of recommendations were proposed to help maximise the sustainability performance of the plan. These are summarised at section 8.1 of the main report.

Monitoring

The Sustainability Report provides preliminary monitoring proposals to measure the Local Plan’s implementation in relation to aspects of the environmental, social and economic baseline which are assessed as likely to be significantly affected, or where opportunities for an improvement in sustainability performance may arise. Monitoring for the SA will be aligned with or incorporated within monitoring that is scheduled for the plan itself, both to avoid duplication and ensure that appropriate remedial action can be taken.

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Next Steps

Following publication of the Draft Local Plan, and its Sustainability Report and evidence base, representations will be analysed by the Council and the SA team. Modifications to both the Local Plan and its Sustainability Appraisal may be made in response to consultation, and any significant changes to the plan will be subject to further appraisal.

Further public consultation is scheduled for the Publication Local Plan and its Sustainability Report prior to an Examination in Public.

Following Examination, a Post Adoption Statement will be published with the adopted version of the Local Plan. The purpose of the Post Adoption Statement is to outline how the SA process has informed and influenced the Local Plan development process and demonstrate how consultation on the SA was taken into account.

Consultation Arrangements

The Draft Local Plan and its Sustainability Report will be made available and can be viewed at:

http://www.luton.gov.uk/Environment/Planning/Regional%20and%20local%20plannin g/Pages/Planning-policy-evidence.aspx

Alternatively hard copies can be viewed at:

Luton Borough Council, Town Hall, George Street, Luton, LU1 2BQ

Responses to this consultation exercise should be sent to:

Local Plans Team, Luton Borough Council, Town Hall George Street, Luton, BedfordshireLU1 2BQ [email protected]

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1 Introduction

1.1 Purpose of this Report

1.1.1 This Sustainability Report has been prepared for Luton Borough Council as part of the combined Sustainability Appraisal (SA) and Strategic Environmental Assessment (SEA) process for the Luton Local Plan 2011-2031.

1.1.2 The Sustainability Report has been produced in compliance with the Town and Country Planning (Local Planning) () Regulations 2012 and Environmental Assessment of Plans and Programmes Regulations 2004. It incorporates the Environmental Report which is required in accordance with EU Directive 2001/42/EC on Environmental Assessment of Plans and Programmes (the SEA Directive).

1.1.3 The report presents an appraisal of the Draft Luton Local Plan which has been prepared for further public consultation subsequent to Regulation 18 of the 2012 Regulations, and forms part of the evidence base upon which the Draft Local Plan is based. A further Sustainability Report will subsequently be prepared to accompany the Publication version of the Local Plan.

1.2 The Luton Local Plan

1.2.1 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 area over the 20 year plan 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.

1.2.2 The Draft Local Plan proposes a spatial development strategy which focuses the majority of new development in the Borough over the plan period on eight Strategic Allocations, whilst protecting the remaining Green Belt from development and regenerating Luton Town Centre. Key elements of the plan, as illustrated on Figure 1.1, include:

 Provision for approximately 5,700 new dwellings;

 Sufficient employment land to provide for 18,000 new jobs;

 Approximately 5,204m2 of convenience retail and 12,201m2 of comparison retail floorspace by 2017, with potentially up to 55,966m2 of new retail floorspace across the whole plan period, based on projected population growth;

 Strategic Allocations at: Land south of Stockwood Park; ; Butterfield Technology Park; Napier Park; High Town; Power Court and the Creative Quarter (indicated by the same label on Figure 1.1); and ;

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 Infrastructure, services and community facilities to serve a new hierarchy of Town, District and Neighbourhood Centres.

1.2.3 Box 1 sets out the key facts relating to the Luton Local Plan.

Box 1: Key facts about the Luton Local Plan Name of Responsible Authority: Luton Borough Council.

Title of plan: Luton Local Plan 2011-2031. What prompted the plan The Council has a statutory duty to prepare a Development Plan (e.g. legislative, regulatory under the Planning and Compulsory Purchase Act 2004, and Town or administrative provision): and Country Planning (Local Planning) (England) Regulations 2012. The Local Plan will be the central document in the Borough’s Development Plan.

Subject (e.g. transport): Spatial plan. Period covered: 2011 to 2031.

Frequency of updates: When required.

Area covered: The Borough of Luton. Purpose and scope of the The Local Plan will govern the way in which development plan: throughout the Borough is delivered during the plan period. It will replace the Luton Local Plan 2001-2011 as well as the general and environmental policies of the Bedfordshire and Luton Minerals & Waste Local Plan (2005). Once adopted, it will sit alongside the Minerals and Waste Local Plan: Strategic Sites and Policies (2014), Neighbourhood Plans and any Supplementary Planning Document or Area Action Plan. Contact point: Local Plan Team, Luton Borough Council, Town Hall, George Street, Luton LU1 2BQ. Tel: 01582 547 087; Email: [email protected]

1.3 The Study Area

1.3.1 Luton is a densely populated town with a rich cultural diversity. Surrounded by Green Belt and situated within the Chilterns Area of Outstanding Natural Beauty, the town benefits from easy access to high quality landscapes, wildlife areas, parks and other sub-regional leisure attractions, such as , , and Woburn Abbey. At the same time the town benefits from good strategic north-south access to the midlands and to Greater London via the M1 and Midland Mainline Railway. It is also served by London Luton Airport which is growing and plays an important role in the economy of the town.

1.3.2 Luton has seen significant investment in civic spaces and transport infrastructure around the town centre and key regeneration sites, which is improving the look, feel and safety of town and the way people use its shops and services. Luton is accessible to skilled workers within the wider sub-region as well as to national and regional markets. Of particular note is a growing aviation-related and skilled engineering sector, an expanding service sector base and developing sub-regional business and office market.

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Figure 1.1: Luton Local Plan Key Diagram

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1.3.3 The town also has an industrial legacy; some older manufacturing areas are in need of economic and environmental regeneration in order to restore investment confidence. There is a need to improve local skill levels and job opportunities to enable people to access housing and services while making more sustainable choices about travel, energy use, leisure, food and health. There is insufficient accessible green space within the urban area to serve some communities, while there is an increasing demand to develop it. However, its green space is typically characterised by important nature conservation or heritage status.

1.3.4 As a densely populated and multi-cultural town, Luton has historically provided access to relatively inexpensive housing and rented accommodation compared to surrounding areas. However, in recent years there has been significant demand to accommodate a growing population both from existing households and from people moving into the area, often with lower skills and wages.

1.3.5 Without having greenfield land on which to build sufficient new housing to meet demand, there is not only a significant level of unmet housing need but an increasing affordability gap, as wages fall behind rising market rents and house prices. Development market values within the town are also significantly low compared to neighbouring towns. Consequently, the viability of mixed use development and recycling costly brownfield sites tends to be uneconomic or so marginal that the market has been unable to deliver affordable housing in recent years.

1.3.6 Luton therefore has much potential for sustainable economic growth which provides quality job opportunities to its neighbours and its residents. However, the realisation of this is limited by a range of critical constraints, the most restricting of which is the lack of capacity to house a growing population, exacerbated by the following exceptional issues:

 Luton is for the most part built up to its boundaries and is surrounded by Green Belt;

 Urban capacity and housing studies demonstrate that the town does not have sufficient land within its own boundaries to meet all of its combined housing needs as well as its full economic potential or environmental needs;

 Housing viability studies demonstrate that delivering social and affordable housing is challenging in Luton due to viability issues associated with the abnormal costs of recycling brownfield employment land in a context of unusually low market values;

 Pressures are increasing to develop a diminishing stock of green spaces, risking health and wellbeing;

 There is a substantial level of unmet housing need that needs to be addressed with neighbouring authorities under the duty to cooperate;

 The town is attractive to business and investment as evidenced in the Employment Land Review study;

 Local industrial firms struggle to find modern, affordable accommodation and must rely on existing industrial sites with lower rents (often of lower quality or ageing), until the new employment land stock is built out;

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 Luton town centre is performing well for shopping, access and improving public realm, however, the town centre must expand and improve its retail offer to remain robust to sub-regional competition and national retailing trends; and

 The town lacks east-west orbital connectivity and so suffers from peak congestion where local traffic and through-traffic conflict at key junctions and around the town centre.

1.3.7 The analysis of this Sustainability Appraisal must be viewed in the context that Luton is constrained by the Green Belt. While there may be negative assessments from potential development at specific sites, these should be seen in the wider sustainability context. Recognition needs to be given to the value of Luton's sub-regional employment role and the need for urban regeneration through the use of existing infrastructure, minimising travel and making effective use of previously developed land.

1.4 The Wider Sub-region

1.4.1 Luton has an important role in the wider sub-region as a centre for employment and shopping as well as housing, community services and transportation infrastructure. The level of housing need within the Luton Housing Market Area (which includes all of Luton Borough and parts of , North Hertfordshire, Dacorum Borough and Aylesbury Vale District) is partly a reflection of this success. However, given the constraints on land supply outlined in the previous section, it will be necessary for part of this objectively assessed housing need to be met in other local authority areas through the Duty to Cooperate. Luton Borough Council has chaired a Luton and Central Bedfordshire Strategic Housing Market Assessment (SHMA) Steering Group of nine local authorities to prepare a joint SHMA. This has identified an objectively assessed need for 30,000 homes within the Luton Housing Market Area, of which 17,800 are generated by population increases within the borough of Luton.

1.4.2 The location, form and scale of development in other local authority areas will need to be determined and tested through the respective authorities’ Local Plans and their associated Sustainability Appraisals. However, decisions on how this housing need is met could nonetheless have implications within Luton. For example, developments such as the proposals (Central Bedfordshire) and East of Luton (North Hertfordshire) would increase demand for community facilities and transport infrastructure within Luton if they were to go ahead.

1.4.3 The Development Strategy for Central Bedfordshire was published for six weeks on 14 January 2013. Submission to Secretary of State was expected in June 2013, however, additional time was taken to consider the representations made and the implications of new population and household projections from the Office for National Statistics. Pre-submission consultation is scheduled for June 2014 with submission expected in October 2014. Additional housing options for consideration within the draft North Hertfordshire Local Plan were consulted on during 2013 and a new time table is being drafted that will allow consideration of cross- boundary issues. Dacorum Borough Council’s Core Strategy was adopted in September 2013 and will be subject to a partial review that will lead to a new local plan for adoption by 2017/18. Aylesbury Vale District Council’s Local Plan was submitted to the Secretary of State for

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Examination in 2013. Following public hearings in December 2013, the plan was withdrawn. A new plan-making timetable indicates publication of a draft plan in 2016, with adoption in 2017.

1.4.4 Future iterations of this Sustainability Appraisal may need to consider the probable location of unmet need once draft plans have been drawn up in more detail by neighbouring authorities, to enable an interpretation of potential effects on sustainability and Luton’s infrastructure and services.

1.5 Sustainable Development

1.5.1 The UK’s sustainable development agenda is shaped by the Sustainable Development Strategy, Securing the Future (2005) and in planning terms by the National Planning Policy Framework (NPPF), which replaced previous national planning policy (Planning Policy Statements and Planning Policy Guidance notes) in March 2012. The NPPF includes a presumption in favour of sustainable development, which it goes on to interpret in a planning context with reference to the Sustainable Development Strategy.

The UK Sustainable Development Strategy

1.5.2 Securing the Future (2005) suggests that for a policy to be sustainable, it must respect all five of the principles set out in Figure 1.2. The strategy also recognises that some policies, while underpinned by all five principles, will place more emphasis on certain principles than others. The strategy states that “we want to achieve our goals of living within environmental limits and a just society, and we will do it by means of a sustainable economy, good governance, and sound science” (Securing the Future, 2005).

1.5.3 The strategy states that the five guiding principles are promoted through four shared priorities:

“Sustainable Consumption and Production – Sustainable consumption and production is about achieving more with less. This means not only looking at how goods and services are produced, but also the impacts of products and materials across their whole lifecycle and building on people’s awareness of social and environmental concerns. This includes reducing the inefficient use of resources which are a drag on the economy, so helping boost business competitiveness and to break the link between economic growth and environmental degradation.

“Climate Change and Energy – The effects of a changing climate can already be seen. Temperatures and sea levels are rising, ice and snow cover are declining, and the consequences could be catastrophic for the natural world and society. Scientific evidence points to the release of greenhouse gases, such as carbon dioxide and methane, into the atmosphere by human activity as the primary cause of climatic change. We will seek to secure a profound change in the way we generate and use energy, and in other activities that release these gases. At the same time we must prepare for the climate change that cannot now be avoided. We must set a good example and will encourage others to follow it.

“Natural Resource Protection and Environmental Enhancement – Natural resources are vital to our existence and that of communities throughout the world. We need a better understanding

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of environmental limits, environmental enhancement and recovery where the environment is most degraded to ensure a decent environment for everyone, and a more integrated policy framework.

“Sustainable Communities – Our aim is to create sustainable communities that embody the principles of sustainable development at the local level. This will involve working to give communities more power in the decisions that affect them and working in partnership at the right level to get things done. The UK uses the same principles of engagement, partnership, and programmes of aid in order to tackle poverty and environmental degradation and to ensure good governance in overseas communities. These priorities for action within the UK will also help to shape the way the UK works internationally, in ensuring that our objectives and activities are aligned with international goals.”

1.5.4 The Sustainability Appraisal for the Luton Local Plan will incorporate these key principles at the heart of the assessment process.

Figure 1.2: Five Guiding Principles of the UK Sustainable Development Strategy, Securing the Future (2005)

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2 Methodology

2.1 Integrated Sustainability Appraisal

2.1.1 The Luton Local Plan is subject to the following assessments:

 Sustainability Appraisal; and

 Strategic Environmental Assessment.

2.1.2 Strategic Environmental Assessment is a systematic process for evaluating the environmental consequences of proposed plans or programmes to ensure environmental issues are fully integrated and addressed at the earliest appropriate stage of decision making. Sustainability Appraisals are broader and promote sustainable development through integration of environmental, social and economic considerations into the plan's preparation.

2.1.3 Strategic Environmental Assessment was introduced to the UK through EU Directive 2001/42/EC. In England the Directive was transposed via the Environmental Assessment of Plans and Programmes Regulations 2004. Sustainability Appraisal is a requirement of the Planning and Compulsory Purchase Act 2004 and applies to Local Development Documents. Integrated SA combines these processes to allow for a single appraisal to be carried out by integrating the requirements of SEA 1 into the SA 2 process. SA should therefore fulfil the requirements for producing an Environmental Report under the Annex 1 of the SEA Directive (see Appendix A which also includes a compliance checklist).

2.1.4 In the interests of efficiency, following guidelines and the desire to avoid duplication, the two assessment types, SA and SEA, are integrated under the umbrella of SA and are being undertaken simultaneously for the Local Plan. The combined approach is based upon the following principles:

 SA Objectives are used for appraising potential impacts of plan policies and proposals on various environmental, social and economic components;

 Baseline and spatial information including environmental, social and economic factors is collected and collated. Predicted effects of plan policies and proposals are evaluated against the baseline and likely evolution thereof in the absence of the plan;

 Alternative options and preferred options for the plan are appraised using an SA Framework , combined with careful consideration of baseline conditions; and

1 Office of the Deputy Prime Minister (September 2005): A Practical Guide to the SEA Directive. The SEA guidance can be found at : https://www.gov.uk/government/publications/strategic-environmental-assessment-directive-guidance

2 Department for Communities and Local Government (August 2013): Draft National Planning Practice Guidance. The SA guidance can be found at: http://planningguidance.planningportal.gov.uk/blog/guidance/strategic-environmental-assessment-and- sustainability-appraisal/what-is-a-sustainability-appraisal-and-how-does-it-relate-to-strategic-environmental-assessment/

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 Indicators and decision-making criteria are devised for all SA Objectives to assist in monitoring delivery of the plan and any significant effects thereof.

2.2 Habitats Regulations Assessment

2.2.1 The application of Habitats Regulations Assessment (HRA) to land use plans is a requirement of the Conservation of Habitats and Species Regulations 2010 (as amended), the UK’s transposition of European Union Directive 92/43/EEC (the Habitats Directive). HRA must be applied to all Local Development Documents in England and Wales which could significantly affect any sites designated for their nature conservation importance as part of a system known collectively as the Natura 2000 network of European sites.

2.2.2 The nearest relevant location of concern is the Chiltern Beechwoods Special Area of Conservation. The beech woods are spread across multiple locations, lying to the west of the A5 around the Gaddesden area, which is approximately 7miles to the south-west of Luton. New planning policies for Luton are unlikely to have a significant effect on the beech woods; therefore further consideration of HRA is not required.

2.3 Stages of Sustainability Appraisal

2.3.1 Table 2.1 provides a summary of the procedural steps for the appraisal, based on both the draft National Planning Practice Guidance and A Practical Guide to the SEA Directive (ODPM, 2005). The steps shaded in green are the stages addressed in this report. The second column indicates where information about each respective stage can be found in this document.

2.3.2 This Sustainability Report has been prepared to accompany the Draft Local Plan. It presents information on the SA process carried out to date and incorporates an appraisal of the Draft Local Plan. Further assessment will take place following the ongoing refinement of the plan and an additional Sustainability Report will be produced at Publication stage. Chapter 9 discusses the next steps for the SA process subsequent to consultation on the current Sustainability Report.

2.4 Approach to the Assessment

2.4.1 The proposed policies and site allocations presented in the Draft Local Plan are assessed against the baseline and SA Framework using a four-stage process.

Site assessment criteria

2.4.2 At the scoping stage the Council outlined a methodology for assessing each potential site allocation against a range of criteria to ensure consistency in approach and robustness in site selection. The criteria aimed to examine the suitability of each site according to its relative accessibility, previous uses, and proximity to sources of, or sensitive receptors to pollution. A range of designated features were also addressed, including nearby heritage assets, important landscapes, nature conservation sites and areas of flood risk.

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Table 2.1: SA/SEA stages and those addressed in this report

Stage A: Setting the context & objectives, establishing the baseline Location in this report and deciding on the scope

1. Identify other relevant policies, plans and programmes, and Section 3.3 sustainability objectives

2. Collect baseline information Sections 3.4 and 4.2

3. Identify sustainability issues and challenges Sections 3.5 and 4.3

4. Develop the Sustainability Appraisal Framework Section 3.6

5. Consult on the scope of the Sustainability Report Section 3.2

Stage B: Developing and refining alternatives and assessing effects

1. Test the Local Plan objectives against the SA Framework Section 5.2

2. Develop the Local Plan options including reasonable alternatives Section 5.3

3. Evaluate the likely effects of the Local Plan and alternatives Sections 6 and 7

4. Consider ways of mitigating adverse, and maximising beneficial effects Section 8.1

5. Propose measures to monitor the significant effects of implementing Section 8.3 the Local Plan

Stage C: Prepare the Sustainability Report

Including the requirements of an SEA Environmental Report Entire document

Stage D: Publish & consult on the Sustainability Report & Local Plan

1. Consult the consultation bodies and public on the draft Local Plan and Section 9.2 Sustainability Report

2. Appraise significant changes resulting from representations, and amend n/a the Local Plan

Stage E: Post adoption reporting and monitoring

1. Prepare and publish the SA Post Adoption Statement n/a

2. Monitor SA indicators during Local Plan implementation n/a

2.4.3 Following discussion with the Council it was decided that, given the very high number of sites to be tested (190), the criteria assessments should be automated within a Geographic Information System (ArcGIS 9.3). The full range of tests, relevant data sources and distance thresholds for each criterion are given at Appendix B. Each site was given a Red-Amber-Green category scoring according to its distance threshold performance under each criterion. So for example, sites within 200m of a bus stop were categorised as Green because they have good accessibility to the bus network, whereas sites between 200m and 400m from a bus stop were categorised as Amber and sites more than 400m from a bus stop were categorised as Red for poor accessibility to the bus network. Conversely, sites within the AONB were categorised as Red because they could potentially lead to adverse landscape effects, whereas sites between 10m and 500m of the AONB were categorised as Amber and sites more than 500m away were categorised as Green because they are less likely to affect the AONB.

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High level assessment

2.4.4 Drawing on the results of the site assessments, the high level assessment uses the SA Framework, review of plans, programmes and policies and baseline data to assess each policy and site proposal in broad terms. Findings are presented in matrix format. The main function of the high level assessment is to identify whether or not the policy options and the long list of sites are likely to bring positive, negative or uncertain effects in relation to the SA Objectives.

2.4.5 A benefit of this approach is that a range of policy options may be assessed, which can then be scrutinised in further detail if a significant number of uncertainties or potential negative effects arise. Proposals are given a score against each SA Objective ranging from Strong Positive, Positive or Neutral, to Negative, Strong Negative or Mixed/Uncertain. This helps identify at a strategic level whether or not the assessment requires a more detailed examination or whether satisfactory conclusions may be drawn from the high-level assessment, without the need for further detailed analysis of a particular policy option or site.

Detailed assessment

2.4.6 Where potential negative effects or uncertainties are identified through the high level assessment in association with a particular policy, option or site, a secondary level of assessment has taken place to examine the proposal in more detail. This process uses Detailed Assessment Matrices to scrutinise potential negative or uncertain effects which have been identified by the high level assessment.

2.4.7 Detailed Assessment Matrices address the range of criteria identified in Annex II of the SEA Directive when determining the likely (positive or negative) significance of effects (Box 2 below), providing a greater level of detail than the high level assessment stage. Detailed Assessment Matrices thus include information relating to:

 A description of the predicted effect;

 The duration of the effect: whether the effect is long, medium or short term;

 The frequency of the effect: whether it will be intermittent or ongoing;

 Whether the effect is temporary or permanent;

 The geographic importance of the receptor: local, sub/regional, national or international;

 The magnitude of effect;

 The scale of significance;

 Whether mitigation is required/possible to reduce the effect; and

 Suggestions for mitigating the effect, or potential improvements to the proposals.

2.4.8 The Detailed Assessment Matrices also include potential mitigation measures to limit potential adverse effects where they arise. At a strategic level it is often difficult to assess significant effects in the absence of widespread data. Instead, orders of magnitude are used, based on the geographic importance of the receptor and impact magnitude. Table 2.2 illustrates this order of magnitude for positive and negative effects.

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Cumulative effects assessment

2.4.9 As required by the SEA Regulations, cumulative, synergistic and indirect effects are identified and evaluated during the assessment. An explanation of these is as follows:

 Indirect effects are effects that are not a direct result of the plan, but occur away from the original effect or as a result of a complex pathway;

 Cumulative effects arise where several developments each have insignificant effects but together have a significant effect, or where several individual effects of the plan have a combined effect;

 Synergistic effects interact to produce a total effect greater than the sum of the individual effects.

Box 2: Criteria for the assessment of significant effects Criteria for determining the likely significance of effects referred to in Article 3(5) of the SEA Directive The characteristics of plans and programmes, having regard, in particular, to a. the degree to which the plan or programme sets a framework for projects and other activities, either with regard to the location, nature, size and operating conditions or by allocating resources; b. the degree to which the plan or programme influences other plans and programmes including those in a hierarchy; c. the relevance of the plan or programme for the integration of environmental considerations in particular with a view to promoting sustainable development; d. environmental problems relevant to the plan or programme; e. the relevance of the plan or programme for the implementation of Community legislation on the environment (e.g. plans and programmes linked to waste management or water protection).

Characteristics of the effects and of the area likely to be affected, having regard, in particular, to a. the probability, duration, frequency and reversibility of the effects; b. the cumulative nature of the effects; c. the transboundary nature of the effects; d. the risks to human health or the environment (e.g. due to accidents); e. the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected); f. the value and vulnerability of the area likely to be affected due to: special natural characteristics or cultural heritage; exceeded environmental quality standards or limit values; intensive land-use; the effects on areas or landscapes which have a recognised national, Community or international protection status.

2.4.10 To enable a complete assessment of the sustainability effects resulting from the Draft Local Plan, the full range of cumulative, incorporating secondary, indirect and synergistic effects were evaluated. Whilst some of these effects are recorded with the appraisal findings for each of the policy and site options, a number of these effects can only be established by examining the Draft Local Plan together as a whole. These interactions are examined in section 7.4 of this report.

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Table 2.2: Significance matrix

Impact Magnitude Negative Positive High Medium Low Negligible Negligible Low Medium High

International Severe Severe Major Moderate Moderate Major Optimal Optimal

National Severe Major Moderate Minor Minor Moderate Major Optimal Neutral

Sub/Regional Major Moderate Minor Negligible Negligible Minor Moderate Major

Importance Geographic Local Moderate Minor Negligible Negligible Negligible Negligible Minor Moderate

2.5 Limitations to the Sustainability Appraisal

2.5.1 It is acknowledged that there are a number of limitations and difficulties surrounding the Sustainability Appraisal process which stem largely from the nature of strategic assessment at the plan level, using secondary data. In most cases assessment has been undertaken without data on environmental limits for example. In some cases data has not been available at all so assessment has in these circumstances erred on the side of caution.

2.5.2 The Detailed Assessment Matrices include a column stating confidence of assessment according to a high, medium or low scoring. Many of the Detailed Assessment Matrices include ratings of medium or low confidence. This reflects a lack of data, information associated with environmental limits or that the assessment conclusions are informed appraisals rather than affirmative decisions. To address these issues, monitoring proposals should seek address data gaps as well as monitor the effects of the plan.

Limitations at the scoping stage

2.5.3 The main problems faced during scoping were concerned with the identification of relevant baseline information. For example, the old processes of local area agreements and comprehensive area assessments were valuable for identifying issues, though monitoring of many of those issues had stopped a few years ago and there was no recent data available. Many other historic data sets were no longer available or kept up-to-date, reflecting the current Government's approach to reducing administrative burdens and allowing greater local control (and therefore variance) over what is monitored and how.

2.5.4 Where historic data sets were no-longer supported, alternative data sources were identified. Some of the baseline data is only available for Luton and no comparison with national or other benchmarks was possible.

Implementation of the Local Plan

2.5.5 The sustainability effects of the Local Plan will largely be dependent on how the plan is implemented. The plan provides a broad picture of the location and type of new development, while setting standards for factors such as design and infrastructure provision. How the developments perform in sustainability terms is very much dependent on what happens at the

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micro-scale. For example if new development does not comply with the aspirations presented in the plan (for example related to energy efficiency or renewable energy) then the positive effects highlighted under the policies addressing these topics will be reduced. In another example, the effect on resource use of new development proposed through the plan will depend on the exact nature of how new houses, offices, shops and community facilities are designed and built, the layout of development, and the actions of the people who will live and work there.

2.5.6 It is therefore noted that the sustainability performance of the Luton Local Plan will be dependent on the implementation of the policies and strategic allocations in particular.

Mitigation measures

2.5.7 The Detailed Assessment Matrices set out a number of mitigation measures for reducing the potential negative effects of the Local Plan. However, these are necessarily broad-brush in approach because the design of mitigation measures to offset the negative effects of the plan will sometimes only realistically be achievable at the project level. The extent to which proposed mitigation measures will offset adverse effects is therefore open to interpretation.

2.5.8 Consequently, the SA process has not attempted to “upgrade” the assessment results to more positive findings through a presumption that the proposed mitigation measures will be delivered and meet their full potential to offset potential negative effects. Clearly where uncertainty of mitigation prevails, monitoring of the residual effect is crucial.

Tension between environmental, social and economic factors

2.5.9 Sustainability Appraisal considers social and economic as well as environmental effects. An often stated weakness of the SA process is that environmental considerations are under- represented, and social and economic gains are over-emphasised. This may be for a number of reasons, including as a result of the social and economic focus of the plan, the overriding need for regeneration, or the range and structure of the SA Framework.

2.5.10 Environmental sustainability considerations have been fully considered through the SA process for the Local Plan by utilising a set of SA Objectives which fully represent environmental sustainability considerations. The summary of appraisal findings presented in Chapter 7 has purposefully separated the environmental sustainability objectives from the socio-economic objectives, and no attempt has been made to justify negative environmental effects on the basis of beneficial socio-economic effects. While the approach of separating out environmental effects is for transparency, the Council intends to take a balanced judgment as a whole, taking into account where net benefits outweigh the costs in formulating the plan's strategy.

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3 Scoping

3.1 Scoping Report

3.1.1 The first phase of the SA was the scoping stage. Scoping is the process of deciding the scope and level of detail of an SA, including the sustainability effects to be considered, the assessment methods to be used, and the structure and contents of the SA Report. The purpose of the Scoping Report is to set the criteria for assessment (including the SA objectives), and establish the baseline data and other information, including a review of relevant policies, programmes and plans. The scoping stage was undertaken internally by the Council.

3.1.2 The Scoping Report3 presents information in relation to the following tasks:

 Identifying other relevant policies, plans and programmes, and sustainability objectives;

 Collecting baseline information;

 Identifying sustainability opportunities and challenges; and

 Developing the SA Framework.

3.2 Scoping Consultation and Review

3.2.1 The Scoping Report was published for consultation with the three Consultation Authorities (English Heritage, Environment Agency and Natural England) in October 2012 for a period of five weeks. A range of other parties were also invited to comment.

3.2.2 Responses were received from English Heritage, Natural England, the Planning Advisory Service and internal colleagues at Luton Borough Council. Appendix C contains an analysis of scoping consultation responses including a description of how the comments have been taken into account. Following receipt of responses, the SA information, including the baseline and policy and plan review, was updated. The updated SA information is included in this SA Report.

3.2.3 Following completion of the scoping stage the Council decided to seek external consultancy assistance with undertaking the remainder of the SA process for the Local Plan. The first task in this commission was to carry out a technical review of scoping stage to ensure that legislative and good practice requirements were adequately addressed, and that the information collated was suitable for use in the later stages of assessment. Minor clarifications to the SA Objectives and process for completing site assessments were made as a result of the review, but generally speaking the scoping stage was found to have met legislative and good practice requirements.

3 The Scoping Report can be found at: http://www.luton.gov.uk/Environment/Planning/Regional%20and%20local%20planning/Pages/Planning-policy-evidence.aspx

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3.3 Policy, Plan and Programme Review

3.3.1 The Local Plan may be influenced in various ways by other policies, plans or programmes (PPPs), or by external sustainability objectives such as those put forward in other strategies or initiatives. The SA process aims to take advantage of potential synergies between these PPPs and address any inconsistencies and constraints.

3.3.2 The Scoping Report presented an evaluation of the key PPPs that are likely to be relevant to the SA process and development within Luton. The review was updated in response to comments at the scoping consultation stage and is re-published at Appendix D.

3.3.3 Each PPP is summarised with a review of the general issues it raises, together with any specific issues that could affect or be addressed by the Local Plan. A summary of the PPP review is presented in Table 3.1, which should be read in conjunction with the more detailed information included Appendix D.

3.4 Gathering Baseline Data

3.4.1 A key part of the scoping process is the collection of baseline data. The purpose of the exercise is to help identify key opportunities and challenges facing the area which might be addressed by the Local Plan, and to provide an evidence base from which to make the assessment.

3.4.2 The baseline section in the Scoping Report provided a review of social, economic and environmental conditions within the borough. One of the purposes of consultation on the Scoping Report was to seek views on whether the data selected was appropriate. Comments were received from a range of stakeholders and in some cases new sources of baseline information were provided or suggested.

3.4.3 Following the scoping stage a series of spatial environmental constraints datasets were collated within a Geographic Information System. Providing a spatial dimension to the baseline data, the GIS data is a valuable tool for examining the likely effects of the Plan on specific assets in the borough (such as for example, biodiversity assets or historic environment features). The datasets are also an effective means of understanding the key issues faced by specific areas in the borough (for example through providing a spatial perspective to local levels of deprivation or health).

3.4.4 The GIS datasets, which include the following data sources, formed the basis for site assessments as described at paragraph 2.4.2:

 Air Quality Management Areas;

 Agricultural Land Classifications and Green Belt;

 Areas of Outstanding Natural Beauty, Areas of Great Landscape Value, and Areas of Local Landscape Importance;

 Flood Risk Zones and Source Protection Zones;

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 Green spaces (allotments, amenity, churchyards and cemeteries, green corridors, semi- natural greenspace, sports pitches, and urban parks and gardens);

 Heritage assets: Scheduled Ancient Monuments, listed buildings, conservation areas, areas of archaeological interest;

 Indices of Multiple Deprivation;

 Nature conservation assets: Sites of Special Scientific Interest, Local Nature Reserves, County Wildlife Sites, District Wildlife Sites, Other Sites of Nature Conservation Importance;

 Schools (nursery, infant, primary, secondary) and playgrounds;

 Sustainable transport networks: train stations, bus stops, the Luton-Dunstable Busway and cycle routes;

 Proposed allocations, centre boundaries, policy boundaries, and sites considered through the Strategic Housing Land Availability Assessment and Employment Land Review; and

 Contextual policy data from the Luton Local Plan 2001-2011.

3.4.5 Chapter 4 presents a summary of baseline conditions affecting the plan area and the likely evolution of the baseline in the absence of the plan.

3.5 Key Sustainability Issues

3.5.1 The policy and plan review and the baseline data revealed a number of key social, environmental and economic issues for the plan area. These issues present the Local Plan with a wide number of opportunities and challenges for achieving sustainability gain within the area. Chapter 4 summarises the key sustainability issues for the area.

3.6 The Sustainability Appraisal Framework

3.6.1 The purpose of the SA Framework is to provide a means of ensuring that the Local Plan considers the sustainability needs of the area in terms of its social, environmental and economic effects. It enables the sustainability effects of the plan to be described, analysed and compared.

3.6.2 The SA Framework consists of sustainability objectives which, where practicable, can be expressed in the form of targets, the achievement of which is measurable using indicators. There is no statutory basis for setting objectives but they are a recognised way of considering the sustainability effects of a plan and comparing alternatives, and as such provide the basis from which effects of the plan can be tested consistently.

3.6.3 The SA Objectives were derived through consideration of the PPP review, the baseline data collection, the key sustainability issues identified for the plan area and the Luton Sustainable Community Strategy. Alongside these, the SEA environmental receptors identified in Annex I (f) of the SEA Directive (Appendix A) were a key determinant when considering which SA

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Objectives should be used for appraisal purposes. The final seven objectives in particular address the social and economic requirements of Sustainability Appraisal, while also retaining a high degree of relevance to SEA. The SA Objectives seek to reflect each of these influences to ensure the assessment process is robust, balanced and comprehensive.

3.6.4 Following the receipt of responses on the Scoping Report, the SA Framework was updated to address the comments received. The SA Objectives included within the SA Framework, and the SEA receptors to which they relate are set out in Table 3.2.

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Table 3.1: Summary of Policy, Plan and Programme Review

Summary of Policy, Plan and Programme Review

Economy

The M1 is expected to be busy along the majority of its route by 2021 and subsequently 2031. This represents a worsening of the 2001 conditions. The motorway and railway sever the town, with limited 'bridging points'. Luton experiences traffic congestion, particularly on main routes between and within urban centres and there is a need to improve connections between local and national networks, especially east-west transport links. Congestion in Luton is estimated to have an economic cost of £51.4m every year and is likely to increase. Enhanced road infrastructure will increase the attractiveness of the car, increase car usage and reduce modal shift. Increased population will increase vehicle kilometres travelled and time spent travelling. Rail-served aggregates depots at Road and Crescent Road are required to avoid the use of the road network to import roadstone from external quarries. The airport is a key employer and driver of local and national economies. Its expansion is central to job growth in Luton and surrounding authorities. Development of the airport can also increase the town’s role in inter-European connectivity. Increasing airport capacity could, however, lead to additional traffic congestion. Hemel Hempstead and Milton Keynes provide competition in terms of industrial sites. Along with St. Albans, they also compete with Luton in terms of office development. Much of the industrial space in Luton is dated and often has associated amenity issues. Luton’s sub-regional employment land offer can support a move to a higher-value, stronger and more competitive economy. A significant number of residents from Central Bedfordshire and other authorities commute to Luton for work. While Luton offers sub-regional employment opportunities, neighbouring authorities might need to accommodate some of Luton's jobs growth that cannot be met within Luton, particularly employment uses that are land-hungry. Economic activity is low among females from certain ethnic communities. Compared to the rest of the region, there are lower rates of business start-up. Luton and southern Central Bedfordshire have fewer people with level 4 qualifications, below regional and national levels. More people have no qualifications, compared to the region and England. There are higher than average levels of unemployment, with lower-skilled occupations most at risk. Unemployment is notably higher in the adjoining towns of Houghton Regis and Dunstable than other parts of Central Bedfordshire. Unemployment is greater than 6 per cent in , , High Town, Northwell and South wards. Luton residents earn around £2000 less than the national average wage, though jobs in Luton pay around £2000 more than the national average wage. Gross disposable household income per head is more than £3,000 less than national and regional averages. Improvements in skill levels and educational achievement can help address economic activity. Support should be given to a thriving, vibrant and diverse local economy that is strong throughout economic cycles. Economic opportunities can be enhanced, particularly within the knowledge-based sectors, the green economy and waste management. Small and local businesses can be supported by an adequate supply of employment land. Creativity, innovation and enterprise should be promoted without compromising environmental objectives. Partnership working can

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Summary of Policy, Plan and Programme Review be encouraged to promote economic cohesion and realise economic potential. There is also a role for high quality telecommunications infrastructure that facilitates economic activity. There are limited opportunities for national multiple retailers with large floor space requirements. Luton's strength as a retail destination is likely to erode unless quantitative and qualitative improvements to the town centre retail offer are carried out. Improvements to the quality of the public realm and evening economy in the town centre are also required. The town centre would benefit from a large food store for main food shopping. The environmental quality of Luton’s centres requires improving to support their vitality and viability. Traffic impact and quality of the street scene are particular concerns. Development of those centres may impact negatively on regeneration ambitions of neighbouring authorities, although there is also the reverse risk that the development of centres outside the authority will compete with and reduce the vitality and viability of those in Luton.

Environment

The region is the country's driest. Luton is situated in an area of serious water stress, with resources classed as over abstracted, over licensed or having no water available. The will continue to experience pressure due to increased water abstraction and the impacts of potential droughts would be amplified. Water bodies within Luton and surrounding areas are classified as being within a 'nitrate vulnerable zone'. The aims and objectives of the local river basin management plan can be supported to improve water quality. Measures to reduce per capita water usage are required. Considerable flooding has been experienced in Luton, most commonly as a result of an inadequate drainage system that has not been upgraded. , , the Telford Way roundabout and the confluence of Houghton Brook with the Upper Lea have flooding problems. Much of the storm water sewer system discharges to the river and when levels on the Lea are high the sewer cannot discharge, backs up and floods. The risk of sewer flooding affects a significant number of properties in low-lying areas. The town centre area of Luton is identified as having 'very high' susceptibility to groundwater flooding. Long term development may affect the occurrence and significance of flooding. Development north of Houghton Regis presents opportunities to reduce flood risk downstream, though may also increase flood risk associated with Houghton Brook if adequate water management measures are not put in place. Development to the north of Luton may increase flood risk associated with the River Lea. Reducing run-off rates through the use of sustainable drainage systems might help to address flooding concerns. Luton is constrained by environmentally sensitive areas within and around it. Potential nationally and locally important plant areas are located in the vicinity of Warden Hill (to the north), Someries Castle (to the south) and Chaul End (to the west). A site of special scientific interest lies on the north-eastern border of Luton (Warden and Galley hills area). Development on the edge of Luton could negatively impact environmental quality in neighbouring areas. Rare sightings of the European otter have been made in the vicinity of Luton Hoo (to the south of Luton). Water voles and Great Crested Newts have been recorded around the source and upper tributaries of the Lea. Adders have been recorded around /Leagrave. Key habitats and wildlife should be safeguarded and positively contribute to the quality of life. A 'Chalk Arc' lies to the north of Luton. Development on the urban fringe may impact on landscape setting including the Chilterns AONB (to the north-east and

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Summary of Policy, Plan and Programme Review south-west), Lea Valley and the ancient Thedeway (to the north of Luton). Views from AONB escarpments may be particularly affected. Potential development of land around Butterfield Park and junction 10A involves significant landscape sensitivity issues. Access to and enjoyment of the surrounding landscape may be reduced if landscape character is diminished. The quality of and access to the natural environment should be improved. New development should contribute to local landscape character. There is a shortage of good quality land suitable for house building and it is likely that the Green Belt will be reviewed to accommodate levels of development need. Mixed-use urban extensions are being planned to the north of Luton and Houghton Regis, which might create a harder, more defined edge between town and country. The airport site has significant ecological value, parts of which support a local green network. Areas predominantly affected by aircraft noise are in the south and south west Luton, Breachwood Green, Whitwell, Slip End, Caddington, Flamstead and Markyate. Surrounding areas are also affected by road traffic noise and overflights travelling to and from other UK airports. Increased activity at the airport will erode the tranquillity of the AONB. Airport development may impact on a landscape conservation area (east, within North Hertfordshire) and an area of great landscape value to the south (in Central Bedfordshire). Airport activities are

seen to be significant sources of PM10 and nitrogen dioxide. Transport policies can help minimise the adverse impacts of noise.

Car travel is the greatest contributor to CO2 emissions in Luton. The residential areas around Junction 11 of the M1 suffer from high levels of poor air quality. Air quality and pollution can be addressed through new technologies and fuels and also by increasing access to destinations by sustainable transport modes and increasing the attractiveness of travel by those modes. The natural environment plays an important role to addressing health and well-being, carbon sequestration, climate change and improving the image and attractiveness of the town to investment. There is, however, an overall deficiency in the provision of green spaces. Parts of the north, north-west, south, west and north-east of the town are devoid of any amenity green space. Natural and semi-natural green space provision is low in parts of the south, south-east, central, west and north-west. Green corridors are unevenly distributed, with little provision in parts of the south, north-west, north and north-east. Allotment provision is low in the central, north-east and south areas. Many open spaces are not fully used as some do not meet the requirements of the Disability Discrimination Act while others suffer significant concerns of safety, crime and vandalism. Wardown and Stockwood parks provide accessible green spaces of strategic significance. Poor linkages between green spaces exist due to road and rail barriers, congestion or high-density development. Links from the north of Luton to the Way bridleway and footpath are required to increase connectivity/accessibility. Population growth will increase pressure on green spaces, requiring new provision, particularly within urban extensions to the north of Luton. New green infrastructure is required at all scales, from strategic through to local and should connect with, extend and enhance, existing green infrastructure.

Society

Luton is ranked third out of the 48 local authorities in the region in terms of deprivation. In 2010 Luton was ranked as one of the 25% most deprived areas in the country. Three wards are among the top 10% most deprived. Parts of Luton are likely to continue to experience high levels of deprivation

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Summary of Policy, Plan and Programme Review and health inequalities. Over 25% of households receive benefits, 1.4 times higher than the East of England average. Poverty affects almost a third of older people in parts of the adjoining towns of Dunstable and Houghton Regis. Almost half of the children from those towns live in low-income families. More than 13,000 (25.1%) children live in poverty in Luton, which is higher than national and regional averages. Deprivation needs to be addressed, with a focus on poverty, which is a key driver of deprivation and equalities concerns. Prevalence of obesity in adults is slightly higher than the average for the country. Significantly more children in reception school year were obese compared with the national average. Physical activity levels are lower than the national average. Luton has higher than national average rates of still births, low birth weight babies and infant mortality. Life expectancy in Luton is over one year below the national average. There is a deficiency of high quality, accessible green space in certain areas, affecting health, well-being and overall quality of life. High rates of health risks relate to lifestyle related illnesses. There is a need for increased provision of sports and leisure facilities such as swimming pools, sports halls and playing pitches. A high percentage of children come from homes where English is not the first language and start school needing extra help. In parts of the adjoining towns of Houghton Regis and Dunstable, young people have a low likelihood of going on to higher education. There are specific concerns relating to an inadequate supply of preschool places. Primary schools are operating at capacity especially in the town centre. There is no spare capacity in secondary schools. Any new growth requires new schools. Educational achievement, the overall skills base and access to learning opportunities across Luton requires improvement. Luton is third worst in the region for crime levels and there is a high demand for custody facilities at police stations. 15% of all crime and 11% of all anti-social behaviour took place in the town centre. Town centre hotspots for crime and anti-social behaviour include Gordon Street, Manchester Street, Bridge Street, and the Mall. 31% of all crime and 31% of all anti-social behaviour took place in the neighbourhoods adjacent to the town centre. 30% of crime was committed by those aged 14-21. Marsh Farm is the main hotspot for environmental anti-social behaviour. Crime needs to be addressed, with particular attention to the night time economy and theft in the town centre, theft and violent crime near to the town centre, anti-social behaviour in Marsh Farm, support for offenders and the protection of people vulnerable to anti-social behaviour. More than 22% of households are unsuitably housed. There is a high demand for affordable housing; a specific concern for the homeless and those living in overcrowded conditions (more common among Asian and Black African households), unable to afford more suitable accommodation. Access to affordable housing is restricted due to shortages of local authority and housing association stock. The viability of delivering further affordable housing is constrained by the cost of recycling Luton’s previously developed land, on which there may be unknown contamination from an industrial heritage. It is not viable to deliver all of Luton's affordable housing requirements within its boundary through the planning system. The demand for affordable housing places pressure to release open spaces for development. Land constraints mean that some housing growth may need to be delivered on the edges of Luton, within neighbouring authorities. Regarding specific client groups, there is a requirement in Luton to re-model existing residential care and sheltered housing provision to address the needs of an ageing population. Around one third of Gypsy and Traveller households reside on unauthorised sites. Security of tenure (certainty of time in accommodation) is a concern for Gypsies and Travellers. Luton has more private rented accommodation than the national average. The condition of stock of private rented accommodation is variable, with concerns that

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Summary of Policy, Plan and Programme Review many properties offer poor living conditions. 7.6% of private sector households in Luton are overcrowded. South, Biscot and Dallow wards have highest levels of non-decent private sector housing. 29% of vulnerable people in Luton live in non-decent homes. Standards should be devised for the required quality, range and affordability of housing. Details should include the mix of housing types and tenures to be provided, including market and affordable and accommodation for specific groups including Gypsies and Travellers and an ageing population. Where they can be viably delivered through statutory regulation, development values and other funding mechanisms, such standards can also reduce the number of non-decent homes, improve conditions within houses in multiple occupancy and address issues of overcrowding that lead to poor living conditions and predominantly affect those on low incomes. Programmes to reduce the number of empty homes should also be supported. Luton is likely to continue to experience pressure for considerable change within some conservation areas, with specific concern for the Victorian/Edwardian townscape. The historic fabric of Plaiters' Lea results in it being an area of significant conservation value, though at risk from re-development. Good design can help improve the built environment, respect heritage assets and reinforce civic pride. A good quality built environment also attracts investment. People in South Luton are least satisfied with their area. 57% of residents say there are parts of the borough they try to avoid, including Marsh Farm, and some areas of the town centre. 24% of residents found accessing hospital services by public transport difficult. 25% found accessing places of worship via public transport difficult. An unequal provision of community centres needs addressing. About 26% of households in Luton do not have access to a car. Considering this statistic, there are low levels of walking, cycling and public transport use, despite the high proportion of people who travel short distances. Reliability concerns, a lack of buses at night and Sundays, frequency and cost reduce the number of people choosing to travel by bus. Safety underlies reasons why people don't walk and cycle (speed of traffic, parking on footways and fear of crime are specific concerns). Growth in households will create demands on the local education system and transport infrastructure. Development to the north of Luton and Houghton Regis may help address needs of current and future residents, including access to community facilities and food stores. New facilities provided within Luton but accessible to residents of Central Bedfordshire may help to address needs across authority boundaries. Likewise, new facilities provided in Central Bedfordshire and accessible to Luton residents may help address Luton's needs. Community facilities should contribute to a sense of place and provide a focal point for community interactions, social cohesion, employment and voluntary activities. Access to and availability of services and facilities to address social exclusion, increase community interaction and provide more support for people with long term needs should be promoted. Equality of opportunity needs to be promoted, supported by policies that respect the protected characteristics of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, marriage and civil partnership.

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Table 3.2: Sustainability Appraisal Objectives

# Objectives SEA Receptors

1 Biodiversity, flora, fauna, Maintain and enhance biodiversity, habitat and landscape landscape

2 Conserve, restore and enhance green infrastructure Cross-cutting (all receptors)

3 Protect and enhance air, soil and water resources Air, soil, water

4 Protect areas that are at risk from flooding and reduce flood risk Material assets, climatic factors

5 Climatic factors, health, Reduce carbon emissions biodiversity, material assets

6 Increase resource efficiency and reduce resource use and waste Material assets, water, soil

7 Identify, protect, maintain and enhance heritage assets and their Cultural heritage (architectural setting / archaeological), landscape

8 Reduce poverty and inequality and promote social inclusion Population, human health

9 Reduce crime and fear of crime Population, human health

10 Encourage healthier lifestyles and reduce adverse health Population, human health impacts of new developments

11 Provide decent, affordable and safe homes for all Population, human health

12 Support vitality and viability of centres Population, human health

13 Provide and encourage the use of sustainable integrated Population, human health, transport systems, improve access and mobility material assets

14 Promote employment, learning, skills and innovation Population, human health

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4 Current and Future Characteristics of the Area and Existing Sustainability Issues

4.1 Introduction

4.1.1 Annex I of the SEA Directive states that the Environmental Report should include the relevant aspects of the current state of the environment, the environmental characteristics of the areas likely to be significantly affected and the likely evolution of the baseline without implementation of the plan. It also requires the Environmental Report to include any existing environmental sustainability issues which are relevant to the plan.

4.1.2 This chapter provides a summary of these baseline conditions. The full baseline data collection can be viewed at Appendix E. For ease of reference, underlined text relates to the baseline data in that appendix.

4.2 Summary of Baseline Conditions and Likely Evolution in Absence of the Plan

Economy

4.2.1 The distance travelled by Luton residents to work compares favourably to regional and national averages. More people commute into Luton than out from it.

 Without a plan to guide the quantity, quality and location of jobs, out-commuting might increase.

 The situation is temporary and reversible. Telecommunications and the distribution, quantity and matching of jobs with skills is a key factor in reducing distances travelled to work and out-commuting. Luton’s larger employers will likely support continued in- commuting.

4.2.2 The percentage of the working-age population in employment is declining and is lower than regional and national benchmarks.

 Without local planning policy, this may not improve.

 The situation is temporary and reversible. Improvements in education and job opportunities (and access to those opportunities) are required.

4.2.3 The percentage of working age people with a limiting long term illness was lower in Luton than the national average but higher than the regional average.

 Without a local plan to address the wider determinants of health, improvements in long- term illness may not be as great.

 The situation is temporary and reversible, though there is a wide range of factors determining long-term illness and so progress may be slow.

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4.2.4 Full-time average gross weekly pay for residents is increasing but remains below the national and regional averages. The distribution of jobs by type shows an increase in lower-skilled jobs being due to the creation of more jobs at that level and a loss of employment opportunities in higher-skilled positions. There are more people employed in lower skilled jobs and less in higher skilled jobs than seen in the regional and national benchmarks.

 Without a plan to address skills and jobs opportunities, improvements in the general wealth of the workforce may not occur.

 The situation is temporary and reversible.

4.2.5 The percentage of residents aged 16-64 with NVQ-equivalent qualifications is increasing but below regional and national benchmarks.

 Without a plan, levels of vocational, educational improvement may not rise as quickly.

 The situation is temporary and reversible. Increasing the availability, quality and access to education is required.

4.2.6 The percentage change in the number of VAT-registered businesses has fluctuated but has generally been higher than regional and national averages.

 Without a local plan to increase the attractiveness of the town to investment, the number of VAT-registered businesses might fall below benchmarks.

 The situation is temporary and reversible. Development that fosters a good quality environment (to attract investment) and creative/entrepreneurial skills should be of benefit.

4.2.7 The nature of the town centre has changed in recent years, with an increase in A1, A3, A5, D1 and D2 uses. A2, A4 and B1a uses have decreased. Shopping yields in Luton town centre have remained steady and compare favourably to other centres in the local region. Yields are better in Milton Keynes and Watford, reflecting their higher position in the retail hierarchy. Vacancy rates in Luton are slightly better than the national average.

 Without a local plan to guide development, the nature of the town centre may change in a manner that harms its vitality and viability, increasing investment yields and vacant premises.

 The situation is temporary and reversible, reflecting the attractiveness to investment in the town centre but subject to national, commercial trends.

Environment

4.2.8 Use of previously developed land is much higher than old national targets but slightly lower than the local target of 100%.

 Without a local plan, it is likely that high rates of PDL re-use will continue, though garden land and public open spaces may come under more pressure to accommodate development needs.

 Loss of undeveloped land is likely to be permanent.

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4.2.9 There is an overall deficiency of open space in Luton, with south-eastern and north-western areas of Luton specifically lacking in accessible strategic green space. Luton recently lost about 2 hectares of Green Belt through the development of leisure facilities. These replaced an ageing facility within the Green Belt, allowing the old site to be demolished and returned back to open space within the Green Belt.

 Without a local plan, Green Belt and other open spaces should be protected by national policies but will come under more pressure to be released for development. Existing deficiencies are less likely to be addressed.

 Loss of Green Belt and other open spaces is likely to be permanent and irreversible. It is unlikely to be possible to provide compensatory or other new land for losses within Luton’s boundaries. Maximising use of brownfield land will reduce pressure on open spaces to take development. Development could contribute to the enhancement of and access to existing green infrastructure.

4.2.10 The Chilterns AONB is being protected from unsuitable development and managed to conserve status.

 Without a local plan, areas of AONB could be lost or views negatively impacted.

 Significant impact is likely to be permanent and irreversible. Careful design that respects landscape setting could minimise impact.

4.2.11 Although the condition of local SSSIs meets national targets, there has been a loss of lower- level wildlife sites to development. A scarce resource in Luton, agricultural land is of better quality in the north than in the south of the town.

 Without a local plan, development in Luton could have a negative impact on the SSSIs located adjacent to the boundary of Luton and pressure to develop wildlife sites will increase. Soil and general environmental quality may suffer more from pollution.

 SSSIs, other wildlife sites and agricultural land are sensitive to disturbance and significant damage may be irreversible. Damage to environmental quality can take many years for natural processes to remedy. Minor damage might be offset by appropriate management plans or financial assistance to existing projects.

4.2.12 River water quality is below standard.

 Without a local plan, quality may deteriorate.

 Improvements are possible, though unlikely. Quality is not predicted to change by 2015 as improvement measures are considered either excessively expensive or technically infeasible. Impact from development can be mitigated through improvements to the river environment and the application of sustainable drainage systems that can minimise pollution.

4.2.13 A large number of properties in Luton are at risk of flooding. The risk of sewer flooding is high in the low-lying areas of the town and is forecast to get worse. Annual monitoring of the number of planning permissions granted contrary to Environment Agency advice on flood defence grounds has shown consistently excellent performance.

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 Without a local plan, Environment Agency advice can still guide development on flood- defence grounds. Development will be less able to be directed to locations of least flood risk, increasing flood risk.

 Development impacting on flood defence and within flood-risk areas is likely to be permanent. Flood mitigation/floodplain compensation for new development in areas of flood risk is possible, but a risk of flooding would likely remain. Flood risk can be minimised through appropriate infrastructure such as sustainable drainage systems, water utilities/sewerage upgrades and improvements to the natural river environment.

4.2.14 Water consumption per capita is higher than the national average and recommended levels. Water resources are over abstracted.

 Without a local plan, there would be fewer policies to implement water efficiency measures and development could place an untenable strain on water resources.

 Water consumption per person per day can be reduced through education, technologies, pricing and good design including water capture and re-use systems. Funds might be assembled to address water efficiency in existing properties.

4.2.15 Domestic gas consumption is declining and only slightly higher than the regional benchmark. Domestic electricity consumption is declining and is lower than the regional benchmark. Commercial/industrial gas consumption is increasing, though is much lower than the regional benchmark. Commercial/industrial electricity consumption is declining, though is higher than the regional benchmark.

 Without a local plan to encourage energy efficiency measures and renewable energy generation, consumption may increase.

 It is uncertain whether the rise in commercial/industrial consumption can decrease as this is dependent on the type of commercial operations and their need for energy from gas and/or electricity. Support for low-carbon heating and energy generation technologies, such as anaerobic energy from waste can help address some concerns relating to energy consumption.

4.2.16 Between 2005 and 2010 local CO2 emissions were below regional and national benchmarks, with an overall decrease in emissions.

 Without a local plan, unrestricted development could lead to increases in emissions.

 New development will likely increase emissions, though could be mitigated through improvements to transport, modal shift, energy efficiency and technological advances. Support for zero-carbon homes and programmes to decarbonise existing stock can help offset any carbon increase from the growth of the town.

4.2.17 Air pollution is a concern in the vicinity of the airport and major roads such as the M1 motorway. Recent years have seen town centre locations exceeding air quality targets (nitrogen dioxide).

 Without a local plan, there would be fewer controls to manage air pollution or the location of development in relation to pollution sources.

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 The location of development near to pollution is irreversible, though future technologies may reduce or limit the increase of pollutants. Considerate location of development, efficient distribution of land uses, sustainable transport options and transport management are part of a raft of measures that can minimise pollution and the effects of pollution. As well as minimising effects of pollution sources on existing land uses, sensitive uses (e.g. residential) could be directed to locations away from existing pollution.

4.2.18 There has been improvement in municipal and household recycling and composting rates but performance remains below the national targets.

 Without a Local Plan, there would be less provision for recycling/composting.

 It is possible to improve recycling/composting rate through education, strategic waste facilities and through good design features that encourage people to recycle and compost. Increasing rates of recycling and composting can help reduce levels of waste going to landfill. Planning policies can help apply the waste hierarchy of reduce, re-use, recycle, composting, energy recovery and, finally, disposal.

Society

4.2.19 Levels of deprivation in Luton are higher than the majority of other local authority areas and are increasing. The percentage of children in income deprived households has remained higher than the average for England. Fuel poverty has increased but is broadly in-line with regional averages.

 Without a local plan to guide regeneration, deprivation could increase. Opportunities to increase skills and employment opportunities will be restricted. Without policies to stimulate improvements in the energy efficiency of new dwellings (or the retro-fitting of solutions for existing homes), fuel poverty may increase at a higher rate.

 Deprivation and poverty is temporary and reversible, though can take a lot of time and resources. New development should address its own impacts (e.g. funding for school places) to avoid additional stresses on existing, essential community infrastructure. It will take time for skills to be improved and economic improvement can be sensitive to national economic trends. An adequate supply of jobs to match existing skills might be required in the short-term.

4.2.20 The percentage of pupils achieving five or more GCSEs at Grade A*-C or equivalent has improved dramatically to be above regional and national averages.

 Without a plan, levels of educational improvement may not rise as quickly.

 The situation is temporary and reversible. Increasing the availability, quality and access to education is required.

4.2.21 Crime rates are generally above regional and national benchmarks.

 Without a local plan and policies to improve the built environment, rates may increase further.

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 The situation is temporary and reversible. The design of new development can improve the quality and safety of the built environment.

4.2.22 Life expectancy has increased in Luton but still lags behind the national benchmark. Within Luton, life expectancy is significantly lower in areas on the western side of Luton than in areas to the east. Infant mortality is increasing, with an exceptionally high number of deaths in 2009 that have inflated rolling averages. Rates are above national averages.

 Without a local plan to address the wider determinants of health, life expectancy may increase at lower rates or even decrease.

 The situation is temporary and reversible, though there is a wide range of factors determining life expectancy and so progress may be slow.

4.2.23 Although adult participation in sport and active recreation is decreasing, the percentage of the population classifying themselves as being in good health is very similar to national and regional averages.

 Without a local plan to address the wider determinants of health (including access to sport and active recreation), improvements in general health may not be as great.

 The situation is temporary and reversible, though there is a wide range of factors determining good health and so progress may be slow. Education and increased accessibility of facilities can help. New development can ensure that they do not burden over-subscribed facilities, while making provision for better access to existing and new services.

4.2.24 There has been an increase (above national benchmarks) in the percentage of charitable and social enterprise organisations who consider that statutory bodies have a positive influence on their success.

 Without a local plan to support delivery of community and social infrastructure, positive influences may decrease.

 The measure is temporary and subject to a wide range of variables including funding and the availability of advice and support. New development that supports community and social infrastructure also supports the actions of charitable and social enterprises.

4.2.25 All areas of Luton generally enjoy excellent access to services. The hospital is situated to the west, resulting in long walking times from areas in the east of the town. Walking access to major retail centres (town centres) is a concern for those in peripheral areas.

 Without a Local Plan, access to services may not be increased and might reduce.

 As Luton is built-up to its boundaries, there are limited options for new service provision in areas where access by walking is poor. Siting new development in locations enjoying excellent accessibility to services with spare capacity will improve the measure.

4.2.26 Compared to regional and national averages, Luton residents have a good utilisation of travel by bus/coach, car-sharing, taxi and on foot. There is lower than average use of motorcycles/scooters, bicycles and home-working. Bus patronage is generally increasing and the trend suggests that the target of 12.5 million passengers in 2014 seems achievable. The

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number of cycle trips is generally increasing and the trend suggests that the target of 1,370 trips in 2014 seems achievable.

 Without a Local Plan, use of less sustainable modes of travel to work may increase.

 The situation is temporary and reversible. A variety of measures to improve the attractiveness of non-car travel can be used to increase sustainable and active travel. New development can be directed to locations near to public transport hubs and provide cycle storage spaces/changing facilities and support for new/enhanced cycling routes.

4.2.27 Projected growth in households will increase the need for homes.

 Without a local plan to guide the location of development, existing services may become over-stretched, the quality of the natural and built environment may decrease and levels of deprivation may increase.

 The situation is permanent and irreversible. To avoid significant negative impact, the capacity of the town to accommodate development should be carefully assessed. Neighbouring authorities may be required to deliver any unmet need.

4.2.28 The ratio between house prices and income in Luton is lower than regional or national benchmarks. The number of people on waiting lists has fluctuated though is equivalent with regional averages and lower than the national benchmark. Provision of affordable housing in Luton has fluctuated.

 Without a local plan to guide quantity and quality of housing and jobs, it is uncertain how the figures may change. With no arrangements for delivering affordable housing through the planning system, provision will suffer and waiting lists might increase.

 The situation is temporary and reversible. Decreasing house prices and increasing income can address housing affordability, though these are subject to national trends as well as local initiatives. New development can help fund affordable housing delivery but is constrained by tight development economics within Luton. While the provision of suitable housing can reduce waiting lists, there is little restriction over the number of people who can apply to be placed on the list.

4.2.29 The percentage of all dwellings that are vacant has fluctuated but compares favourably to national and regional benchmarks. Figures for empty local authority and housing association homes have fallen and are better than the regional and national averages. This has resulted in a statistical increase in the percentage of empty homes in private ownership (higher than regional and national averages).

 Without a local plan that might support local initiatives, vacancy rates could increase.

 The situation is temporary and reversible, through education and funding for the re-use of vacant dwellings.

4.2.30 Luton is an urban, densely developed borough. Heritage assets at risk include Drays Ditches scheduled monument, Bury registered park/garden and buildings within the Plaiters Lea conservation area. The status of other conservation areas is generally healthy although the

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areas of High Town and Plaiters’ Lea are at risk and deteriorating. Many of Luton’s assets are not on or assessed by national lists, though have significant local importance.

 While high density development is likely to continue, the lack of a local plan could result in densities that are not in keeping with the character of specific areas. The protection of conservation areas will be more difficult and their character would likely be eroded, leading to the loss of their status. Loss of and damage to heritage assets would be more likely.

 It is unlikely that high density development would be replaced at lower densities. Loss of heritage assets is permanent. Impact of development on local character can be mitigated through good design.

4.3 Key Sustainability Issues

4.3.1 Table 4.1 presents a summary of the key sustainability issues and challenges relevant to the Local Plan. These are derived from a consideration of the sustainability context provided by the policy and plan review and the baseline conditions within the borough. Example data sources are noted (italicised within brackets).

4.3.2 The identification of sustainability issues helps the SA process to focus on the main constraints and opportunities which may be addressed through the Local Plan and the key problems that should be considered during the appraisal process.

Table 4.1: Key sustainability issues for the Luton Local Plan

Issue Evidence

Economic

1 Low employment levels Below regional and national averages (NOMIS)

2 Low incomes Average pay is lower than regional and national averages and has seen less growth (NOMIS)

3 Low skills levels The percentage of lower-skilled jobs has increased and is above regional and national averages. The percentage of higher-skilled jobs have decreased and are below regional and national averages (NOMIS)

4 Congestion Congestion in Luton has an economic cost of £51.4m per year and is forecast to get worse (Local Transport Plan)

5 Vitality and viability of Town centre requires large units and district centres require centres improved physical environments (Retail Study)

Environmental

6 Poor ecological quality Currently poor to moderate and not expected to improve of water bodies (Environment Agency)

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Issue Evidence

7 Loss of open spaces Significant deficiency of open space. Recent history of development on county wildlife sites. Existing spaces under pressure from development needs. Open spaces required, among other reasons, to mitigate impact of climate change and support health and well- being (Luton and South Bedfordshire Draft Green Space Strategy, LBC annual monitoring reports)

8 Biodiversity and habitat Recent development on county wildlife sites. Presence of important plant areas, habitats and species (Bedfordshire and Luton Biodiversity Action Plan)

9 Green infrastructure Green infrastructure links within Luton and to surrounding areas network require strengthening to benefit health and well-being, carbon sequestration and the image of the town to attract investment (Green Infrastructure Plan, ‘Nature Nearby’)

10 Loss of agricultural land Little agricultural land remaining (www.magic.gov.uk)

11 Air quality Air pollution is a constraint to development near major transport infrastructure such as the motorway and airport. Nitrogen dioxide levels are also of increasing concern in the town centre (LBC Air Quality Progress Report)

12 Landscape and setting Scale of development needs in the area together with accompanying infrastructure is a potential threat to local and national landscape designations and their settings (Chilterns AONB Conservation Board and the Bedfordshire and Luton Strategic Green Infrastructure Plan)

13 Pressure on water Luton sits in an area of high water stress and over-abstraction. resources Pressures are due to increase with climate change (Water Resources Management Plan and Abstraction Management Strategy)

14 Flood risk Significant areas are at risk from sewer flooding. Flooding from water bodies and overland flows are also of concern. Flood risk is expected to increase with climate change (Strategic Flood Risk Assessment)

15 Waste reduction Recycling and composting rates are below regional and national averages (DEFRA)

16 Noise Noise impact from airport operations could increase with the future development of airport. Airport is close to residential areas. Air noise contour maps are available to assist planning decisions (Airport monitoring reports)

17 Carbon reduction Need to support national carbon reduction targets by supporting low-carbon buildings, transport, industry and electricity (UK Carbon Plan)

Social

18 Low educational Academic achievement below regional and national averages achievement though improving at a faster rate (NOMIS)

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Issue Evidence

19 School capacity Capacity concerns across primary and secondary schools (Social and Community Infrastructure Study: Identifying Existing and Future Social and Community Infrastructure Needs for Luton and South Bedfordshire)

20 Heritage at risk , Drays’ Ditches and the Plaiters’ Lea and High Town conservations areas are at risk (English Heritage and SAVE)

21 Deprivation Overall deprivation is increasing. (Index of Multiple Deprivation)

22 Children in poverty 30% of children live in income-deprived households (IDACI)

23 Fuel poverty 17% of households are in fuel poverty (DECC)

24 Crime High levels of violent crime, burglary and criminal damage (ONS and Home Office)

25 Health inequalities Life expectancy is below national and regional benchmarks and varies between wards. Obesity is of concern, particularly among children (Health Profiles and Department of Health and Joint Strategic Needs Assessment)

26 Decreasing adult Levels of adult participation in sport are decreasing (Sport England) participation in sport and active recreation

27 High percentage of Local authorities and registered providers have reduced the empty homes in private numbers of empty homes in their care, resulting in over 98% of all ownership empty homes being in private ownership (www.emptyhomes.com)

28 Low affordable housing Residential development viability is constrained due to high costs provision and low sales prices, restricting the delivery of affordable housing (Strategic Housing Market Assessment)

29 Accommodation for Homes need to be able to cater for an ageing population. Gypsies specific groups and Travellers require legal accommodation and certainty of tenure (Strategic Housing Market Assessment and the Bedfordshire and Luton Gypsy & Traveller Accommodation Needs Assessment)

30 Quality of existing A significant percentage of vulnerable people live in non-decent housing accommodation. Non-decent accommodation is more prevalent in certain areas (Luton Private Sector Renewal Strategy)

31 Access to services by A significant percentage of households do not have access to a car non-car travel (Luton Local Transport Plan 2011-2026)

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5 Testing Objectives, Identifying Alternatives

5.1 Vision and Objectives of the Draft Local Plan

5.1.1 The vision for the Local Plan is reproduced in Box 3.

Box 3: Luton Local Plan Vision

Luton’s economic, social and environmental resources and assets will be used efficiently and sustainably to deliver economic prosperity and an improved quality of life for all the residents of the borough. Luton will strengthen and transform the places that make the borough unique. It will continue to be a place for diverse communities, building on its strategic importance as a sub-regional driver of economic growth. The capacity of London Luton Airport will be improved to provide more jobs related to aviation industries. The completion of Butterfield Technology Park will support more job opportunities in high technology industries. Across Luton, a mix of high quality and low cost business accommodation will support a range of jobs suitable for the skills of local and neighbouring residents with Power Court and Napier Park making a strategic contribution to an increase in jobs. The creative and cultural industries will grow, stimulated by the presence of a modernised University of Bedfordshire and Luton town centre’s Creative Quarter. Housing will be delivered in the borough and in neighbouring authority areas to ensure there is sufficient housing, appropriate mix of dwelling type, size and tenure offering local residents choice of where to live. The local workforce will be more highly skilled and unemployment will be reduced considerably. There will be improved high standards in educational establishments, with students achieving high levels of educational attainment. Set alongside the River Lea and surrounded by the Chilterns Area of Outstanding Natural Beauty, Luton Hoo, the Green Belt and within a network of parks and waterways, Luton will protect and enhance its natural features which will continue to provide integral open space and leisure opportunities for a densely populated borough. Luton will prosper through a well connected network of vibrant and regenerated locally distinct places centred around Luton Town Centre, district centres and neighbourhood centres which have evolved from the borough’s rich history. Luton Town Centre will be a sub-regional focus for inward investment for development including retail, the creative and cultural economy, new homes and town centre uses. The district centres at Bury Park, Marsh Farm, Marsh Road, and Wigmore will also be a focus for development to enable their shops and services to thrive for the benefit of their local communities. Neighbourhood centres will be distributed across the town, between the larger centres, to serve day- to-day needs. Luton’s communities will be better connected and become less dependent on the car to promote healthy communities with good access to jobs, goods services and leisure and cultural activities an effective network of town, district and neighbourhood centres will serve as the heart of local neighbourhoods with improved access to by train, bus, walking and cycling. Each place will build on its distinctive identity, role and function and will be well-designed, vibrant, and above all, a great place to live.

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5.1.2 The strategic objectives form the link between the high level spatial vision and the detailed strategy. They are the objectives needed to fulfil the vision. The policies and delivery programme within the Luton Local Plan show how this can be achieved within the plan period. The vision and objectives build on and reflect Borough’s Sustainable Community Strategy. The Local Plan objectives are listed in Table 5.1.

Table 5.1: Local Plan Objectives

Luton Local Plan Objectives

Strategic Objective 1: Retain and enhance Luton’s important sub-regional role as a place for economic growth and opportunity.

Strategic Objective 2: To utilise Luton’s economic, social and environmental resources efficiently and sustainably within the limited physical land capacity of the borough.

Strategic Objective 3: To ensure that new housing delivers an appropriate level of provision to meet local requirements in terms of quantum, mix of dwelling types, sizes and tenures offer local residents a choice of where to live and addresses issues of affordability and overcrowding.

Strategic Objective 4: To establish an effective network and hierarchy of town, district and neighbourhood centres to serve as the heart of local communities and improve health through improved access by train, bus, walking & cycling to a mix of uses including shopping, services and jobs.

Strategic Objective 5: To improve the built and natural environment to deliver quality places, through high quality design and sustainability taking into account the character and setting of the neighbourhoods, including historic assets and seeking safe environments which help to reduce crime and the fear of crime.

Strategic Objective 6: Reduce social, economic and environmental deprivation, particularly where it is spatially concentrated, by taking priority measures to reduce unemployment, improve skills and education and renew housing, community and environmental conditions.

Strategic Objective 7: To enable new community and educational facilities to be delivered and expanded to meet the needs of a growing and diverse borough.

Strategic Objective 8: Improve accessibility, connectivity, sustainability and ease of movement to, from and within the borough.

Strategic Objective 9: To deliver a new Luton football stadium in a location capable of good access to transport infrastructure.

Strategic Objective 10: Improve the quality and accessibility of green space and nature, whilst protecting and enhancing biodiversity.

Strategic Objective 11: To safeguard and ensure the prudent use of natural resources, increase energy and water efficiency and encourage and promote the use of renewable energy sources to help adapt to climate change, and manage pollution, natural and landuse operational hazards, avoid inappropriate development in areas at risk of flooding, secure improvements in air and water quality and ensure effective waste management.

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5.2 Assessing the Plan’s Objectives against the SA Objectives

5.2.1 Table 5.2 presents a compatibility appraisal of the Draft Local Plan objectives against the SA Objectives. The assessment shows that the plan objectives broadly support the full range of SA Objectives and that there is a good degree of compatibility between the two sets of objectives. Some potential for conflict exists between plan objectives which drive towards economic, housing or larger scale development, and SA Objectives which provide for environmental protection, but these largely depend on the how the objective would be implemented.

Table 5.2: Compatibility assessment between plan objectives and SA Objectives

Local Plan Objectives SA 1 2 3 4 5 6 7 8 9 10 11

1 ?  ?      ?  

2   ?        

3   ?      ?  

4           

5         ?  

6 ?  ?      ?  

7           

8           

9           

10           

11           

12           

13           

14           

 Compatible ? Potentially incompatible  Incompatible

5.3 Identifying Reasonable Alternatives

5.3.1 The SEA Directive requires that the Environmental Report contains an outline of the reasons for selecting the alternatives dealt with in light of the other options which were potentially available. The following sections describe this process.

5.3.2 A broad range of strategic issues and alternatives were identified through a review of:

 Responses to the June – August 2012 notification exercise (questionnaires and workshops);

 Outcomes from early workshops with councillors in October and November 2011; and

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 The consultation statement and Sustainability Appraisal associated with the (withdrawn) Luton and southern Central Bedfordshire Joint Core Strategy.

5.3.3 Some of the options identified through this review were not taken forward through the Sustainability Appraisal. This is because they were not considered to be realistic or reasonable alternatives in the context of constrained land supply and/or viability constraints that are specific to Luton. These options are explained below.

Housing and employment targets

5.3.4 The Council jointly commissioned a Strategic Housing Market Assessment with neighbouring authorities to establish the overall housing need within the market area:

 Aylesbury Vale District Council;

Borough Council;

 Dacorum Borough Council;

 Luton Borough Council;

;

 North Hertfordshire District Council;

City and District Council; and

 Stevenage Borough Council.

5.3.5 The objectively assessed housing need within the Luton Housing Market Area is 30,000 new homes. The market area covers all of Luton, much of Central Bedfordshire and parts of Aylesbury Vale, Dacorum and North Hertfordshire. Of the overall housing need, 17,800 homes are required to support population increases within the borough of Luton. The constrained capacity of Luton to accommodate development is demonstrated by the Strategic Housing Land Availability Assessment (November 2012) which concludes that there is sufficient land to accommodate approximately 5,300 new homes. This was increased to around 6,000 by considering potential sites that could be allocated for residential development. These additional, potential sites were assessed by the SHLAA as being suitable but not available in the new plan period. It is considered allocating the sites for development will stimulate their availability.

5.3.6 This results in a requirement for unmet housing need to be located within the administrative areas of other local authorities. This fundamental issue goes back at least as far as the Bedfordshire Structure Plan 2011 (adopted 1997) and was a central consideration in the development of the Milton Keynes & South Midlands Sub-regional Strategy (adopted 2005), the Luton Local Plan 2001-2011 (adopted 2006) and the East of England Plan (adopted 2008). Were unmet housing needs not to be delivered in neighbouring administrative areas the town will likely suffer from worsening housing conditions and further pressure on infrastructure and services.

5.3.7 The Council also commissioned an Employment Land Review as well as a range of other studies addressing subjects such as development viability, retail capacity, and the possible need for a

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Community Infrastructure Levy. It then looked to all potentially available sites which might be allocated for residential development, including existing employment sites, open spaces and brownfield land. It examined these according to a consistent and rigorous set of site assessment criteria (see section 2.4.2) to determine which sites were most suitable for residential use, in the context of the available evidence, and which should remain in their current use or be allocated for different purposes such as retail or employment. This process is further described below.

Prioritising different land uses

5.3.8 Due to the constrained nature of Luton, a potential option would be to prioritise certain land uses over others. For example, there could be a policy to redevelop employment land and open spaces to maximise housing provision. Alternatively, employment or open space uses could be prioritised over housing. These are not considered to be reasonable alternatives for appraisal due to the importance of each of those land uses in their own right.

5.3.9 Luton has a recognised deficiency of open space across the borough as a whole. To prevent that deficiency from worsening, the majority of open spaces will need to be retained and protected. Reviews of open spaces have been conducted during the preparation of the local plan to identify priority sites for retention and those of lesser importance that could be used for redevelopment. Open spaces considered suitable for redevelopment have been incorporated into assessments of urban capacity and within the section of this sustainability appraisal that considers site-specific allocations (section 6.2). While small areas of new open space may be provided as part of larger development schemes, it is unlikely that Luton will see land in other uses being returned to open space. This is because developed land generally has a higher value than open space and would result in a financial loss for a land owner.

5.3.10 The Employment Land Review4 concludes that that all of Luton’s key employment sites are of good quality, none are likely to remain undeveloped during the plan period and they should all be retained for employment use as all are required to meet forecast needs (executive summary, paragraph 27). Development of existing employment land to other uses would therefore result in a loss of land for which there is an identified need. The financial viability of redeveloping employment land is also constrained by costs (executive summary, paragraph 25) to the extent that sites would need to deteriorate to such an extent that existing use values fall to a low enough level.

5.3.11 The redevelopment of existing housing land would be of even greater concern than seen with employment land. The level of housing need in Luton is so great that net losses of homes would result in an even greater quantity of unmet need that would require provision in other locations outside of the borough.

New build or conversion

5.3.12 The conversion of existing buildings to other uses is widely considered to be a generally sustainable approach to meeting development needs. The energy invested in an existing building is not lost and development could be financially more viable as there is no need to

4 Nathaniel Lichfield & Partners (March 2013): Luton Borough Council: Employment Land Review – Final Report.

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demolish and re-build. Strategic options for the local plan therefore could be to prioritise conversion or new build or to facilitate a mix of both.

5.3.13 As with the option to prioritise different land uses (above), evidence suggests that there is a need to retain all of existing employment land to meet identified need. Due to the significant volume of predicted population growth, Luton can also not afford to see a net loss of existing housing land. The retail study refresh does not identify any locations where existing retail uses could be converted to other uses and recommends increased investment to support the vitality and viability of centres across the town.

5.3.14 The Review of Town Centre Office/Business Premises for Alternative Re-use5 does identify some capacity for viable conversion to residential. This is of a limited scale (there is a good prospect for conversion to 136 new residential units) and has informed the urban capacity study. While it is recognised that development will occur both through new build and conversions, there is no clear evidence to suggest that the prioritisation of either is a reasonable strategic option for the local plan.

Housing density

5.3.15 The consideration of different, minimum densities of development is not a viable option in Luton. By increasing minimum densities, one should be able to deliver more development on a given area of land. This would result in more development within Luton's boundaries and reduce the level of unmet need that would require delivery elsewhere. While this is attractive in theory, it is not viable in practice.

5.3.16 The Affordable Housing Viability Study6 (p.6) considers three broad types of development and identifies that lower-density family housing at 35 dwellings per hectare (dph) is the most viable form of residential development in Luton. This is then followed by mixed schemes of houses and flats at 60dph, with the least viable type of development being 2-3 bed houses at 50dph. It further recommends that small schemes delivering less than 15 homes can viably contribute towards affordable housing provision. It goes on to identify that flats are less viable than houses, development around the town centre will struggle and that large schemes have additional and higher development costs than smaller ones.

5.3.17 While increased residential density could result in more of the borough's needs being met within its boundaries, the viability assessment shows that it is not an option that is financially viable.

Distribution of development

5.3.18 The broad pattern of development is another potential, strategic option. Alternatives could be stated in terms of 'distribute development evenly' or, 'focus on broad locations'. In Luton, broad locations could include (i) town and neighbourhood centres, (ii) areas of deprivation, or (iii) near to the Luton-Dunstable busway.

5 Peter Brett Associates (May, 2013): Luton Borough Council: Review of Town Centre Office/Business Premises for Alternative Reuse. 6 Three Dragons (April 2013): Luton Borough Council: Affordable Housing Viability Study.

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5.3.19 While options for the distribution of development appear reasonable, the overriding fact is that Luton is built up to its boundaries and there is little scope to pick and choose where development should be located. In reality, the local plan will need to promote development across the whole of the borough. Town centres (including then town centre, district and neighbourhood centres) will be a focus for development in-line with the directions provided by paragraph 23 of the NPPF. Such a focus should support their vitality and viability while ensuring good access to goods and services for residents across Luton. Carefully planned development in and around areas of deprivation should help to address local problems. The presence of the Luton-Dunstable busway should benefit the financial viability of other development schemes and one would expect the provision of new homes and businesses to be stimulated near to its stops.

Employment opportunities

5.3.20 There are potential options to plan for different types of employment opportunities, potentially labelled as 'balanced', 'low-skilled' and 'high-skilled'. These would reflect the known, local economic concerns such as low skill-levels among Luton's population and higher-paid positions being occupied by those who live outside Luton.

5.3.21 High and low-skilled options are not considered to be reasonable. To prioritise low-skilled employment could be to the detriment of improving the skills (and education) levels of Luton's residents, while prioritisation of higher-skilled jobs would restrict opportunities for lower-skilled workers. The 'balanced' option is the only reasonable approach as it seeks to improve on local strengths (e.g. airport-related employment and higher-skilled, M1-corridor office jobs) and opportunities (e.g. higher-technology jobs at ) while maintaining older employment land and premises that cater for a range of skills and budgets.

Strategic allocations

5.3.22 Eight strategic allocations are considered within the Draft Local Plan. The majority of these are rolled forward and updated from the previous Local Plan 2001-2011, as in the case of Butterfield Technology Park, Land South of Stockwood Park and Century Park (now combined with the Luton Airport Strategic Allocation). These represent the last remaining suitable greenfield sites for strategic development. Strategic allocations at Napier Park, Power Court, Creative Quarter, High Town and Marsh Farm are all previously developed sites that are in need of redevelopment and improvement.

5.3.23 Given the economic viability issues in the borough, coupled with the extent of environmental remediation required at a number of the sites, particularly Napier Park and Power Court, the quantum, mix of uses and phasing of allocations on previously developed land will need to be carefully considered to reflect the outcome of more detailed evidence on economic viability and remediation costs, and consultation with landowners and stakeholders.

5.3.24 Reasonable strategic alternatives are available for some of these sites, but not for others. For example, Land south of Stockwood Park could be allocated primarily for employment, or for employment and a relocated Luton Town Football Club, or for residential or mixed uses. Napier Park and Power Court could be allocated to a greater or lesser degree for retail, or for a

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mix of retail, residential and other uses. Butterfield Park and Century Park could continue their current roles as strategic employment allocations, or could be partially of fully released for residential and/or mixed uses.

5.3.25 Conversely, other sites do not have a choice of reasonable alternatives either due to their existing or adjacent use, or because alternatives have already been tested through earlier plans. These can be summarised as follows:

 High Town: a densely populated area in need of regeneration and environmental improvement. No reasonable alternatives available.

 Creative Quarter: comprises the ‘station quarter’ and ‘northern gateway’ allocations from the Local Plan 2001-2011, and builds on community aspirations and activities in recent years.

 Marsh Farm: The largest housing estate in Luton in need of reconfiguration, regeneration and environmental improvement, which can be stimulated by its designation as a district centre with associated uses (e.g. convenience retail).

Summary of reasonable strategic alternatives for assessment

5.3.26 The following bullets summarise those strategic alternatives which are considered to be reasonable, and which are therefore subject to appraisal in the following chapters:

 A range of residential and employment development targets;

 Releasing employment sites for residential or mixed uses;

 Converting town centre employment sites to residential use;

 Housing density: high density throughout, low density throughout, or mix of densities with higher densities focused on centre hierarchy and Luton-Dunstable busway;

 Land south of Stockwood Park: employment only, or employment with relocated Luton Town FC, or residential only, or mixed uses;

 Butterfield Park: employment only, residential only or mixed use;

 Century Park: employment only, residential only or mixed use;

 Napier Park: retail only, residential only or mixed use; and

 Power Court: retail only, residential only, mixed use or relocated Luton Town FC.

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6 Assessment of Alternative Options

6.1 Assessment of Strategic Alternatives

6.1.1 Table 6.1 to Table 6.10 present the appraisal of the strategic alternatives that were selected as reasonable to consider for inclusion in the Luton Local Plan, as discussed in the previous chapter. The appraisal is intended to give a high-level overview of the relative sustainability performance of each strategic alternative against the SA Objectives (see Table 3.2). A key to symbols used in the appraisal is given below, and a commentary on predicted effects follows.

Key to Appraisal for Strategic Alternatives:  Likely strong positive effect  Likely positive effect 0 Neutral/no effect  Likely negative effect  Likely strong negative effect ? Uncertain effects

6.1.2 In summary, there is considerable uncertainty in appraising the residential development target because little is known about where unmet housing need could be delivered. Future iterations of the Sustainability Appraisal may need to consider the probable location of unmet need once draft plans have been drawn up by neighbouring authorities, to enable an interpretation of potential effects on sustainability and Luton’s infrastructure and services. However, the appraisal shows that aiming to deliver the maximum number of homes permitted by available land capacity helps to meet socio-economic objectives with Luton. Aiming for a greater number of homes within Luton risks increasing the pressure on greenspaces, sites in other uses, and infrastructure and services. However, these risks also result from delivering unmet housing need outside the borough because there is less control over planning for the delivery of infrastructure and services. But if Luton’s unmet housing needs (including supporting infrastructure and services) are not delivered elsewhere then the town will likely suffer from worsening housing conditions and further pressure on infrastructure and services.

6.1.3 There are a range of implementation uncertainties regarding the employment development target, but higher levels of development are expected to have more strongly negative impacts on environmental sustainability objectives by increasing the use of land and resources. Conversely, higher development targets are expected to perform better against socio- economic development objectives. There are not predicted to be any particular sustainability benefits to the release of employment land for residential or mixed-use development, whether widespread or focused on the town centre. Apart from the obvious limiting effect on the borough’s economy, negative effects are likely to be highly spatially-specific. On the other hand, targeted releases of some lower quality sites would contribute towards the borough’s housing need, and this should be guided by the ongoing viability of existing uses.

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6.1.4 There are benefits to pursuing both high and low density housing options. Higher density developments would deliver a greater number of homes and may help to create the population density necessary to support services and facilities in certain locations. Conversely, there is an identified need for larger houses which are more suited to a lower housing density. Pursuing higher densities close to centres of good accessibility is likely to promote more sustainable transport patterns while also allowing for lower densities to meet a range of housing needs.

6.1.5 The sustainability benefits of all options for a strategic allocation at Land south of Stockwood Park are constrained by the site’s greenfield, out-of-centre location. Development would lead to a loss of soil resources and agricultural land. It could have negative effects on landscape, biodiversity and green infrastructure, although there are significant opportunities related to these also depending on how the development is implemented. Employment only, or employment with a relocated football club, would be likely to generate a significant amount of new employment, with associated socio-economic benefits, which would be augmented in a purely employment scheme. However, this could be to the detriment of the town centre’s vitality and viability. Residential only, or a mixed use development would contribute less strongly to economic objectives, but have the added advantage of helping to meet housing need. All options would lock-in unsustainable travel patterns unless accompanied by an attractive public transport solution, but a mixed use development preforms most strongly in this respect due to its ability to meet a range of needs and reduce the need to travel.

6.1.6 Butterfield Park and Century Park are large greenfield sites in out-of-centre locations, currently in agricultural use. Both are constrained in terms of likely effects on landscape, biodiversity and heritage assets, especially Butterfield Park. Century Park is additionally constrained by its proximity to London Luton Airport which makes it poorly suited to residential uses due air quality and noise impacts. Both sites are close to existing green infrastructure facilities, and both could incorporate an element of new accessible GI within future uses. The options considered for each site are broadly comparable and the sustainability of each is limited by the greenfield, out-of-centre location. Marginally greater benefits for sustainability objectives are predicted for a mixed use development due to its ability to meet a range of needs, and to provide for a sustainable mix of uses on site to reduce the need to travel, notwithstanding Century Park’s poor suitability for residential development.

6.1.7 Napier Park and Power Court are large brownfield sites within the urban area. Power Court is a derelict site within the town centre, has excellent accessibility and is presently used for employment, but underutilised. It is partially subject to flood risk, within an archaeological area and close to listed buildings and a conservation area. Napier Park is a much larger vacant site which also has excellent accessibility, although it is not within the town centre. A high degree of beneficial effects are predicted for both sites, subject to proper management of potential impacts to biodiversity and heritage assets for example. Regarding land uses, Power Court’s central location is suitable for retail, or retail-led mixed uses. Relocating the football club here also scores well but would limit the town’s ability to fulfil its retail capacity. The size and good accessibility of Napier Park make it a sustainable location for a residential-led mixed use scheme, making a significant contribution to provision of housing and potentially green infrastructure while also improving the local service offering.

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Table 6.1: Appraisal of Strategic Alternatives: Residential target and location of unmet need

Option 1 Option 2 Option 3 # SA Objective Urban capacity: 5,700 More than 5,700 Less than 5,700

1 Biodiversity and ?  ?

landscape Aiming for a higher number of homes will increase pressure on undeveloped sites in Luton, with possible biodiversity and landscape impacts, but fewer homes will increase level of unmet need to be delivered outside Luton which could also lead to biodiversity and landscape impacts

2 Green ?  ?

infrastructure Depends on site selection; aiming for a higher number of homes will increase pressure to develop greenfield sites resulting in loss of green infrastructure in Luton

3 Air, soil, water ? ? 

resources Depends on site selection but a lower number of homes may lead to increased impacts on soil resources by increasing development requirements outside of Luton

4 Flood risk ? ? ?

Depends on site selection

5 Carbon emissions 0 0 0

Overall emissions likely to be broadly comparable regardless of whether housing need is met inside Luton or in neighbouring authority areas

6 Resource efficiency 0 0 0

& waste Overall resource use likely to be broadly comparable regardless of whether housing need is met inside Luton or in neighbouring authority areas

7 Heritage assets ? ? ?

Depends on site selection

8 Poverty,   

inequality, Aiming for a higher number of homes will increase pressure to release employment inclusion land for residential development, but a lower target will worsen barriers to housing

9 Crime, fear of 0 0 0

crime No direct correlation

10 Health 0 0 0

No direct correlation

11 Affordable, decent ? ? ?

homes A higher development target should deliver more homes in Luton, but not necessarily decent homes if density or space standards suffer due to lack of urban capacity

12 Vitality & viability   

Fully utilising available urban capacity will enhance vitality; overdeveloping Luton or directing development to its edges may lead to strains on infrastructure and services

13 Sustainable   

transport & access Fully utilising available urban capacity will enhance accessibility; overdeveloping Luton or directing development to its edges may lead to strains on infrastructure

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Option 1 Option 2 Option 3

14 Employment &   

skills All options are likely to create opportunities for work and help alleviate poverty, however, option 2 will increase pressure to release employment land

Summary: There is considerable uncertainty in the assessment results because little is known about where unmet housing need could be delivered at this stage. However, the appraisal shows that aiming to deliver the maximum number of homes permitted by the available capacity helps to meet socio-economic objectives within Luton. Aiming for a greater number of homes within Luton risks increasing pressure on greenspaces, sites in other uses, and infrastructure and services. However, these risks also result from delivering unmet housing need outside the borough because there is less control over planning for the delivery of infrastructure and services

Table 6.2: Appraisal of Strategic Alternatives: Employment development target7 Option 1 Option 2 Option 3 Option 4 Option 5 # SA Objective 121,640m2 118,400 m2 206,000 m2 109,500 m2 242,300 m2 1 Biodiversity ? ?  ?  and landscape Depends on site selection, but a higher employment figure is like to increase pressure to develop greenfield sites, with impacts to biodiversity and landscape 2 Green ? ?  ?  infrastructure Depends on site selection, but a higher employment figure is like to increase pressure to develop greenfield sites, with impacts to green infrastructure 3 Air, soil, water      resources All options are likely to lead to increased use of resources 4 Flood risk ? ? ? ? ? Depends on site selection 5 Carbon      emissions All options are likely to lead to increased carbon emissions 6 Resource      efficiency & All options are likely to lead to increased use of resources waste 7 Heritage ? ? ? ? ? assets Depends on site selection 8 Poverty,      inequality, All options are likely to increase job opportunities and potential for poverty reduction inclusion 9 Crime, fear of      crime All options are likely to increase job opportunities, thereby reducing a cause of crime

7 These options are taken from the Employment Land Review which estimates employment floorspace requirements according to five different scenarios: (i) East of England Forecast Modelling, (ii) ONS-based forecast growth, (iii) projections based on past development rates, (iv) a lower future rate of development, or (v) a higher future rate of development.

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Option 1 Option 2 Option 3 Option 4 Option 5 10 Health 0 0 0 0 0 No direct correlation 11 Affordable, 0 0  0  decent homes No direct correlation, but a higher employment target may reduce the amount of land available for residential use 12 Vitality & ? ? ? ? ? viability Depends on site selection; re-use of town centre sites for employment would contribute to vitality of centres (although overdevelopment may reduce land available for other town centre uses) whereas a focus on edge-of-centre locations could have a detrimental effect on centres 13 Sustainable ? ? ? ? ? transport & Depends on site selection; re-use of town centre sites for employment would contribute to access improved accessibility whereas a focus on edge-of-centre locations could increase reliance on car transport 14 Employment &      skills All options are expect to contribute positively to this objective Summary: There are a range of implementation uncertainties regarding the employment development target, but higher levels of development are expected to have more strongly negative impacts on environmental sustainability objectives by increasing the use of land and resources. Conversely, higher development targets are expected to perform better against socio-economic development objectives.

Table 6.3: Appraisal of Strategic Alternatives: Release of employment sites Option 1 Option 2 Option 3 # SA Objective Retain employment Release for residential Release for mixed use sites development development

1 Biodiversity and 0 0 0

landscape Effects would be site-specific but unlikely to be significant due to current use

2 Green 0 0 0

infrastructure Effects would be site-specific but unlikely to be significant due to current use

3 Air, soil, water ? ? ?

resources Employment uses are significant trip generators, but then so are retail uses. Residential uses tend to attract fewer trips but are a significant source of supply

4 Flood risk 0 ? ?

Depends on location and type of use; residential is more vulnerable

5 Carbon emissions 0 0 0

All use types contribute towards carbon emission, but redevelopment might provide opportunity for efficiency gains

6 Resource efficiency   

& waste Redevelopment would increase use of resources in comparison to retention

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Option 1 Option 2 Option 3

7 Heritage assets 0 ? ?

Effects would be site-specific; retention may preserve current heritage assets but may also bypass opportunities for enhancement

8 Poverty,   ?

inequality, Employment sites would yield a higher density of jobs than mixed use sites, thereby inclusion helping to reduce poverty. Conversion to residential would lead to local loss of jobs

9 Crime, fear of 0 0 0

crime Effects would be site-specific but unlikely to be significant if site is currently in use

10 Health 0 0 0

No direct correlation

11 Affordable, decent   

homes Conversion to residential would help resolve unmet housing need; mixed uses would make a lesser contribution to this objective

12 Vitality & viability   

All use types would contribute to vitality in their own way

13 Sustainable 0 0 0

transport & access Effects would be site-specific

14 Employment &   ?

skills Employment sites would yield a higher density of jobs than mixed use sites, thereby helping to reduce poverty. Conversion to residential would lead to local loss of jobs

Summary: No option performs substantially better than the others against the SA Objectives. Effects would be highly spatially specific. Viability likely to be key determinant

Table 6.4: Appraisal of Strategic Alternatives: Converting TC employment sites to residential Option 1 Option 2 # SA Objective Retain employment sites Release for residential development

1 Biodiversity and 0 0

landscape Effects would be site-specific but unlikely to be significant due to current use

2 Green 0 0

infrastructure Effects would be site-specific but unlikely to be significant due to current use

3 Air, soil, water ? ?

resources Employment uses are significant trip generators. Residential uses tend to attract fewer trips but are a significant source of supply

4 Flood risk 0 ?

Depends on location; residential is more vulnerable

5 Carbon emissions 0 0

Both use types contribute towards carbon emission, but redevelopment might provide opportunity for efficiency gains

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Option 1 Option 2

6 Resource efficiency  

& waste Both conversion and retention are an efficient use of resources in comparison to new or re-development

7 Heritage assets 0 ?

Effects would be site-specific; retention may preserve current heritage assets but may also bypass opportunities for enhancement

8 Poverty,  

inequality, Conversion to residential would lead to local loss of jobs inclusion

9 Crime, fear of 0 0

crime Effects would be site-specific but unlikely to be significant if site is currently in use

10 Health 0 0

No direct correlation

11 Affordable, decent  

homes Conversion to residential would help resolve unmet housing need

12 Vitality & viability  

Both use types would contribute to vitality in their own way

13 Sustainable 0 0

transport & access Effects would be site-specific

14 Employment &  

skills Conversion to residential would lead to local loss of jobs

Summary: Retaining town centre employment sites performs marginally better than conversion to residential. But some limited conversions may be appropriate where viability of existing use is low

Table 6.5: Appraisal of Strategic Alternatives: Housing density Option 1 Option 2 Option 3 # SA Objective High density borough- Low density borough- Higher at centres and wide wide close to busway 1 Biodiversity and 0 0 0 landscape Effects would be site-specific but unlikely to be significantly different 2 Green ? ? ? infrastructure Higher density development could decrease the amount of space available for GI within development sites but may also reduce the pressure to develop existing open spaces 3 Air, soil, water    resources Higher densities in more accessible locations will encourage the use of sustainable transport, with benefits to air quality. The borough’s few remaining soil resources may come under increasing development pressure at low density rates

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Option 1 Option 2 Option 3 4 Flood risk ? ? ? Depends on location 5 Carbon emissions    Higher densities are more suited to energy efficiency, renewable energy and district heating; those in accessible locations will also have lower transport-related carbon 6 Resource efficiency  0  & waste Higher density development could facilitate greater resource-efficiency during construction, and are likely to make a better use of available land 7 Heritage assets ? ? ? Effects would be site-specific 8 Poverty, 0 0 0 inequality, No direct correlation inclusion 9 Crime, fear of 0 0 0 crime No direct correlation 10 Health 0 0 0 No direct correlation 11 Affordable, decent    homes Higher density developments would lead to greater increases in the supply of homes, but homes at lower densities are also needed in the borough 12 Vitality & viability 0 0  Higher densities in centres would contribute towards their vitality and viability 13 Sustainable 0 0  transport & access Higher densities in more accessible locations will encourage use of public transport 14 Employment & 0 0 0 skills No direct correlation Summary: Subject to viability, the promotion of higher densities at centres and in accessible locations is likely to maximise beneficial sustainability effects, while allowing for lower densities in suitable areas

Table 6.6: Appraisal of Strategic Alternatives: Land south of Stockwood Park Option 1 Option 2 Option 3 Option 4 # SA Objective Employment only Emp + Luton FC Residential only Mixed use 1 Biodiversity     and landscape All options involve development of large greenfield site which, despite predominant agricultural use, has some landscape and biodiversity value 2 Green ? ? ? ? infrastructure Limited accessible GI currently present on site, which could be significantly improved depending on how the proposal is implemented 3 Air, soil, water     resources Out-of-centre location will mean that all options will contribute to road transport

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Option 1 Option 2 Option 3 Option 4 emissions, and all will lead to loss of agricultural land. A mixed-use would be least damaging in this respect as it would be able to provide locally for some of the needs of new residents 4 Flood risk 0 0 0 0 Site not subject to flood risk 5 Carbon     emissions Out -of-centre location will mean that all options will contribute to road transport emissions, and will lead to increased energy consumption. As with Objective 3, a mixed use development is least damaging in this respect 6 Resource     efficiency & All options will lead to loss of agricultural land and an increase in use of resources waste 7 Heritage assets 0 0 0 0 Site does not contain known heritage assets 8 Poverty,     inequality, Options 1 and 2 will provide employment opportunities, especially the employment only inclusion option, thereby helping alleviate poverty. Option 3 would not contribute to employment, but would help to provide the opportunity for good living standards 9 Crime, fear of 0 0 0 0 crime No direct correlation 10 Health 0  0 0 New sporting facilities (Option 2) could contribute to improved health, although the proposal could simply entail a relocation of existing facilities to a less accessible location 11 Affordable, 0 0   decent homes Option 3 provides the greatest opportunity for meeting this objective 12 Vitality &     viability Out -of-centre location will not contribute to, and may detract from, vitality and viability of centres 13 Sustainable     transport & Out-of-centre location will not improve accessibility or use of sustainable transport unless access specific measures are incorporated (e.g. Park & Ride, busway connection) 14 Employment &     skills Options 1, 2 and 4 will provide employment opportunities, especially the employment only option, thereby helping alleviate poverty Summary: The options are broadly comparable and the sustainability of each is limited by the greenfield, out-of-centre location. Marginally greater benefits for sustainability objectives are predicted from Options 2 and 4 due to their ability to meet a range of needs, and to provide for a sustainable mix of uses on site to reduce the need to travel. Due to the location of the site, residential uses would be exposed and isolated, remote from services

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Table 6.7: Appraisal of Strategic Alternatives: Butterfield Park Option 1 Option 2 Option 3 # SA Objective Employment only Residential only Mixed use

1 Biodiversity and    landscape Although partially developed already, site is adjacent to AONB and open countryside, with areas of biodiversity value on site and adjacent

2 Green 0 0 0 infrastructure Limited accessible GI presently on site, but significant assets nearby (e.g. Butterfield Green) and development could incorporate an element of new accessible GI

3 Air, soil, water    resources Out-of-centre location will mean that all options will contribute to road transport emissions, and all will lead to loss of agricultural land. A mixed-use would be least damaging in this respect as it would be able to provide locally for some of the needs of new residents

4 Flood risk 0 0 0

Site not subject to flood risk

5 Carbon emissions    Out -of-centre location will mean that all options will contribute to road transport emissions, and will lead to increased energy consumption. As with Objective 3, a mixed use development is least damaging in this respect

6 Resource efficiency    & waste All options will lead to loss of agricultural land and an increase in use of resources

7 Heritage assets    Site includes and is surrounded by several archaeological areas, and all options are likely to negatively affect these

8 Poverty,    inequality, Option 1 and 3 will provide employment opportunities, especially the employment inclusion only option, thereby helping alleviate poverty. Option 2 would not contribute to employment, but would help to provide the opportunity for good living standards

9 Crime, fear of 0 0 0 crime No direct correlation

10 Health 0 0 0

No direct correlation unless specific GI, sports, fitness or healthcare uses included

11 Affordable, decent   

homes A higher proportion of residential development would better serve this objective

12 Vitality & viability    Out -of-centre location will not contribute to, and may detract from, vitality and viability of centres

13 Sustainable    transport & access Out-of-centre location will not improve accessibility or use of sustainable transport unless specific measures are incorporated (e.g. Park & Ride, busway connection)

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Option 1 Option 2 Option 3

14 Employment &   

skills Options 1 and 3 will provide employment opportunities, especially the employment only option, thereby helping alleviate poverty

Summary: The options are broadly comparable and the sustainability of each is limited by the greenfield, out-of-centre location. Marginally greater benefits for sustainability objectives are predicted from Option 3 due to its ability to meet a range of needs, and to provide for a sustainable mix of uses on site to reduce the need to travel

Table 6.8: Appraisal of Strategic Alternatives: Century Park Option 1 Option 2 Option 3 # SA Objective Employment only Residential only Mixed use

1 Biodiversity and    landscape Although partially developed already, site is adjacent to green belt and open countryside, with areas of biodiversity value on site and adjacent

2 Green 0 0 0 infrastructure Limited accessible GI presently on site, but significant assets nearby (e.g. Wigmore Valley) and development could incorporate an element of new accessible GI

3 Air, soil, water    resources Out-of-centre location will mean that all options will contribute to road transport emissions, and all will lead to loss of agricultural land. A mixed-use would be least damaging in this respect as it would be able to provide locally for some of the needs of new residents. Site is adjacent to the airport, a significant source of air pollution

4 Flood risk 0 0 0

Site not subject to flood risk

5 Carbon emissions    Out -of-centre location will mean that all options will contribute to road transport emissions, and will lead to increased energy consumption. As with Objective 3, a mixed use development is least damaging in this respect

6 Resource efficiency    & waste All options will lead to loss of agricultural land and an increase in use of resources

7 Heritage assets    Site includes an archaeological area, and all options may lead to negatively effects

8 Poverty,    inequality, Option 1 and 3 will provide employment opportunities, especially the employment inclusion only option, thereby helping alleviate poverty. Option 2 would not contribute to employment, but would help to provide the opportunity for good living standards

9 Crime, fear of 0 0 0 crime No direct correlation

10 Health 0  

Site is adjacent to the airport with a small area falling within the Public Safety Zone. Residential uses are not well suited and would be subject to significant air and noise pollution impacts

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Option 1 Option 2 Option 3

11 Affordable, decent   

homes A higher proportion of residential development would better serve this objective

12 Vitality & viability    Out -of-centre location will not contribute to, and may detract from, vitality and viability of centres

13 Sustainable    transport & access Out-of-centre location will not improve accessibility or use of sustainable transport unless specific measures are incorporated (e.g. Park & Ride, busway connection)

14 Employment &   

skills Options 1 and 3 will provide employment opportunities, especially the employment only option, thereby helping alleviate poverty

Summary: The options are broadly comparable and the sustainability of each is limited by the greenfield, out-of-centre location. Marginally greater benefits for sustainability objectives are predicted from Option 3 due to its ability to meet a range of needs, and to provide for a sustainable mix of uses on site to reduce the need to travel. Due to the proximity of the airport, the site is not well suited to residential uses and would be more appropriate for less sensitive uses such as employment. As identified by paragraph 5.25 of the 2013 Employment Land Review, this is the only large site suitable for industrial uses (particularly for the larger units that Luton is short of) and it is critical to meeting a large part of forecast future industrial demand in the Borough

Table 6.9: Appraisal of Strategic Alternatives: Napier Park Option 1 Option 2 Option 3 # SA Objective Retail only Residential only Mixed use

1 Biodiversity and ? ? ?

landscape Depends on implementation; significant gains possible but protection needed for nearby wildlife designations

2 Green   

infrastructure Depends on implementation but significant gains possible; site currently vacant

3 Air, soil, water ? ? ?

resources Risk of pollution to air and water during construction but prior remediation likely to be of benefit

4 Flood risk 0 0 0

Site not subject to flood risk

5 Carbon emissions ? ? ?

Scale of potential development likely to increase emissions at least in short to medium term but opportunities for building-in efficiency and/or renewables

6 Resource efficiency   

& waste Redevelopment of vacant site constitutes an efficient use of land

7 Heritage assets 0 0 0

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Option 1 Option 2 Option 3

No known heritage assets on site

8 Poverty,   

inequality, All options are likely to create opportunities for work and help alleviate poverty, but inclusion this would be limited to construction phase only for a purely residential scheme

9 Crime, fear of   

crime All options would be an improvement on the currently vacant site

10 Health 0 0 0

No direct correlation unless specific GI, sports, fitness or healthcare uses included

11 Affordable, decent   

homes A higher proportion of residential development would better serve this objective

12 Vitality & viability   

All options would be an improvement on the currently vacant site

13 Sustainable   

transport & access The site has very good accessibility to sustainable transport services

14 Employment &   

skills All options are likely to create opportunities for work and help alleviate poverty, but this would limited to construction phase only for a purely residential scheme

Summary: All three options would make a significant contribution to the SA Objectives but the mixed use option performs better due to its ability to meet a range of the borough’s needs, and to provide for a sustainable mix of uses on site to reduce the need to travel

Table 6.10: Appraisal of Strategic Alternatives: Power Court Option 1 Option 2 Option 3 Option 4 # SA Objective Retail only Residential only Mixed use Football club 1 Biodiversity ? ? ? ? and landscape Depends on implementation; significant gains possible but protection needed for nearby wildlife designations 2 Green     infrastructure Depends on implementation but significant gains possible 3 Air, soil, water ? ? ? ? resources Risk of pollution to air and water during construction but prior remediation likely to be of benefit 4 Flood risk 0   0 Site partially at subject to flood risk; residential is a more vulnerable use 5 Carbon ? ? ? ? emissions Scale of potential development likely to increase emissions at least in short to medium term but opportunities for building-in efficiency and/or renewables 6 Resource     efficiency & Redevelopment of derelict site constitutes an efficient use of land waste

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Option 1 Option 2 Option 3 Option 4 7 Heritage assets     Site within archaeological area, close to listed buildings and conservation area

8 Poverty,     inequality, All options are likely to create opportunities for work and help alleviate poverty, but this inclusion would be limited to construction phase only for a purely residential scheme and may be intermittent for a football club 9 Crime, fear of     crime All options would be an improvement if the site is currently under utilised 10 Health 0 0 0 0 No direct correlation unless specific GI, sports, fitness or healthcare uses included 11 Affordable,     decent homes A higher proportion of residential development would better serve this objective 12 Vitality &     viability All options would be an improvement by adding vibrancy to the town centre 13 Sustainable     transport & The site has very good accessibility to sustainable transport services and is within the town access centre 14 Employment &     skills All options are likely to create opportunities for work and help alleviate poverty, but this would be limited to construction phase only for a purely residential scheme and may be intermittent for a football club Summary: Locating the football club at Power Court or allocating the site purely for retail would seem to be the most sustainable options but, given the acute shortage of housing land and site’s highly accessible location, it would also be of benefit to deliver new homes

6.2 Assessment of Sites for Allocation

6.2.1 The results of the site criteria assessments and high level assessment, as described at section 2.4, for the long list of 190 possible site allocations are shown at Appendix F. A summary of the assessment results for the shortlist of 31 preferred sites is given at Appendix G.

Site assessments

6.2.2 Although the majority of sites considered for residential allocation show reasonably high accessibility to services such as schools, healthcare facilities and bus routes, a very high number (156) are not accessible to (within 200m) an open space with formal play provision and many (67) are more than 1km from the nearest sports facility. Proximity to train stations and cycle routes is patchy among the possible allocations, and several (42) coincide with sites categorised as ‘Green’ (fit for purpose) or ‘Amber’ (viable but requiring intervention to improve viability) by the Employment Land Review. Allocating such sites for housing would hence have a detrimental effect on the availability of job opportunities in the relevant locality.

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6.2.3 Virtually all 190 sites are within Source Protection Zone (SPZ) 1 or 2, reflecting the importance of Luton with respect to drinking water supplies. Comparatively few sites (36) were found to potentially affect the fabric or setting of a listed building (within 100m), many of which are among the 41 potential allocations which fall within or close to a conservation area. Over a quarter (50) are within, or close to (400m) an area defined locally as Area of Great Landscape Value (AGLV) or Area of Local Landscape Importance (ALLI). A similar number (41) could negatively affect a Country Wildlife Site (CWS), District Wildlife Site (DWS) or other Site of Nature Conservation Importance (SNCI), while 48 coincide with or are within 20m of open space. Far fewer (12) are currently affected by fluvial flood risk.

High level assessment

6.2.4 Drawing on the findings of the site assessments, a high level assessment (HLA) was undertaken for each potential allocation against the full range of 14 SA Objectives. The HLA gives a broad overview of the sustainability performance of each site, categorising each effect as strongly positive, positive, neutral, mixed/uncertain, negative or strongly negative. Many of the objectives share a strong relationship with the site assessment criteria, and this is borne out in the high level assessment conclusions.

6.2.5 For example, virtually all of the potential allocations exhibited negative or uncertain effects against SA Objective 3 (Protect and enhance air, soil and water resources) largely due to the presence of SPZ1/2, and in some cases due to a loss of soil resources or proximity to a source of air pollution, such as the M1, airport of Air Quality Management Area (AQMA). Fifty sites were predicted to have uncertain or negative effects against SA Objective 1 (biodiversity and landscape), and 42 were assessed as potentially affect green infrastructure (GI; Objective 2)) either through loss or degradation. Mixed impacts were predicted against Objective 6 (resource efficiency), including for example loss of agricultural land or re-use of previously developed land (PDL) and Objective 7 (heritage assets).

6.2.6 At the HLA stage, the majority of possible allocations were found to have positive effects on the socioeconomic SA Objectives, including Objective 8 (poverty and social inclusion), Objective 11 (decent, affordable homes), Objective 13 (sustainable transport and accessibility) and Objective 14 (employment, learning and skills). This is because of their potential contribution towards meeting housing need, including affordable homes, in accessible locations, while also providing employment opportunities (at least during construction).

6.2.7 The performance of potential allocations against Objective 10 (health) was quite varied. This was due to a number of factors, including relative proximity to healthcare or sporting facilities, accessibility to public transport and cycling routes, and whether or not the proposal would result in a loss of existing open space. The majority of sites were judged – at a strategic level – to be neutral in relation to Objective 4 (flood risk), Objective 5 (carbon emissions), Objective 9 (crime) and Objective 12 (vitality and viability of centres).

Conclusions

6.2.8 It is important to note that the primary benefit in carrying out a high level assessment is to allow high volumes of data to be processed, and to give an indication of the relative (not absolute)

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sustainability performance of a long list of sites. The findings of the site assessments and high level assessment must be used to determine which sites are unsustainable as opposed to sustainable sites. This has been used by Council officers alongside other considerations to sieve the long list of 190 sites into a sustainable shortlist of 31. Residential development is expected to come forward on many of the other sites, though they did not meet the criteria for specific allocation. Additional sources of residential land supply are set-out in the SHLAA and an appendix to the Draft Local Plan.

6.2.9 Sites that befitted from the following characteristics were viewed favourably, and were among the key considerations for the Council when establishing the shortlist:

 That the site was capable of yielding 25 or more dwellings. Sites potentially delivering 24 units or less may be included within the housing trajectory but were not generally considered large enough to warrant specific allocation;

 That the site was categorised with less than four Red scores against the site assessment criteria;

 That the site was not predicted to have any strongly negative effects against any of the SA Objectives; and

 That the site shows a good degree of development viability.

6.2.10 A table summarising which sites were selected as preferred allocations for the Local Plan, together with a brief justification, is given at Appendix H.

6.2.11 The following chapter goes on to describe the assessment processes for the Draft Local Plan, including proposed policies and the shortlist of site allocations.

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7 Assessment of Draft Local Plan

7.1 High Level Assessment of Policies

7.1.1 Having completed high level assessments for the long list of potential site allocations, it was considered prudent to repeat the process for the draft proposed policies for the Local Plan. The results are given at Appendix I. Applying the HLA to the proposed policies allows attention to be focused on particular policy locations – such as Strategic Allocations – or themes which potentially lead to significant negative effects, while identifying which are broadly neutral or positive overall.

7.1.2 The findings show that the Spatial Development Strategy (LP2) is predicted to lead to a broad range of mixed and uncertain effects against the majority of SA Objectives. Similar conclusions are drawn regarding the Economic Strategy (LP13) and Housing Provision (LP15). This is because the effects of these policies will largely be determined by the way they are implemented and are likely to be spatially-specific; they will depend on which sites are allocated to implement the strategy.

7.1.3 The majority of Development Management policies were predicted to have mainly neutral or positive impacts, which is unsurprising because they aim to influence the design of development proposals and identify standards to which they should strive to adhere. The exceptions are the transport-related policies; LP31 Sustainable Transport Strategy, LP32 Parking and LP33 Freight. Work is ongoing to develop specific aspects of these policies in detail and it is anticipated that more detailed assessments will be achievable at the next main stage in plan- making. However, a number of positive (+ve) and negative (-ve) effects were predicted to result from the Strategic Allocations which required more detailed assessment.

7.2 Detailed Assessment Matrices

7.2.1 Detailed assessment matrices (DAMs), as described at section 2.4.6, were prepared for any proposed site allocation with one or more negative or strongly negative effect, or more than two uncertain effects at the high level assessment stage (see Chapter 6 and Appendix G). They were also prepared for each of the Strategic Allocations as well as the Town Centre Strategy. To summarise, DAMs were prepared for the following policies and sites, and can be viewed at Appendix J:

 LP3: Luton Town Centre Strategy;  LP5: Land south of Stockwood Park;

 LP6: London Luton Airport;  LP7: Butterfield Technology Park;

 LP8: Napier Park;  LP9: Power Court;

 LP10: High Town;  LP11: Creative Quarter;

 LP12: Marsh Farm;  ID155: Guardian Estate;

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 ID161: Oxen Industrial Estate;  ID174: Land at Caleb Close;

 ID176: Car park off Telford Way;  ID180: Dalroad Industrial Estate;

 ID182: 69 Felstead Way;  ID220: Luton Town Football Club;

 ID221: Midland House, 41 King Street;  ID337: Land west of Newlands Road;

 ID339: Land at Stockingstone Road;  ID342: The Laurels, Ely Way;

 ID343: Westlea, 121 High Street;  ID351: 27a Upper George Street;

 ID352: 40-58 Collingdon Street;  ID353: CP adj. 95 Maple Road East;

 ID359: Centre, Weltmore Rd;  ID361: 2-32 Beechwood Road;

 ID364: 10-12 Caleb Close;  ID365: 146-158 Park Street;

 ID402: The Orchard Centre Strangers Way;  ID412: 38a Wingate Road; and

7.3 Appraisal Commentary by SA Objective

SA1: Maintain and enhance biodiversity, habitat and landscape

7.3.1 The borough is predominantly built-up to its boundaries, and in certain locations is deficient in semi-natural habitats, particularly in more central locations. However, it benefits from larger areas of open space towards it fringes, and several green corridors penetrate towards the Town Centre. Flanked by Areas of Outstanding Natural Beauty to the north and south, but densely developed towards the centre, the borough has listed six Areas of Great Landscape Value or Areas of Local Landscape Importance, one of which is towards the Town Centre at Hart Hill.

7.3.2 As would be expected, the range of biodiversity and landscape impacts predicted by the assessment is heavily influenced by these spatial variations. Several of the smaller site allocations are predicted to have very limited ecological impacts, restricted to common urban flora and fauna and which, at the strategic level, are capable of mitigation by requiring planning proposals to be accompanied by site-specific survey and assessment information. A range of standard recommendations are made for sites of this type which seek to build biodiversity into the fabric of redevelopments by protecting existing features or incorporating new biodiverse habitats into development layouts. Such measures are also of benefit to the landscape/townscape value of new development proposals and, where there is a risk of impacts to nearby sensitive landscapes, further Landscape and Visual Impact Assessment is recommended.

7.3.3 However, it is the Strategic Allocations which present both the greatest risk of impacts, and opportunities for greatest gains, in relation to biodiversity and landscape, as illustrated in Table 7.1. The greenfield sites (Land south of Stockwood Park, Butterfield Technology Park, and Century Park at London Luton Airport) are likely to be hotspots of greatest ecological value currently within the borough, despite the intensive agricultural use of most of these areas. Significant mature hedgerows and treelines, which also play an important landscape role, provide wildlife corridors and refuge habitats for a broad range of fauna. Many of these sites

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are also adjacent to County or District Wildlife Sites which may be degraded as a consequence of adjacent development plans.

Table 7.1: Scale of Significance: Biodiversity & Landscape - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Major -ve LP6 London Luton Airport Major -ve

LP7 Butterfield Technology Park Major -ve LP8 Napier Park Minor, Mixed

LP9 Power Court Minor, Mixed LP10 High Town Neg.,-ve

LP11 Creative Quarter Minor, Mixed LP12 Marsh Farm Neg.,-ve

7.3.4 It is recommended that, wherever possible, pre-existing features such as these should be incorporated into the layout of new developments at the masterplanning stage. Opportunities should be sought to link-up currently fragmented habitats through landscaping proposals. And where Sustainable Urban Drainage systems are a practical option given the Source Protection Zone, these provide opportunities to create extensive, interlinked wetland and meadow habitats.

7.3.5 The other, larger brownfield sites (Power Court, Napier Park, and to a lesser extent the Creative Quarter), while not without the risk of impacts, present substantial opportunities for ecological gain. Again this could be achieved by increasing the coverage of semi-natural habitats, but also by linking with other valuable features nearby. For example, Napier Park is adjacent to Church Cemetery CWS which provides the opportunity to bring natural areas into the heart of the new neighbourhood. Meanwhile Power Court and the Creative Quarter are dissected by the culverted River Lea CWS/DWS which, if space and viability allows, could be de-culverted to create new riverine habitats and open spaces. Proposals at High Town and Marsh Farm are less extensive and provide fewer opportunities for enhancement, but a general greening of the environment and increase in parkland and/or tree cover will be of benefit.

7.3.6 Overall, while some potentially significant site-specific impacts to biodiversity and landscape are possible without proper assessment and management, there is widespread opportunity to improve the ecological value of the borough and protects its important landscapes through implementation of the Local Plan. Proposed policies LP28 and LP29 provide an appropriate framework for assessing the ecological and landscape impacts of development proposals to ensure that effects are avoided or reduced through development management.

SA2: Conserve, enhance and restore green infrastructure

7.3.7 Green infrastructure clearly has a close association with biodiversity and landscape and, to avoid undue repetition, assessments against this objective have generally sought to emphasise the opportunities for improvement unless there is likely to be a significant loss of GI assets. The borough has notable concentrations of GI, particularly along the River Lea, at Dallow Downs and Winsdon Hill to the west, and Stopsley Common and Bradgers Hill to the north. Beyond these, it is peppered with amenity greenspaces and occasional sports pitches, but has few pockets of woodland remaining especially towards more central areas.

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7.3.8 The Strategic Allocations in particular lend themselves to creating extensive multifunctional, biodiverse open spaces, linked to neighbouring assets via new or improved rights of way, to provide a range of health, recreation and ecosystem services through landscaping, drainage proposals and habitat creation. Land south of Stockwood Park, Century Park at London Luton Airport, Butterfield Technology Park, Napier Park and Power Court all offer substantial opportunities of this nature (see Table 7.2), although it is acknowledged that there will be other competing uses for the land. At Land south of Stockwood Park, for example, development provides an opportunity to link with the diverse GI offering in Stockwood Park itself, which includes golf, rugby and athletics, to provide high quality integrated sporting/leisure facilities. Impacts are likely to be negative during construction but, if opportunities are seized, there is potential for significant positive effects.

Table 7.2: Scale of Significance: Green Infrastructure - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Mod. +ve LP6 London Luton Airport Mod. +ve

LP7 Butterfield Technology Park Mod. +ve LP8 Napier Park Mod. +ve

LP9 Power Court Minor +ve LP10 High Town Minor +ve

LP11 Creative Quarter Minor +ve LP12 Marsh Farm Minor +ve

7.3.9 In more constrained urban locations, including the Town Centre, Marsh Farm and High Town, as well as many of the individual site allocations, smaller scale improvements will still be achievable. For example, even at a relatively small scale new areas of parkland (combining amenity grassland within wildflower meadows and low-density tree-planting) can offer health and recreation benefits, urban cooling, biodiversity and surface water attenuation. Even on the smallest sites, developments could be encouraged to incorporate pocket parks, natural and formal play spaces, green roofs/walls, street trees or small urban orchards.

7.3.10 Three of the proposed allocations will lead to a loss of open space. Land at 69 Felstead Way and Land west of Newlands Road (ID 182 and 337) are undeveloped and, while not listed as part of the borough’s green space, will still play a role in the GI network. Retention of wildlife corridor functions is recommended for these sites. The Bramingham Centre site (ID359) will result in the loss of playing fields adjacent to Limbury Riverside Park, leading to minor negative effects. Recommendations for this site are to consider retaining some green space or developing a pocket park and incorporating green roofs/walls into the development, while retaining ecological connectivity to surrounding areas. Proposed policy LP27 provides an appropriate framework for assessing the development proposals which could negatively affect green infrastructure or open spaces to ensure that effects are avoided or reduced through development management.

SA3: Protect and enhance air, soil and water resources

7.3.11 The borough sits atop of a major drinking water aquifer and is largely covered by a Source Protection Zone (SPZ). It is dissected by the River Lea, in culvert in central locations, and of poor ecological water quality. Cat Brook and Houghton Brook are both of moderate water quality. The vast majority of the borough is previously developed and several development

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sites may be affected by contamination due to prior industrial uses, but where greenfield land remains, the quality of agricultural land is better to the north of the borough than the south. Over the past six years 99% of residential developments have occurred on previously developed land; the figure drops to 80% over three years for employment land. There are four Air Quality Management Areas, all associated with the M1, but air quality also suffers around the airport.

7.3.12 The assessment findings predict negative effects against SA3 for virtually every site, including the Strategic Allocations (see Table 7.3), predominantly because of the potential for mobilising contaminants into surface and groundwater and the risk of it entering the SPZ. This could limit the ability to incorporate Sustainable Drainage Systems (SuDS) within new development proposals, with possible indirect effects for flood risk by reducing the options available for sustainably managing surface water. The effect is capable of being mitigated at the strategic scale by requiring development proposals to be supported by site investigations, and requiring remediation strategies to be accompanied by Construction Environmental Management Plan (CEMP) to reduce and manage the risk of mobilising contaminants. Within the Town Centre, impacts may result from a number of sites and a strategic approach to remediation and surface water management may be appropriate, while opportunities to open-up culverted sections of the Lea and improve water quality should be encouraged.

Table 7.3: Scale of Significance: Air, water, soil - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Minor -ve LP6 London Luton Airport Minor -ve

LP7 Butterfield Technology Park Minor -ve LP8 Napier Park Minor -ve

LP9 Power Court Minor -ve LP10 High Town Minor -ve

LP11 Creative Quarter Minor -ve LP12 Marsh Farm Minor -ve

7.3.13 Regarding air pollution, the assessment considers both the risk presented to proposed site allocations from existing pollution sources, and the proposals contribution to pollution principally as a result of associated traffic. Site accessibility to sustainable transport modes is hence an important consideration as this will help to reduce reliance on car transport. Recommendations therefore focus on improving links to the sustainable transport network, particularly for edge-of-centre locations, and providing on site cycle facilities.

7.3.14 Turning to soil, the assessment highlights where proposed development could lead to a permanent loss of remaining soil resources including at Land south of Stockwood Park, Century Park and Butterfield Technology Park, and recommends that soils could be removed prior to construction, stored and re-used for landscaping and habitat creation elsewhere on site. In addition to these Strategic Allocations, one further site would lead to a loss of agricultural land; Land west of Newlands Road (ID337).

7.3.15 Overall, the Local Plan can be expected to lead to localised increases in air pollution as a result of traffic associated with residential, employment and retail proposals. However, it is a generally sustainable location to focus such development, being served by three train stations, a guided busway, and extensive bus and cycle networks. Loss of soil resources is expected to

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be limited in extent, while pollution to ground and surface waters is capable of being mitigated through the development management process. Proposed policy LP38 provides a suitable framework for requiring development proposals to take account of their potential pollution impacts, and preventing inappropriate proposals through the development management process.

SA4: Protect areas that are at risk from flooding and reduce flood risk

7.3.16 Parts of the borough close to the River Lea are subject to fluvial flood risk, with relatively extensive areas of land within Flood Zone (FZ) 2 or 3 around Leagrave, Icknield and north of the Town Centre. Most of the central part of the borough, from the Town Centre northwards, is subject to a degree of risk from sewer flooding. Most of the Strategic Allocations are not constrained by flood risk – see Table 7.4.

Table 7.4: Scale of Significance: Flood risk - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Neutral LP6 London Luton Airport Neutral

LP7 Butterfield Technology Park Neutral LP8 Napier Park Neutral

LP9 Power Court Minor -ve LP10 High Town Minor -ve

LP11 Creative Quarter Minor -ve LP12 Marsh Farm Neutral

7.3.17 Ten proposed site allocations are subject to some degree of flood risk, the worst affected being Car park at Telford Way (ID176), 40-58 Collingdon Street (ID352) and the Bramingham Centre (ID359), while redevelopments throughout the Town Centre, Creative Quarter and High Town will need to take account of the risk of sewer flooding. Recommendations to address these risks include requiring new development to separate surface and foul water outfalls to reduce pressure on sewer capacity, and de-culverting the River Lea where feasible. Development can facilitate de-culverting and the restoration of riverine habitats at sites such as Power Court, which can help to ease flood risk across the town. Proposed policy LP36 contains a comprehensive suite of measures to ensure development addresses the risk of flooding, including the use of SuDS to attenuate surface water flows, however, given the presence of an SPZ covering much of the town, SuDS will need to be carefully designed and implemented in order to avoid negatively affecting ground water.

7.3.18 Overall, the Local Plan is considered to be neutral with regard to flood risk. Although some sites proposed for allocation are affected by flood risk, proposed policy LP36 deals with this and ensures there is no increase in flood risk elsewhere as a result of development.

SA5: Reduce carbon emissions

7.3.19 Between 2005 and 2011, carbon emissions in Luton were below regional and national benchmarks, with an overall decrease in emissions from 5.5 to 4.1 tonnes per capita. Local emissions have been consistently below regional and national averages.

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7.3.20 Proposed site allocations are considered neutral in relation to this objective because, although they may contribute to a minor overall increase in carbon emissions in the borough (by contributing to an increased population) they are unlikely to change per capita emissions. Larger scale developments, such as those planned for the Town Centre and Strategic Allocations, are assessed as having a minor negative effect on carbon emissions (see Table 7.5, particularly during the construction phase and in early stages of operation before initiatives such as district heating (where applicable) come on online. Construction and operation phase traffic-related emissions are also a consideration (see also above: SA3).

Table 7.5: Scale of Significance: Carbon emissions - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Minor -ve LP6 London Luton Airport Major -ve

LP7 Butterfield Technology Park Minor -ve LP8 Napier Park Minor -ve

LP9 Power Court Minor -ve LP10 High Town Neutral

LP11 Creative Quarter Neutral LP12 Marsh Farm Neutral

7.3.21 Proposed policy LP6 London Luton Airport is assessed as having a major negative impact on carbon emissions due to the scale of development, its edge-of-centre position and associated traffic emissions, and airport expansion which will inevitably lead to increased carbon emissions contributing to global climate change. The Local Plan is not feasibly capable of mitigating the impact of airport expansion which is driven by wider trends and policy at the national level.

7.3.22 Recommended mitigation measures include initiatives such as district heating, which may particularly suited to larger Strategic Allocations such as LP5, LP6 (Century Park), LP7, LP8 and LP9. Areas of tree cover should be retained or re-provided where possible, as these will both act as carbon sinks and provide an urban cooling function. All proposed sites should consider installing renewable energy including solar thermal or photovoltaic, micro wind turbines, ground-source heat pumps or Combined Heat and Power (CHP). Proposed policy LP37 requires proposals to consider the energy hierarchy during design, to incorporate decentralised energy generation where possible, or to plan for allowable solutions to make equivalent carbon savings when providing decentralised energy generation on site is not feasible. It also requires every proposal to be accompanied by an Energy Statement (either standalone or within the Design and Access Statement).

SA6: Increase resource efficiency and reduce resource use and waste

7.3.23 Consumption patterns in Luton are broadly comparable with national and regional averages. Water consumption is estimated to 160 litres per person per day (l/p/d), compared to a national average of 150l/p/d, and a Water Resource Management Plan target for 2031 of 152l/p/d, and a Water Cycle Study recommendation of 105l/p/d. Domestic gas consumption is higher than the regional average but falling, and electricity consumption is lower than the regional average and also falling. Household and municipal recycling rates are behind the national targets but increasing.

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7.3.24 The overwhelming majority of proposed site allocations, and many of the Strategic Allocations (Table 7.6), are on previously developed land (see also SA3). The Local Plan is predicted to drive local resource consumption as a result of its development and regeneration proposals, with minor negative effects for this objective. On a per site basis, this effect is expected to be short- to medium-term and limited to the construction phase. Operational schemes are unlikely to significantly increase resource consumption on a per capita basis, and may in fact help to reduce them as a result of better building performance and technology.

Table 7.6: Scale of Significance: Resource efficiency - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Minor -ve LP6 London Luton Airport Major -ve

LP7 Butterfield Technology Park Minor -ve LP8 Napier Park Minor -ve

LP9 Power Court Minor -ve LP10 High Town Minor +ve

LP11 Creative Quarter Minor +ve LP12 Marsh Farm Minor +ve

7.3.25 Recommended mitigation for these effects includes re-using materials during construction, and encouraging recycling during operation. For brownfield sites, therefore, waste materials produced during demolition and groundworks should be re-used on site wherever possible, or re-processed off site for future use in aggregates. On larger sites, soils removed during ground preparation prior to construction could be stored and re-used for landscaping and habitat creation elsewhere on site. All proposals with a significant residential element should provide adequate storage space for recycling and consider providing communal composting facilities.

SA7: Identify, protect, maintain and enhance heritage assets and their setting

7.3.26 The borough is graced with 102 listed buildings, two Scheduled Ancient Monuments (SAM), two registered parks/gardens, five conservation areas and a range or archaeologically important areas associated with the area’s Neolithic, Roman, medieval and industrial history. Given this rich heritage, it is unsurprising that many of the Strategic Allocations and proposed site allocations have the potential to negatively affect heritage assets or their setting.

Table 7.7: Scale of Significance: Heritage assets - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Neutral LP6 London Luton Airport Major -ve

LP7 Butterfield Technology Park Minor -ve LP8 Napier Park Neg. -ve

LP9 Power Court Minor -ve LP10 High Town Minor +ve

LP11 Creative Quarter Minor mixed LP12 Marsh Farm Minor +ve

7.3.27 Butterfield Technology Park (LP7) is particularly constrained in this respect as it includes and is surrounded by several archaeological areas. HER15528 (Romano British pot & tile) is within the site, and earthworks at Whitehill Farm (now ploughed; HER5474) is partially on site. HER12399, a triangular green shown on 1842 map which has produced medieval pottery, is also partially on

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site. Swifts Green medieval settlement (HER17099) and earthworks at Manor Farm (HER 3341) are both adjacent to south, while HER15527 is adjacent to the north, and HER15526 is nearby to north-west. Power Court, the Town Centre and Creative Quarter all overlie the site of Medieval Luton while also containing several listed buildings and being covered by conservation areas to a greater or lesser extent. Some sites currently have a negative impact on neighbouring heritage assets. For example, the derelict Power Court degrades the setting of the Grade 1 listed St. Mary’s Church. While development may damage heritage if not conducted sensitively, appropriate redevelopment can address current, negative impacts.

7.3.28 Conversely, proposals for the High Town, Creative Quarter and Marsh Farm are expected to lead to positive effects in the long-term despite the risk of negative impacts during construction. These policies are particularly aimed at regeneration and improving the quality of the environment which, if implemented sensitively, is expected to lead to an overall improvement in the setting of heritage features.

7.3.29 Impacts as a result of these schemes, and others similarly affected, are possible through the loss of or damage to buried assets, particularly in early stages of development. Building designs and layout will need to ensure an appropriate selection of materials to ensure that the setting of heritage features is not compromised, and that important views are maintained. Recommendations for mitigating site-level impacts are also given, such as building protection measures for listed buildings, and requiring Heritage Statements to be prepared. Where evidence points to potential presence of remains, further mitigation will be required (e.g. investigative trenching, watching brief, recovery and interpretation of remains). Proposed policy LP 30 contains a suitable policy framework for ensuring that development proposals respond to the historic environment, and for taking this into account during the development management process.

SA8: Reduce poverty and inequality and promote social inclusion

7.3.30 In 2010, nine out of Luton’s 121 lower super output areas were amongst the 10% most deprived in England: 2 in Northwell; 1 in High Town, 2 in Dallow, 2 in Biscot, 1 in Farley and 1 in South. Deprivation has increased in Luton between 2004 and 2010. In general, and especially through the Strategic Allocations (Table 7.8), the Local Plan is expected to have a significant positive effect on this objective, albeit largely indirectly through contributions to Objective 11 (decent, affordable homes) and Objective 14 (employment, learning and skills).

Table 7.8: Scale of Significance: Poverty & social inclusion - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Mod. +ve LP6 London Luton Airport Mod. +ve

LP7 Butterfield Technology Park Mod. +ve LP8 Napier Park Mod. +ve

LP9 Power Court Mod. +ve LP10 High Town Minor +ve

LP11 Creative Quarter Mod. +ve LP12 Marsh Farm Neg. +ve

7.3.31 Whilst mitigation is not specifically required because the effect overall is predicted to be positive, recommendations are made to help maximise beneficial effects. These focus on

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providing opportunities for work-based training during the construction phase, incorporating business incubator facilities into larger schemes, and providing for live-work units in locations such as the Creative Quarter (already a policy requirement).

SA9: Reduce crime and the fear of crime

7.3.32 Rates of crime in Luton are higher than the regional and national averages. A number of the Strategic Allocations, those for High Town and Marsh Farm in particular, specifically target a reduction in crime and the fear of crime by aiming to improve environmental quality, increase footfall and natural surveillance, enhance the public realm and increase accessibility and permeability. So long as comprehensive proposals come forward to implement these policies, significant beneficial effects should be achieved.

Table 7.9: Scale of Significance: Crime - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Neutral LP6 London Luton Airport Neutral

LP7 Butterfield Technology Park Neutral LP8 Napier Park Minor +ve

LP9 Power Court Minor +ve LP10 High Town Mod. +ve

LP11 Creative Quarter Minor +ve LP12 Marsh Farm Mod. +ve

7.3.33 A range of proposed site allocations will perform a similar function albeit on a smaller scale. For example, Land at Guardian Estate (ID 155), Oxen Industrial Estate (ID161), car park off Telford Way (ID176), Dalroad Industrial Estate (ID180), and car park adjacent to 95 Maple Road East (ID353) are all expected to result in increased activity and natural surveillance post-development when compared to their current use. Proposals for Luton Town Football Club’s current ground at (ID220) are predicted to have added positive impacts by reducing crowd- related safety issues and antisocial behaviour in what is otherwise a largely residential area. These beneficial impacts should be highlighted when deciding on the location for suitable replacement grounds.

7.3.34 Overall the Local Plan is predicted to have positive effects on this objective.

SA10: Encourage healthier lifestyles and reduce the adverse health impacts of new developments

7.3.35 The borough suffers from health deprivation and life expectancy in Luton has been consistently worse than the national average despite increasing between 2001 and 2009. Adult participation in sport has decreased between 2005 and 2011. Strategic Allocations and proposed site allocations were assessed with regard to the sites’ current accessibility to healthcare facilities (hospital, GP, pharmacy or dentist) as well as distance to the nearest sports facilities.

7.3.36 Generally speaking, the Local Plan is expected have positive effects on health and healthy lifestyles, reflecting the relatively high levels of accessibility across the borough. All of the Strategic Allocations and many of the site allocations are expected to lead to positive effects. The health benefits of Land south of Stockwood Park are notable through provision of

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additional sports/training facilities, and could be significant particularly if combined with recommended links to existing facilities at Stockwood Park, green infrastructure and cycle routes.

Table 7.10: Scale of Significance: Health - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Mod. +ve LP6 London Luton Airport Minor +ve

LP7 Butterfield Technology Park Minor +ve LP8 Napier Park Neg. +ve

LP9 Power Court Neg. +ve LP10 High Town Neg. +ve

LP11 Creative Quarter Neg. +ve LP12 Marsh Farm Minor +ve

7.3.37 Where negative effects are predicted, recommendations aim to improve the site’s accessibility to sports facilities, open space, or cycle routes, including through the provision of pocket parks and play spaces. Where playing fields are to be lost through proposed development, it is recommended that the facility is re-provided nearby in accordance with LP27. Alternatively, where the site is proposed for allocation because there is a surplus of one kind of open space in the locality, improvements could be made to open spaces in a different typology.

SA11: Provide decent, affordable and safe homes for all

7.3.38 Dwelling vacancy rates in Luton are favourable when compared to regional and national averages, but the supply of new affordable housing has been variable and well below identified needs in recent years. The five year average to 2009/10 was 124 new affordable homes per year against a need of 400 per year between 2007 and 2021. The number of people on housing waiting lists has steadily increased between 2005 and 2011 and currently stands at 6.5% of all households, slightly above the regional average of 6.4% but below the national average of 8.2%.

Table 7.11: Scale of Significance: Housing - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Neutral LP6 London Luton Airport Neutral

LP7 Butterfield Technology Park Neutral LP8 Napier Park Mod. +ve

LP9 Power Court Mod. +ve LP10 High Town Minor +ve

LP11 Creative Quarter Mod. +ve LP12 Marsh Farm Neg. +ve

7.3.39 The Local Plan is expected to have a major positive effect on the provision of homes, including affordable homes, despite the constrained land supply which requires Luton to look beyond its boundaries to meet housing need. Policy LP16 stipulates that 20% of all dwellings provided should be affordable, or an equivalent financial contribution be made, subject to viability. Policies LP15 to LP20 target a range of factors related to housing, including size, density, type, tenure and provision for gypsies, travellers and travelling showpeople, while the decency of homes is also addressed in policies on design and sustainability.

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SA12: Support vitality and viability of centres

7.3.40 Shopping yields in Luton town centre have remained steady and compare favourably to other centres in the local region. Yields are better in Milton Keynes and Watford, reflecting their higher position in the retail hierarchy. Vacancy rates in Luton are slightly better than the national average.

7.3.41 The Local Plan is predicted to lead to significant positive effects for the ongoing vitality and viability of centres, Strategic Allocations at Napier Park and Power Court in particular. Napier Park will bring a large vacant site on the edge of the Town Centre back into use by providing for a new neighbourhood with facilities to serve its inhabitants. Redevelopment of Power Court will help meet identified needs for convenience retail floorspace within the Town Centre and make more productive use of the land available, while also providing new Town Centre homes. Proposals to regenerate High Town and Marsh Farm, though more difficult to achieve, are expected to make substantial contributions to the vitality and viability of these centres. These policies are supported by a new centre hierarchy which adds the new classification of Neighbourhood Centre.

7.3.42 Conversely, LP5, LP6 and LP7 are assessed as having minor negative effects because of their out-of-centre locations, which could negatively affect the Town Centre by decreasing the relative attractiveness of the latter for new investment. This is, however, expected to be a short- to medium-term impact and there are no other identified, alternative options as to where significant levels of equivalent development could be delivered. While development at the airport is considered to have a minor negative effect, this is likely to be counter balanced by benefits of economic growth and investment confidence in the town including for visitors, workers and businesses. This would generate revenue that can be used to increase the delivery of services, accessibility and viability of the town and other centres.

Table 7.12: Scale of Significance: Vitality of centres – Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Minor -ve LP6 London Luton Airport Minor -ve

LP7 Butterfield Technology Park Minor -ve LP8 Napier Park Mod. +ve

LP9 Power Court Mod. +ve LP10 High Town Mod. +ve

LP11 Creative Quarter Mod. +ve LP12 Marsh Farm Mod. +ve

SA13: Provide and encourage the use of sustainable integrated transport systems, improve access and mobility

7.3.43 All areas of Luton generally enjoy excellent access to services. The hospital is situated to the west, resulting in long walking times from areas in the east of the town. Walking access to major retail centres (town centres) is a concern for those in peripheral areas. Compared to regional and national averages, Luton residents have a good utilisation of travel by bus/ coach, car-sharing, taxi and on foot. There is lower than average use of motorcycles/ scooters, bicycles and home-working.

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7.3.44 The Local Plan allocations aim to promote higher density development close to centres and locations with better accessibility to high quality public transport, including the Luton-Dunstable Busway, as reflected in the positive assessment against this objective achieved by many of the individual site allocations. As indicated above, there are some exceptions in the Strategic Allocations such as LP5, LP6 and LP7 which are assessed as having minor mixed effects because of their edge-of-centre locations. However, the policies for these sites include objectives to provide for sustainable transport such Park and Ride and connections to the Busway.

7.3.45 A number of proposed site allocations are predicted to have negative effects. This is largely as a result of their poor accessibility to facilities or current transport networks and recommendations include maximising provision for sustainable transport modes (such as cycle facilities) and improved pedestrian links to public transport.

Table 7.13: Scale of Significance: Transport & accessibility - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Minor mixed LP6 London Luton Airport Minor mixed

LP7 Butterfield Technology Park Minor mixed LP8 Napier Park Minor +ve

LP9 Power Court Minor +ve LP10 High Town Minor +ve

LP11 Creative Quarter Minor +ve LP12 Marsh Farm Minor +ve

SA14: Promote employment, learning, skills and innovation

7.3.46 The percentage of the working-age population in employment is declining in Luton and is lower than regional and national benchmarks. The distribution of jobs by type shows an increase in lower-skilled jobs being due to the creation of more jobs at that level and due to a loss of employment opportunities in higher-skilled positions. There are more people employed in lower skilled jobs and less in higher skilled jobs than seen in the regional and national benchmarks. The percentage of residents aged 16-64 with NVQ-equivalent qualifications is increasing but below regional and national benchmarks.

7.3.47 Overall the Local Plan is assessed as having major beneficial effects by retaining the best employment areas, allocating new high quality sites for additional employment uses and targeting existing strengths in technology, aviation, media and creative industries, and a strong retail offering. This is particularly reflected in assessments for Land south of Stockwood Park, London Luton Airport, Butterfield Technology Park, Power Court, Napier Park and the Creative Quarter. The minor negative impacts that result from the loss of some smaller, lower quality employment sites due to allocation for residential development is considered to be largely offset by the Strategic Allocations.

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Table 7.14: Scale of Significance: Employment, learning & skills - Strategic Allocations

Strategic Allocation Scale Strategic Allocation Scale

LP5 Land South of Stockwood Park Major +ve LP6 London Luton Airport Mod. +ve

LP7 Butterfield Technology Park Major +ve LP8 Napier Park Mod. +ve

LP9 Power Court Mod. +ve LP10 High Town Minor +ve

LP11 Creative Quarter Mod. +ve LP12 Marsh Farm Neg. +ve

7.4 Cumulative Effects Assessment

7.4.1 The results of the cumulative effects assessment are presented in Table 7.15.

Table 7.15: Cumulative, synergistic and indirect effects

SA Objective Proposals which combine to bring Significance cumulative/synergistic effects

1.Maintain and LP1, LP3, LP4, LP25-29, LP36, LP38 have Significant positive effects over enhance biodiversity, cumulative and synergistic effects by the short, medium and long term habitat and landscape providing for retention of habitats and landscapes or offering opportunities for biodiversity gain Significant negative effects over LP5, LP6, LP7, LP10, LP12, LP24 have the short to medium term in cumulative and synergistic effects particular through losses of semi-natural habitats

although many impacts are capable of

being mitigated Significant negative effects LP2, LP8, LP9, LP11 have mixed and expected over the short term, but indirect effects on biodiversity and positive over the medium to long landscapes while remaining policies are term considered neutral

2. Conserve, restore LP1, LP3, LP4, LP5, LP6, LP7, LP8, LP9, Significant positive effects over and enhance green LP10, LP11, LP12, LP25, LP27-29, LP36, the short, medium and long term infrastructure LP38, LP39 have cumulative and synergistic effects by providing opportunities for new, improved green infrastructure, or better linkages between existing assets LP2, LP24 have mixed impacts while remaining policies are considered neutral

3. Protect and LP1, LP4, LP21-23, LP27, LP31, LP36-39 Significant positive effects over enhance air, soil and have cumulative and synergistic effects the short, medium and long term water resources by protecting air, soil and water resources

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SA Objective Proposals which combine to bring Significance cumulative/synergistic effects

LP3, LP5, LP6, LP7, LP8, LP9, LP10, Significant negative effects over LP11, LP12 have cumulative and the short to medium term in synergistic effects through loss of soil particular

resources or increased pollution to air and water although many impacts are capable of being mitigated LP2, LP13, LP15, LP32, LP33 have mixed impacts while remaining policies are considered neutral

4. Protect areas that LP3, LP9, LP10, LP11 have cumulative Significant negative effects over are at risk from and synergistic effects by promoting the short, medium and long term flooding and reduce development in or close to areas at risk flood risk of fluvial or sewer flooding LP1, LP36, LP37, LP39 have cumulative and synergistic effects by promoting climate change adaptation LP2 has mixed impacts while remaining policies are considered neutral

5.Reduce carbon LP2, LP3, LP5, LP6, LP7, LP8, LP9 have Significant negative effects over emissions cumulative and synergistic effects by the short, medium and long term promoting development in a location that is likely to increase reliance on car transport LP1, LP, LP21-23, LP25, LP37 have Significant positive effects over cumulative and synergistic effects by the short, medium and long term promoting accessibility, good design and carbon reduction LP13 and LP31-33 are mixed while remaining policies are considered neutral

6. Increase resource LP1, LP4, LP10, LP11, LP12, LP14, LP15, Significant positive effects over efficiency and reduce LP17, LP20, LP24, LP25, LP27, LP30, the short, medium and long term resource use and LP37, LP38 have cumulative and waste synergistic effects by promoting an efficient use of land LP3, LP5, LP6, LP7, LP8, LP9 have Significant negative effects over cumulative and synergistic effects by the short, medium and long term promoting development on land of agricultural value LP2, LP13 have mixed impacts while the remaining policies are considered neutral

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SA Objective Proposals which combine to bring Significance cumulative/synergistic effects

7. Identify, protect, LP1, LP4, LP10, LP12, LP18, LP25-27, Significant positive effects over maintain and enhance LP29-30 have cumulative and the short, medium and long term heritage assets and synergistic effects by promoting the their setting reuse of historic buildings or regeneration of conservation areas LP3, LP6, LP7, LP9 have cumulative and Significant negative effects over synergistic effects by allocating the short, medium and long term development in areas which may have unknown heritage assets Significant negative effects LP2, LP11 have mixed and indirect expected over the short term, but effects on heritage assets. Remaining positive over the medium to long policies are considered neutral term

8. Reduce poverty and LP1, LP2, LP3, LP5-25, LP27, LP29, LP30, Significant positive effects over inequality and LP39 have cumulative and synergistic the short, medium and long term promote social effects by encouraging social inclusion inclusion and helping to reduce poverty. Remaining policies are considered neutral

9. Reduce crime and LP1, LP3, LP8, LP9, LP10, LP11, LP12, Significant positive effects over fear of crime LP24, LP25, LP39 have cumulative and the short, medium and long term synergistic effects by helping to reduce crime. Remaining policies are considered neutral

10. Encourage LP1, LP3, LP4, LP5, LP6, LP7, LP8, LP9, Significant positive effects over healthier lifestyles and LP10, LP12, LP22, LP23, LP25, LP27-29, the short, medium and long term reduce adverse health LP31, LP32, LP34, LP36, LP38, LP39 impacts of new have cumulative and synergistic effects developments by encouraging healthy lifestyles LP2 and LP24 have mixed effects. Remaining policies are considered neutral

11.Provide decent, LP1, LP2, LP3, LP8, LP9, LP10, LP11, Significant positive effects over affordable and safe LP14-20, LP25, LP36, LP37 have the short, medium and long term homes for all cumulative and synergistic effects by providing for significant numbers of new homes. Remaining policies are considered neutral

12. Support vitality LP1, LP2, LP3, LP4, LP8, LP9, LP10, Significant positive effects over and viability of centres LP11, LP12, LP13, LP14, LP15, LP16, the short, medium and long term LP21-23, LP25, LP27-33, LP35-36, LP39 have cumulative and synergistic effects by helping to regenerate town and district centres

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SA Objective Proposals which combine to bring Significance cumulative/synergistic effects

LP5, LP6, LP7 have cumulative and Significant negative effects over synergistic effects by promoting the short, medium and long term development in out-of centre locations. Remaining policies are considered neutral

13. Provide and LP1, LP3, LP4, LP8, LP9, LP10, LP11, Significant positive effects over encourage the use of LP12, LP15, LP18, LP20-25, LP27, LP29, the short, medium and long term sustainable integrated LP31-33, LP35, LP39 have cumulative transport systems, and synergistic effects by promoting improve access and development in accessible locations mobility LP2, LP5, LP6, LP7, LP13 have mixed effects by promoting development Significant positive and negative edge-of centre locations and providing effects over the short, medium for better transport links. Remaining and long term policies are considered neutral

14. Promote LP1, LP2, LP3, LP4-11, LP13, LP14, LP24 Significant positive effects over employment, learning, and LP35 have cumulative and the short, medium and long term skills and innovation synergistic effects by promoting employment development and providing for improved skills. The remaining policies are considered neutral

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8 Mitigation and Monitoring

8.1 Summary of Mitigation

8.1.1 Table 8.1 summarises the range of mitigation measures proposed through the SA process to date. Many of these measures are recommended against proposals which are predicted to have positive effects, and are therefore intended to help maximise the positive sustainability effects of implementing the policy or proposal.

Table 8.1: Summary of proposed mitigation

SA Objective Mitigation Recommended

1.Maintain and Ecological surveys and assessment will be required for most sites to establish which enhance (if any) protected species may be using the site and to design a suitable mitigation biodiversity, strategy. Habitats of greatest interest should be retained (e.g. woodland, habitat and hedgerows, mature/veteran trees, ponds, etc) and incorporated into development landscape layout. New biodiverse habitats should be created via landscaping plans, both to reduce landscape & visual impacts and to increase robustness of existing habitats or adjacent designated sites. New habitats could include new woodlands, treebelts and hedgerows, parkland, tree-lined avenues, wildflower meadows and wetlands associated with sustainable drainage measures. Other measures include:  Site layout should seek to retain & increase coverage of trees, hedges & other natural features wherever possible, especially TPO trees. Root protected areas to be implemented during construction.  Opportunities for habitat creation could focus on proposals for River Lea de- culverting (if feasible) as well as new parkland and tree-lined avenues.  It is recommended that native flora is used.  An LVIA should be carried out to assess impacts (if any) to AGLV.  Opportunities to provide habitat linkages with other green space in the area could be explored.  Development should seek to enhance/protect local wildlife sites for instance by implementation of native planting scheme, improvement of footpath network or provision of interpretation boards.  Construction should be carried out under a CEMP to avoid potential impacts to the river and/or adjacent habitats.

2. Conserve, Overall GI provision could be enhanced, where viability allows, by creating additional restore and multifunctional, biodiverse open spaces permeating throughout development sites, enhance green particularly larger sites and Strategic Allocations, providing a range of health, infrastructure recreation and ecosystem services through landscaping and habitat creation. Opportunities to de-culvert River Lea in combination with new public spaces to provide multifunctional, biodiverse open spaces. Other measures include:  Opportunities to provide new greenspaces, parkland and town squares,

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SA Objective Mitigation Recommended street trees, green walls/roofs should be explored.  Enhance ecological connectivity in wider area for species moving through development from adjacent areas of semi-natural habitats and local wildlife sites through wildlife corridors and connected undeveloped land.

3. Protect and Retention/strengthening of tree-lines along boundaries of sites close to existing enhance air, sources of air pollution, such as the M1 and airport, may help reduce air pollution soil and water impact (and possibly noise attenuation barrier although development not highly resources sensitive). Opportunity to extend the guided bus way should be pursued. Other measures include:  Following site investigation, design of remediation strategies should include a CEMP to reduce and manage risk of mobilising contaminants.  Sustainable transport measures should be maximised (e.g. onsite cycle parking facilities, strengthened links to public transport).  Impacts may result from a number of sites within Luton town centre; a strategic approach to remediation / surface water management may be appropriate. The policy already promotes sustainable transport measures  Soils within built footprint could be removed prior to development for re-use in landscaping and habitat creation elsewhere on site.

4. Protect  New and re-developments should be required to separate foul and surface areas that are water drainage outfalls to reduce pressure on sewer capacity. at risk from  De-culverting proposals will help to reduce flood risk upstream by creating flooding and more space for water, but adjacent land uses will need to be water reduce flood compatible or made flood resilient. risk  SuDS may not be suitable in all locations given Source Protection Zone.  Opportunity to create extensive new wetland habitats as part of sustainable drainage plans.

5.Reduce  District heating type initiatives could be particularly suitable for larger carbon strategic sites. emissions  All sites should consider use of renewable energy (e.g. solar thermal/PV, micro wind, ground source heat, CHP etc.).  Areas of tree cover (carbon sink, urban cooling) should be retained / re- provided where possible.

6. Increase  Waste materials produced during demolition and groundworks should be re- resource used on site wherever possible, or re-processed off site for future use in efficiency and aggregates. reduce  Soils within built footprint of proposed developments could be removed resource use prior to construction for re-use in landscaping and habitat creation elsewhere and waste on site.

7. Identify,  As required by LP30, it should be possible to reduce most negative effects protect, via high quality designs which respond to and enhance the setting of maintain and historical features, and use an appropriate selection of materials. enhance  Heritage Statements should be prepared for sites with heritage constraints heritage assets and, where evidence points to potential presence of remains, mitigation and their should be implemented (e.g. investigative trenching, watching brief, recovery

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SA Objective Mitigation Recommended setting & interpretation of remains).

8. Reduce  Opportunities to provide work-based training during construction should be poverty and explored; inequality and  Provision for live/work units would be suitable for some sites. promote social inclusion

9. Reduce None. crime and fear of crime

10. Encourage  Opportunities to provide play space, pockets parks, fitness trails or improved healthier access to cycle routes should be explored. lifestyles and reduce adverse health impacts of new developments

11.Provide None decent, affordable and safe homes for all

12. Support None vitality and viability of centres

13. Provide  Opportunities exist to extend the guided busway and improve connections and encourage to rail stations and cycle links. the use of  Sustainable transport measures should be maximised (e.g. onsite cycle sustainable facilities such as bicycle parking). integrated transport systems, improve access and mobility

14. Promote  Opportunities to provide work-based training during construction should be employment, explored; provision for business incubator and/or live/work units may be learning, skills suitable on some sites. and innovation

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8.2 Requirements for Monitoring

8.2.1 The SEA Directive states that “Member States shall monitor the significant environmental effects of the implementation of plans and programmes in order, inter alia, to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action” (Article 10.1). In addition, the Environmental Report (or Sustainability Report) should provide “… a description of the measures envisaged concerning monitoring” (Annex I (i)).

8.2.2 The SA monitoring framework should be targeted towards the aspects of the environmental, social and economic baseline which are assessed as likely to be significantly affected during implementation of the plan. Ideally SA monitoring proposals should be aligned with or incorporated within monitoring that is scheduled for the plan itself, both to avoid duplication and ensure that appropriate remedial action can be taken.

8.2.3 Monitoring is particularly useful in helping to answer the following questions:

 Were the assessment’s predictions of sustainability effects accurate?

 Is the plan contributing to the achievement of desired sustainability objectives?

 Are mitigation measures performing as well as expected?

 Are there any unforeseen adverse effects? Are these within acceptable limits, or is remedial action required?

8.3 Preliminary Monitoring Proposals

8.3.1 Table 8.2 provides preliminary proposals for a programme of monitoring to measure the plan’s performance in relation to the SA Objectives against which significant effects were identified, and seeks to monitor where uncertainties relating to the appraisal findings arose.

8.3.2 The monitoring programme is, at this stage, preliminary and may evolve in response to the results of consultation or changes to the plan. The final monitoring programme will be included in the Post Adoption Statement. Consultees are invited to suggest any further indicators that they feel are necessary or suitable for inclusion in this monitoring programme.

Table 8.2: Proposed monitoring framework

SA Objective Parameter Cycle Action (trigger)

1.Maintain and Changes to the total area of Every two Identify opportunities for enhance biodiversity, locally designated sites (e.g. years habitat management / creation habitat and landscape CWS and DWS) (>5% loss of total area)

Change to the total area of Every two Identify opportunities for natural and semi-natural years habitat management / creation spaces (>5% loss of total area)

2. Conserve, restore Progress towards overall Every two Identify opportunities to and enhance green greenspace provision years increase greenspace infrastructure recommended by draft requirements on existing allocations (Overall provision

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SA Objective Parameter Cycle Action (trigger) greenspace standards worsens against baseline)

Length of culvert removal from Every five Identify alternative approaches River Lea years to de-culverting other than through associated development (0 metres de- culverted)

3. Protect and Area of ALC Grade 3a or Every year Consider introduction of enhance air, soil and above sterilised by stronger policies to protect water resources development remaining land (>5% loss of total area)

Amount (tonnes) of soil reused Every five Consider introduction of within Strategic Allocations years stronger policies to protect remaining land

No. proposals within SPZ1/2 Every two Consider introduction of not accompanied by CEMP years stronger policies

4. Protect areas that No. proposals not Every two Consider introduction of are at risk from accompanied by SuDS years stronger policies flooding and reduce No. dwellings permitted within Every year Consider introduction of flood risk FZ2/3 stronger policies (>0 dwellings)

5.Reduce carbon No. dwellings / amount of Every five Consider introduction of emissions non-resi floorspace designed years stronger policies with district heating

Kilowatt-hours of renewable Every year Consider introduction of energy designed for use within stronger policies development

6. Increase resource Proportion of recycled Every five Consider introduction of efficiency and reduce aggregate / materials years stronger policies resource use and proposed for use within waste Strategic Allocations

7. Identify, protect, Change in number of heritage Every two Case-specific maintain and enhance assets on the at-risk register years heritage assets and their setting

8. Reduce poverty Not required due to positive - - and inequality and effects promote social inclusion

9. Reduce crime and Not required due to positive - - fear of crime effects

10. Encourage Number of air quality Every year Review detailed air quality healthier lifestyles monitoring locations reports to identify potential and reduce adverse recording pollution in excess

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SA Objective Parameter Cycle Action (trigger) health impacts of new of air quality objectives solutions (If no improvement) developments

11.Provide decent, Not required due to positive - - affordable and safe effects homes for all

12. Support vitality Buoyancy of Primary / Every two Work with relevant operators and viability of Secondary Shopping years to understand and address centres Frontages: footfall, viability, reasons for decline vacancy

13. Provide and No. dwellings permitted within Every two Consider introduction of encourage the use of 5min & 10min walking distance years stronger policies sustainable to busway stop or interchange integrated transport Length of new cycle routes Every two Consider introduction of systems, improve adopted years stronger policies access and mobility

14. Promote Not required due to positive - - employment, effects learning, skills and innovation

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9 Summary and Consultation Arrangements

9.1 Summary and Next Steps

9.1.1 The Sustainability Report presents the findings of a combined Sustainability Appraisal and Strategic Environmental Assessment for the Luton Local Plan.

9.1.2 The report accompanies the Draft Local Plan for further consultation subsequent to Regulation 18 of the 2012 Regulations, forming part of the evidence base upon which the plan is based, and incorporates the Environmental Report which is required in accordance with the SEA Directive. It includes an assessment of the reasonable alternatives which were considered during preparation of the plan, and makes recommendations for mitigating and monitoring it significant effects.

9.1.3 Overall, significant long-term positive sustainability effects are predicted to result from the Local Plan, particularly in relation to poverty and social inclusion, green infrastructure, healthy lifestyles, provision of housing, the vitality of centres, and employment learning and skills. Nonetheless, significant negative effects are also predicted, especially in relation to biodiversity, air, soil and water resources, and heritage assets, although many of these impacts are capable of being mitigated.

9.1.4 Following publication of the Draft Local Plan, and its Sustainability Report and evidence base, representations will be analysed by the Council and the SA team. Modifications to both the Local Plan and its Sustainability Appraisal may be made in response to consultation, and any significant changes to the plan will be subject to further appraisal. Further public consultation is scheduled for the Publication Local Plan and its Sustainability Report prior to an Examination in Public.

9.1.5 SEA Regulations 16.3c)(iii) and 16.4 require that a ‘statement’ be made available to accompany the plan, as soon as possible after the adoption of the plan or programme. The purpose of the Post Adoption Statement is to outline how the SA process has informed and influenced the development planning process and demonstrate how consultation on the SA was taken into account. The statement will contain the following information:

 The reasons for choosing the plan as adopted in the light of other reasonable alternatives dealt with;

 How environmental considerations were integrated into the plan;

 How consultation responses were taken into account; and

 Measures that are to be taken to monitor the significant effects of the plan.

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9.2 Consultation Arrangements

9.2.1 The Sustainability Report will be made available for consultation and can be viewed at:

http://www.luton.gov.uk/Environment/Planning/Regional%20and%20local% 20planning/Pages/Planning-policy-evidence.aspx

9.2.2 Alternatively hard copies can be viewed at:

Luton Borough Council, Town Hall, George Street, Luton, Bedfordshire LU1 2BQ

9.2.3 Responses to this consultation exercise should be sent to:

Local Plans Team, Luton Borough Council, Town Hall George Street, Luton, BedfordshireLU1 2BQ [email protected]

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Appendix A: Annex 1 of the SEA Directive

Directive 2001/42/EC of the European Parliament and of the Council on the Assessment of the Effects of Certain Plans and Programmes on the Environment

Annex 1: Information for Environmental Reports (referred to in Article 5(1))

Requirement Location in this SEA 1. An outline of the contents and main objectives of the plan or Sections 1.2 and 3.3 programme, and of its relationship with other relevant plans and programmes. 2. The relevant aspects of the current state of the environment and the Chapter 4 and Scoping likely evolution thereof without implementation of the plan or programme. Report 3. The environmental characteristics of areas likely to be significantly Chapter 4 and Scoping affected. Report 4. Any existing environmental problems which are relevant to the plan or Chapter 4 and Scoping programme including, in particular, those relating to any areas of a Report particular environmental importance, such as areas designated pursuant to Council Directive 79/409/EEC on the conservation of wild birds and the Council Directive 92/43/EEC on the conservation of habitats and species. 5. The environmental protection objectives, established at international, Section3.3, Appendix D Community or Member State level, which are relevant to the plan or and Scoping Report programme and the way those objectives and any environmental considerations have been taken into account during its preparation. 6. The likely significant effects on the environment, including short, medium Chapters 5, 6 and 7, and and long-term effects, permanent and temporary effects, positive and Appendices F, G, H and negative effects, and secondary, cumulative and synergistic effects, on J issues such as biodiversity, population, human health, flora, fauna, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the inter- relationship between these factors. 7. The measures envisaged to prevent, reduce and as fully as possible offset Chapter 8, and any significant adverse effects on the environment of implementing the Appendix J plan or programme. 8. An outline of the reasons for selecting the alternatives dealt with, and a Chapter 5 and Appendix description of how the assessment was undertaken including any difficulties H (such as technical deficiencies or lack of know-how) encountered in compiling the required information. 9. A description of the measures envisaged concerning monitoring in Chapter 8 accordance with regulation 17. 10. A non-technical summary of the information provided under paragraphs Non Technical Summary 1 to 9.

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Appendix B: Site Assessment Criteria

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D Criterion MinRed MaxRed MinAmber MaxAmber MinGreen MaxGreen Dataset UE-0130 Luton Local Plan 1a) Distance to the nearest town or district centre 2000 3000 1000 2000 0 1000 SA\Data\Proposed_Allocations\130816\Centre_Boundaries.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 1b) Distance to the nearest town or district centre 2000 3000 1000 2000 0 1000 2011\Central_area\Central Area CA1.shp UE-0130 Luton Local Plan 1c) Distance to the nearest town or district centre 2000 3000 1000 2000 0 1000 SA\Data\Proposed_Allocations\130816\Centre_Boundaries.shp IMPORT FROM LATEST SPREADSHEETS: GP.xls, Hospitals DH list_2008.xls, 2) Distance to the nearest health centre or GP service 2000 3000 1000 2000 0 1000 Pharmacies.xls 3) Distance to the nearest dental clinic 2000 3000 1000 2000 0 1000 IMPORT FROM LATEST SPREADSHEETS: Dentists.xls 4) Distance to the nearest infant school 2000 3000 1000 2000 0 1000 Constraints/Schools/Schools.shp 5) Distance to the nearest junior school 2000 3000 1000 2000 0 1000 Constraints/Schools/Schools.shp 6) Distance to the nearest secondary school 2000 3000 1000 2000 0 1000 Constraints/Schools/Schools.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton wide\Key 7a) Distance to the nearest employment area 2000 3000 1000 2000 0 1000 Employment Areas EM1.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 7b) Distance to the nearest employment area 2000 3000 1000 2000 0 1000 wide\Capability Green Employment Area EM2.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 7c) Distance to the nearest employment area 2000 3000 1000 2000 0 1000 wide\Wigmore Employment Area EM3.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 7d) Distance to the nearest employment area 2000 3000 1000 2000 0 1000 wide\Kimpton Road Area KR1.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 7e) Distance to the nearest employment area 2000 3000 1000 2000 0 1000 wide\London Luton Airport LLA1.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 7f) Distance to the nearest employment area 2000 3000 1000 2000 0 1000 wide\Butterfield Area BA1.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 7g) Distance to the nearest employment area 2000 3000 1000 2000 0 1000 wide\Central Area CA1.shp 8) Distance to the nearest formal sports/ health and UE-0130 Luton Local Plan SA\Data\Constraints\GreenSpace2013\Green Space fitness facility 2000 3000 1000 2000 0 1000 2013 v2.shp 9) Distance to the nearest open space with formal provision for children 400 3000 200 400 0 200 DIGITISE FROM Map of Luton Identifying Play Areas (5).pdf NOTE: "LOCAL" DELETED UE-0130 Luton Local Plan SA\Data\Constraints\GreenSpace2013\Green Space 10) Distance to nearest open space 600 3000 300 600 0 300 2013 v2.shp 15) Distance to the nearest childcare service (crèche). 2000 3000 1000 2000 0 1000 Constraints/Schools/Schools.shp UE-0130 Luton Local Plan SA\Data\Proposed_Allocations\130816\ELR 16) Loss of viable employment land Loss of 'Green' ELR site Loss of 'Amber' ELR site Loss of 'Red' or no ELR site Estates.shp 17) Distance to the nearest bus stop 400 3000 200 400 0 200 IMPORT FROM: Luton bus stops.xlsx DIGITISE FROM GOOGLEMAP/BING: Leagrave, Luton, Luton Airport 18) Distance to the nearest train station 800 3000 400 800 0 400 Parkway [UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 19a) Distance to the nearest cycle route 400 3000 200 400 0 200 2011\Central_area\Strategic Cycle Network.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 19b) Distance to the nearest cycle route 400 3000 200 400 0 200 wide\National Cycle Network T8.shp 19c) Distance to the nearest cycle route 400 3000 200 400 0 200 Cycle routes 20) Loss of high quality agricultural land Loss of Grade 1 land Loss of Grade 2/3 land Not ALC land mgalcshp.zip

21a) Use of previously developed land PDL Partially PDL Not PDL Draft Local Plan Housing Trajectory for allocations appraisal_160813_for UE.xls UE-0130 Luton Local Plan SA\Data\Constraints\AQMA\Air Quality Management 22a) Distance to areas of poor air quality 0 50 50 50 50 3000 Areas.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 22b) Distance to areas of poor air quality 0 0 0 100 100 3000 wide\London Luton Airport LLA1.shp OS Strategi data (motorways) - 22c) Distance to areas of poor air quality 0 0 0 100 100 3000 https://www.ordnancesurvey.co.uk/opendatadownload/products.html 23) Source Protection Zone SPZ1 SPZ2/3 Not SPZ1/2/3 Envt Agency Source Protection Zones UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 24a) Impact on Scheduled Ancient Monuments 0 10 10 500 500 3000 wide\Scheduled Ancient Monument ENV6.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 24b) Impact on Scheduled Ancient Monuments 0 10 10 500 500 3000 wide\Scheduled Ancient Monument ENV6.shp EH Designated Datasets: http://services.english- 24c) Impact on Scheduled Ancient Monuments 0 10 10 500 500 3000 heritage.org.uk/NMRDataDownload/

UE-0130_Stage2_Comp_Quant_Assess_10_130910_abbreviated DetailedDistances 1 / 2 Criterion MinRed MaxRed MinAmber MaxAmber MinGreen MaxGreen Dataset UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 26a) Impact on historic parks and gardens 0 1 1 100 100 3000 wide\Registered Park & Garden ENV1.shp EH Designated Datasets: http://services.english- 26b) Impact on historic parks and gardens 0 1 1 100 100 3000 heritage.org.uk/NMRDataDownload/ UE-0130 Luton Local Plan 27a) Impact on conservation areas 0 0.1 0.1 50 50 3000 SA\Data\Constraints\Heritage\CONSERVATION_AREAS.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 27b) Impact on conservation areas 0 0.1 0.1 50 50 3000 2011\Central_area\Conservation Area ENV8.shp

UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 28) Impact on Chilterns AONB 0 10 10 500 500 3000 wide\Chilterns Area of Outstanding Natural Beauty ENV1.shp 29) Impact on Sites of Special Scientific Interest (SSSI) 0 10 10 400 400 3000 NE SSSI dataset: http://www.gis.naturalengland.org.uk/pubs/gis/GIS_register.asp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 30) Impact on areas of great landscape value 0 10 10 400 400 3000 wide\Area of Great Landscape Value ENV2.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 31) Impact on areas of local landscape importance 0 10 10 400 400 3000 wide\Area of Local Landscape Importance ENV2.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 32) Impact on Green Belt 0 0.1 0.1 20 20 3000 wide\Green Belt ENV3.shp

UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 33a) Impact on local nature reserves 0 0.1 0.1 20 20 3000 wide\Leagrave Common & Wauluds Bank Proposed Local Nature Reserve ENV5

33b) Impact on local nature reserves 0 0.1 0.1 20 20 3000 NE LNR dataset: http://www.gis.naturalengland.org.uk/pubs/gis/GIS_register.asp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 34a) Impact on county wildlife sites 0 0.1 0.1 20 20 3000 wide\County Wildlife Site ENV5.shp

34b) Impact on county wildlife sites 0 0.1 0.1 20 20 3000 UE-0130 Luton Local Plan SA\Data\Constraints\CWS\CWS_region.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 34c) Impact on county wildlife sites 0 0.1 0.1 20 20 3000 wide\River Lea County Wildlife Site ENV5.shp

35a) Impact on other sites of nature conservation UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton importance 0 0.1 0.1 20 20 3000 wide\Other Site of Nature Conservation Interest ENV5.shp 35b) Impact on other sites of nature conservation importance 0 0.1 0.1 20 20 3000 UE-0130 Luton Local Plan SA\Data\Constraints\DWS\DWS_region.shp UE-0130 Luton Local Plan SA\Data\GIS_Local Plan 2001 to 2011\Luton 36a) Impact on open space. 0 0.1 0.1 20 20 3000 wide\Proposed Green Space LC2.shp UE-0130 Luton Local Plan SA\Data\Constraints\GreenSpace2013\Green Space 36b) Impact on open space. 0 0.1 0.1 20 20 3000 2013 v2.shp UE-0130 Luton Local Plan SA\Data\Constraints\GreenSpace2013\Green Space 37) Impact on allotments 0 0.1 0.1 20 20 3000 2013 v2.shp UE-0130 Luton Local Plan 39a) Flood zone impact FZ3 FZ2 FZ1 or not FZ SA\Data\Constraints\FloodRisk\nat_floodzone2_v201308.shp UE-0130 Luton Local Plan 39b) Flood zone impact FZ3 FZ2 FZ1 or not FZ SA\Data\Constraints\FloodRisk\nat_floodzone3_v201308.shp

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Appendix C: Scoping Consultation Responses

Please see insert.

E

and Planning Transportation

Scoping Report for the Sustainability Appraisal of the Luton Local Plan 2011-2031

March 2013

Appendix 4: Comments on Draft Scoping Report

A draft scoping report and appendices were issued by email to a range of parties on Tuesday 02nd October 2012. All but the statutory consultees were given until 12th October 2012 to respond with comments. Statutory consultees were given the 5- week period as described in SEA regulations, up to 06th November 2012.

The majority of parties were invited to review the draft documents to identify whether any significant sustainability issues had been overlooked. The Planning Advisory Service (PAS) support contacts were specifically asked to focus on aspects of process and conformity with known rules and regulations.

The following table describes the parties contacted and whether they responded. The rest of this appendix contains the comments submitted and a summary of how those comments were addressed in the final scoping report.

Table 1: Parties Contacted To Review Draft Scoping Report Name Job title/ role Response Response received? Date

LBC Strategic Planning team Kevin Owen Local Plans Team Leader Greg Macredecian Local Plans Senior Planning Officer Graeme Markland Local Plans Planning Officer Jackie Collins Local Projects Team Leader Fabiana Panetta Local Projects Planning Officer Gemma Pike Local Projects Heritage Officer Trevor Tween Local Projects Biodiversity Officer Jackie Barnell Development Control Manager Chris Pagdin Head of Planning and Transportation

LBC internal colleagues Chimeme Egbutah Health & Wellbeing Co-Ordinator Bren McGowan Local Strategic Partnership Manager Yes 12/10/12 Maureen Drummond Social Justice Adviser Martin Pratt Corporate Director, Children and Learning Nicola Perry Head of Service Policy & Performance Paul Adams Interim Economic Development Service Manager Claire Jaggard Environmental Protection Technical Yes 30/10/12 Officer Barry Timms Parks & Cemeteries Manager Shaun Askins Strategic Waste Manager Yes 04/10/12 Paul Barton Research & Geospatial Information Manager Keith Dove Transportation Strategy Manager Graham Wrycroft Interim Head Of Adult Social Care Name Job title/ role Response Response received? Date Alan Thompson Housing Strategy & Development Manager

Planning Advisory Service (PAS) Support Alison Blom-Cooper Allocated support for sustainability Yes 24/10/12 appraisal work by PAS Tineke Rennie Allocated support for sustainability Yes 23/10/12 appraisal work by PAS

SEA Statutory Consultees Consultation team Natural England Yes 17/10/12 Strategic Planning Environment Agency team Tom Gilbert- English Heritage Yes 02/11/12 Wooldridge

Neighbouring Authorities Chris Butcher Central Bedfordshire Council Chris Bearton Hertfordshire County Council CSC Highways Hertfordshire County Council team

Response Date: 04/10/12 Respondent Name: Shaun Askins Respondent Title: Strategic Waste Manager Respondent Organisation: Luton Borough Council

Response: Briefly looking at the scoping , I note that a few bits of waste legislation have been superseded and some of the ones which will have an impact are missing, I will try to pull a few links together for you so that you can use these to keep up to date.

Summary of actions: List of other plans, policies and programmes updated to include references to: • Anaerobic Digestion Strategy and Action Plan 2011 • Defra Climate Change Action Plan 2010 • Low Carbon Transition Plan, 2009 • Government Review of Waste Policy in England 2011

Main findings from the review of policies, plans and programmes updated to include importance of waste management to economic activity.

Response Date: 12/10/12 Respondent Name: Bren McGowan Respondent Title: Local Strategic Partnership Manager Respondent Organisation: Luton Borough Council

Response: Scoping Report: 2.2 Key findings – although overcrowding can be inferred, a specific reference to issues relating to overcrowding would be helpful.

Clarity is needed about community safety issues – benchmarking uses East of England rather than ‘most similar group’ – i.e. , Coventry, Croydon, , Enfield, Gloucester, Hastings, Ipswich, Northampton, North Tyneside, , , Southend and . (Sophie Langston would be able to advise on data)

3.2 Economy – it would be helpful to put this is the context of the overall number of jobs in the town (if the increase in lower skilled jobs was all accounted for with new jobs and high skilled jobs had remained the same, that would be a different issue)

Society – violence is mentioned, but a specific reference to domestic violence might better reflect the local situation. The priorities of the Community Safety Partnership currently include locations, offenders and victims:

Locations : • The Town Centre – focusing on night time economy (NTE) related offences, shoplifting in The Mall and robbery

• Neighbourhoods adjacent to the town centre (South (not including the town centre), Dallow, High Town and Biscot) – focusing on burglary, violent crime, ASB and robbery • Marsh Farm – focusing on environmental ASB, deliberate fires and public perception of crime and ASB

Offenders: • Reducing re-offending across all age groups • Offenders aged between 14 and 21 years

Victims: • Prevention and support to vulnerable victims – focusing on the victims of ASB and the victims of domestic abuse across Luton

Night-time economy particularly doesn’t seem to have much recognition in the documentation.

Society – “The percentage of empty homes in private ownership is increasing”. Again, it would be useful to have that in the context of the overall number.

Society – sports participation: there are some questions about the validity of the information (Active Luton was seeing an increase – but Sport England’s methodology may have stayed the same so would be comparable) so it may be useful to reflect that.

Note: Tables on page 10 - 13 are a bit tricky to follow since they are supposed to be linked. It’s more of a question of presentation.

5.3 Sustainable Community Strategy – it reflects the SCS priorities, but also needs to include the shorter term priorities agreed in 2011: • Fewer people living in poverty • More people, including those who are vulnerable, able to live independently • Increased healthy life expectancy • Improved educational attainment for children and young people • Increased number of people with appropriate skills, helping business create the jobs that lead to employment • A reduction in serious crime and the fear it causes • An improved and sustainable natural and built environment • Stronger community cohesion across the town

There’s not a reference to the issue of Luton being just north of London and the potential risk of people moving from the capital as a result of welfare reform (or other reasons), so the current situation is likely to be exacerbated. I’m not sure where it would best fit, but it will need to be taken into account.

Appendix 1: Review of Policies, Plans and Programmes:

Possible impact of the Localism Act 2011 – neighbourhood planning; community right to build; assets of community value etc. This could be significant.

Is Skills for Sustainable Growth Strategy still live? If so, that should probably be referenced.

I couldn’t see any reference to SEMLEP – does that need to be included under regional issues?

It may be useful to refer to the recommendations of the Commission on Community Cohesion – although this could be taken as implied under the Social Justice Framework.

Do we need a reference to the ‘transformation’ of the public sector? There will be service changes and service reduction. If services are being provided in different ways, this will have a significant impact on the estate (it already has), so is reference needed to that?

There is also an issue about NNDR changing to local funding. Empty commercial properties could have a huge impact on the local tax base. Does this need to be reflected? (Not necessarily in the section – possibly in the scoping document.)

Appendix 2: Baseline Information: Pg 5 Average density – if average density is increasing, does this mean that higher- end housing is decreasing? Does this have an impact on image – and attractiveness for outside investment? (Or if it is average, does it make it even more crowded (more flats?) in some areas?) Colin has certainly made the point a number of times about the lack of top of the market housing as a disincentive.

Pg 14 “In 2010, nine areas were amongst the 10% most deprived in England: 2 in Northwell; 1 in High Town, 2 in Dallow, 2 in Biscot, 1 in Farley and 1 in South.” This is potentially misleading unless we know how many ‘areas’ (what level) there are in Luton.

Note: Some timescales are shown most recent to oldest, others are shown oldest to most recent; consistency would help for ease of reading.

Note: Crime figures are compared with regional and national – would statistical neighbours be more useful (and would it make a difference)? The statistical neighbours are listed above.

Pg 19 Infant mortality – 2009 was an exception (high) and inflates the three-year rolling average figures. Text could reflect this to give a more accurate picture. (Caroline Thickens in Public Health would be able to advise on that.)

Summary of actions:

List of other plans, policies and programmes updated to include references to: • Luton Private Sector Renewal Strategy 2010-2013 • Skills for Sustainable Growth, 2010 • Getting Down to Business: Plan for growth April 2012-March 2013 (SEMLEP) • Building Cohesion in Luton: report of the Luton commission on community cohesion (January 2011) • solutions Community Safety Partnership Plan • Luton Joint Strategic Needs Assessment 2011

Baseline data sets updated to display timescales from earliest to latest and include: • Count of all people in employment by type of job • Count of empty homes by ownership type • Reference to the use of lower super output areas for deprivation information and that Luton contains 121 LSOAs • Reference to density impacting on the character of the area and the need for good design • Infant mortality rates updated with note on 2009 anomaly.

Baseline not amended to include benchmarking on ‘most similar groups’. Available data on this was provisional and not to be used in the public domain. Baseline unchanged as it reports publicly accessible and publishable data.

Baseline data on sports participation not amended as local data is considered less robust than that provided by Sport England.

Main findings from the review of policies, plans and programmes updated to include: • Importance of overcrowding concerns • Need to address crime, with reference to the night-time economy and other priorities from the community safety partnership plan

Short-term SCS priorities that were agreed in 2011 are not specifically included in section 5.3 as these may change across the longer time-period of the local plan. The identified sustainability objectives cover the short-term SCS priorities.

Reference to migration from London is not included as there is little, certain information on how this may affect Luton. The scoping report does recognise that Luton does not have enough land to meet its housing needs, which is based on population forecasts that include up-to-date migration assumptions.

Transformation of the public sector, including changes to business rate collection, is not included. There is little information on how this might affect Luton and effects are dependent on future decisions as to how the Council manages its finances. Corporate decisions are assessed against social, economic and environmental impacts before being made.

Response Date: 17/10/12 Respondent Name: Roslyn Deeming

Respondent Title: Land Use Adviser Respondent Organisation: Natural England

Response: Thank you for your consultation on the above dated 02 October 2012 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England is generally supportive of the Sustainability Appraisal Report and considers that it correctly identifies the main issues within Luton Borough. We particularly welcome the following sustainability objectives: 1. Maintain and enhance biodiversity; 2. Conserve, restore and enhance landscape and open spaces; 3. Protect and enhance air, soil and water resources; and 5. Adapt to and mitigate the impact of climate change.

Although Green Infrastructure (GI) has been mentioned in Table 4. Luton’s Sustainability Issues (point 8), we consider that the SA Objectives could be improved by considering the importance of GI and its multifunctional benefits as an objective on its own. This would assist in the delivery of a range of SA topic areas, e.g. biodiversity, landscape, health and wellbeing and climate change and ensure that GI is an integral, cross-cutting theme throughout the local plan policies.

We would particularly like the SA to emphasise the importance of good quality local accessible green spaces as they can offer a range of benefits, e.g. • Access to local greenspace can reduce health inequalities • Increased and improved accessibility to greenspace can help increase physical activity • Contact with greenspace can help improve health and wellbeing • Green space contributes to functioning ecosystem services that can have a positive influence on health. Ecosystem services can assist in adapting to the extremes of climate change, e.g. green areas have less heat-island effect than built up areas. • Greenspace can also help improve air quality and respiratory irritants. Function ecosystem services can also mitigate the risks associated with flooding from extreme rainfall events.

We note that both in Appendix 2: Baseline and Appendix 4: Site Assessment Criteria that reference is made to access to open space or to strategic GI. The provision of accessible semi-natural greenspace within green infrastructure in and around urban areas significantly contributes to creating places where people want to live and work. Its provision is therefore vital to sustainable development and communities. Natural England's Accessible Natural Greenspace Standards (ANGSt) provides a set of benchmarks for ensuring adequate access to natural and semi-natural greenspace near to where people live. The ANGSt methodology provides a powerful tool in assessing current levels of accessible natural greenspace and planning for better provision. Natural England’s most recent wording of the standard is:

• No person should live more than 300m from their nearest area of accessible natural green space of at least 2ha in size; • There should be at least one 20ha accessible natural green space within 2km from home; • There should be one 100ha accessible green space site within 5km; • There should be one 500ha accessible natural green space site within 10km; • At least 1ha of statutory Local Nature reserve should be provided per 1000 population.

There are also other national standards such as Green Flag for parks and open spaces and the County Park accreditation schemes.

Further information on delivering and managing natural and semi-natural greenspace can be found in our report Nature Nearby - Accessible Natural Greenspace Guidance (Natural England 2010) http://publications.naturalengland.org.uk/publication/40004.

Summary of actions: List of other plans, policies and programmes updated to include references to: • ‘Nature Nearby’: Accessible Natural Greenspace Guidance (Natural England, March 2010)

Main findings from the review of policies, plans and programmes updated to include importance of the natural environment to improving health and well-being, carbon sequestration and improving the image and attractiveness of the town to investment.

List of sustainability issues (point 8) amended to reflect the importance of green infrastructure to health and well-being, carbon sequestration and improving the image of the town to attract investment.

Sustainability objectives amended: • Objective 1, ‘Maintain and enhance biodiversity’ changed to ‘Maintain and enhance biodiversity, habitat and landscape’. Related sustainability issues changed from points 6, 7 and 8 to points 6, 7, 9 and 11. This reflects a hierarchy where biodiversity exists within habitats that, in turn, exist within landscapes. This objective focuses on the role of the environment to support flora and fauna. • Objective 2, ‘Conserve, restore and enhance landscape and open spaces’ changed to ‘Conserve, restore and enhance green infrastructure’. Related sustainability issues changed from points 7, 8, 9, 13 and 23 to points 7, 8, 10, 13 and 23. This better reflects the importance of green infrastructure as raised by Natural England, focussing on the role of the environment to support humans.

Table 6 (SEA Directive topics and SA objectives) amended to reflect difference between objectives 1 and 2: • Biodiversity, flora and fauna topic previously linked to objectives 1, 2 and 3, now linked only to objective 1. • Landscape topic previously linked to objectives 2 and 3, now linked only to objective 1. • Link between water topic and objectives 1 has been removed.

• Soil topic previously linked to objectives 1, 2 and 3, now linked only to objective 3.

Table 8 (Sustainability objectives and the sustainable community strategy) amended to reflect difference between objectives 1 and 2: • SCS priority to successfully adapt and mitigating climate change now also linked with objective 2. • SCS priority to improve public transport, access and mobility by sustainable modes of transport now also linked with objective 2. • SCS priority to increase economic activity now also linked with objective 2. • SCS priority to improve the health of children and young people now also linked with objective 2.

Standards for access to open space have been taken from the local green space strategy, rather than those from Natural England’s ANG standards. The local standards were devised from a review of guidance available at the time and are broadly in-line with those of Natural England.

Response Date: 23/10/12 Respondent Name: Tineke Rennie Respondent Title: Senior Planner Respondent Organisation: Arup (allocated support for sustainability appraisal work by PAS)

Response: You had a couple of further specific queries in connection with undertaking the SA, please see our response below in italics:

Stage B (developing and refining alternatives and assessing the effects) Should alternatives to the Plan objectives be assessed in addition to alternatives to the Plan policies and site allocations?

Plan objectives should be tested against the SA/SEA objectives and also against other Plan objectives for compatibility. This is essentially the test which may then require you to look at alternatives if the objectives don’t test well against the SEA /SA objectives.

In terms of undertaking the assessment, we recommend that you assess/compare the plan objectives with the SA objectives first. Then review the findings from this assessment. It may be the case that a potentially adverse impact from one of the plan objectives would be mitigated by one of the other objectives. However, if this is not the case then you could explore alternative objectives and/or additional objectives to mitigate potentially adverse impacts from the plan objectives.

Resourcing In terms of resourcing, you are considering putting together a specific team dedicated to working on the scoping report and taking the SA forward to the next stage. This team will comprise of various officers such as a health officer, but not policy staff already working on the Plan. Would it be preferable to have officers already writing

the policy to undertake the SA work, as they will know the issues and baseline evidence in depth?

It is sensible for the policy makers to undertake the SA as it should then inform their final policies in terms of mitigation and any changes to policy, and is owned by them and more proportionate. However, it is very sensible to have a critical eye cast over this and in practice this is the measure that proves verification for what the Council has done and reduces the risk of being seen as judge and jury. So some form of fresh eyes reviewing the work – whether it is someone else within the Council or someone from an adjoining authority or external is sensible.

Summary of actions: ‘Appraising the local plan objectives’ updated to reflect guidance on the development and testing of plan objectives, including a new matrix to summarise their compatibility with each other.

‘Who does the testing?’ updated to reflect the change whereby policy officers will conduct the appraisal, which will then be reviewed by other officers with specific roles in health and equality.

Response Date: 24/10/12 Respondent Name: Alison Blom-Cooper Respondent Title: Director Respondent Organisation: Fortismere Associates (allocated support for sustainability appraisal work by PAS)

Response: 1.0 Introduction 1.1 This note forms advice that was requested by officers at Luton Borough Council following telephone discussions and initial correspondence with PAS. The consultant discussions were held on 9 October 2012 and this clarified that officers sought advice specifically to review the process being followed for sustainability appraisal (SA). In particular a quick review of the Scoping Report was sought by the Council to establish that the breadth and depth of the Scoping Report was appropriate to the Borough’s SA and that the correct process had been followed.

1.2 The following advice is given in the context of the Council wishing to take forward the plan making process as expeditiously as possible and is based upon the material provided by the Council. The documents reviewed were : • the Scoping Report for the Sustainability Appraisal of the Luton Local Plan • 2011-2031; • Appendix 1: Review of Policies, Plans and Programmes; • Appendix 2: Baseline Information; • and Appendix 3: Site Assessment Criteria.

The Planning Advisory Service is able to offer support to review an authority’s work with respect to plan making but not advise on the soundness of a plan or

the policy choices made within a plan. There are therefore limitations to the approach taken in terms of the role of PAS. The Council will be in possession of a wider picture with regard to the local context than can be achieved in a short commission such as this. Whilst advice can be proffered the Council is responsible for ensuring that the manner in which the plan has been developed is fit for purpose and the Council should take any legal advice considered necessary.

1.3 This note works through the issues raised by officers on which they sought advice together with some observations and recommendations. It has not in the time available sought to look at all aspects of the work but rather the process of undertaking Stage 1 in developing the Sustainability Appraisal Framework for Luton.

2.0 SA Process: Stage 1 Setting objectives and developing the baseline 2.1 Luton Borough Council Officers have commenced preparation of a framework for sustainability appraisal for the new Luton Local Plan 2011-2031, which is due to be issued for pre-submission representations in March 2013. A joint core strategy that had been prepared for Luton and southern Central Bedfordshire was withdrawn on 18 May 2011. The SA framework has built on this previous work but also includes more recent evidence specific to Luton.

2.2 Officers have based the preparation of the SA framework on the process set out in the Plan-making Manual prepared by the Department of Communities and Local Government and the Planning Advisory Service. The first stage, setting objectives and developing the baseline is set out in the document Scoping Report for the Sustainability Appraisal of the Luton Local Plan 2011 – 2031 together with a description of how the remaining stages of the SA will be conducted. The Scoping Report has been issued for consultation with the relevant sections of the Council; the neighbouring authorities of Central Bedfordshire and Hertfordshire County Council; and the statutory Consultation Bodies.

2.3 Officers are seeking advice on the process, breadth and depth of the Scoping Report that has been issued for consultation.

2.4 The Council is responsible for ensuring that the SA process complies with the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (SI 1633). These regulations which set out the SA process are underpinned by the requirements of the EU Strategic Environmental Assessment Directive which applies to all Local Plans. The application of an SA in accordance with the SEA Directive is further endorsed within the National Planning Policy Framework (paragraph 165).

2.5 This review has therefore focussed on testing the requirements of the Environmental Assessment and Programme Regulations in connection with Stage 1 of the Plan making manual ‘setting objectives and developing the baseline’, and suggesting areas for improvement.

2.6 Observations

2.7 Table 1 in Appendix 1 tests the Scoping Report against the requirements of the SEA Directive (Annex 1 a-j) and summarises suggestions for improvement where relevant. The key areas of potential non-compliance are outlined below.

2.8 Baseline information is collected to help identify environmental problems. The indicators selected to achieve this should therefore demonstrate the current situation and predicted environmental effects; their magnitude; how reversible, irreversible, temporary or permanent they are; whether they can offset or remedy any damage. Furthermore, the extent of the environmental effects should also be considered on a ‘business as usual’ case without implementation of the Local Plan.

2.9 The scope of baseline information presented in Appendix 2 of the Scoping Report appears to cover the sustainability aspects of the borough that could be affected by the Local Plan once implemented. However, the presentation of the baseline information does not clearly identify whether the extent of the environmental effects has been considered based on the likely future evolution of the baseline without the Local Plan (‘business as usual’). This could be rectified through amendments to Appendix 2 and in particular the use of ‘Status’ column which is not clearly defined within Section 3.1 of the Scoping Report and the description of ‘trends’ in Appendix 2 of the Scoping Report. In some instances the text in this column of the table does not describe either a current or future trend (e.g. comments on “other sources of flooding” which does not state that the FRA forecasts an increase in the risk of sewer flooding in the future).

2.10 It is assumed that ‘Status’ provides an overall assessment of the state of the environment as demonstrated by the indicator, based on a ‘business as usual’ scenario. However neither Appendix 2 or the main body of the Scoping set out the reasoned justification for the status, such as the basis for the magnitude of any identified problems nor the factors influencing this such as those listed in 2.9 above. Whilst the use of the traffic light system is visually helpful, it does not provide sufficient detail to document the extent of the problems at base line so that an accurate assessment of the likely significant effects on the environment can be made at Stage 3. As such, compliance with SEA Directive Annexe 1 (b) is borderline, and is setting the scene for potential non- compliance of Annexe 1(f).

2.11 Trends play an important role in highlighting existing and future environmental problems under a no plan or ‘business as usual’ scenario. They also measure the progress indicators are making towards meeting the SA objectives. The trends within Appendix 2 are at times making an assumption or statement rather than confirming quantifiable or definite trends as outlined in 2.9 above. In these instances, a ‘no available trend’ statement should be applied. The descriptive comments however are informative and may be better placed within an ‘Issues/constraints’ column, which is discussed further in paragraph 2.17 below.

2.12 As outlined above, the purpose of the collection of baseline data is to identify environmental effects that may occur as a result of the Local Plan that will in

turn define the SA objectives. As such, it is considered premature to include an ‘Action for Local Plan’ column as the SA objectives will define this later when they test the Plan objectives. By stating the actions for the Local Plan in advance is to anticipate the SA objectives and the impact they will have on the evaluation of the effects of the plan and the alternatives before they have been established.

2.13 Sustainability objectives are not a requirement of the SEA Directive, however they are a recognised tool for considering the environmental effects of a plan and comparing the effects of alternatives.

2.14 The range of objectives is tightly focussed. However they are heavily focussed on environmental and social issues and do not include issues such as supporting or creating new employment opportunities to contribute towards sustainable economic growth. Given the wider social deprivation issues in the Borough this is likely to be an important issue for the Local Plan and would benefit by being reflected by an objective in the SA/SEA.

2.15 Recommendations 2.16 Appendix 2 which sets out the baseline information to include a column for ‘Issues/ constraints’ that allows overall comments to be made about the situation for that indicator; how reversible, irreversible, temporary or permanent the problems are; whether they can offset or remedy any damage, how far the current situation is from established targets or thresholds. This column could be provided in addition, or in place of the ‘status’ column. Removal of the ‘Action for Local Plan’ column on the basis that consideration of how the baseline indicators should influence the Local Plan objectives is premature at this stage.

2.17 Table 1 in Appendix 1 is reviewed and the comments it contains considered in the light of the SEA Directive Framework.

2.18 Whilst not formally required, it is recommended that the ‘SEA’ QA Checklist1 is used as an aid to improving the quality of the SA Report.

Appendix 1 Testing the Scoping Report for the Sustainability Appraisal of the Luton Local Plan 2011- 2031 against the requirements of the SEA Directive.

Review of the Scoping Report for the Sustainability Appraisal of the Luton Local Plan 2011-2031 Table 1 tests the SA Scoping Report against the requirements of the Environmental Assessment of Plans and Programme Regulations 2004. The final column of the table makes suggestions for improvement to the SA Report.

SEA Directive Requirement Covered by the SA Scoping Suggestions for Improvement Report? a). An outline of the contents and Unable to locate this in the report. At this stage this information is not required for the main objectives of the plan or Scoping Report. However it will need to be included in programme and... the SA Report/ Environmental Report when the emerging Local Plan is issued for public consultation.) ...its relationship with other relevant Appendix 1 provides a Consider & update of sustainability context in light of UK plans and programmes; comprehensive list of plans/ Carbon Plan. strategies/ policies and the relevant information for the SA. Table 2 to include another column that identifies the However it does not directly link implications for the Local Plan and another column the findings from this review with setting out the implications for the SA /SEA. issues relevant to Luton. b). The relevant aspects of the Appendix 2 Doesn’t clearly identify the likely future evolution of the current state of the environment baseline without the Local Plan (‘business as usual’). and the likely evolution thereof without implementation of the plan ‘Status’ and therefore the basis and magnitude of the or programme; problems are not clearly defined. Does ‘status’: • Reflect the state of the environment over time without implementation of the Local Plan objectives? • Refer to how good or bad the current situation is? • Reflect whether the problems are reversible, irreversible, permanent or temporary? • Reflect whether the problems can be offset, or any damage remedied?

‘Trends’ at times are making an assumption or statement rather than confirming quantifiable or definite trends, ie “At sub-regional level, there is a lack of large areas and corridors of linked accessible semi-natural green space” (p4),and “As population increases and open spaces are brought forward for development, the amount of green space per person decreases” (P4). ‘Trends’ should be examined under a no plan or ‘business as usual’ scenario and to establish whether targets are being met under the targets of the existing Plan.

Whilst the traffic lighting system for ‘Status’ is visually helpful, it may be more useful to replace this column or provide it in addition to an ‘Issues/ Constraints’ column which can provide a general comment about how good or bad the situation is, whether the problems are reversible, irreversible, permanent or temporary, how difficult it would be to offset or remedy any change and the likely future evolution of the baseline without the Local Plan.

For clarity, it would be useful to provide a comment stating that objectives are linked to indicators explicitly measuring progress or otherwise towards them in 3.1 (paragraph 3).

Table 3 in Scoping Report – the following changes may assist for accuracy and completeness: • Separate out reduction in land of agricultural quality

from open spaces as these are separate issues • Affordable Housing shown as red status on page 22 of Appendix 2 should be included c). The environmental Appendix 2; Section 3.2 Key The range of topics covered appears to cover the issues (sustainability) characteristics of Findings for Luton; and Section 4 and topics that would normally be found in the baseline areas likely to be significantly Identifying Sustainability Issues section of a SA Report. However, there could be some affected; benefits to expand the range of objectives to include contributing towards job creation and sustainable economic growth.

If consultation responses to the Scoping Report identify potential gaps in the information presented they should, where reasonably practicable, be filled. d). Any existing environmental Appendix 2; Section 3.2 Key See comment above. problems which are relevant to the Findings for Luton; and Section 4 plan including, in particular, those Identifying Sustainability Issues relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC (Conservation of Wild Birds) and 92/43/EEC (Habitats Directive) e). The environmental protection Appendix 1 provides a See Annex 1 (a) comments above. objectives, established at comprehensive list of plans/ international, Community or national strategies/ policies including level which are relevant to the environmental protection plan... and have been taken into objectives. However it does not account during it’s preparation directly link the findings from this review with issues relevant to Luton. (f). The likely significant effects on To be undertaken in Stage 3 The selection of sites is a critical part of the development the environment Refining options and assessing of the Local Plan and the Council need to be able to

effects. demonstrate that the sustainability implications of different allocations have been taken into account during the development of the Local Plan. This can be achieved by comparing the site allocation criteria with the SA objectives to ensure that as many of the SA objectives (i.e. those with strong spatial characteristics) are reflected in the site allocation criteria. For example flood risk and proximity to public transport infrastructure could be included and analysis undertaken using GIS. By enhancing the site assessment matrix it will be easier for the Council to demonstrate that the SA/SEA process has assessed all aspects of the Local Plan (and also therefore demonstrate this at the examination in public). g). The measures envisaged to To be undertaken in Stage 3 Not required at this stage. prevent, reduce and as fully as Refining options and assessing possible offset any significant effects. effects on the environment of implementing the plan or programme; (h) An outline of the reasons for To be undertaken in Stage 3 Not required at this stage. selecting the alternatives dealt Refining options and assessing with... effects. ...and a description of how the Not provided. Not required at this stage. assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information) i). A description of measures To be undertaken in Stage 3 Not required at this stage. envisaged concerning monitoring in Refining options and assessing accordance with Article 10; effects. However, we note that the indicators described in

Appendix 2 would form the basis for a suite of monitoring indicators. j). A non-technical summary of the Not required at this stage. Not required at this stage. information provided under the above headings. Quality Assurance Not formally required by SEA You may find completion of the SEA QA checklist is a Environmental reports should be of Regs. useful management tool to help the SA team self-assess a sufficient standard to meet the the extent to which the requirements of the SEA directive requirements of the SEA Directive (a-j above) have been met. Self-assessment could help (Art.12). to identify any further areas for improvement and as a Refer DCLG ‘A Practical Guide to means of illustrating how effectively the SA the SEA Directive Appendix 9 QA considerations have been integrated into the plan- Checklist making process. Good SA practice emphasises the value of this integration and the risk that SA benefits may be lost if dealt with as a parallel work-stream. Consider inclusion of a QA section within an addendum SA

Summary of actions: List of other plans, policies and programmes updated to include references to: • The Carbon Plan: Delivering our low carbon future (December 2011)

Main findings from the review of policies, plans and programmes updated to include • support for low-carbon transport technologies • support low-carbon heating and energy generation technologies.

List of sustainability issues amended to include new issue on the need to address carbon reduction.

Table of sustainability objectives for Luton amended to: • link objective 3 (protect and enhance air, soil and water resources) with the new issue of carbon reduction • link objective 5 (adapt to and mitigate the impact of climate change) with the new issue of carbon reduction • create new objective to reduce carbon emissions

Table summarising SEA Directive topics and SA objectives amended to link new SA objective on carbon reduction with the topics on air, human health and climatic factors.

Matrix of compatibility of sustainability objectives with each other updated to include new objective on carbon reduction.

Table summarising the links between the SA objectives and the SCS updated to include references to the new objective on carbon reduction.

Appendix 3: Site Assessment Criteria amended to link the new objective on carbon reduction with relevant assessment criteria.

Appendix 1: Review of Policies, Plans and Programmes amended to include two new columns setting-out the general objectives of each document and any specific information on concerns for Luton.

Chapter 2, Table 2 updated from the new column of general objectives shown in appendix 1. Table is renamed accordingly as ‘General objectives from the review of policies, plans and programmes’. Economic objective on regional growth agenda removed in the light of the revocation of regional strategies. Three economic objectives on town and district centres (vitality and viability) combined into one. Two new economic objectives added, relating to telecommunications and skills. Environmental objective on contaminated land removed as it was unsupported by the review in appendix 1 (it is also covered by the objective recognising the value of natural assets). Social objectives on affordable housing in the town centre and viability of delivering affordable housing removed as they were unsupported by the review in appendix 1 (it is also covered by the objective on identifying housing need). Social policy on housing needs of an ageing population incorporated with the objective on the social and economic implications of an ageing society. Tow new social objectives included to cover urban-rural links and poverty.

Appendix 2: Baseline Information amended to: • remove ‘status’ column • remove ‘action for local plan column’ • include ‘issues/ constraints column’ with overall comments to be made about the situation for that indicator; how reversible, irreversible, temporary or permanent the problems are; whether they can offset or remedy any damage, how far the current situation is from established targets or thresholds

Chapter 3: Collecting Baseline Information updated to include summary of ‘issues/ constraints’ column from appendix 2.

New objective on employment opportunities has not been included. Table 5 shows that objective 8 (poverty reduction) already relates to issues of employment/ economic growth.

Response Date: 30/10/12 Respondent Name: Claire Jaggard Respondent Title: Environmental Protection Technical Officer Respondent Organisation: Luton Borough Council

Response: 1. Scoping report section 2.2 – This doesn’t mention that we do not want development on land that has poor air quality (i.e. would be in an area of air quality exceedence if developed) 2. Scoping report section 3.2 – This doesn’t mention that air quality is poor in the town centre (see points 3 and 5 below). 3. Scoping report section 4.2 – no 10. Is this a quote or your interpretation of the findings of the progress report? Which progress report? 2012’s (in respect of 2011) has been published and accepted by DEFRA now. This latest report identifies a possible issue with air quality in the town centre also. 4. Scoping report section 4.2 – no 15. This mentions noise but does not mention noise from industry and busy roads. These are also considerations that EH have when assessing planning applications. If you would like any supporting evidence in respect of these, Ian Pringle should be able to help you. 5. Appendix 2 – Air quality baseline data is for 2010. 2011’s data is now available (or will be very shortly) on the council’s internet (I think I sent a copy to you previously but if you require another one, please let me know) 6. Appendix 3 – What do R,A and G stand for? Which parts of LBC are to be allocated these letters for Air Quality?

Summary of actions: Appendix 2: Baseline Information updated to refer to 2012 air quality report instead of the 2011 report.

Chapter 3: Collecting Baseline Information updated to refer to information from 2012 air quality report. Also includes reference to locating new development away from areas of poor air quality.

Section 4.2: 10 th sustainability issue updated to include reference to town centre air pollution.

Environmental noise (e.g. from roads) not included due to lack of information at local level. DEFRA noise maps currently do not cover Luton.

RAG ratings already removed to address comments from Alison Blom-Cooper.

Response Date: 30/10/12 Respondent Name: Tom Gilbert-Wooldridge Respondent Title: Environmental Protection Technical Officer Respondent Organisation: Luton Borough Council

Response: General comments We have enclosed an electronic copy of our guidance on SEA, SA and the Historic Environment, which sets out how such documents should be produced in terms of heritage matters. We hope this provides useful information on areas such as relevant plans, baseline information, issues, objectives and indicators.

We note that for Chapters 2, 3 and 4 that the historic environment is mentioned under the heading for “Social” or “Society”, rather than “Environment”. Although the historic environment has strong links with social and economic issues, we feel that it should be recognised as an environmental issue. The historic environment is a tangible and physical resource that influences the appearance of places and is something people experience. It is therefore part of the wider environment.

Chapter 2: Relevant Policies, Plans and Programmes We welcome the identification of local documents relating to the historic environment in Appendix 1, including the Environmental Sensitivity Assessment and the Historic Area Assessment for the Plaiters Lea Conservation Area. We suggest that it might also be helpful to refer to any conservation area appraisals that have been produced for the borough’s conservation areas, even if these have yet to be adopted.

We welcome the reference to the historic environment in Table 2, although it should be under the environment heading (see above).

Chapter 3: Baseline Information We welcome reference to heritage assets, including heritage at risk, in Appendix 2, although the baseline should state the number of scheduled monuments and registered parks & gardens within the borough (in addition to the number of listed buildings and conservation areas). The actions for the Local Plan are welcomed, although preservation of scheduled monuments and registered parks & gardens (not just their settings) should also be mentioned. Furthermore, protecting all heritage assets (not just those designated nationally or locally) should be mentioned.

It should be noted that the Heritage at Risk Register only includes Grade I and II* listed buildings (outside of London). Given that most of Luton’s listed buildings are Grade II, it is not possible to say that “none are at risk” in terms of the register’s criteria. Indeed, SAVE Britain’s Heritage have identified that a number of buildings in the Plaiters Lea Conservation Area are at risk, which presumably includes some listed buildings. The statement in Appendix 2 should read “Luton has 102 listed buildings, with none currently on the national Heritage at Risk Register”.

It should also be noted that the register includes conservation areas, with two of Luton’s conservation areas currently considered to be “at risk” (High Town and Plaiters Lea). We hope that the draft appraisals for some of Luton’s conservation areas can be adopted soon. We welcome the action to use the Historic Area Assessment report to inform policies around Plaiters Lea.

We welcome the reference to the historic environment in Table 3, although it should be under the environment heading (see above).

Chapter 4: Sustainability Issues We welcome the reference to heritage at risk in Table 4, although it should be under the environment heading (see above).

Chapter 5: Sustainability Appraisal Objectives We welcome the inclusion of an objective (No. 7) relating to the historic environment in Table 5, although it should be shown addressing environmental matters (see above).

In Table 7, Objective 7 is not necessarily incompatible with Objectives 11 and 14. It will depend on specific policies and proposals and in many cases the objectives will be compatible. It might be helpful if the table included an uncertain/unknown (“?”) relationship for some objectives.

Appendix 3: Site Assessment Criteria We note that Section 6.4 outlines the approach to assessing proposed site allocations, with further details provided in Appendix 3. We suggest that it might be more appropriate to undertake the quantitative assessment in Stage 1, followed by the qualitative assessment in Stage 2. This would allow basic facts to be established before a more subjective assessment is undertaken.

In terms of Stages 1 and 2 as set out in the appendix, we welcome the criteria relating to designated heritage assets, although they need refining. For the quantitative assessment (currently Criteria 24 to 27), we agree that sites within or containing a designated heritage asset should be shown as Red (although this may not automatically exclude sites from allocation depending on the proposal, e.g. sensitive in-fill development within a conservation area). However, the distances proposed for Amber to Green seem arbitrary without any justification (including why distances differ depending on the type of heritage asset). Given that every heritage asset is unique in terms of the asset itself and its surroundings it is difficult to apply standard distances of 100, 200 or 400 metres. For example, a proposed allocation within 100m of a listed building might be less harmful than a proposed allocation more than 100m away in another case, depending on the site and its surroundings

(e.g. topography, existing built form and landscaping). We suggest that Amber for the quantitative assessment reads “within the setting of [listed building, conservation area etc]”, while the Green reads “not within the setting of [listed building, conservation area etc]. Determining whether something is within the setting of a heritage asset may not always been possible in terms of an objective assessment, but it should be possible in most cases to confirm whether a site allocation would affect the setting (including impact on views). Our setting guidance “The Setting of Heritage Assets” might be useful (available at: www.english- heritage.org.uk/publications/setting-heritage-assets/), particularly Steps 1, 2 and 3.

In terms of the qualitative assessment (currently Criteria 10 to 13), this should focus on the harm that might be caused by a proposed site allocation. Red should read “likely to cause harm to the [listed building, conservation area etc], Amber should read “might cause harm....” and Green “would not cause harm”. This will be a subjective judgement, based in part on the quantitative assessment. We appreciate that in some cases is might be difficult to judge harm accurately due to limited information about a site and its potential development (in such cases, an Amber rating would probably apply).

Consideration should also be given to criteria relating to non-designated heritage assets (including locally listed buildings) when assessing sites.

Summary of actions: Appendix 2: Baseline Information updated to include the number of registered parks/ gardens and scheduled monuments. Reference to the national Heritage at Risk Register also included.

Section 3.2 updated to include reference to many of Luton’s assets not being nationally recognised or assessed. Reference to specific status of High Town and Plaiters’ Lea also included.

Section 5.2: Sustainability Objectives. Objective 7 amended to include protection of the setting of heritage assets. Text relating to table 7 updated to note the simplicity of the matrix.

Site Assessment stages 1 and two not reversed. The qualitative assessment is devised to provide a quick overview of a site, while the quantitative assessment is a more time-consuming, detailed approach.

Appendix 3: Site Assessment Criteria. Qualitative criteria 10 to13 adjusted to reflect setting of heritage asset, rather than distance. Respondent requested this to be applied to the second stage (quantitative assessment), though it was considered best to apply this to the first stage to provide a quick overview of potential impact. Quantitative criteria 24 to 27 adjusted to reflect potential harm to heritage assets, rather than distance. Respondent requested this to be applied to the first stage (qualitative assessment), though it was considered best to apply this to the second stage to provide a more considered appraisal of potential impact.

Other conservation area appraisals not referred to as they are considered either to be out-of-date or not well enough developed for use.

General changes following all amendments from respondents: Tables 2 and 3 deleted as the review of other documents and baseline information is now presented as more extensive text. All information from the tables checked to ensure it is present in the main text of those sections.

Table of sustainability issues updated to reflect changes to chapters 2 and 3, including new concerns relating to: • Biodiversity and habitat (‘Loss of open spaces and wildlife sites’ changed to ‘Loss of open spaces’ as wildlife sites now noted under new habitat issue). • School capacity • Housing for specific groups • Quality of existing housing • Access to services via sustainable transport

Objective 5 on climate change replaced with one on carbon reduction. Identified climate change concerns for Luton are covered by objectives 1 to 6.

Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

Appendix D: PPP Review

Please see insert.

F

Planning and Transportation

Scoping Report for the Sustainability Appraisal of the Luton Local Plan 2011-2031

March 2013

Appendix 1: Review of Policies, Plans and Programmes

Planning and Transportation Department of Environment and Regeneration

Plan/Strategy/Policy General Review General Issues Specific Issues International The strategy considers 7 key priority challenges, • New technologies and fuels • Implement urban transport the majority of which are based around actions for • Sustainable transport plans and systems the commission and Member States: • Sustainable consumption considering closer co- 1. Climate change and clean energy • Sustainable production operation between cities and 2. Sustainable transport • Natural resource surrounding regions 3. Sustainable consumption & production conservation 4. Conservation and management of natural • Public health Review of the EU resources • Social inclusion Sustainable Development 5. Public Health • Demography Strategy (EU SDS) − 6. Social inclusion, demography and • Migration Renewed Strategy migration 7. Global poverty and sustainable • Poverty development challenges

Actions for sustainable transport require local authorities to develop and implement urban transport plans and systems considering closer co- operation between cities and surrounding regions.

The convention aims to: • Flora and fauna conservation • No specific direction for local • conserve wild flora, fauna and natural • Natural habitats conservation plans. Local information habitats • Protection of vulnerable and provided through lower-level • promote co-operation between states endangered species documents (biodiversity • give particular attention to endangered and action plan). vulnerable species, including endangered Bern Convention on the and vulnerable migratory species Conservation of Appendices provide detailed information on European Wildlife and species and habitats protected under the Natural Habitats (1979) convention.

Obligations for contracting parties: conservation of wild flora and fauna and all natural habitats in general, by promoting national conservation policies taking conservation into account in regional planning policies and pollution abatement promoting education and information

2 Plan/Strategy/Policy General Review General Issues Specific Issues The convention is designed to conserve biological • Biological diversity • No specific direction for local diversity, ensure the sustainable use of this plans. Local information diversity and share the benefits generated by the provided through lower-level use of genetic resources. documents (biodiversity The Convention on Each contracting party should (article 6a) action plan). Biological Diversity, Rio develop national strategies for the conservation de Janeiro (1992) and sustainable use of biological diversity integrate the conservation and sustainable use of biological diversity into relevant sectoral and cross- sectoral plans, programmes and policies The Kyoto Protocol supports the United Nations • Climate change Reduce anthropogenic Framework Convention on Climate Change which • Transport emissions greenhouse gasses to at least sets an overall framework for intergovernmental 5% below 1990 levels by efforts to tackle the challenge posed by climate 2012. change. Articles 2(a-vii) & Article 3: Applies the Protocol to reduction of ozone-depleting gases produced by the transport sector not covered by the Montreal Kyoto Protocol on Protocol (CFCs and fluorocarbons). Article 3 Climate Change (UN, contains the key obligation requiring reduction in 1997) anthropogenic CO 2 levels to at least 5% below 1990 levels by 2012. Article 10(b-1): Requires signatories to implement and publish regular plans detailing how reduction targets will be met in specific sectors, including transport. It might be argued that sustainable transport policies RTSs and LTPs might contribute to this commitment. All 191 UN member states set out eight millennium • Climate change • No specific direction for local The UN Millennium development goals which should be met by 2015. • Biodiversity preservation plans. Local information Declaration and ‘We must tackle, issues of climate change, • Water resources provided through lower-level Millennium Development preserving biodiversity, managing our forests and management documents. Goals (2002) water resources, and reducing the impacts of natural and man-made disasters.’

3 Plan/Strategy/Policy General Review General Issues Specific Issues Aimed to address difficult challenges including • Resource efficiency • No specific direction for local improving people's lives and conserving our natural • Waste reduction plans. Local information resources in a world that is growing in population, • Renewable energy provided through lower-level with ever increasing demands for food, water, promotion documents. World Summit on shelter, sanitation, energy, health services and • Biodiversity Sustainable Development economic security. - Earth Summit (2002) Fundamental goals include: • Greater resource efficiency • Waste reduction • Promotion of renewable energy • Significantly reduce loss of biodiversity by 2010 Aims to reflect European identity and diversity • Living landscapes • Integrate landscape into through the landscape which is a living natural and policies. cultural heritage, whether it is ordinary or European Landscape outstanding, urban or rural, on land or in water. Convention, Florence, The Convention promotes the protection, 2000 management and planning of European landscapes and organises European co-operation on landscape issues. It raises awareness of the value of a living landscape. This EU Directive addresses the prevailing issue of • Noise impact • No specific direction for local noise as a by product of transportation and plans. Local information Industry and investigates its impact on the provided through lower-level EU Directive on Environment. The main aim is to provide a documents (airport noise Environmental Noise, common basis for tackling the noise problem action plan). 2002/49/EC, EC, 2002 across the EU through the use of 'strategic noise maps' for major roads, railways, airports and agglomerations, using harmonised noise indicators. Provides long term protection and conservation of • Avian habitat protection • No specific direction for local all bird species naturally living in the wild within the plans. Local information EU Directive on the European Member States. provided through lower-level Conservation of Wild Imposes duty on Member States to sustain documents (biodiversity Birds, 2009/147/EC populations of naturally occurring wild birds by action plan). (2009) sustaining areas of habitats in order to maintain

populations at ecologically and scientifically sound levels.

4 Plan/Strategy/Policy General Review General Issues Specific Issues The revised directive emphasises the waste • Waste hierarchy application • No specific direction for local hierarchy to ensure that waste is dealt with in the plans. Local information EU Waste Framework priority order of: provided through lower-level Directive, 2008/98/EC 1. prevention; documents. (2008) 2. preparing for re-use;

3. recycling;

4. other recovery (for example, energy recovery); 5. disposal Addresses water pollution by nitrates from • Water pollution • Luton and surrounding areas agriculture. It seeks to reduce or prevent the classified as a ‘nitrate pollution of water caused by the application and vulnerable zone’. storage of inorganic fertiliser and manure on farmland. It is designed both to safeguard drinking water supplies and to prevent wider ecological damage in the form of the eutrophication of freshwater and marine waters generally. Polluted waters are: EU Nitrates Directive • Surface freshwaters, in particular those used or (91/676/EEC) intended for the abstraction of drinking water, that contain or could contain, more than the concentration of nitrates laid down in accordance with Directive 75/440/EEC; • Groundwaters containing or that could contain more than 50 mg/l nitrates; • Natural freshwater lakes, other freshwater bodies, estuaries, coastal waters and marine waters found or likely to be eutrophic. Contribute towards biodiversity through the • Natural habitat conservation • No specific direction for local conservation of natural habitats and of wild fauna plans. Local information in European Member States. Measures are provided through lower-level designed to maintain or restore, at favourable documents (biodiversity EU Habitats Directive conservation status. (92/43/EEC) as amended action plan). The article provides limited scope for development by 97/62/EC in designated areas. It is only acceptable on grounds of human health and safety (not economic development) if it affects habitats supporting protected species.

5 Plan/Strategy/Policy General Review General Issues Specific Issues Introduces new air quality standards for previously • Air quality • Local information provided unregulated pollutants, setting the timetable for the through lower-level development of daughter directives on a range of documents (local air quality pollutants. The list of pollutants to be considered report). EU Directive on Ambient includes sulphur dioxide, nitrogen dioxide, Air Quality and Cleaner particulate matter, lead, ozone, benzene, carbon Air for Europe, monoxide, poly-aromatic hydrocarbons, cadmium, 2008/50/EC (2008) arsenic, nickel and mercury.

Establishes mandatory standards for air quality and sets limits and guides values for sulphur and nitrogen dioxide, suspended particulates and lead in air. The aim of spatial development policies is to work • Economic cohesion • No specific direction for local towards a balanced and sustainable development • Social cohesion plans. Local information of the territory of the European Union. Aims to • Natural resources provided through lower-level ensure that the three fundamental goals of • Cultural heritage documents. European policy are achieved equally in all the regions of the EU: • Economic and social cohesion; European Spatial • Conservation and management of natural Development Perspective resources and cultural heritage; (ESDP), EU Ministers for Spatial Planning, 1999 • More balanced competitiveness of the European territory. Fostering European heritage should be an important part of modern architecture, urban and landscape planning in all regions of the EU. A big challenge for spatial development policy is to contribute to the objectives of reducing emissions into the global ecological system.

6 Plan/Strategy/Policy General Review General Issues Specific Issues Aims at reducing the amount of waste landfilled, to • Landfill reduction • Reduce biodegradable promote recycling and recovery and to establish municipal waste sent to high standards of landfill practice across the EU landfill to 75% of the total and to prevent the shipping of waste from one generated in 1995 by 2010, country to another. Prevent or reduce negative 50% by 2013 and 35% by effects on the environment from the landfilling of 2020. waste, by introducing stringent technical EU Waste to Landfill requirements for waste and landfills. Directive (99/31/EC) Prevent or reduce the adverse effects of the landfill of waste on the environment, in particular on surface water, groundwater, soil, air and human health. It defines the different categories of waste (municipal waste, hazardous waste, non- hazardous waste and inert waste) and applies to all landfills. Requires ‘good’ ecological status of inland water • Ecological water quality • Water bodies to be of ‘good’ The Water Framework bodies by 2015, and limits the quantity of • Water abstraction ecological status by 2015. Directive (2000/60/EC) – groundwater abstraction to that portion of overall recharge not needed by ecology. The paper sets-out 40 action points that aim to: • Air pollution • Local information provided • Deliver an efficient and integrated mobility • New transport technologies through lower-level system • Inter-European connectivity documents (local air quality European Commission • Innovate technology and behaviour for the report). White Paper on the future European Transport • Implement modern infrastructure and smart Policy: Roadmap to a funding Single European • Increase connections between the EU and Transport Area - Towards non-EU countries. a competitive and resource efficient The majority of these are based around actions for transport system (2011) the commission, European agencies and member states.

At a local level, the paper makes repeated references to issues of local air pollution.

7 Plan/Strategy/Policy General Review General Issues Specific Issues The directive covers the following concerns: • Renewable energy • No specific direction for local • National targets and measures generation plans. Local information EU Directive on the • National renewable energy action plans provided through lower-level Promotion of the Use of • Cooperation between member states documents. Energy From Renewable • Guaranteeing the origin of power from renewable Sources, 2009/28/EC (2009) energy sources • Prioritising infrastructure for renewable energy in the transport sector • Account for energy from biofuels and bioliquids Contains 20 actions for the six targets: • Habitat and ecosystem • No specific direction for local 1. Full implementation of the birds and habitats conservation plans. Local information directives provided through lower-level Our life insurance, our 2. Maintenance and restoration of ecosystem documents (biodiversity natural capital: an EU services action plan). biodiversity strategy to 3. More sustainable agriculture and forestry 2020 (2011) 4. Better management of fish stocks 5. Tighter controls on invasive alien species 6. A bigger EU contribution to averting global biodiversity loss

National • Promoting public health • No specific direction for local Choosing Health: Making Sets-out the key principles for supporting the public plans. Local information Healthier Choices Easier, to make healthier and more informed choices in provided through lower-level Department of Health, regards to their health. documents (joint strategic 2004 needs assessment. Lifetime Homes, Lifetime Outlines plans for ensuring enough appropriate • Delivering lifetime homes • Take into account the Neighbourhoods: A housing is available in future to relieve the proposed timetable for National Strategy for forecasted unsustainable pressures on homes, introducing lifetime homes. Housing in an Ageing health and social care services. Society (February 2008)

8 Plan/Strategy/Policy General Review General Issues Specific Issues Sets out reforms to: • Delivering housing • Housing directions for local • Get the housing market moving again plans provided through • Lay foundations for a more responsive, National Planning Policy effective and stable housing market in the Framework. Laying the Foundations: future A Housing Strategy for • Support choice and quality for tenants England (November 2011) • Improve environmental standards and design quality • Make it easier to secure mortgages on new homes, improve fairness in social housing and ensure empty homes are lived in again.

Provides guidance on: • Promote partnership working • No specific direction for local • The link between levels of government and plans. Local information Creating Strong, Safe their partners provided through lower-level and Prosperous • Governance and engagement documents (sustainable Communities (July 2008) • Establishing a vision community strategy). • Establishing priorities • Delivery of outcomes

• Support statutory natural • No specific direction for local National Parks and Gave powers to English Nature to designate Sites designations plans. Local information Access to the of Specific Scientific Interest and National Nature provided through lower-level Countryside Act 1949 (as Reserves. It also gave local authorities power to documents (strategic green amended) designate Local Nature Reserves. infrastructure plan and green space strategy). Implements the Convention on the Conservation of • Wildlife protection • No specific direction for local European Wildlife and Natural Habitats (the 'Bern • Habitat protection plans. Local information Convention') and the European Union Directives provided through lower-level on the Conservation of Wild Birds and Natural documents (biodiversity Wildlife and Countryside Habitats. Concerned with the protection of wildlife action plan). Act 1981 (as amended) and their habitat. Addresses the problem of species protection and habitat loss by setting out the protection that is afforded to wild animals and plants in Britain.

9 Plan/Strategy/Policy General Review General Issues Specific Issues • Habitat protection • No specific direction for local The Conservation of Consolidates all the various amendments made to plans. Local information Habitats and Species the Conservation (Natural Habitats, &c.) provided through lower-level Regulations 2010 Regulations 1994 in respect of England and Wales. documents (biodiversity

action plan). Provides a range of priorities and key actions • Cross-boundary biodiversity • Consider support for ‘nature including: conservation improvement areas’. • A more integrated large-scale approach to • River quality conservation on land and at sea • Flood management • Putting people at the heart of biodiversity policy • Air pollution • A strategic approach to planning for nature Biodiversity 2020: within and across local areas A strategy for England’s • Alignment of measures to protect the water wildlife and ecosystem environment with action for biodiversity services (2011) • Approaches to flood and erosion management that conserve the natural environment and improve biodiversity • Reduce air pollution impacts on biodiversity targeted at the sectors that are the source of relevant pollutants

• Habitat protection • No specific direction for local UK National Ecosystem plans. Local information Assesses the quality of the UK’s broad habitat Assessment 2011 provided through lower-level types. documents (biodiversity action plan). A white paper setting out objectives to: • Natural environmental • Consider support for ‘nature The Natural Choice – • Protect and improve the natural environment protection improvement areas’. Local securing the value of • Grow a green economy • Green economy information provided through nature (June 2011) lower-level documents • Reconnect people and nature • Connecting people and nature (green space strategy).

10 Plan/Strategy/Policy General Review General Issues Specific Issues Builds upon England Forestry Strategy ‘A New • Woodland protection • Identify and address Focus for England’s Woodlands’ of 1998 which had deficiencies in access to been fully reviewed in 2006. woodland. • Local information provided Five key aims for government intervention in trees, through lower-level woods and forests: A Strategy for England’s documents (green space 1. Secure trees and woodlands for future Trees, Woods and strategy). generations; Forests, DEFRA (2007) 2. Ensure resilience to climate change;

3. Protect and enhance natural resources; 4. Increase the contribution that trees, woods and forests make to our quality of life; 5. Improve the competitiveness of woodland businesses and products

Presents standards and objectives for air quality in • Air quality • Address concerns where air relation to: quality does not or might • Particulate matter meet stated objectives • Oxides of nitrogen (limits). Air Quality Strategy for • Ozone • Local information provided England, Scotland, • Sulphur Dioxide through lower-level Wales, Northern Ireland • Polycyclic aromatic hydrocarbons documents (local air quality (2007) report). • Benzene • 1,3-butadiene • Carbon monoxide • Lead • Ammonia

11 Plan/Strategy/Policy General Review General Issues Specific Issues Commentary on recent developments since the • Air pollution • Integrate air quality and 2007 air quality strategy. Includes the following climate change policies. key messages: • Local information provided • Air pollution often originates from the same through lower-level activities that contribute to climate change documents (local air quality • Optimising climate policy to account for air report). pollution could yield additional financial Air Pollution: Action in a benefits Changing Climate • Air quality/ climate change co-benefits can be (March 2010) realised through the promotion of low-carbon

vehicles and renewable sources of energy that do not involve combustion. • Action will be needed at local levels to make sure air quality and climate change policies are integrated to maximise the co-benefits of tackling both.

Discusses listing of special and listed buildings, • Cultural heritage • Identify and protect cultural with procedures to follow for a development within heritage features of the built Planning (Listed Buildings or near a listed building or a Conservation Area, environment. and Conservation Areas) including control of demolition. The Act lists Act, 1990 general duties of Planning Authorities to while dealing with a Conservation Area. Extends the public's ability to enjoy the countryside • Access to the countryside • Identify and protect whilst providing safeguards for landowners and • Protection of natural landscapes and other occupiers. It creates a new statutory right of access environment features of the natural Countryside and Rights of to open country and registered common land, environment. Way Act – CRoW modernises the rights of way system, gives greater (ODPM, 2000) protection to Sites of Special Scientific Interest, provides better management arrangements for Areas of Outstanding Natural Beauty and strengthens wildlife enforcement legislation.

12 Plan/Strategy/Policy General Review General Issues Specific Issues Government Urban White • Economic growth • No specific direction for local Sustainable economic growth is based on thriving Paper: Our Towns, Our plans. Local information towns and cities that are the economic hubs of • Protection of natural Cities, the Future. provided through lower-level large areas. To arrest urban decline by taking a environment Delivering an urban documents. joined approach to policies on housing, planning, renaissance (DETR, transport and education in and for cities and towns. 2000) Sets out the Government’s vision for sustainable • Reduce waste not re-used, • Local waste management waste management. recycled or composted targets and actions are set Annual greenhouse gas emissions: through the local minerals • Reduction of 10 million tonnes of CO 2 and waste development equivalents by 2020. plans Household waste recycling and composting: • 2010 – 40% • 2015 – 45% • 2010 – 50% Waste Strategy for Household residual waste (waste not re-used, England 2007 recycled or composted): • 2010 – 29% reduction from 2000 levels • 2015 – 35% reduction from 2000 levels • 2020 – 45% reduction from 2000 levels Municipal waste recovery: • 2010 – 53% • 2015 – 67% • 2020 – 75% Commercial and industrial waste landfill: • 2010 – expected 20% reduction from 2004 levels

13 Plan/Strategy/Policy General Review General Issues Specific Issues

Sets out the Government’s approaches to climate • Reduce CO 2 emissions • Support local change. It explains why the climate is changing • Adapt to climate change microgeneration of and what its effects might be, the UK’s legally renewable energy binding target under the Kyoto Protocol to reduce • Support sustainable transport its greenhouse gas emissions to 12.5% below modes 1990 levels by 2008-2012 and its domestic goal of • Implement demand a 20% reduction in carbon dioxide emissions below UK Climate Change management schemes on 1990 levels by 2010; new measures the Programme (2006) the road network Government is introducing to reduce emissions • Promote energy efficiency further and achieve the UK’s climate change measures targets and how climate change is expected to • Promote design principles affect the UK, how the UK might need to adapt, which take account of and the action the Government has started to take adapting to a future climate to prepare for this. The Programme aims at cutting UK carbon dioxide emissions by 60% by 2050. The intention of the Government to protect the • Protect and sustain the • Adopt a positive approach to historic environment recognising its major historic environment the management of the contribution to the economy in rural and deprived historic environment The Historic Environment: communities as well as in traditional economic A Force for Our Future centres. It also states the need for the development (2001) of new policies to further realise economic and educational potential. The historic environment should be protected and sustained for the benefit of our own and future generations. The proposals are based on three core principles: • Protect and sustain the • Identify and protect local • The need to develop a unified approach to the historic environment heritage assets historic environment Heritage Protection for st • Maximising opportunities for inclusion and the 21 Century – White involvement Paper, 2007 • Supporting sustainable communities by putting the historic environment at the heart of effective planning system

14 Plan/Strategy/Policy General Review General Issues Specific Issues Identifies the main causes of fuel poverty in the UK • Reduce fuel poverty • Improve the energy efficiency (a combination of poor energy efficiency in homes of all residential UK Fuel Poverty Strategy and low incomes) and outlines its effects on quality accommodation (2001) of life and health. The strategy aims to reduce fuel poverty especially of vulnerable members of society, such as children and the elderly. Defines a long-term strategic vision for energy • Reduce CO2 emissions • No specific direction for local policy combining our environmental, security of plans. Local information supply, competitiveness and social goals. The provided through lower-level Our Energy Future - implementation of the White Paper is being taken documents. Creating a Low Carbon forward via the Sustainable Energy Policy Network Economy' - UK white (SEPN). paper on energy (2003) To put ourselves on a path to cut the UK’s carbon dioxide emissions by 60% by 2050 with real progress by 2020. A long term strategy for a modern, efficient and • Increase transport safety and • Local information provided The Future of Transport sustainable transport system over the next 15 efficiency through local transport plan. – UK white paper on years. To ensure that transport makes its full transport (2004) contribution to reducing CO 2 emissions cost effectively. The Future of Air A strategic framework for the development of • Support air transport • Optimise capacity at Luton Transport – White Paper airport capacity in the UK over the next 30 years airport December 2003 against the wider context of the air transport sector. The Government’s approach to policy and delivery • Protection of natural • Recognise role of Luton in of the rural white paper. It identifies three key environment providing services to priorities for rural policy. • Increased access to services surrounding rural locations • Economic and Social Regeneration – supporting • Recognise impact of enterprise across rural England, but targeting development on adjoining greater resources at areas of greatest need natural features England Rural Strategy • Social Justice for All – tackling rural social (2004) exclusion wherever it occurs and providing fair access to services and opportunities for all rural people • Enhancing the Value of our countryside - protecting the natural environment for this and future generations

15 Plan/Strategy/Policy General Review General Issues Specific Issues • Creation of Natural England to enhance • Protection of natural • No specific direction for local biodiversity and landscape and promote access environment plans. Local information and recreation under one organisation provided through lower-level • Establish a Commission for Rural Communities documents • Restrict new public rights of way for mechanically propelled vehicles unless they are created or constructed expressly for motor vehicles. Natural Environment and • Dedication of restricted byways and use by Rural Communities Act, bicycles 2006 • Gives National Park authorities the power to make traffic regulation orders on rights of way and carriageways with unsealed surfaces within National Park boundaries • Provides a private right of way for people who need to access their land or property in cases where a public right of way has been extinguished by the Act. Promotes sustainable development. • Promote sustainable • Sustainable development is Five principles (an explicit focus on environmental communities detailed through the National limits) Planning Policy Framework Four agreed priorities (sustainable consumption Securing the Future – and production, climate change, natural resource Delivering UK production and sustainable communities) Sustainable Development New indicator set with new indicators such as on Strategy, Central well being Government, 2005 The new objectives included within the strategy are: • Living within environmental limits • Promoting good governance • Using sound science responsibly

16 Plan/Strategy/Policy General Review General Issues Specific Issues Incorporates the waste hierarchy set-out in the • Reduce waste not re-used, • Local waste management Waste Framework Directive: recycled or composted targets and actions are set PPS10 – Planning for • prevention; through the local minerals Sustainable Waste • preparing for re-use; and waste development Management (March • recycling; plans 2011) • other recovery (for example, energy recovery); • disposal

Confirms all new homes to be zero carbon by 2016 • Reduce carbon footprint of • Consider targets for limiting with a major progressive tightening of the energy new residential development the carbon footprint of efficiency building regulations – by 25% in 2010 buildings, such as through Building a greener future: and by 44% in 2013. applying the Code for policy statement (2007) Sustainable Homes

Responds to key issues raised in response to the consultation paper Building a Greener Future: Towards Zero Carbon Development. Seeks views on changes to the Code for • Increase energy efficiency of • Consider targets for limiting Sustainable Homes in 2010 to align with changes residential development the carbon footprint of to the Building Regulations and the proposed buildings, such as through Sustainable New Homes: approach to adopting the 2016 definition of zero applying the Code for The Road to Zero carbon. The most significant changes are within Carbon: Consultation on Sustainable Homes the energy section of the Code. the Code for Sustainable The consultation also puts forward changes to Homes and the Energy credit issues such as Lifetime Homes, Home Efficiency standard for Security, Surface Water Run-Off and waste as well Zero Carbon Homes, as setting out issues for further investigation. It also December 2009 seeks views on the energy efficiency definition zero carbon homes from 2016 and whether that should be introduced into Building Regulations from 2013.

17 Plan/Strategy/Policy General Review General Issues Specific Issues Analysis of options for zero carbon standards for • Increase energy efficiency of • Consider targets for limiting new non-domestic buildings. non-residential development the carbon footprint of buildings, such as through Part L 2010 has been brought into legislation and applying BREEAM standards the latest iteration of the Simplified Building Energy Zero carbon non- Model (SBEM) has been published. domestic buildings: Phase 3 final report (July Reviews scope of an energy efficiency standard. 2011) Re-calculates achievable carbon compliance target levels.

Incorporation of public sector buildings into cost- benefit analysis.

Four main themes: • Protect and enhance soil • No specific direction for local • sustainable use of agricultural soils resources plans. • the role of soils in mitigating and adapting to climate change Safeguarding our Soils: A • protecting soil functions during construction and Strategy for England development (September 2009) • preventing pollution and dealing with historic contamination

Aim to protect and manage soils to optimise the varied and important functions they perform. • Promote sustainable • Regional planning and Provides the broader context for Luton. It identifies development growth agendas superseded a key role for four growth areas in facilitating the by direction for a more local Sustainable Communities delivery of an additional 200,000 homes above approach to planning. Plan (February 2003) levels currently planned for. Luton and southern National Planning Policy Central Bedfordshire are part of the Milton Keynes- Framework sets-out the South Midlands growth area. principles of sustainable development.

18 Plan/Strategy/Policy General Review General Issues Specific Issues • Building a strong, • Ensure plan is prepared in- competitive economy line with the requirements of • Ensuring the vitality of town the NPPF centres • Promoting sustainable transport • Supporting high quality communications infrastructure • Delivering a wide choice of National Planning Policy Sets-out the principles of sustainable development, high quality homes Framework (2012) plan making and decision-making • Requiring good design • Promoting healthy communities • Protecting Green Belt land • Meeting the challenge of climate change and flooding • Conserving and enhancing the natural environment • Conserving and enhancing the historic environment • Facilitating the sustainable use of minerals The equality duty covers the following protected • Support equality of • No specific direction for local characteristics: opportunity for all plans. Local information Equality Act 2010: Public • age provided through lower-level Sector Equality Duty • disability documents (e.g. joint What Do I Need To • gender reassignment strategic needs assessment) Know? • pregnancy and maternity A Quick Start Guide For • race Public Sector Organisations • religion or belief • sex • sexual orientation • marriage and civil partnership

19 Plan/Strategy/Policy General Review General Issues Specific Issues A commitment to increase energy from waste • Increase energy from waste • Local waste management through anaerobic digestion. through anaerobic digestion targets and actions are set through the local minerals Key aspects are information dissemination, and waste development Anaerobic Digestion development of good practice, building end plans Strategy and Action Plan markets for digestate and research & development (2011) to stimulate market opportunities.

A loan fund and the development of training packages are proposed. Specifies actions that Defra is taking to meet the • Meet the challenge of • No specific direction for local carbon budget and what indicators are used to climate change plans. Local information track progress. The aim is to achieve a reduction provided through lower-level Climate Change Action of 1Mt CO2 by 2020 through reducing the amount documents (e.g. strategic Plan (DEFRA, 2010) of biodegradable waste produced, diverting more flood risk assessment) biodegradable waste from landfill and promoting alternatives such as recycling, energy generation and utilising more methane from landfill. Sets-out how the UK will become a low carbon • Reduce CO2 emissions • No specific direction for local country. Activity is focused on reducing waste to • Meet the challenge of climate plans. Local information Low Carbon Transition landfill, better capture of landfill emissions and change provided through lower-level Plan (2009) support for anaerobic digestion. Aims to will cut documents such as minerals emissions from farming and waste by 6% on 2008 and waste plans and local levels, by 2020. transport plan. Analyses the key risks and opportunities that • Minimise the risk of • No specific direction for local changes to the climate bring to the UK significant climate change. plans UK Climate Change Risk • Better understand Assessment (DEFRA, The baseline of the CCRA Evidence Report allows vulnerability to current January 2012) Government and others to assess the extent to climate which our actions and plans are climate resilient, • Increase resilience of the and to judge what more needs to be done. economy, environment and society

20 Plan/Strategy/Policy General Review General Issues Specific Issues Indicators for individual authorities removed • Reduce waste not re-used, • Local waste management although a national household waste recycling recycled or composted targets and actions are set target of 50% by 2020 remains in place. through the local minerals and waste development A local recycling and waste services commitment plans will make it easier for households and businesses to address waste.

The Landfill Allowance Trading Scheme is to be abolished. Charging for controlled waste and clarification of definitions are to be resolved through new regulations. Potential to open-up household waste recycling centres (HWRCs) to SMEs. Authorities will be encouraged to review HWRCs, their suitability for accepting business waste and appropriate charging structures.

Government Review of Authorities should ensure that appropriate street Waste Policy in England infrastructure is in place for collecting recyclables. (DEFRA, 2011) Improvement in collection is needed. Importance of managing food waste is acknowledged, alongside a commitment to increase the frequency and quality of waste collections. Service levels will be monitored through WRAP and the cost of waste management per household is a key indicator.

Potential for refuse collection facilities to be put in place at civic amenity sites. Consultation on a landfill ban for wood was announced with a review on a ban for textiles and biodegradable waste.

The focus will remain on weight based reporting although a carbon metric has been proposed.

Includes a commitment to repeal the Climate Change Act powers for household charging.

21 Plan/Strategy/Policy General Review General Issues Specific Issues Skills improvement is important to social inclusion, • Improve options and access • No specific direction for local mobility and sustainable, economic growth. to education plans.

The strategy is founded on the principles of fairness, responsibility and freedom.

Promotes: • Apprenticeships • Vocational qualifications • Professional standards • Growth and innovation funds

Recognises that: • Young people suffer disproportionately from unemployment • Education at all levels is fundamental to a Skills for Sustainable fair society Growth (BIS, 2010) • Adult literacy and numeracy skills are a concern • Both individuals and employers share the responsibility to address skills needs

Proposes that success is measured against: • the proportion of graduates and college leavers going onto employment or further training; • international comparison (within the OECD) of the qualification levels of the working age population in England; • the funding per student in further education as a measure of efficiency; and • the administrative cost of the further education system as a proportion of total funding to further education colleges

22 Plan/Strategy/Policy General Review General Issues Specific Issues • Improve access to natural • No person should live more green spaces than 300m from their • Improve naturalness of nearest area of accessible Emphasises the importance of good quality local green spaces natural green space of at accessible green spaces as they offer a range of • Improve connectivity of least 2ha; benefits including: natural green spaces • At least one 20ha • reducing health inequalities accessible natural green ‘Nature Nearby’: • increasing physical activity space within 2km from Accessible Natural • improving health and well-being home; Greenspace Guidance • functional ecosystem services that can assist in • There should be one 100ha (Natural England, March adapting to the extremes of climate change and accessible green space site 2010) flooding within 5km; • improving air quality and respiratory irritants • There should be one 500ha accessible natural green Proposes relevant standards space site within 10km; • At least 1ha of statutory Local Nature Reserve should be provided per 1000 population. Sets-out the governments strategy to reduce • Reduce CO2 emissions • No specific direction for local carbon emissions by 80%, compared to levels in plans. Local information 1990. The strategy will be delivered through five provided through lower-level aspects: documents such as the local The Carbon Plan: 1. Low carbon buildings (energy efficiency, low transport plan and minerals Delivering our low carbon carbon heating) and waste plans. future (December 2011) 2. Low carbon transport 3. Low carbon industry 4. Low carbon electricity 5. Agriculture, land use, forestry and waste

23 Plan/Strategy/Policy General Review General Issues Specific Issues The Act provides for better, more comprehensive • Local flood risk management • No specific local guidance- management of flood risk for people, homes and and the increased use of will be contained in Strategic businesses, helps safeguard community groups sustainable drainage Flood Risk Assessment, from unaffordable rises in surface water drainage systems Local Flood Risk charges and protects water supplies to the • Meet the challenge of climate Management Strategy and consumer. change Water Cycle studies • Design principles to minimise The Act implements Sir Michael Pitt’s risk of flooding recommendations requiring urgent legislation, Flood and Water following his review of the 2007 floods. Management Act 2010

Lead Local Flood Authorities (LLFA) are required to develop a strategy to tackle local flood risks, involving flooding from surface water, ordinary watercourses, groundwater and small reservoirs.

The cost of damages in England associated with local flooding are estimated to be between £1.2 billion and £2.3 billion1 per year and are predicted to rise due to climate change and continued building development.

Regional

24 Plan/Strategy/Policy General Review General Issues Specific Issues • Reduce impact on and • Offers development options adapt to climate change that can be tested against • Address housing shortages locally derived alternatives • Realise economic potential • The River Lee will continue • Improve quality of life to experience pressure due • Improve and conserve the to increased water environment abstraction and the impacts of potential droughts would be amplified • Parts of the area would likely continue to experience high levels of deprivation The preferred growth scenario is the lowest and is and health inequalities a continuation of the existing housing target, East Of England Plan 508,000 overall. 64,500 for Bedfordshire and Luton • Luton would likely continue 2031 Draft revision to the to experience pressure for (3,230 per annum) while job targets for Regional Spatial Strategy Bedfordshire and Luton are of 52,000, for the considerable change within (March 2010). period 2011-2031. some conservation areas.

• Luton is ranked third out of The accompanying SA highlights local issues the 48 local authorities in the Region in terms of multiple deprivation and includes some of the localities where deprivation is most concentrated. • The M1 is expected to be busy along the majority of its route by 2021 and subsequently 2031. This represents a worsening of the 2001 conditions.

25 Plan/Strategy/Policy General Review General Issues Specific Issues Identifies that Luton / Dunstable / Houghton Regis • Meet need for market and • Revoked in January 2013, and Leighton Linslade are to accommodate an affordable housing though offers development additional 26,300 homes in the period 2001 to • Develop economic growth options that can be tested 2021. The development proposed will be monitored and skills against locally derived Milton Keynes and South against an increase in employment of 12,000 jobs • Prioritise delivery in urban alternatives Midlands (MKSM) Sub- in Luton and 600 jobs in South Bedfordshire in the areas • Green belt review may be Regional Strategy (March period 2001 to 2021. • Environmental improvement required to accommodate 2005) Subject to testing, land should also be safeguarded • Meet existing and future levels of development need for a further 15,400 houses and 7,400 jobs in the infrastructure needs period 2021 to 2031. An allowance should be • Create sustainable made for the availability of urban land for recycling. communities Expands on the identification of Milton Keynes and • Reduce impact on and • Revoked in January 2013, South Midlands, including Luton and Bedfordshire, adapt to climate change though offers development as a growth area with Policy SS3 identifying Luton, • Address housing shortages options that can be tested Dunstable, Houghton Regis and Leighton Linslade • Realise economic potential against locally derived as a key centre for development and change. • Improve quality of life alternatives Policy SS5 identifies Luton, Dunstable and • Improve and conserve the • Green belt review may be Houghton Regis as a priority area for regeneration. environment required to accommodate Key issues identified in the East of England Plan: levels of development need • The requirement for additional jobs and employment opportunities in Luton and southern East of England Plan: Bedfordshire (23,000 additional jobs to 2021) The Revisions to the • Luton as a major town centre in the East of Regional Spatial Strategy England; for the East of England • Following on from the MKSRSMS, to provide (May 2008) 26,3000 new homes to 2021 around Luton, Dunstable, Houghton Regis and Leighton Linslade with an additional 1,000 in the rest of southern Bedfordshire; • Support for transport by sustainable modes; • Setting of renewable energy targets; • Ensure flood risk management; • Protection and enhancement of green infrastructure, open space, biodiversity and the historic environment.

26 Plan/Strategy/Policy General Review General Issues Specific Issues Sets targets for Gypsy and Traveller pitches. Key • Address housing need of • Revoked in January 2013, Accommodation for elements include an increase in the number of Gypsies and Travellers though offers development Gypsies and Travellers pitches to be provided for in the East of options that can be tested and Travelling England, the provision of transit sites and the against locally derived Showpeople in the East provision for travelling showpeople. alternatives of England: A Revision to For Luton these requirements equate to 15 pitches the Regional Spatial to 2011 with a 3% growth rate beyond 2011 and a Strategy for the East of requirement for a transit pitch in Luton and England (July 2009) Bedfordshire. • Promote sustainable • No specific direction for growth within local plans. Regional plans environmental limits would have provided such • Reduce poverty and detail. inequality and promote social inclusion • Reduce greenhouse gas emissions • Adapt to the impacts of climate change A statement of sustainable development • Promote employment, objectives, priorities and challenges facing the East Sustainable Futures: learning, skills and of England. Integrated Sustainability innovation

Framework for the East of The framework does not set targets for each of the • Increase resource England (January 2009) efficiency and reduce objectives; it expresses relevant targets from the resource use and waste RSS and RES under the appropriate objective. • Conserve, restore and enhance the region’s natural and built environment • Move goods and people sustainably • Meet the needs of the changing regional demographic • Provide decent, affordable and safe homes for all

27 Plan/Strategy/Policy General Review General Issues Specific Issues • Raise employment and • Revoked in January 2013, skills rates though offers development Promotes Luton as a regional city that should: • Growth of Luton as a options that can be tested • Continue the transition to a higher value regional city against locally derived economy and raise GVA growth rates • Promote business growth alternatives • Develop a stronger sub-regional • Delivery of high quality, • economic activity is low employment land offer and marketing mixed housing supply among females from certain proposition to attract and retain • Provision of green ethnic communities. companies and entrepreneurs infrastructure of national • compared to the rest of the importance region, there are lower rates Identifies the following constraints: • Improving public transport of business start-up Inventing our future. • Compared to the region, lower rates of provision and connections • poor East/West transport Collective action for a business start-up to the national road network links sustainable economy. • Meeting demand in supply of affordable • traffic congestion, The regional economic housing particularly on main routes strategy for the East of • Poor East/West transport links between and within urban England 2008-2031. • Traffic congestion, particularly on main centres and a need to (2008) routes between and within urban centres, improve connections and the need for improved connection between local and national between the local and national network networks • In Luton and South Bedfordshire just • Luton and South under 23% of the working-age population Bedfordshire have fewer have level 4 qualifications, below regional people with level 4 and national levels. 17% have no qualifications, below qualifications compared to 14 per cent in regional and national levels. the region and England More people have no • Persistent pockets of deprivation. qualifications, compared to the region and England • persistent pockets of deprivation

28 Plan/Strategy/Policy General Review General Issues Specific Issues • effective and inclusive • Luton is a ‘hot spot’ in terms participation, representation of future water deficiency and leadership in • Higher than average levels governance of unemployment, with • living in an environmentally lower-skilled occupations friendly way, including most at risk action on, climate change • Increase the role of the • a thriving, vibrant and airport as an international diverse local economy gateway and a major • well-designed, high-quality employment generator buildings in a well-balanced • Invest in infrastructure to environment support growth, including • well-connected traffic management, J10a communities with good improvements, Luton transport services linking Northern Bypass, Luton Sets out how the region is working to deliver the people to jobs and services North and Luton Parkway East of England vision and priorities in the Regional Economic • public, private and Station Implementation Plan Strategy and in the East of England Plan. community and voluntary • Move to higher value (February 2010) services that are available industry through sufficient Identifies the following priorities for Luton and to all high-quality employment southern Central Bedfordshire • active, inclusive, safe and land and infrastructure, strong local culture with building on investments at shared community activities Butterfield Green and • equity for everyone for Napier Park today’s and tomorrow’s • Town centre regeneration to communities address transport issues, provide quality environments and a range of retail and services • Protect/ expand green infrastructure, integrating into urban areas • Promote the university as a knowledge hub, ensuring further education provision is expanded at colleges

29 Plan/Strategy/Policy General Review General Issues Specific Issues • Address housing affordability • Regional planning and This document implements the national growth agendas superseded Sustainable Communities Strategy. • Improve transport by direction for a more local Creating Sustainable infrastructure approach to planning. Communities in the East Key issues for the region are identified. • Address scarce water National Planning Policy of England (2005) resources Framework sets-out the The document does not set new targets or principles of sustainable indicators. development. • People shaping the future of • No specific direction for local Aims to implement the Government’s Urban White their community plans. Regional plans would Paper and Sustainable Communities Plan in the • Attractive, well-kept towns have provided such detail. East of England. • Good design that makes it

Towns and Cities – practical to live more It has the same objectives as the urban White Strategy and Action Plan: environmentally sustainably Paper, supplemented by the objective that people Urban Renaissance in the • Towns and cities able to and organisations should possess the right skills to East of England create and share prosperity deliver an urban renaissance. • Good quality services The strategy contains no specific targets but it • Developing the skills suggests some indicators. necessary to deliver the urban renaissance • Address issues of climate • The region is the country’s change driest. Forecast increasing Sets out the aspirations of the climate change demand for water, where partnership and identifies key strategic objectives resources are already fully that will form framework for the action plan. committed and in many areas already classified as The East of England Objectives include: under serious water stress. Climate Change • Leadership; • Greater intensity and Partnership: Draft Climate • Reduced greenhouse gas emissions; frequency of winter rainfall Change Action Plan (April • Transport; may increase the risk of 2009) • Resilience for a sustainable economy, flooding. built environment and society; • Heat related deaths may • Resilience for a sustainable natural increase environment. • Habitat and wildlife will be threatened by the changing climate

30 Plan/Strategy/Policy General Review General Issues Specific Issues • Protect and enhance • Development may affect land Chilterns Area of adjacent to/ visible from the Contains policies and actions to conserve and Outstanding Natural Beauty Chilterns on a large scale. enhance the natural beauty of the Chilterns, • There may be a harder, Chilterns Area of increase understanding and enjoyment of them more defined edge between Outstanding Beauty and fostering social and economic well being. It town and country. Management Plan 2008 - also looks at the likely impact of climate change on • The view from the AONB 2013 the Chilterns over the next few decades, escarpment will significantly highlighting the importance of good management. be affected in some places. • Increased activity at the airport will erode tranquillity of the AONB. Sets-out the local enterprise partnership’s 6 • Support local enterprise • No specific direction for local priorities: plans. 1. Successful delivery of Northampton Waterside Enterprise Zone for new jobs and businesses 2. Attract new overseas business into the South East Midlands through local investment plans Getting Down to 3. Investment in key infrastructure to unlock short Business: Plan for growth and medium term development April 2012-March 2013 4. Investment in key digital infrastructure to (SEMLEP) accelerate development 5. To work with the secondary, further, higher, voluntary and community, and private sector education and training providers to ensure skills outcomes match enterprise needs 6. To support local authorities to deliver economic development plans and related activities County

31 Plan/Strategy/Policy General Review General Issues Specific Issues This plan aims to deliver long term guidance on • Promote environmental • Revoked in January 2013, land use change in the county. The plan has 6 stewardship though offers development saved policies relating to: • Enhance economic options that can be tested • Areas of Great Landscape Value; against locally derived Bedfordshire Structure opportunities • Defence sites and institutions; alternatives Plan 2011, 1997 • Increase social • Infrastructure; opportunities • New infrastructure; • Other airfields; and • Luton Town Football Club. • Promote resource efficiency • Replacement plans under construction, due for adoption mid-2013 • Rail aggregate depot at Leagrave Road is Sets out the detailed land use policy framework for Bedfordshire and Luton safeguarded the extraction of minerals and management of Minerals and Waste Local waste in Bedfordshire and Luton. • Additional, unused railhead Plan, 2005 facility at Church Street/

Crescent Road • Target of 33% of municipal waste should be recycled or composted by 2015

• Promote waste reduction • Rail-served aggregates • Protect and enhance depots at Leagrave Road Minerals and Waste Core Sets out the detailed land use policy framework for biodiversity/ landscape and Crescent Road are Strategy Plan for the extraction of minerals and management of fabric required to avoid the use of Submission waste in Bedfordshire and Luton between 2013 • Protect and enhance the the road network to import with Main Modifications and 2028. Will replace the 2005 minerals and safety of the road network roadstone from external and Additional waste plan. quarries Modifications (Central • Protect and enhance • Concrete batching plants at Bedfordshire, Bedford Seeks to recover 70% of municipal solid waste and cultural, social and Cosgrove Way and and Luton borough 75% of commercial/ industrial waste by 2015. environmental heritage Selbourne Road are councils, May 2012) • Reduce transport issues and carbon emissions safeguarded

32 Plan/Strategy/Policy General Review General Issues Specific Issues Set up to find alternative waste disposal solutions • Promote resource efficiency • No specific direction for to landfill. Aims to find sustainable solutions to local plans. avoid penalty fines and rising taxes. The project is working towards providing a waste treatment facility in Brogborough, which should be Bedfordshire Energy and operational by 2016. Recycling Project Target of 60% recycling and composting by 2020. Luton and Bedford Borough Councils pulled out of the project in 2009. Luton Borough Council will use its own facilities until 2016 and are looking for new/alternative arrangements post 2016. A 10 year programme of activity to improve access • Enhance access to • A ‘Chalk Arc’ lies to the to the countryside to meet the current and future countryside north of Luton, of which the needs of the residents of Bedfordshire and visitors The Outdoor Access quality of access and visitor to the county. experience is planned to be Improvement Plan for The Plan looks at public access in rural and urban enhanced. Central Bedfordshire areas - both the rights of way network and all other 2013 to 2023 • Developer contributions 'open country' and countryside that is available for (consultation draft) may be required to fund public access. It also considers how other parts of improvements to ‘outdoor the transport network, such as minor roads, are access’ important in getting to rights of way and other countryside sites. The overarching, long-term goal for transport in the • Protect air quality • Optimising capacity of Luton county is: • Improve the road network airport could lead to Bedfordshire Local ‘To improve the quality of life and economic • Address congestion additional traffic congestion Transport Plan 2006/7 – prosperity in Bedfordshire by connecting 2010/11 communities and businesses, and improving access to services and amenities.’

Local

33 Plan/Strategy/Policy General Review General Issues Specific Issues • Reducing commuting • A significant number of distances Central Bedfordshire • Regenerating town centres residents commute to Luton • Improving educational for work, which CBC would achievement like to see reduced • Improve urban-rural • Development of Luton town connections centres may impact • Improve health, well-being, negatively on regeneration and quality of life ambitions of neighbouring • Enhance biodiversity authorities • Protect valued landscapes • A significant amount of • Improve air quality people migrate from Luton For the period 2011 to 2031, the strategy sets-out to Central Bedfordshire policies to guide development with respect to: • Central Bedfordshire plan to • Employment and economy accommodate some of Development • Town centres and retailing Luton’s jobs growth that Strategy for cannot be met within Luton, • Infrastructure Central Bedfordshire particularly provision of B • Transport Pre-submission version, Classes that are more land- January 2013 • Housing provision hungry • Settlements and green belt • Expansion of Luton airport • Countryside and natural environment is key to delivering job • Site-specific policies growth in southern Central Bedfordshire • Mixed-use urban extensions are planned to the north of Luton and Houghton Regis • Development North of Houghton Regis presents opportunities to reduce flood risk downstream, in Luton • Development north of Luton may help address needs of current and future residents

34 Plan/Strategy/Policy General Review General Issues Specific Issues • Protect and enhance the • The policies are based on natural and historic evidence that is dated. environment Recent evidence (including • Support good design documents in this list) The overarching aim of the Local Plan is to achieve provides up-to-date details sustainable development in Luton while targeting • Meet housing needs • Rolling forward existing the following areas: • Provide adequate policies into a new plan can • Environment community infrastructure Luton Local Plan 2001- be tested among other • Social Matters • Increase employment 11, 2006 opportunities policy options • Economy • Maintain vitality and viability • Infrastructure of retail centres • Action Areas • Reduce the need to travel • Implementation and Monitoring by car • Accommodate telecommunications • Mange waste and energy • Support vitality and viability • There are limited of retail centres opportunities for new The report gives consideration to retail issues that national multiple retailers are prevalent. It aims to: with large floorspace • assess existing retail patterns, giving requirements consideration to the town centres of Luton, Dunstable, , and • Luton’s strength as a retail destination is likely to erode Luton and South Beds Houghton Regis unless quantitative and Retail Study, 2005 • assess likely future retail patterns, giving qualitative improvements to consideration to the town centres of the town centre retail offer Luton, Dunstable, Leighton Buzzard, and are carried out Houghton Regis • Improvements to the quality • evaluate the need for retail floor space of the public realm and provision in the future evening economy in the town centre are required

35 Plan/Strategy/Policy General Review General Issues Specific Issues • Support vitality and viability • A significant increase in of retail centres town centre representation from national multiples seeking large format premises is unlikely due to the dearth of suitably large and modern town centre premises, thus potentially limiting the town centre’s Updates the 2005 retail study and considers retail ability to increase its issues within the wider conurbation, specifically in competitiveness as a major order to provide guidance on the type, size and shopping destination. location of future retail provision. The study is Luton and South Beds • The town centre would based on a full assessment of the role and Retail Study, 2009 update benefit from a large functions of the study area’s principal town centres, foodstore for main food taking account of retail activity since the 2005 shopping. study and plans to accommodate major strategic • Environmental quality of growth. district centres requires improving • Additional foodstores should be provided in potential urban extensions. • New comparison retail should be prioritised at the Northern Gateway and Power Court

36 Plan/Strategy/Policy General Review General Issues Specific Issues • Promote equality • High demand for affordable • Promote social inclusion housing • Promote social cohesion • Deficiency of high quality accessible green space in certain areas affects peoples health, wellbeing and overall quality of life • Three wards are in the top 10% most deprived in the country wards This Community Strategy provides a shared vision • The proportion of the for how Luton will be in 2026 and how they intend working population claiming to get there. It is based in 3 overarching themes: benefits is 1.4 times higher Luton’s Sustainable equality, inclusion and cohesion. The themes than that for the East of Community Strategy include: England 2008 – 2026 • Stronger and safer community; • Unemployment is above the • Health and wellbeing; regional and national • Environment and economic development; averages • Children and young people. • There is a high percentage of children from homes where English is not the first language and who start school needing extra help with their English. • Luton is third worst in the region for crime levels • High rates of health risks in Luton centre on lifestyle related illnesses

37 Plan/Strategy/Policy General Review General Issues Specific Issues • Maximising employment • Unemployment is notably opportunities higher in Houghton Regis The most deprived areas in Central Bedfordshire • Delivering housing growth and Dunstable than other are found in parts of Dunstable and Houghton to meet needs parts of Central Regis. In these locations, young people are much • Ensuring local people have Bedfordshire less likely to go on to higher education, almost half the skills to prosper • In parts of Houghton Regis the children live in a low-income family and almost and Dunstable, young a third of older people live in poverty. • Keeping communities safe people are much less likely • Nurturing a sense of pride to go on to higher education Sustainable Community The strategy seeks to deliver: and belonging • Almost half of children live Strategy 2010-2031: A • a widening of the M1 between junctions • Access to services in low-income families in Prospectus for Central 10 to 13 • Caring for a green and Bedfordshire parts of Dunstable and • a new junction 11a clean environment Houghton Regis • completion of the Woodside road • Promoting health and • Poverty affects almost a connection in Houghton Regis reducing health inequalities • Educating, protecting and third of older people in parts • the Luton-Dunstable guided bus way of Dunstable and Houghton • an A5-M1 link road providing opportunities for children and young people Regis • a north Luton bypass linking the A6 to A505 • Supporting and caring for an ageing population and those who are most vulnerable

38 Plan/Strategy/Policy General Review General Issues Specific Issues The transport vision to 2026 is ‘to make Luton a • Supporting the economy • Congestion in Luton is safer and healthier place in which to live, work, • Protecting the environment estimated to have an learn and have fun, we will provide an integrated, • Improving road safety and economic cost of £51.4m safe, accessible and more sustainable transport personal safety every year and is likely to system which supports the economic regeneration • Improving health and increase. and prosperity of the conurbation and the planned wellbeing • The M1 and railway sever growth of the area whilst reducing unnecessary car • Reducing carbon emissions the conurbation, with limited use and CO2 emissions, enhances the • Increasing attractiveness of ‘bridging points’ environment and generally improves the health and public transport and other • Conurbation is constrained quality of life of the community’. non-car transport options by environmentally sensitive • Improving air quality areas within and around it This vision will be delivered through 7 aims: • About 26% of households in 1. Generate continued employment and prosperity Luton do not have access to Luton Local Transport 2. Create and preserve an attractive environment a car Plan 2011-2026 (March and pleasant living conditions • Low levels of walking, 2011) 3. Promote equitable opportunities and access to cycling and public transport services for all members of the community use, despite the high 4. Promote the development of Luton Town Centre proportion of people who as a sub-regional centre travel short distances 5. Give people the opportunity to choose more • Car travel is the greatest sustainable travel habits contributor to CO 2 6. Support Luton’s growth as an international emissions in Luton gateway • The residential areas 7. Lay the foundations for future expansion around Junction 11 of the M1 suffer from higher levels The main priority is to improve east-west of poor air quality connectivity particularly between Luton and Dunstable/Houghton Regis.

39 Plan/Strategy/Policy General Review General Issues Specific Issues Assesses the overall scale and spatial allocation of • Delivery of required • Infrastructure requirements infrastructure required across the Luton and infrastructure for Luton are identified Southern Bedfordshire area, associated with the through studies on Luton Gateway delivery of homes and associated employment individual topic areas Infrastructure Delivery development identified through the MKSMSRS. • A revised IDP collating the Plan & Funding Strategy, most recent evidence of January 2010 Provides details of identified funding sources and needs for Luton will be recommendations on delivery and management produced to inform new arrangements. planning policies The three key objectives are to: • Addressing congestion • The plan addresses 1. Support the economic growth of the area, • Maintaining traffic flow and parking-related concerns Luton Borough Council meeting obligations to manage the transport road safety raised by the local transport Parking Policy and Plan, network and congestion; • Encouraging use of plan. No new issues are Final Draft (2013) 2. Manage the demand for parking in residential alternatives to the car identified areas to meet community needs; and • Contribute towards modal 3. Satisfy road and community safety obligations shift

• Contribute towards modal • (Un)reliability, lack of buses shift at night and Sundays, The plan promotes travel by walking, cycling, bus, • Promote sustainable travel frequency and cost reduce rail, car-sharing, electric cars and powered two- Luton Sustainable Travel the number of people wheelers. • Reduce carbon emissions Plan 2011-2015 (August choosing to travel by bus • Promote road safety 2011) • Safety underlies reasons Investment is required in both infrastructure and why people don’t walk and education. cycle with speed of traffic,

park and cycle on footways and fear of crime • Reduce car use and • More than 13,000 (25.1%) increase the use of children live in poverty in Aims to reduce car use and increase the use of sustainable transport Luton, which is higher than ‘Sustainable Modes of sustainable transport in order to improve the national and regional Travel to Schools and physical well-being of those that use them and the averages Colleges Strategy 2009- environmental well-being of the area. Sets out the • Growth in households will 2013’ (October 2009) sub-objectives relating to safety, education, health create demands on the local and transport and funding. education system and transport infrastructure

40 Plan/Strategy/Policy General Review General Issues Specific Issues • Habitat protection • Potential nationally and locally important plant areas Objectives and aims include: are located in the vicinity of • Conservation of species and natural Warden Hill, Someries habitats Castle and Chaul End • Provide focus and information for local • Rare sightings of the initiatives that promote biodiversity European otter have been Bedfordshire and Luton • Give locals a chance to share their views made in the vicinity of Luton Biodiversity Action Plan, on the subject Hoo 2001 (updated 2007) • Register targets that reflect the views of • Water voles and Great the locals Crested Newts have been • Promote partnerships that will help recorded around the source promote and protect biodiversity and upper tributaries of the • Raise awareness Lea • Adders have been recorded around Challney/ Leagrave • Addressing flood risk • Considerable flooding has • Managing the impacts of been experienced, most Key recommendations are: climate change commonly as a result of an inadequate drainage system • In flood zones 1, 2 and 3 Flood Risk • Promote the use of that has not been upgraded Assessments should focus on the sustainable sustainable drainage management of storm water and have regard to systems • Limbury, Wardown Park, the cumulative impact draining development sites the Telford Way roundabout and the confluence of Luton Borough Council can have on existing infrastructure and flood risk; Houghton Brook with the and South Bedfordshire • Engage with developers and local regulators Upper Lee have flooding District Council Level 1 throughout the development process and take a problems Strategic Flood Risk pro-active approach to reducing flood risk; • Much of the storm water Assessment, September • Protect areas required for future flood alleviation sewer system discharges to 2008 schemes, including areas in the Upper Lee the river. When levels on catchment and Clipstone Brook as already the Lee are high the sewer identified by the Environment Agency; is cannot discharge, backs • Require new developments within 8m of the up and floods River Lee to upgrade/ maintain river banks; • Risk of sewer flooding • Protect floodplains / compensate these areas affects a significant number of properties in the low-lying areas

41 Plan/Strategy/Policy General Review General Issues Specific Issues LBC is defined as a Lead Local Flood Authority • Addressing flood risk • Long term development (LLFA) under the Act. LLFAs are required under • Managing the impact of may affect the occurrence the Act to develop a strategy for local flood risk climate change and significance of flooding management. • The town centre area of

Luton Preliminary Flood Luton is identified as having The first step is to carry out a Preliminary Flood Risk Assessment (June ‘Very high’ susceptibility to Risk Assessment (PFRA). This document presents 2011) groundwater flooding. the findings of the PFRA for Luton. The PFRA

process is aimed at providing a high level overview of flood risk from all sources within a local area, including consideration of surface water, groundwater, ordinary watercourses and canals. The strategy brings together other local strategies • Adapt to and mitigate • No new issues identified, under four key areas: climate change the framework is a summary 1. Successfully adapting and mitigating for • Protect and enhance the of the environmental climate change natural and built aspects of other local plans 2. Protecting and enhancing the natural and environment and strategies Luton Borough Council built environment • Reducing consumption and Environment Strategy 3. Reducing consumption of water, energy, waste Framework (July 2010) materials and minimising waste, including • Support renewable energy support for renewable energy generation generation (approved by Executive 4. Improving public transport, access and th • Improve public transport, Committee on 29 March mobility and increasing travel to work by access and mobility 2010) sustainable modes of transport, including • Increase travel to work by public transport, walking and cycling sustainable transport

These will be implemented through 91 actions across all council activities.

42 Plan/Strategy/Policy General Review General Issues Specific Issues • Place shaping and • Overcrowding maintaining sustainable • High levels of communities homelessness • Improving housing • Variable conditions in the conditions across all private rented sector tenures • A shortage of good quality • Meeting housing need land suitable for house • Tackling homelessness building • Over 25% of households Sets-out locally identified housing issues and receive benefits Luton Housing Strategy actions to address them. Shows how housing can 2012-2015 contribute to the wider corporate goals included in • Access to affordable the Luton Borough Council Corporate Plan. housing is restricted due to shortages of local authority and housing association stock • High levels of homelessness • Focussing development on brownfield sites adds cost, impacting on viability of schemes

43 Plan/Strategy/Policy General Review General Issues Specific Issues • Protect and enhance • Development on the urban environmental assets fringe may impact on • Provision of green landscape and historic infrastructure setting including the AONB, With reference to the MKSM-SRS growth agenda, Lea Valley and Thedeway this defines strategic green infrastructure, • Development within Luton assesses existing provision and identifies may impact on the deficiencies in strategic provision. The plan Victorian/ Edwardian identifies ways to integrate existing provision (both townscape accessible and inaccessible) with opportunity areas • Wardown and Stockwood in order to create green networks of access routes, parks provide accessible Bedfordshire and Luton landscape, heritage, biodiversity and accessible greenspace of strategic Strategic Green green space. significance Infrastructure Plan 2007 The following broad areas and corridors for • National Cycle Network strategic multifunctional green infrastructure are Route 6 and the Upper Lea identified: Valley Walk are the two • Ouzel River Valley Corridor strategic, non-motorised • Chalk Arc Corridor access routes through • Upper Lea Valley River Corridor Luton • Leighton Linslade to Dunstable Corridor • Links from the north of Luton to the Icknield Way Bridleway and Footpath are required to increase connectivity/ accessibility

44 Plan/Strategy/Policy General Review General Issues Specific Issues • Achieve a sustainable • Hemel Hempstead and A refresh of the 2008 study with a specific focus on balance between housing/ Milton Keynes provide the preferred development options from the (now employment delivery competition in terms of withdrawn) joint core strategy. • Achieve transition to a more industrial sites diverse and knowledge • Luton may not have the Luton and South Recommendations include: based economy land for large employment Bedfordshire Employment • Policies that focus on underprovided sectors developments Land and Market (small industrial units, start-up, incubation and • St. Albans, Hemel Assessment Study managed office/workshop space). Hempstead and Milton (March 2010) • Flexibility for developers over size, scale and Keynes provide competition type of provision, with a range provided to ensure in terms of office a ‘ladder’ of space for companies to move into. development • Ensure employment sites do not come under • Much of the industrial space pressure from non-B employment uses. in Luton is dated and often has associated amenity issues • Reduce car use and • Enhanced road Assess transport related impacts of the withdrawn, increase the use of infrastructure will increase joint core strategy. Luton and South sustainable transport the attractiveness of the car,

Bedfordshire Local increase car usage and The findings were that there was a need for a Development Framework reduce modal shift significant shift to public transport and there would Transport Appraisal be increased levels of congestion if the growth was • Increased population will (March 2009) increase vehicle kilometres not met without additional investment in strategic travelled and time spent highway infrastructure. travelling

45 Plan/Strategy/Policy General Review General Issues Specific Issues • Provide, protect and • Population growth will enhance an accessible increase pressure on green network of green spaces spaces, requiring new provision • Deficiency in overall provision of urban parks and gardens • Absence of any amenity greenspace in parts of the Aims to set appropriate policies and guidance for north, northwest, south, land owners and developers on the provision of west and north east accessible green spaces. Key objectives are to: • Natural and semi-natural • provide and enhance a network of accessible, greenspace provision is low high quality green space that meets the needs of in parts of the south, south the local people now and in the future east, central, west and north • incorporate good green space design principles west in all new developments Luton and South • Green corridors unevenly • encourage community involvement in the design, Bedfordshire Green distributed, with little management and care of their local green Space Strategy, February provision in parts of the spaces and promote health and social well being 2008 (Consultation south, northwest, north and Version) • provide a sustainable approach to green space north east management and maintenance • Allotment provision is low in • provide a framework for resource allocation that the central, north east and maximise funding to support improvements south areas

• Urban extensions to the Includes specific, spatial priorities for Luton and north will increase demand surrounding areas for green space

• Poor linkages between

green spaces due to road and rail barriers, congestion or high density development • Many sites do not meet the requirements of the Disability Discrimination Act • Significant concerns about safety, crime and vandalism in green spaces

46 Plan/Strategy/Policy General Review General Issues Specific Issues Assesses landscape sensitivity and key visual • Respect landscape value • Development on the urban sensitivities/ constraints and opportunities for fringe may impact on Environmental Sensitivity • Respect biodiversity potential urban extensions in southern landscape, biodiversity and Assessment (April 2008) • Respect historic assets Bedfordshire. Landscape, biodiversity, archaeology historic setting including the and Revised Assessment and history are assessed. Establishes a set of AONB, Lea Valley and (December 2008) guidelines and potential mitigation proposals Thedeway relating to the study areas. • Address flood risk • Luton is situated in an area • Manage the impact of of serious water stress, with climate change resources classed as over abstracted, over licensed or Examines the potential impacts of the future growth having no water available on all the main aspects of the water cycle, namely; • New development may water resources, water quality, flood risk and increase runoff and flood Luton and South ecology. The findings include: risk to existing development Bedfordshire Outline • Flood risk is an issue for certain sites; • Development to the north- Water Cycle Study Phase • There are capacity issues of wastewater and foul east of Houghton Regis 1 (December 2008) network treatment due to the planned growth; may increase flood risk • Issues with existing resources of water supplying associated with Houghton the growth. Brook • Development to the north of Luton may increase flood risk associated with the River Lea

47 Plan/Strategy/Policy General Review General Issues Specific Issues There is a significant challenge to meet the • Address flood risk • The document expands on requirements of the Water Framework Directive, in • Manage the impact of the phase 1 study, no new particular phosphate standards. This can be climate change issues are identified achieved through sustainable drainage systems. • Water quality • Efficient use of water Major development to the east of Luton may be accommodated with minor upgrades to foul drainage infrastructure draining to East Hyde.

Luton and Southern Ensure there is no detriment to the existing surface Central Bedfordshire water flooding issues downstream of new Water Cycle Strategy development. Phase 2 (June 2010)

For brownfield sites in Luton, reduce surface water run-off rates and volumes to greenfield equivalent.

Drainage at the airport should prevent increased risk of bird strike.

Impose a maximum calculated water consumption equating to CSH level of 3/4.

• Adapt to climate change • The document provides little Luton Borough Council information on local issues The purpose of this adaptation action plan is to • Minimising flood risk Climate Change other than flooding (covered address the risks (and opportunities) a changing • Designing sustainability into Adaptation Action Plan by other papers) climate may pose to Luton new developments (March 2010)

48 Plan/Strategy/Policy General Review General Issues Specific Issues • Maintain supply of land to • Identified capacity for 4,777 meet housing requirements further dwellings • Capacity for a further 4,408 dwellings from sites that are LBC Strategic Housing currently not available and Land availability achievable Assesses the capacity of Luton to accommodate Assessment (November residential development. • If private-sector 2012) developments on PDL are unable to fulfil their obligations, this may result in public open spaces developed for affordable homes. • Protect and enhance • 1 or 2 x 4-lane, 25m provision of sports facilities swimming pool(s) required Assists in guiding the future provision of a range of • 4 x 4-court sports halls indoor and outdoor sports facilities in Luton and Luton Sports Facilities required identifies a clear and prioritised framework for Strategy 2008 – 2021 • 356 fitness stations required future investment in sports facility provision. The (March 2008) findings identified a need for additional sports • 3 x 3-rink indoor bowl facilities with an increased population. facilities required • 5 all-weather turf pitches required • Protect and enhance • New facilities provided provision of sports facilities within Luton but accessible to residents of Central Assists in guiding the future provision of a range of Bedfordshire may help to South Bedfordshire sports facilities in South Bedfordshire. The Strategy address needs. Likewise, Sports Facilities Strategy makes recommendations for different sports new facilities provided in (June 2008) pitches and recommendations for funding and Central Bedfordshire and resources. accessible to Luton residents may help address Luton’s needs.

49 Plan/Strategy/Policy General Review General Issues Specific Issues • Provision of social and • Concerns from stakeholders community infrastructure relating to an inadequate supply of preschool places • Primary schools are Offers advice on the community infrastructure Social and Community operating at capacity needed to support the growth in development Infrastructure Study: especially in the town centre expected in Luton and South Bedfordshire up to Identifying Existing and • No spare capacity in 2021 and 2031. It identifies the anticipated social Future Social and secondary schools and community infrastructure needed in relation to Community Infrastructure the projected population projections and includes • Any new growth would Needs for Luton and require new schools the current deficiencies. In assessing the need, the South Bedfordshire study determines how best these can be delivered • High demand for custody (August 2008) and provided for. facilities at police stations • Unequal provision of community centres and their geographical spread needs addressing • Delivering sustainable • Development of land at development Junction 10A involves significant landscape sensitivity issues, competition with other strategic sites, phasing of Core Strategy: Site junction 10A improvements Assessment Matrix Updates appraisal of urban extensions and and relocation of the town’s Update (November 2010) incorporates strategic employment sites. football club • Development of land around Butterfield Park involves significant landscape sensitivity, biodiversity and heritage issues. May require significant strategic transport improvements

50 Plan/Strategy/Policy General Review General Issues Specific Issues Rolls forwards the two previous objectives with • Improve public transport • No issues identified, revised target dates: links document proposes London Luton Airport • increase the proportion of passengers travelling • Reduce transport emissions approach to increasing Surface Access Strategy to and from the airport by public transport to • Reduce road congestion travel by sustainable modes 2012 – 2017 more than 40% by 2017 • reduce the proportion of staff travelling alone by car to and from the airport to 60% or lower by 2017 • Mitigating impact of aircraft • Areas predominantly noise affected by aircraft noise • Mitigating road traffic impact are in areas of south and south west Luton, Breachwood Green, London Luton Airport Contains 55 specific actions including the Whitwell, Slip End, Noise Action Plan 2010 – discouragement of residential development close Caddington, Flamstead and 2015 to the airport boundary or areas affected by aircraft Markyate noise. • Surrounding areas are also affected to by road traffic noise and overflights travelling to and from other UK airports

51 Plan/Strategy/Policy General Review General Issues Specific Issues • Encouraging economic • The airport is a key development employer and driver of the • Increasing job opportunities local economy Adopted by Council as SPG • The airport site has significant ecological value, Outlines the future form and proposed expansion parts of which support a of the airport and addresses the following issues: local green network London Luton Airport • Air and ground noise • Airport development may Development Brief 2001 • Surface access impact on a landscape (Supplementary Planning • Ecology conservation area (east, Guidance) within North Hertfordshire) • Landscape and an area of great • Air quality landscape value to the • Geology, hydrogeology and water resources south (in Central • Energy management Bedfordshire) • Airport activities seen to be significant sources of PM 10 and nitrogen dioxide The policy makes 10 general commitments to • Reducing carbon emissions • No specific issues identified managing environmental impact. These include: • Resource efficiency • Seeking continual environmental improvement London Luton Airport and prevention of pollution at the airport. Environmental Policy • Respecting the environment and prudent use of (2010) natural resources. • Enhancing the airport’s operations to improve energy efficiency and reduce associated carbon emissions.

52 Plan/Strategy/Policy General Review General Issues Specific Issues • Conservation of visual • Development on the edge of Environmental Sensitivity quality, biodiversity, Luton could negatively Assessment: South Provides local information on environmental archaeological and historic impact environmental Bedfordshire Growth sensitivity with respect to proposed locations of landscape quality in neighbouring Area Supplementary development to support growth across Luton and areas Report Relating to southern Central Bedfordshire. Portions of Land in • It may be possible for some development to take place Adjoining Council Areas Luton is surrounded by sensitive landscape, in the (with appropriate mitigation) Potentially Affected by majority of which it is not considered appropriate to the north-east of the the Delivery of Growth for development to take place. airport, the northern fringe (December 2008) of Luton and on the fringes of Caddington and Slip End • Conservation and • Development within and on enhancement of Luton’s the edge of Luton could landscape setting negatively impact the • Increasing opportunities to character of Luton’s access and enjoy the landscape setting distinct character of the • Access to and enjoyment of surrounding landscape the surrounding landscape Provides local information on landscape character may be reduced if with respect to proposed locations of development landscape character is South Bedfordshire to support growth across Luton and southern diminished District Landscape Central Bedfordshire. • The Chilterns AONB lies to Character Assessment the north-east and south- (April 2009) Landscape to the north of Luton is characterised by west of Luton chalk escarpments and farmland, while chalk dipslopes and valleys are characteristic of the • To the south-east lies the landscape to the south. registered park and gardens of Luton Hoo • A site of special scientific interest lies on the north- eastern border of Luton (Warden and Galley hills area)

53 Plan/Strategy/Policy General Review General Issues Specific Issues Recommends: • Reducing carbon emissions • Document considers • Encouraging investment in solutions to issues raised in The collection/ processing of food waste to renewable energy and other documents. No generate low carbon heat and power. decentralised energy specific direction in terms of production a Local plan for Luton All new residential buildings post 2016 to be • Planning to adapt to climate carbon neutral with non-residential buildings being change carbon neutral by 2019. Buildings must perform to • Sustainable water cycle CfSH Level 4 for energy efficiency and aspire management towards Level 6 from 2016/2019. • Promoting energy efficiency in new developments Central Bedfordshire and New developments to: • Decarbonising existing Luton Borough Council’s • Achieve minimum net water efficiency of 105 building stock Joint Committee l/p/day. The target figure for new developments Sustainable Development is 80 l/p/day and Adaptation & • Conform to the CIBSE guidance on overheating. Mitigation of Climate • Comply with the Lawson criteria for pedestrian Change Study (February site comfort in wind 2010) Allow developers to choose the appropriate mix of technology to achieve CO2 reduction.

Developments in close proximity to existing or planned communal heat networks/ CHP be required to develop a shared heating network.

A sustainability fund be set up to facilitate carbon and water use reduction in existing buildings, funded by developers that are not able to comply with energy and water efficiency targets.

54 Plan/Strategy/Policy General Review General Issues Specific Issues Considers the joint, regional strategy housing • Meeting housing needs • It is not viable to deliver all target for Luton and southern Central Bedfordshire. of Luton’s affordable housing requirements within Identifies that a target of 35% affordable housing its boundary through the contribution should be viable through the period to planning system 2021. This should be further split as 25% social • There is requirement in rent and 10% intermediate tenures. Luton to re-model existing residential care and Developers should be encouraged to produce sheltered housing provision specialised housing for older people and other • 22.7% of households are vulnerable households. Bedfordshire and Luton unsuitably housed

Strategic Housing Market • The need for affordable There remains a need for continued investment to Assessment (March housing is greater than the deliver decent homes and improve thermal comfort 2010) target for all new housing in the private sector, focussing on the needs of • Land constraints mean that vulnerable occupiers. some housing growth will need to be delivered on the To tackle overcrowding, opportunities should be edges of Luton, within identified for extending/ converting existing neighbouring authorities affordable housing and purchasing larger market • Overcrowding is a particular housing, as well as delivering larger affordable concern among Asian and homes on new developments. Under-occupation Black African households should be tackled, providing housing that meets the aspirations of older people currently occupying larger family housing.

55 Plan/Strategy/Policy General Review General Issues Specific Issues • Meeting housing needs • A lack of space and other constraints means that regional growth needs are unlikely to be Housing Provision Identifies that Luton’s is the main source of natural accommodated within Technical Note (July population growth in the Luton and southern Luton’s administrative 2010) Central Bedfordshire area. boundary. • Growth expected in Luton will need to be diverted to surrounding areas including Central Bedfordshire, Bedford and Northampton Identifies: • Meeting affordable housing • The presence of affordable No evidence related to support setting of needs housing has a thresholds based on economies of scale. disproportionate, negative impact on the marketability Need for development schemes to be designed to of smaller housing schemes attract the maximum available grant funding. • The majority of development sites fall below Recognises that developments offering commuted Technical Note: the threshold for affordable sums will generate a greater overall development Affordable Housing Site housing provision. value than those providing affordable housing on- Size Thresholds Evidence suggests many site. (September 2010) developers propose

schemes just below the There is an administrative cost to applying site size threshold thresholds.

Recommends a threshold of 15 units for Luton dues to tighter margins for viable delivery of affordable housing and concerns over the efficient use of land.

56 Plan/Strategy/Policy General Review General Issues Specific Issues Recommends new accommodation in Luton to • Meeting housing needs of • Around one third of Gypsy support 11-17 households between 2006 and Gypsies and Travellers and Traveller households 2011. Post 2011, targets should be based on a reside on unauthorised sites new family formation rate of 6.9% per year. • Security of tenure (certainty of time in accommodation) New sites should be of an appropriate size to is a concern for Gypsies accommodate larger families, visitors, vehicles and and Travellers trailers. Bedfordshire and Luton Gypsy & Traveller There are strong social and practical reasons for Accommodation Needs enabling families to develop and manage their own Assessment (2006) sites.

Suggests a need for emergency stopping places across Bedfordshire to accommodate around 45 households per year.

Planning permissions should restrict the size of sites and, where appropriate, recommend limiting the number of people allowed to live on the site on a permanent basis and for transit / visiting.

Showpeople Study, • Meeting housing needs of • No identified issues for Related to the Gypsy and Traveller needs Bedfordshire Appendix specific groups Luton assessment, this considers housing need for (2007) showpeople.

57 Plan/Strategy/Policy General Review General Issues Specific Issues Recommends: • Conservation of heritage • Historic fabric of Plaiters’ Comprehensive appraisal of the area should be areas Lea results in it being an prepared and adopted by the council, including a area of significant management plan. conservation value, though at risk from re-development Review of the conservation area boundary to include the northern side of Guildford Street, west of 40 Guildford Street. Plaiters’ Lea Conservation Area, Further investigation of a number of properties with Luton: Historic Area a view towards potential designation. Assessment (2011) A reassertion of the significance and value of the historic fabric within the Plaiters’ Lea conservation area.

The existing building fabric should play a pivotal role, resulting in a heritage-lead approach to the development of the ‘Northern Gateway’.

Describes eight key, strategic priorities for Luton • Improving health • Information in the Corporate Borough Council as a corporate entity • Delivering development Plan is drawn from other • Empower, support and protect the vulnerable across economic cycles plans/strategies/policies • Improve health and promote health equality • Increasing voluntary and contained in this appendix: • Improve life and learning opportunities for all community sector activity no new information • Create a vibrant environment where businesses • Reducing family poverty Luton Borough Council thrive and prosper • Facilitating economic Corporate Plan 2011 – • Reduce crime, antisocial behaviour and the fear development 2014 (2011) it causes • Increasing community • Protect and enhance the quality of the natural cohesion and built environment • Strengthen community cohesion • Ensure a financially sound and efficient Council

58 Plan/Strategy/Policy General Review General Issues Specific Issues Describes 18 measures for improvement: • Ensuring equality • People in South Luton are 1. Proportion of residents who think that there is a • Increasing community least satisfied with their problem with local people not treating each cohesion area other with consideration and respect • Increasing inclusion • 57% of residents say there 2. Proportion of residents who say that people are parts of the borough from different backgrounds get along they try to avoid, including 3. Satisfaction with public services in relation to Marsh Farm, Bury Park and treating residents with respect and some areas of the town consideration centre 4. Resident / customer /patient feedback analysis • Unemployment is greater 5. Proportion of residents who say they can than 6 per cent in Biscot, influence decisions Dallow, High Town, 6. Diversity of the profile of participants in further / Northwell and South wards higher education • 24% of residents found 7. Workforce / employment profile accessing hospital services 8. Business and enterprise profile by public transport difficult A Social Justice 9. Proportion of residents in each ward / area who • 25% found accessing Framework for Luton say they feel strongly that they have a sense of places of worship via public 2012-2026 belonging to their local area. transport difficult 10. Level of crime (especially hate crime) and fear of crime 11. Gap in life expectancy at birth between the lowest and highest deprivation areas 12. Gap in life expectancy between Luton and the rest of England 13. Income gap between the least and most deprived areas 14. Income gap between different groups 15. Income gap between Luton and the regional and national averages 16. Gap in educational attainment between children living in the least and most disadvantaged areas 17. Gap in relation to children and young people not in education, employment or training 18. Levels of anti-social behaviour

59 Plan/Strategy/Policy General Review General Issues Specific Issues Details 8 equality objective priority areas: • Ensuring equality of • No specific issues identified 1. Customer access and satisfaction across all opportunity equality strands • Increasing community 2. Educational attainment cohesion 3. Access to buildings/ transport for disabled people Luton Borough Council 4. Personalisation of social care Equality Objectives 2012- 5. Access to employment in Luton 2013 6. Reporting of homophobic incidents

7. Successful implementation of the Community Cohesion Commission 8. Increased action to improve the health of older and vulnerable people through prevention services, targeting the five priority areas in Luton • Improving the condition of • Luton has more private housing stock rented accommodation than • Increasing energy efficiency the national average Identifies priority actions including: • Meeting residential needs • 29% of vulnerable people in • Financial assistance to improve the standards • Reducing number of non- Luton live in non-decent and energy efficiency of private dwellings Luton Private Sector decent homes homes • Reducing the number of empty homes Renewal Strategy 2010- • Reducing fuel poverty • 7.6% of private sector • Implementing and landlord accreditation scheme 2013 • Reducing overcrowding households in Luton are • Addressing overcrowding, which is seen to • Reducing homelessness overcrowded stimulate growth of homes in multiple occupation • South, Biscot and Dallow • Reducing number of empty homes wards have highest levels of • Improving standard of non-decent private sector HMOs housing

60 Plan/Strategy/Policy General Review General Issues Specific Issues Identifies six main concerns: • Improving community • Luton residents earn around • Economy – local people’s capacity to benefit cohesion £2000 less than the national from the opportunities offered by Luton’s • Improving skills of residents average wage, though jobs economy and its excellent transport connections. • Delivering development in Luton pay around £2000 • Image – not hiding the difficult issues but during economic downturn more than the national achieving a fair and balanced picture. • Encouraging civic pride and average wage • Understanding – the needs of local communities involvement • Skills of Luton residents are and what the Council, public, voluntary and • Meeting the needs of local well below national community sectors can realistically achieve. communities averages at most levels • Communication – around Luton’s image, and to • Improving social inclusion bridge the gap in understanding between local Building Cohesion in communities. Luton: report of the Luton • Resource access – where fairness and commission on transparency are especially important during the community cohesion current time of austerity. (January 2011) • English language – helping people gain the skills they need, connecting them with others.

Recommends actions including: • Measures that create new jobs and give priority to helping local people access those jobs. • Understanding the needs of Luton’s different communities. • Cultural infrastructure to bring people together. • Signposting people in need of improved English language skills to relevant services.

61 Plan/Strategy/Policy General Review General Issues Specific Issues Details six priorities under three sub-headings: • Reducing levels of crime, • 15% of all crime and 11% of Locations disorder and anti social all ASB took place in the • The Town Centre – focusing on night time behaviour town centre. Town centre economy (NTE) related offences, shoplifting in • Increasing community hotspots for crime and ASB The Mall and robbery safety include Gordon Street, • Neighbourhoods adjacent to the town centre Manchester Street, Bridge (South (not including the town centre), Dallow, Street, and the Mall. High Town and Biscot) – focusing on burglary, • 31% of all crime and 31% of solutions Community violent crime, ASB and robbery all ASB took place in the Safety Partnership Plan • Marsh Farm – focusing on environmental ASB, neighbourhoods adjacent to (Second Refresh, deliberate fires and public perception of crime the town centre. 2012/13) and ASB • Marsh Farm is the main Offenders hotspot for environmental • Reducing re-offending across all age groups ASB. • Offenders aged between 14 and 21 years • 30% of crime was Victims committed by those aged • Prevention and support to vulnerable victims – 14-21 focusing on the victims of ASB and the victims of domestic abuse across Luton

62 Plan/Strategy/Policy General Review General Issues Specific Issues Details 26 health-related priorities for Luton, many • Improving mental and • Significantly more children of which are linked to education, income-related physical health and young people live in deprivation and the general quality of the built and • Reducing inequality poverty than the national natural environment: • Reducing deprivation average Children and Adults and Health • Reducing poverty • In 2010 Luton was ranked Young People Older People Services • Promoting independent as one of the 25% most Family poverty Independent Improving living deprived areas living outcomes in • Increasing physical activity • Unemployment is higher general • Reducing obesity than the national average practice • Improving access to • Significantly more of the Infant mortality Obesity Diabetes education, training and working age population and COPD employment have no qualifications, than Childhood Physical Improving • Improving housing options the national average obesity activity cancer and access to housing • Gross disposable survival household income per head rates is more that £3,000 less Dental health Smoking than national and regional Luton Joint Strategic (under 5s) averages Needs Assessment 2011 Emotional Alcohol • Significantly more children health and in reception school year wellbeing were obese compared with Children in Drugs the average for the country care and care • Prevalence of obesity in leavers adults is slightly higher than Young Mental health the average for the country offenders • Physical activity levels are Young carers Dementia lower than the national Drugs and Learning average alcohol disabilities • Luton has higher than KS2 Autism national average of still performance births, low birth weight Carers babies and infant mortality Offenders • Life expectancy in Luton is Domestic over one year below the abuse national average

63 Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

Appendix E: Baseline Data

Please see insert.

G

and Planning Transportation

Scoping Report for the Sustainability Appraisal of the Luton Local Plan 2011-2031

March 2013

Appendix 2: Baseline Information

Planning and Transportation Department of Environment and Regeneration

Objective 1: Maintain and enhance biodiversity

Indicator Data and Source Comparators / Targets Trends Issues / Constraints Condition of Natural England, April 2012 The Government's Public Service No trend data The condition of local SSIs meets sites of special Agreement (PSA) target is for 95% of national targets. scientific There are no SSSIs in Luton. The the SSSI area to be in favourable or interest closest are: recovering condition by 2010. Without a local plan, development (SSSIs) in Luton could have a negative Favourable: 23.26% impact on the SSSI’s located Unfavourable recovering: 76.74% adjacent to the boundary of Luton Blow’s Down Unfavourable recovering: 100% SSIs are sensitive to disturbance Sundon Chalk Quarry and significant damage may be Favourable: 94.44% irreversible. Minor damage might Unfavourable recovering: 5.56% be offset by appropriate management plans.

Wildlife sites Liaison with LBC Biodiversity Officer. No loss or significant harm to wildlife No trend data There has been a loss of wildlife lost to habitat. sites to development. development In recent years, development has taken place on a county wildlife site at Without a local plan, pressure to Croda Colloids (opposite Wardown develop wildlife sites will increase. park). Loss of wildlife sites to development Development of the Luton-Dunstable is permanent and irreversible. bus way is taking place on the CWS of the former rail line. Minor harm may be mitigated by financial contributions. Permission was granted in 2012 for development on a site of nature conservation importance near to Roebuck Close. Objective 2: Conserve, restore and enhance landscape and open spaces Indicator Data and Source Comparators / Targets Trends Issues / Constraints

2

Status of area Chilterns AONB Conservation Board, Conserve and enhance the No trend data The Chilterns AONB is being of outstanding State of the Environment Report 2011 designated area and its setting. protected from unsuitable natural beauty (http://www.chilternsaonb.org/conserv development and managed to (AONB) ation-board/board-publications.html ) conserve status.

Luton lies within a gap in the north- Without a local plan, areas of AONB east stretch of the Chilterns Area of could be lost or views negatively Outstanding Natural Beauty. There impacted. are two small allocations of AONB within the the north-east borough: Significant impact is likely to be near Stopsley Common and Dray’s permanent and irreversible. Ditches. Careful design that respects There are no known issues within the landscape setting could minimise borough, though development on the impact. north-east and south-west borders may affect AONB setting. Net change in LBC annual monitoring reports Protection of Green Belt No trend data Luton recently lost about 2.7 green belt hectares of Green Belt through area Luton contains 138 hectares of green development of leisure facilities. belt. These are located on the borough boundary near Dray’s Without a local plan, Green Belt Ditches, Stopsley Common, should be protected by national Putteridge Bury and the airport. policies.

Development of swimming and leisure Loss of Green Belt is likely to be facilities in 2012 at Stopsley removed permanent and irreversible. about 2.7 hectares of Green Belt land. Unlikely to be possible to provide compensatory land for loss of green belt within Luton’s boundaries.

Maximising use of brownfield land will reduce pressure on Green Belt to take development.

3

Open space Luton and South Bedfordshire Draft The draft Green Space Strategy No trend data There is an overall deficiency of provision Green Space Strategy 2008 recommends 51 square metres per open space in Luton. person. LBC Population Estimate 2010 Without a local plan, open space (July 2011) will come under more pressure to Population 205,900 be released for development. Sq.M Green Space per Loss of open space to development Typology Sq.M. person is likely to be permanent and Allotment irreversible. Unlikely to be possible Gardens 369,661 1.80 to provide compensatory land for Amenity loss of open spaces within Luton’s Greenspace 1,150,847 5.59 boundaries. Churchyard and Cemeteries 319,711 1.55 Development could contribute to the Green Corridor 342,844 1.67 enhancement of existing open spaces. Natural and Semi-Natural Greenspace 2,061,836 10.01 Urban Parks and Gardens 941,162 4.57 Sport and Leisure Sites 2,051,998 9.97 Total 7,238,059 35.15

4

Access to Bedfordshire and Luton Strategic N/A No trend data South-eastern and north-western strategic green Green Infrastructure Plan February areas of Luton are lacking in infrastructure 2007 accessible strategic green space.

Luton and South Bedfordshire draft Without a local plan, access Green Space Strategy (2008) problems to strategic green infrastructure are likely to remain. Wigmore, , Leagrave, Challney and are deficient in Access problems are reversible accessible, strategic greenspace. through the creation of new links. Lack of strategic green space may be irreversible considering lack of land fro new provision within the borough.

New development could enhance access to existing (or new) strategic green infrastructure. Objective 3: Protect and enhance air, soil and water resources Indicator Data and Source Comparators / Targets Trends Issues / Constraints % New homes LBC annual monitoring reports Previous national target of 60% of Consistently high Use of previously developed land is on previously new housing to be built on PDL has performance much higher than old national developed 2005/06: 99.8% been removed. targets but slightly lower than the land (PDL) 2006/07: 95% local target of 100%. 2007/08: 100% 2008/09: 100% Without a local plan, it is likely that 2009/10: 100% high rates of PDL re-use will 2010/11: 99.6% continue, though garden land and public open spaces may come under more pressure to accommodate development needs.

Loss of undeveloped land is likely to be permanent.

5

% New LBC annual monitoring reports N/A Increasing Use of previously developed land employment performance over for employment uses has improved floor space on 2008/09: 39.44% recent years. in recent years. PDL 2009/10: 100% 2010/11: 100% Without a local plan, it is likely that high rates of PDL re-use will continue.

Loss of undeveloped land is likely to be permanent. Average Land Use Change Statistics, DCLG England Average density has Luton is an urban, densely density of new 1995-1998: 25 increased developed borough. completions 1995-1998: 31 1999-2002: 26 consistently above (dwellings per 1999-2002: 35 2003-2006: 38 the national average While high density development is hectare) 2003-2006: 76 2007-2010: 43 likely to continue, the lack of a local 2007-2010: 82 plan could result in densities that 40 dwellings per hectare is the are not in keeping with the minimum target of the Luton Local character of specific areas. Plan 2001-2011 It is unlikely that high density development would be replaced at lower densities.

Impact of high density on local character can be mitigated through good design.

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Air pollution Luton Borough Council Air Quality Set out in the Air Quality (England) There are an Air pollution is a concern in the Updating and Screening Assessment Regulations 2000 (SI 928) and the Air increasing number of vicinity of the airport and major (2012) Quality (England) (Amendment) locations with roads such as the M1 motorway. Regulations 2002 (SI 3043). excessive levels of Recent years have seen town In 2010, 5 monitoring locations nitrogen dioxide. centre locations exceeding air exceeded the mean annual targets for quality targets (nitrogen dioxide). nitrogen dioxide. • Caddington Road Without a local plan, there would be • Airport terminal patio fewer controls to manage air • Airport approach road pollution or the location of • Airport runway apron development in relation to pollution • Airport junction at President Way sources.

In 2011, 9 monitoring locations The location of development near to exceeded the mean annual targets for pollution is irreversible, though nitrogen dioxide. future technologies may reduce or • Liverpool/ Dunstable Road limit the increase of pollutants. • Guildford/ Bute Street Considerate location of • Caddington Road development, efficient distribution of • Airport terminal patio land uses, sustainable transport • Airport approach road options and transport management • Airport runway apron are part of a raft of measures that • Airport junction at President Way can minimise pollution and the • Airport stand 60 effects of pollution. • Eaton Green Road

Levels of other pollutants are acceptable.

7

Agricultural www.magic.gov.uk N/A No trend data A scarce resource in Luton, land agricultural land is of better quality classification Luton is mainly urban. in the north than in the south of the town. Where land has not previously been developed, the agricultural quality of Without a local plan, agricultural the land is generally better to the land may suffer from pollution and north of the town (grade 2) than the come under increased pressure for south (grade 4). development purposes.

Loss of agricultural land to other uses would be permanent.

Degradation to the quality of agricultural land cannot be remedied quickly. It is a longer- term, more natural process. River water Thames River Basin Management All three water bodies have the target No trend data River water quality is below quality Plan – Annex B, December 2009, of ‘good’ ecological status by 2027 standard. Environment Agency Without a local plan, quality may The chemical status of the three deteriorate water bodies in Luton does not require assessment, only ecological Improvements are possible, though status is assessed. unlikely. Quality is not predicted to change by 2015 as improvement Cat Brook measures are considered either Ecological Potential: Moderate excessively expensive or technically Status Objective: Good by 2027 infeasible. Houghton Brook Ecological Potential: Moderate Impact from development can be Status Objective: Good by 2027 mitigated through improvements to Lee (from Luton to Luton Hoo the river environment and the lakes) application of sustainable drainage Ecological Potential: Poor systems that can minimise pollution. Status Objective: Good by 2027 Objective 4: Protect areas that are at risk from flooding and reduce flood risk Indicator Data and Source Comparators / Targets Trends Issues / Constraints

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Number of LBC annual monitoring reports Reduce flood risks to people and Between 2007 and Annual monitoring of the number of planning property by not permitting 2011, 0 planning permissions granted permissions 2007/08: 0 development contrary to EA advice. developments were contrary to Environment Agency granted 2008/09: 0 permitted contrary to advice on flood defence grounds contrary to 2009/10: 0 Target = 0 EA advice has shown consistently excellent Environment 2010/11: 0 performance Agency advice on flood Without a local plan, Environment defence Agency advice can still guide grounds development on flood-defence grounds.

Development impacting on flood defence is likely to be permanent.

Flood mitigation / floodplain compensation for new development in areas of flood risk is possible, but a risk of flooding would likely remain. Number of Draft Surface Water Management Aim to reduce flood risks to people No trend data A large number of properties in properties at Plan for Luton and property Luton are at flood risk. risk from flooding 130 properties at risk from 1 in 100 Without a local plan, development is year flood, increasing to 250 with less able to be directed to locations effects of climate change. of least flood risk.

Development in areas at risk of flooding is permanent, though the risk of flooding might be reduced through extensive infrastructure improvements.

Flood risk can be minimised through appropriate infrastructure such as sustainable drainage systems, water utilities infrastructure and improvements to the natural river environment.

9

Other sources Luton Borough Council and South Aim to reduce flood risks to people The SFRA forecasts The risk of sewer flooding is high in of flooding Bedfordshire District Council Level 1 and property an increase in the the low-lying areas of the town Strategic Flood Risk Assessment, risk of sewer flooding and.is forecast to get worse. 2008 in the future Without a local plan, development Large parts of Luton are at risk from could exacerbate the problem sewer flooding: Area 2007 risk 2115 Sewer flooding can be reduced forecast through extensive (expensive) Dallow Low Medium upgrades to sewerage.

Town Medium High Centre Biscot High High Limbury Medium High Icknield Medium High Barnfield Low High

Stopsley, Barnfield and Icknield are also subject to overland flows due to sloping hills. Objective 5: Reduce carbon emissions

Indicator Data and Source Comparators / Targets Trends Issues / Constraints

10

Per capita CO 2 DECC, CO2 emissions within the East of National Local emissions have Between 2005 and 2010 local emissions been consistently emissions were below regional and scope of influence of local authorities England ‘05 ‘10 ‘05 ‘10 below regional and national benchmarks, with an Industry 2.8 2.4 3.2 2.7 national benchmarks overall decrease in emissions. 2005 2010 Domestic 2.5 2.2 2.6 2.4 Industry 2.3 1.9 Road Without a local plan, unrestricted Domestic 2.3 1.9 Transport 2.1 1.9 1.7 1.6 development could lead to increases in emissions. Road Total 7.4 6.6 7.5 6.6 Transport 0.9 0.8 Total 5.5 4.6 New development will likely increase emissions, though could be mitigated through improvements to transport, modal shift, energy efficiency and technological advances.

Objective 6: Increase resource efficiency and reduce resource use and waste

Indicator Data and Source Comparators / Targets Trends Issues / Constraints Water Veolia Water Central, Water Veolia WRMP 2010 plans for a No trend data Water consumption per capita is consumption weighted average consumption of higher than the national average per person per Resources Management Plan, March approximately 152l/p/d by 2031. and recommended levels. day 2010 National average approx. 150l/p/d. Without a local plan, there would be fewer policies to implement water Existing water demand in Veolia June 2010 Water Cycle Strategy efficiency measures. Water Central northern zone recommends 105l/p/d and equivalent estimated to be 160 litres per head or non-domestic dwellings. Water consumption per person per day can be reduced through per day. 37% households metered. education, technologies, pricing and good design including water capture and re-use systems.

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Capacity to The Upper Lee Catchment Aim to move to ‘less over-abstracted’ No trend data Water resources are over increase water status within the next six years. abstracted. abstraction Abstraction Management Strategy, Environment Agency, June 2006 Without a local plan, unconstrained development could place an untenable strain on water The area is over abstracted. resources.

Possible to improve / reverse trends overtime by use of water efficiency measures in new and existing properties.

Household DEFRA , Local Authority collected Waste Strategy for England 2007 Recycling rates are There has been improvement in recycling and waste for England – annual statistics targets: increasing, slightly household recycling and composting behind national composting rates but performance rate http://www.defra.gov.uk/statistics/envi 2010 – 40% targets remains below the national targets. ronment/waste/wrfg23-wrmsannual/ 2015 – 45% 2020 – 50% Without a Local Plan, there would 2005/6: 24% be less provision for recycling/ 2006/7: 29% composting. 2007/8: 32% 2008/9: 35% It is possible to improve household 2009/10: 36% recycling / composting rate through 2010/11: 35% education, strategic waste facilities and through good design features that encourage residents to recycle and compost.

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Municipal DEFRA , Local Authority collected Waste Strategy for England 2007 Recycling rates are There has been improvement in recycling rate waste for England – annual statistics targets: increasing, slightly municipal recycling rates but behind national performance remains below http://www.defra.gov.uk/statistics/envi 2010 – 53% targets national targets. ronment/waste/wrfg23-wrmsannual/ 2015 – 67% 2020 – 75% Without a Local Plan, there might 2005/6: 25% be less provision for municipal 2006/7: 30% recycling. 2007/8: 34% The local Minerals and Waste Core 2008/9: 43% Strategy Plan for Submission, It is possible to improve municipal 2009/10: 48% November 2011 seeks to recover recycling rate through education, 70% of municipal solid waste by strategic waste facilities and good 2015. design that encourages people to recycle. Average gas DECC, ‘Sub-national gas sales and East of England Domestic energy Domestic gas consumption is consumption number of customers 2005-2010’ Year Domestic Commerc consumption has declining and only slightly higher (Kilowatt hours (http://www.decc.gov.uk/en/content/c e/ Industry decreased between than the regional benchmark. per customer) ms/statistics/energy_stats/regional/ga 2005 18,854 629,552 2005 and 2010, Commercial/ industrial consumption s/gas.aspx ) broadly in-line with is increasing, though is much lower 2006 18,032 620,768 regional changes. than the regional benchmark. Domestic Commerce 2007 17,482 645,628 / Industrial 2008 16,746 700,530 Commercial/ Without a local plan to encourage 2005 19,717 510,232 2009 15,434 701,695 industrial gas energy efficiency measures and 2010 15,341 724,055 consumption has renewable energy generation, 2006 18,798 526,476 increased between consumption may increase. 2007 18,276 524,309 2005 and 2010, 2008 17,383 504,654 though to a lesser It is uncertain whether the rise in 2009 15,937 521,309 degree than across commercial/ industrial consumption 2010 15,800 558,741 the region. can decrease as this is dependent on the type of commercial operations and their need for energy from gas.

13

Average DECC, ‘Sub-national local authority East of England Domestic energy Domestic electricity consumption is electricity electricity consumption statistics Year Domesti Commerce/ consumption has declining and is lower than the consumption 2005-2010’ c Industry decreased between regional benchmark. Commercial/ (Kilowatt hours (http://www.decc.gov.uk/en/content/c 2005 4,951 78,854 2005 and 2010, industrial consumption is also per customer) ms/statistics/energy_stats/regional/ele broadly in-line with declining, though is higher than the ctricity/electricity.aspx ) 2006 4,873 77,414 regional changes. regional benchmark. 2007 4,795 75,083 Domestic Commerce 2008 4,538 75,796 Commercial/ Without a local plan to encourage / Industrial 2009 4,459 79,930 industrial electricity energy efficiency measures and 2005 4,340 92,076 2010 4,482 75,206 consumption has renewable energy generation, decreased between consumption may increase. 2006 4,281 96,037 2005 and 2010, 2007 4,188 89,182 broadly in-line with It is uncertain whether the rise in 2008 3,980 91,688 regional changes. commercial/ industrial consumption 2009 3,919 84,242 can decrease further as this is 2010 3,942 87,995 dependent on the type of commercial operations and their need for energy from electricity.

Objective 7: Identify, protect, maintain and enhance heritage assets

Indicator Data and Source Comparators / Targets Trends Issues / Constraints

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Number of http://www.english- N/A No trend data Heritage assets at risk include assets on the heritage.org.uk/caring/heritage-at-risk/ Drays Ditches scheduled ‘heritage at monument, Putterdge Bury risk’ register Luton has 102 Listed buildings with registered park/ garden and none currently on the national buildings within the Plaiters Lea Heritage at Risk Register. conservation area.

There are two scheduled monuments: Without a local plan to guide the Waulud’s Bank and Dray Ditches. form and location of development, The latter is at risk, primarily from fly- loss of and damage to heritage tipping. assets is more likely

Luton has two registered parks/ Loss of heritage assets is gardens: Putteridge Bury and permanent. Wardown Park. The setting of Putteridge Bury is at risk from Good design can minimise impact development on the boundary of on heritage assets. Luton.

A number of buildings in the Plaiters Lea Conservation Area are on the SAVE Britain’s Heritage Building at Risk Register.

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Conservation www.english-heritage.org.uk N/A No trend data Conservation area status is area status generally healthy. High Town and Luton has 5 conservation areas Plaiters’ Lea are, however, at risk totalling 42.01ha: and deteriorating. • Rothesay: 14.09ha • Town Centre: 11.16ha • Luton South: 10.18 Without a local plan, protection of • Plaiters’ Lea: 4.46ha conservation areas will be more • High Town: 2.12ha difficult and their character would likely be eroded, leading to the loss High Town and Plaiters’ Lea are at of their status. risk and deteriorating. Significant harm to conservation Conservation area appraisals written areas would be permanent and for High Town, Plaiters’ Lea and irreversible. Luton South along with Management Plan for High Town (all yet to be Strong design policies can mitigate formally adopted). impact of development within conservation areas. English Heritage has published an area assessment of Plaiters’ Lea.

Article 4 direction for Rothesay to provide additional controls (yet to be adopted). Objective 8: Reduce poverty and inequality and promote social inclusion

Indicator Data and Source Comparators / Targets Trends Issues / Constraints

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Indices of Index of Multiple Deprivation N/A Deprivation has Levels of deprivation in Luton are deprivation http://www.neighbourhood.statistics.g increased in Luton higher than the majority of other ov.uk between 2004 and local authority areas and are (average 2010 increasing. score and 2010 Indices of Multiple Deprivation, Local Authority LBC, August 2011 Without a local plan to guide Ranking out of regeneration, deprivation could 354 Local Score Rank increase. Authority 2004 23.27 101 areas) 2007 24.73 87 Deprivation is temporary and 2010 25.78 69 reversible, though can take a lot of time and resources. In 2010, nine out of Luton’s 121 lower super output areas were amongst the New development should address 10% most deprived in England: 2 in its own impacts (e.g. funding for Northwell; 1 in High Town, 2 in school places) to avoid additional Dallow, 2 in Biscot, 1 in Farley and 1 stresses on existing, essential in South. community infrastructure.

% Children in Child poverty - IMD 2010 IDACI , the England Level of child in The percentage of children in income- network of Public Health 2007: 22.44% income deprived income deprived households has deprived Observatories 2008: 20.9% households has remained higher than the average households www.apho.org.uk 2010: 21.8% remained consistently for England. higher than the 2007: 31.3% England average Without a local plan, opportunities 2008: 28.4% between 2007 and to increase skills and employment 2010: 30.3% 2010 opportunities will be restricted.

The situation is reversible but will take time for skills to be improved and is sensitive to national economic trends.

An adequate supply of jobs to match existing skills might be required in the short-term.

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% Households DECC Sub-regional fuel poverty East of England Increasing levels of Fuel poverty has increased but is that are fuel levels. fuel poverty between broadly in-line with regional poor 2008: 12.5% 2008 and 2010, averages. 2008: 12.1% 2009: 16.2% reflecting the regional 2009: 15.7% 2010: 16% trend Without a local plan to stimulate 2010: 16.9% improvements in the energy efficiency of new dwellings (or the retro-fitting of solutions for existing homes), fuel poverty may increase at a higher rate.

The situation is temporary and reversible, though may take some time to address as it is influenced both by household income and energy-efficiency of homes.

% of charitable Ipsos MORI/ Cabinet Office: National National Increase between There has been an increase (above and social Survey of Charities and Social 2008 – 16% 2008 and 2010 national benchmarks) in the enterprise Enterprises 2010 – 18% reflecting the national percentage of charitable and social organisations http://www.nscsesurvey.com/ figures. enterprise organisations who who consider that statutory bodies have consider that Luton a positive influence on their success statutory 2008 – 19% bodies have a 2010 – 21% Without a local plan to support positive delivery of community and social influence on infrastructure, positive influences their success may decrease.

The measure is temporary and subject to a wide range of variables including funding and the availability of advice and support.

New development that supports community and social infrastructure also supports the actions of charitable and social enterprises.

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Objective 9: Reduce crime and fear of crime

Indicator Data and Source Comparators / Targets Trends Issues / Constraints Violence Neighbourhood Statistics (ONS Rates in Luton Rates of violence against the against the population estimates and Home Year East of England increased between person have generally declined person (counts Office crime data) England 2001 and 2005 and since a peak in 2005, though are per 1,000 2001 7.9 12.4 then began to above regional and national population) 2001 12.4 decrease to 2010, benchmarks. 2002 12.7 15.8 2002 18.2 2003 15 18.2 2003 20.7 Rates are higher than Without a local plan and policies to 2004 2004 24.1 16.2 19.7 for the East of improve the built environment, rates 2005 26.2 2005 14.9 19.8 England and England may increase further. 2006 23.8 2006 14.5 19.2 2007 19.2 2007 13.1 17.6 The situation is temporary and 2008 17.1 2008 12.1 16.4 reversible.

2009 16.9 2009 12.1 15.8 The design of new development 2010 18.5 2010 12.1 14.7 can improve the quality and safety of the built environment. Burglary in a Neighbourhood Statistics (ONS Year East of England Rates have fluctuated Rates of domestic burglary have dwelling population estimates and Home England but remained fairly fluctuated since a peak in 2003 and (counts per Office crime data) 2001 4.6 8.5 constant. The rates are above regional and national 1,000 remained higher than benchmarks. 2002 5.1 8.5 population) 2001 9.5 the East of England 2003 2002 10.2 5 7.8 and England Without a local plan and policies to 2003 14.9 2004 4 6.2 averages. The rates improve the built environment, rates 2004 10.6 2005 3.8 5.8 did not reflect the may increase further. 2005 9.2 2006 3.8 5.5 reduction in rates 2006 9.5 2007 3.9 5.3 seen for the England The situation is temporary and 2007 13 2008 4.1 5.3 average. reversible.

2008 10.6 2009 3.8 5 The design of new development 2009 7.6 2010 3.7 4.8 2010 9.1 can improve the quality and safety of the built environment.

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Theft from a Neighbourhood Statistics (ONS Year East of England Large reduction in Rates of theft from a motor vehicle motor vehicle population estimates and Home England theft from motor have fluctuated since a peak in (counts per Office crime data) 2001 10.3 12.7 vehicles between 2001 and are above regional and 1,000 2007 and 2010. national benchmarks. 2002 10.6 12.6 population) 2001 19.8 Between 2001 and 2003 2002 19.6 9.3 11.4 2007 the rate was Without a local plan and policies to 2003 18.1 2004 7.8 9.4 consistently much improve the built environment, rates 2004 15.3 2005 7.8 9.5 higher. Rates were may increase further. 2005 16.9 2006 7.6 9.3 much higher than the 2006 18.4 2007 6.7 8 East of England and The situation is temporary and 2007 17.3 2008 6 7.2 England averages reversible. but by 2010 rates had 2008 11.9 2009 5 6.2 2009 7.4 fallen to be much The design of new development 2010 4.7 5.7 2010 6.6 closer to these can improve the quality and safety benchmarks. of the built environment.

Criminal Neighbourhood Statistics (ONS Year East of England Between 2001 and Rates of criminal damage including damage population estimates and Home England 2010 the level arson have fluctuated since a peak including Office crime data) 2001 16.6 12.5 increased and in 2003 and are above regional and arson (counts remained constant in national benchmarks. 2002 18.8 21 per 1,000 2001 15.5 Luton before 2003 population) 2002 21 20.5 22.8 beginning to fall. Without a local plan and policies to 2004 2003 21.4 20 22.4 improve the built environment, rates 2004 19.3 2005 19.4 21.9 This reflected the may increase further. 2005 21.1 2006 19.2 21.8 regional and country 2006 20.2 2007 16.8 18.9 wide trend. The situation is temporary and 2007 18.6 2008 14.7 16.9 reversible.

2008 16.7 2009 12.8 14.5 The design of new development 2009 14.1 2010 11.4 12.5 can improve the quality and safety 2010 14.7 of the built environment.

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Other Neighbourhood Statistics (ONS Year East of England The rate has Rates of other wounding have wounding population estimates and Home England fluctuated from year fluctuated since a peak in 2005 and (counts per Office crime data) 2001 2.5 4.1 to year between 2001 are above regional and national 1,000 and 2010, and benchmarks. 2002 5.7 6.5 population) 2001 4.7 remained higher than 2003 2002 10.1 7.1 8.2 the East of England Without a local plan and policies to 2003 11.6 2004 7.9 9.2 and England improve the built environment, rates 2004 12 2005 7.4 9.7 averages. may increase further. 2005 13.4 2006 6.7 9.1 2006 12 2007 5.8 8 The situation is temporary and 2007 10.4 2008 5.2 7.2 reversible.

2008 8.7 2009 5.2 6.8 2009 8.7 The design of new development 2010 5 6.3 2010 9.3 can improve the quality and safety of the built environment. Objective 10: Encourage healthier lifestyles and reduce adverse health impacts of new developments

Indicator Data and Source Comparators / Targets Trends Issues / Constraints Life Health Profiles, the network of Public England Life expectancy in Life expectancy has increased in expectancy at Health Observatories Years Male Female Luton has been Luton but still lags behind the birth http://www.apho.org.uk/default.aspx? 2001/3 76.2 80.7 consistently worse countrywide life expectancy rates. QN=P_HEALTH_PROFILES 2002/4 76.5 80.9 than the national 2003/5 76.9 81.1 average. Life Without a local plan to address the Years Male Female 2004/6 77.3 81.6 expectancy in Luton wider determinants of health, life 2001/3 75.2 79.2 2005/7 77.7 81.8 increased between expectancy may increase at lower 2002/4 75.5 79.6 2006/8 77.9 82.0 2001 and 2009 rates or even decrease.

2003/5 75.7 79.9 2007/9 78.3 82.3 2004/6 76.1 80.0 The situation is temporary and 2005/7 76.5 80.3 reversible, though there is a wide 2006/8 76.7 80.4 range of factors determining life 2007/9 77.2 80.6 expectancy and so progress may be slow.

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Inequalities in Source: Department of Health, N/A No trend data Life expectancy is significantly life expectancy http://www.communityhealthprofiles.in lower in areas on the western side at birth for fo/profiles/00KA-HP.pdf of Luton than in areas to the east. males and females Comparison to England average Without a local plan to address the combined, by 2000-04 wider determinants of health, life ward based on Significantly lower: Northwell; expectancy may increase at lower significance Leagrave; Challney; Dallow; Biscot; rates or even decrease. above and Saints; Farley; High Town; South below the Lower but not statistically The situation is temporary and England significant: Lewsey; Icknield reversible, though there is a wide average Higher but not statistically range of factors determining life significant: Sundon Park; Barnfield; expectancy and so progress may Stopsley; Crawley; Wigmore be slow. Significantly higher : Bramingham; Limbury; Infant mortality Health Profiles, the network of Public England Infant mortality rate in Infant mortality is increasing, with rate – deaths Health Observatories Luton increased from exceptionally high number of deaths up to 1 year http://www.apho.org.uk/default.aspx? 2003-05: 5.1 2003 to 2009, in in 2009 that have inflated rolling per 1,000 live QN=P_HEALTH_PROFILES 2004-06: 5.0 contrast to the averages. Rates are above births 2005-07: 4.9 England average national averages. 2003-05: 5.3 2006-08: 4.8 which fell during the 2004-06: 6.2 2007-09: 4.7 same period. Without a local plan to address the 2005-07: 6.0 wider determinants of health, infant 2006-08: 6.0 mortality may not decrease. 2007-09: 7.4 The situation is temporary and reversible, though there is a wide range of factors determining infant mortality and so progress may be slow.

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% of resident National Statistics, November 2006 East of England No trend data The percentage of the population population that http://neighbourhood.statistics.gov.uk/ • Good 70.35% classifying themselves as being in classify dissemination/LeadKeyFigures.do?a= • Fairly Good 22.05% good health is very similar to themselves as 5&b=276882&c=south+bedfordshire& • Not Good 7.6% national and regional averages. being in good d=13&e=6&g=423906&i=1001x1003x health 1004&o=219&m=0&enc=1 Without a local plan to address the England wider determinants of health, 2001 • Good 68.76% improvements in general health • Good 69.64% • Fairly Good 22.21% may not be as great. • Fairly Good 22.1% • Not Good 9.01% • Not Good 8.05% The situation is temporary and reversible, though there is a wide range of factors determining good health and so progress may be slow. % of people National Statistics, November 2006 East of England No trend data The percentage of working age of working age http://neighbourhood.statistics.gov.uk/ • Illness 11.4% people with a limiting long term with a limiting dissemination/LeadKeyFigures.do?a= illness was lower in Luton than the long term 5&b=276882&c=south+bedfordshire& England national average but higher than the illness d=13&e=6&g=423906&i=1001x1003x • Illness 13.29% regional average. 1004&o=219&m=0&enc=1 Without a local plan to address the 2001 wider determinants of health, • Illness 12.33% improvements in long-term illness may not be as great.

The situation is temporary and reversible, though there is a wide range of factors determining long- term illness and so progress may be slow.

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Adult Sport England website, Active People N/A Decreasing adult Adult participation in sport and participation in Survey participation in sport active recreation is decreasing. sport and between 2005 and active Regular participation (3 days a week, 2011. Without a local plan to increase recreation 30 minutes moderate intensity) access to sport and active recreation, the trend may not be 2005/06: 18.5% reversed. 2007/09: 15.1% 2009/11: 14.9% The situation is temporary and reversible through education and increased accessibility of facilities.

New development can ensure that they do not burden over-subscribed facilities, while making provision for better access to existing and new services. Objective 11: Provide decent, affordable and safe homes for all Indicator Data and Source Comparators / Targets Trends Issues / Constraints % of all www.emptyhomes.com East of England The percentage of The percentage of all dwellings that dwellings that Year East of England empty homes in are vacant has fluctuated but are vacant 2005: 3.4 England Luton decreased compares favourably to national 2006: 3.4 2005 2.3 2.9 between 2005 and and regional benchmarks. 2007: 3.9 2006 2.6 2.9 2011. 2008: 2.7 2007 2.4 2.9 Without a local plan that might 2009: 1.7 2008 2.6 3.1 support local initiatives, vacancy 2010: 2.9 2009 2.2 2.9 rates could increase. 2011: 2.7 2010 2.8 3.2 2011 2.7 3.1 The situation is temporary and reversible, through education and funding for the re-use of vacant dwellings.

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% off empty www.emptyhomes.com East of England Number of empty Figures for empty local authority homes owned % empty homes local authority and and housing association homes by local % empty homes Year LA HA PO housing association have fallen and are better than the authority (LA), Year LA HA PO 2007 4.1 4.3 89.9 homes fell between regional and national averages. housing 2007 2.3 1.9 95.8 2008 3.3 4.7 91.0 2007 and 2011. This has resulted in a statistical association 2008 3.1 2.7 94.2 2009 4.2 n/a n/a increase in the percentage of empty (HA) or are in 2009 7.7 n/a n/a 2010 3.7 3.5 91.8 Number of empty homes in private ownership (higher private 2010 0.1 1.7 98.2 2011 3.1 3.5 92.5 homes in private than regional and national ownership 2011 0.1 1.0 98.8 ownership also averages). (PO) England decreased, though Count of empty homes % empty homes the percentage Without a local plan that might Year LA HA PO Year LA HA PO increased. support local initiatives, vacancy 2007 66 56 2,796 2007 6.1 5.7 87.3 rates could increase. 2008 63 55 1,929 2008 5.3 6.0 87.9 The situation is temporary and 2009 104 n/a n/a 2009 5.3 n/a n/a reversible, through education and 2010 3 37 2,179 2010 4.2 5.8 89.1 funding for the re-use of vacant 2011 3 22 2,076 2011 3.9 5.8 89.7 dwellings.

House price to Table 577: Ratio of median house Year East of England Yearly fluctuations The ratio between house prices and income ratio price to median earnings by district England but generally income in Luton is lower than from 1997, DCLG 2005 7.5 6.8 constant regional or national benchmarks. 2006 7.5 7.0 2005: 6.0 2007 7.9 7.2 Without a local plan to guide 2006: 6.1 2008 7.8 6.9 quantity and quality of housing and 2007: 6.3 2009 6.8 6.3 jobs, it is uncertain how the figures 2008: 6.3 may change. 2010 7.5 7.0 2009: 5.5 2010: 6.2 The situation is temporary and reversible.

Decreasing house prices and increasing income can address housing affordability, though these are subject to national trends as well as local initiatives.

25

Provision of Table 1008: Additional affordable Year East of England Local delivery rates Provision of affordable housing in affordable dwellings provided by local authority England have fluctuated, while Luton has fluctuated. housing area, DCLG 2004/05 4,390 37,470 national and regional 2005/06 5,670 45,980 rates have generally Without a local plan to make 2004/05: 200 2006/07 5,560 44,300 increased (2004- arrangements for affordable 2005/06: 140 2007/08 7,140 53,180 2010) housing through the planning 2006/07: 80 2008/09 7,670 55,500 system, provision will suffer. 2007/08: 90 2009/10 8,160 58,010 2008/09: 190 The situation is temporary and 2009/10: 120 The 2010 SHMA shows a reversible, though constrained by requirement for 5,700 affordable units tight development economic that between 2007 and 2021. This exist within the town. equates to more than 400 per year. New development can help fund affordable housing delivery.

Household LBC Population Projections, 2010. England N/A Projected growth in households will estimates and ONS population projections 2010/11: 52,234 increase the need for homes. projections 2015/16: 54,468 2010: 204,750 2020/21: 56,607 Without a local plan to guide the 2015: 209,400 – 213,800 2025/26: 58,607 location of development, existing 2020: 213,250 – 221,600 2030/31: 60,410 services may become over- 2025: 216,600 – 228,400 stretched, the quality of the natural 2030: 220,350 – 235,100 Increase between 2010 and 2030: and built environment may (The lower figures consider migration 15.7% decrease and levels of deprivation whereas the higher figures represent may increase. basic population growth without migration) The situation is permanent and irreversible. Increase between 2010 and 2030: 7.6% – 14.8% To avoid significant negative impact, the capacity of the town to accommodate development needs should be carefully assessed. Neighbouring authorities may be required to deliver any unmet need.

26

Number of Numbers of households on local In the East of England, 6.4% of all Fluctuating number, The number of people on waiting people on authorities’ housing waiting lists, by households were on a waiting list. peaking in 2008 lists has fluctuated though is housing district: England 1997-2011, DCLG Across England, 8.2% of all equivalent with regional averages waiting lists (http://www.communities.gov.uk/housi households were on a waiting list. and lower than the national ng/housingresearch/housingstatistics/ benchmark. housingstatisticsby/rentslettings/liveta bles/ ) Without a local plan to guide the delivery of housing types and Year Count tenures, waiting lists may increase. 2005 3,358 2006 3,815 The situation is temporary and 2007 5,171 reversible. 2008 6,813 2009 6,369 While the provision of suitable 2010 3,180 housing can reduce waiting lists, 2011 4,900 there is little restriction over the number of people who can apply to be placed on the list. % all households 6.5 (2011) Objective 12: Support town/ district centre vitality and viability

Indicator Data and Source Comparators / Targets Trends Issues / Constraints Change of LBC annual monitoring reports Support for A1 retail in town centres A1, A3, A5, D1 and The nature of the town centre has town centre D2 uses have changed in recent years, with an floor space 2008-09 2009-10 2010-11 increased their floor increase in A1, A3, A5, D1 and D2 (square A1 -463 -428 2678 space. uses. A2, A4 and B1a uses have metres, net) A2 158 -457 -26 decreased. A3 85 266 114 A2, A4 and B1a uses A4 -559 0 0 have reduced their Without a local plan to guide A5 227 119 63 floor space. development, the nature of the town B1a -214 -258 -1614 centre may change in a manner that D1 -212 744 6801 harms its vitality and viability. D2 19 0 0 Total -959 -14 8016 The situation is temporary and reversible, though subject to national, commercial trends.

27

Changes in Luton & South Beds’ Retail Study Bedford Consistent Shopping yields in Luton town shopping Update, January 2009 2001 2003 2005 2008 performance between centre have remained steady and yields (Luton 2001 and 2008 compare favourably to other centres town centre) 2001 2003 2005 2008 6.00 6.00 6.00 6.25 in the local region. Yields are better 5.75 5.50 5.50 5.75 in Milton Keynes and Watford, Dunstable reflecting their higher position in the 2001 2003 2005 2008 retail hierarchy. There are 6 district centres within Luton, though there is no available 8.00 8.00 8.00 8.25 data on yields for these locations. Without a local plan to guide The retail study indicates that all have development, the nature of the town Leighton Buzzard centre may change in a manner that good levels of vitality and viability 2001 2003 2005 2008 though there are concerns that road undermines yields. traffic compromises quality and 8.00 8.00 8.00 8.25 restricts pedestrian movement. The situation is temporary and Stevenage reversible, reflecting the 2001 2003 2005 2008 attractiveness to investment in the town centre. 7.00 7.00 6.50 6.75

Milton Keynes (Central) 2001 2003 2005 2008

4.75 4.75 4.75 4.75

Watford 2001 2003 2005 2008

5.50 5.50 5.50 5.50 Vacancy rates Luton & South Beds’ Retail Study UK Average: Vacancy rates Vacancy rates in Luton are slightly (% of units Update, January 2009 2008: 12% remained the same better than the national average. vacant) between 2002 and Luton town centre: 2008 Without a plan to guide the nature 2002: 10% of the town centre, vacancy rates 2005: 10% might increase. 2008: 11% The situation is temporary and reversible, reflecting the attractiveness to investment in the town centre.

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Objective 13: Provide and encourage the use of sustainable integrated transport systems, improve access and mobility Indicator Data and Source Comparators / Targets Trends Issues / Constraints Access to LBC Annual Monitoring Report Not available No trend data All areas of Luton generally enjoy services 2006/07 excellent access to services. The hospital is situated to the west, 100% of completed residential sites resulting in long walking times from were within 30 minutes public areas in the east of the town. transport travel of a GP, school, Walking access to major retail employment area and major retail centres (town centres) is a concern centre. 83% were within 30 minutes for those in peripheral areas. public transport time to a hospital. Without a Local Plan, access to Accessibility Assessment of Strategic services may not be increased and Housing Land Availability might reduce. Assessment, January 2009 As Luton is built-up to its At least 90% of sites are within 30 boundaries, there are limited minutes walk, cycle or public transport options for new service provision in from a GP, school, employment area areas where access by walking is or dental surgery. 13.1% of sites poor. were within 30 minutes walk of a hospital, while 56% were within 30 Siting new development in locations minutes walk of a major retail centre. enjoying excellent accessibility to services with spare capacity will improve the measure.

29

Modes of Method of Travel to Work - Resident No trend data Compared to regional and national travel to work Population (UV39) East of England averages, Luton residents have a (2001) www.statistics.gov.uk England good utilisation of travel by bus/ Undergroun 0.56 2.00 coach, car-sharing, taxi and on foot. % People Underground/ Metro 0.13 d/ Metro There is lower than average use of aged 16-74 Train 3.01 Train 4.02 2.67 motorcycles/ scooters, bicycles and who usually Bus, mini bus or 4.90 Bus, mini 2.65 4.74 home-working. travel to work coach bus or by different Motorcycle, scooter 0.54 coach Without a Local Plan, use of less modes Driving a car or van 35.25 Motorcycle, 0.74 0.70 sustainable modes of travel to work Passenger in a car 4.92 scooter may increase. or van Driving a 39.10 34.68 Taxi or minicab 0.63 car or van The situation is temporary and Bicycle 1.09 Passenger 3.88 3.86 reversible. On foot 7.26 in a car or A variety of measures to improve Other 0.25 van the attractiveness of non-car travel Work mainly from 4.58 Taxi or 0.30 0.33 can be used to increase sustainable home minicab Bicycle 2.58 1.79 and active travel. On foot 6.02 6.31 Other 0.30 0.29 Work mainly 6.27 5.78 from home Distance Census 2001 (replicated in evidence East of National No trend data The distance travelled by Luton travelled to base for LTP3) England residents to work compares work for Less 50.75% 58.32% favourably to regional and national residents Less than 10km 62.8% than averages. (indicator of job 10km Without a plan to guide the quantity, self containment) More 19.72% 12.56% quality and location of jobs, out- More than 20km 16.31% than (indicator of out- commuting might increase. 20km commuting) The situation is temporary and reversible. Telecommunications and the distribution, quantity and matching of jobs with skills is a key factor in reducing distances travelled to work.

30

Level of in and Census 2001 (replicated in evidence N/A No trend data More people commute into Luton out commuting base for LTP3) than out from it.

# Working age 82,362 Without a local plan, commuting population from Luton could increase. # Commuting 27,805 from Luton The situation is temporary and # Commuting to 29,359 reversible. Telecommunications Luton and the distribution, quantity and matching of jobs with skills is a key % working age 33.76% factor in reducing out-commuting. population Luton’s larger employers will likely commuting from support continued in-commuting. Luton

Bus Patronage Luton Local Transport Plan 2011- Target of Bus patronage Bus patronage is generally (number of 2026 12.5 million passengers in 2014 declined then increasing and the trend suggests passenger increased between that the target of 12.5 million trips) 05/06 8.55 million 2005 and 2010 passengers in 2014 seems 06/07 7.95 million achievable. 07/08 7.89 million 08/09 10.73 million Without a plan to guide 09/10 10.24 million development to public transport hubs, bus patronage might decline.

The situation is temporary and reversible.

31

Number of Luton Local Transport Plan 3, March LTP target of 1,370 cycle trips by Number of cycle trips The number of cycle trips is cycle trips 2011 2014. in Luton increased generally increasing and the trend from 2005 to 2010 suggests that the target of 1,370 Year # Cycle Trips trips in 2014 seems achievable. 2005/6 863 2006/7 934 Without a plan, cycle trips might 2007/8 1070 decline. 2008/9 1166 The situation is temporary and 2009/10 1246 reversible. New developments can support cycling by providing cycle storage spaces/ changing facilities and support for new/ enhanced cycling routes. Objective 14: Promote employment, learning, skills and innovation

Indicator Data and Source Comparators / Targets Trends Issues / Constraints Percentage of NOMIS (http://www.nomisweb/co.uk ) Year East of Great Percentage remained The percentage of the working-age the working- England Britain constant between population in employment is age (16-59/64) Luton: Oct04- 78.3% 74.6% 2004 and 2008. declining and is lower than regional population that Oct04-Sep05 68.9% Sep05 Luton is consistently and national benchmarks. is in Oct05-Sep06 68.4% Oct05- 77.4% 74.1% below the regional employment Oct 06-Sep07 69.1% Sep06 and national average Without local planning policy, this Oct07-Sep08 67.0% Oct 06- 76.9% 74.3% may not improve. Sep07 Oct07- 77.6% 74.5% The situation is temporary and reversible. Improvements in Sep08 education and job opportunities (and access to those opportunities) are required.

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% change in NOMIS website, percentage derived Year East of Great No trend. Fluctuating The percentage change in the number of from absolute numbers England Britain results between 2003 number of VAT registered VAT 2003 2.1% 2.1% and 2007 businesses has fluctuated but has registered 2003 2.4% 2004 1.6% 1.8% generally been higher than regional businesses 2004 1.8% 2005 2.2% 2.1% and national averages. over previous 2005 1.5% 2006 1.7% 2.0% year, 2003 to 2006 1.9% Without a local plan to increase the 2007 2.5% 3.0% 2007 2007 3.6% attractiveness of the town to investment, the number of VAT- registered businesses might decrease.

The situation is temporary and reversible. Development that fosters a good quality environment and creative/ entrepreneurial skills should be of benefit.

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% all in NOMIS Official Labour Market Great Britain Percentage of lower- The distribution of jobs by type employment Statistics apr 2004- apr 2011- skilled jobs has shows an increase in lower-skilled by type of job mar 2005 mar 2012 increased, while jobs being due to the creation of apr 2004- apr 2011- % % higher-skilled jobs more jobs at that level and due to a 1) manager, mar 2005 mar 2012 1 9.7 10.0 have decreased loss of employment opportunities in director and % % 2 17.0 19.2 higher-skilled positions. There are senior official 1 8.3 5.7 3 13.1 14.0 more people employed in lower 2) professional 2 13.0 12.0 4 13.0 11.1 skilled jobs and less in higher 3) associate 3 13.4 11.2 5 11.9 10.8 skilled jobs than seen in the prof & tech 4 12.9 12.9 6 7.8 9.1 regional and national benchmarks. 4) admin and 5 14.4 11.0 7 8.5 8.1 secretarial Without a plan to address skills and 6 7.2 11.1 8 7.5 6.4 5) skilled jobs opportunities, improvements in 7 7.8 8.3 9 11.1 10.9 trades general wealth of the workforce 8 8.3 12.0 6) caring, may not occur. 9 14.6 15.5 East of England leisure and apr 2004- apr 2011- other service The situation is temporary and apr 2004- apr 2011- mar 2005 mar 2012 7) sales and reversible. mar 2005 mar 2012 customer % % service Count Count 1 10.0 11.1 8) process, 1 7,000 5,000 2 16.7 18.6 plant and 2 11,000 10,400 3 13.6 14.2 machine 3 11,300 9,700 4 13.5 11.5 operatives 4 10,800 11,300 5 12.5 11.0 9) elementary 5 12,100 9,700 6 7.9 9.0 occupations 6 6,100 9,600 7 7.6 7.7 7 6,600 7,300 8 7.1 6.5 8 7,000 10,500 9 10.8 10.1 9 12,300 13,500

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Full-time, NOMIS Official Labour Market Year East of Great Full time average Full time average gross weekly pay average gross Statistics England Britain gross weekly pay for for residents is increasing but weekly pay for 2004 £447.6 £421.3 residents increased remains below the national and residents 2004 £416.3 2005 £456.7 £432.8 regional averages. 2005 £425.1 2006 £466.0 £445.9 2006 £427.8 2007 £479.9 £460.0 Without a plan to address skills and 2007 £431.2 2008 £499.0 £480.0 jobs opportunities, improvements in 2008 £433.8 2009 £509.5 £490.5 general wealth of the workforce 2009 £444.3 2010 £523.3 £501.7 may not occur. 2010 £461.8 2011 £528.5 £503.1 2011 £479.1 The situation is temporary and reversible.

35

% residents NOMIS Official Labour Market Great Britain Consistently below The percentage of residents aged aged 16-64 Statistics 2004 2011 benchmarks but 16-64 with NVQ-equivalent with NVQ4 or 26.1 32.9 levels of qualifications is increasing but qualifications 2004 2011 higher qualifications are below regional and national NVQ4 or 19.6 27.6 NVQ3 or 46.8 52.7 rising at a faster rate benchmarks. higher higher NVQ3 or 39.3 43.9 NVQ2 or 62.1 69.7 Without a plan, levels of vocational, higher higher educational improvement may not NVQ2 or 53.1 58.6 NVQ1 or 76.5 82.7 rise as quickly. higher higher NVQ1 or 67.7 72.7 Other 8.4 6.7 The situation is temporary and higher quals reversible. Increasing the Other 13.8 9.4 No quals 15.1 10.6 availability, quality and access to quals education is required.

No quals 18.4 17.9 East of England 2004 2011 NVQ4 or 25.0 29.2 higher NVQ3 or 45.1 49.9 higher NVQ2 or 61.7 68.5 higher NVQ1 or 77.8 83.8 higher Other 7.6 6.6 quals No quals 14.6 9.6

36

% pupils Department for Education East of England Upward trend The percentage of pupils achieving achieving five http://www.education.gov.uk/inyourar England five or more GCSEs at Grade A*-C or more ea/ 2005 56.6 56.3 or equivalent has improved GCSEs at 2006 59.3 59 dramatically to be above regional Grade A*-C or 2005: 49.9 2007 61.2 61.4 and national averages. equivalent 2006: 51.0 2008 64.7 65.3 2007: 55.4 2009 69 70 Without a plan, levels of educational 2008: 62.2 improvement may not rise as 2010 74.3 75.4 2009: 69.3 quickly. 2010: 76.7 The situation is temporary and reversible. Increasing the availability, quality and access to education is required.

37 Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

Appendix F: Site Assessments and High Level Assessment for Long List

Please see insert.

H Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

This page is intentionally blank.

I Luton Possible Allocations Site Assessment Criteria (as amended) C1 Dist to centres C2 Dist to health C3 Dist to dental C4 Distance to infant C5 Dist to junior C6 Dist to 2ary C7 Dist to emp C8 Dist to sports C9 Dist to play C10 Dist to open space C15 Dist crèche C16 Loss of emp C17 Dist to bus C18 Dist to train C19 Dist to cycle C20 Loss of agric C21 Use of PDL C22 Dist to AP source C23 Impact on SPZ C24 Impact on SAM

ID Site Name Size/Capacity/Use Green = 1km 1km 1km 1km 1km 1km 1km 1km 200m 300m 1km Red 200m 400m 200m Not ALC1/2/3 Y >50m and >100m Not SPZ1/2/3 None High Town NC 9m N; Royal Pharmacy 207m Sharing Smiles 373m SW Hillborough Infant & St Matthews 1ary 397m Barnfield Skills Academy EM1 site 705m SE; within Hightown Community Bell's Cl 513m N The Moor (Amenity) Hart Hill Nursery 758m E 5.8% of site is part of Rail Station Luton 0m 67m W Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2970m 136 Midland Road West, High Town Block A 0.39 - 19 - SG Bury Park DC 390m W; NE; Dr Saleh''s GP 265m Nursery 1304m SW NW 373m NE Central Area Sports and Arts Centre 325m W Midland Rd (1) ELR Entrance/Midland Rd >100m from Airport/M1 SE Within TC NE 367m NE Green site within site High Town NC 102m Royal Pharmacy 239m N; Maeer Dental Surgery Infant St Matthews 1ary 415m N Barnfield Skills Academy EM1 site 507m SE; within Hightown Community Bell's Cl 566m N St Mary's Church Hart Hill Nursery 538m E Not ELR site Midland Rd / Church St Luton 9m W 143m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2741m NW; Bury Park DC 676m Dr Saleh''s GP 352m N 525m SW 1088m E 285m NE Central Area Sports and Arts Centre (Ch'yard/Cem'y) 278m S within site >100m from Airport/M1 SE 137 Midland Road East, High Town Block B 0.29 - 14 - SG W; Within TC 309m N

3% within High Town Royal Pharmacy 110m Sharing Smiles 475m SW Crawley Green Infant St Matthews 1ary 294m Barnfield Skills Academy EM1 site 770m SE; CA Hightown Community Bell's Cl 393m N Peoples Park (Urban Hart Hill Nursery 765m E 46.2% of site is part of Rail Station Luton 53m SE 176m W Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 3027m NC; Bury Park DC 492m NE; Dr Saleh''s GP 158m 1306m E NE 325m E 7m S Sports and Arts Centre P&G) 305m N Albion Rd ELR Red site Entrance/Midland Rd >100m from Airport/M1 SE 139 Albion Road, High Town Block D 0.33 - 14 - B1 W; TC 7m S NE; L&D Hospital 4269m 305m N 27.5m SW W 2.3% within High Town Royal Pharmacy 213m E; Sharing Smiles 365m SW Hillborough Infant & St Matthews 1ary 356m Barnfield Skills Academy EM1 site 770m SE; CA Hightown Community Bell's Cl 393m NE The Moor (Amenity) Rothesay Rd Nursery 22.3% of site is part of Villa Rd/Old Bedford Rd Luton 55m SE 20m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 3098m Old Bedford Road Block, High Town NC; Bury Park DC 322m Dr Saleh''s GP 226m NE Nursery 1301m SW NE 449m E 2m S Sports and Arts Centre 214m W 830m SW North St / Dudley St ELR 0.3m W >100m from Airport/M1 SE 140 1.71 - 35 - B1-2 Block E W; TC 2m S 423m E Amber site

80.2% within High Town Royal Pharmacy 20m SE Sharing Smiles 610m SW Crawley Green Infant St Matthews 1ary 157m Barnfield Skills Academy CA 151m S Hightown Community Bell's Cl 268m N Peoples Park (Urban Hart Hill Nursery 728m E Not ELR site Berkley Path/Wenlock St Luton 165m SE 283m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km NC; TC 51m S 1254m E NE 248m E Sports and Arts Centre P&G) 181m N 1.3m SW >100m from Airport/M1 141 Wenlock Street, High Town Block F 0.38 - 29 - SG 214m E

27.3% within High Town Royal Pharmacy 53m W Sharing Smiles 712m SW Crawley Green Infant St Matthews 1ary 106m Barnfield Skills Academy EM1 site 718m SE; within Hightown Community Bell's Cl 278m NW Peoples Park (Urban Hart Hill Nursery 576m Taylor Street & St Matthews Luton 221m SW 399m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2880m NC; TC 206m S 1089m E NW 85m SE Central Area Sports and Arts Centre P&G) 211m NW SE Street ELR Red site 6m primary/High Town Rd >100m from Airport/M1 SE 142 Back Street Block, High Town Block G 0.75 - 16 - B2 45m E NE 58m N

5.0% within High Town Royal Pharmacy 30m NW Sharing Smiles 513m SW Crawley Green Infant St Matthews 1ary 182m N Barnfield Skills Academy EM1 site 570m SE; CA Hightown Community Bell's Cl 332m N Hitchin Rd / Pomfret Ave Hart Hill Nursery 479m E 67.1% of site is part of Adjacent to Midland Rd / Luton 16m SW 190m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2765m NC; TC 2m S 1019m E 90m NE 2m S Sports and Arts Centre (ANG) 209m E Midland Rd (2) ELR Rails Station Entrance >100m from Airport/M1 SE 143 Duke Street, High Town Block H 3.73 - 118 - B1 109m N Amber site

High Town NC 57m NW; Royal Pharmacy 141m W Sharing Smiles 750m SW Crawley Green Infant St Matthews 1ary 186m Barnfield Skills Academy EM1 site 637m SE; CA Hightown Community Bell's Cl 358m NW Hitchin Rd / Pomfret Ave Hart Hill Nursery 467m 31.3% within Taylor St Matthews Luton 221m SW 376m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2774m TC 195m SW 996m E NW 37m NE 195m SW Sports and Arts Centre (ANG) 160m E SE Street & York Street ELR primary/High Town Rd >100m from Airport/M1 SE 144 Brunswick Street, High Town Block J 0.51 - 19 - B2 35.6m E Red site 122m N

High Town NC 7m SW; Dr Saleh''s GP 139m W Sharing Smiles 823m SW Crawley Green Infant St Matthews 1ary 89m Barnfield Skills Academy EM1 site 695m S; CA Hightown Community Bell's Cl 258m NW Hitchin Rd / Pomfret Ave Hart Hill Nursery 456m 34.4% within Concorde Adjacent to Charles Luton 310m SW 482m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2779m TC 294m S 939m E NW 70m SW 294m S Sports and Arts Centre (ANG) 53m SE SE Street ELR Red site St/Hitchin Rd >100m from Airport/M1 SE 145 Concorde Street, High Town Block K 2.44 - 92 - B1 23m SE

High Town NC 175m Royal Pharmacy 251m Maeer Dental Surgery Crawley Green Infant St Matthews 1ary 290m Barnfield Skills Academy EM1 site 577m SE; CA Hightown Community Bell's Cl 449m NW Hitchin Rd / Pomfret Ave Hart Hill Nursery 429m Hitchin Rd / Brunswick St Charles St/Hitchin Rd Luton 204m SW 319m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2744m NW; TC 139m SW NW 705m SW 928m E NW 41m NW 139m SW Sports and Arts Centre (ANG) 70m E SE ELR Amber site 11m NW 18m N >100m from Airport/M1 SE 146 Hitchin Road, High Town Block L 0.29 - 11 - SG 83m NW

High Town NC 142m Royal Pharmacy 203m Maeer Dental Surgery Crawley Green Infant St Matthews 1ary 346m N Barnfield Skills Academy EM1 site 527m SE; CA Hightown Community Bell's Cl 510m N Hitchin Rd / Pomfret Ave Hart Hill Nursery 507m E 35.3% of site is part of Midland Rd / Church St Luton 65m W 182m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2750m NW; TC 2m S NW 564m SW 1055m E 193m NE 2m S Sports and Arts Centre (ANG) 283m NE Midland Rd (2) ELR 21m SW >100m from Airport/M1 SE 147 Burr Street, High Town Block M 0.43 - 10 - B1 212m NE Amber site

High Town NC 118m N; Boots Chemist 226m SW Maeer Dental Surgery Crawley Green Infant St Matthews 1ary 501m N Barnfield Skills Academy EM1 site 448m SE Hightown Community Bell's Cl 631m N St Mary's Church Hart Hill Nursery 578m E Power Court ELR Red Adjacent to 'Luton Bus Luton 14m N 2m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2731m within TC 362m S 1124m E 366m NE Sports and Arts Centre (Ch'yard/Cem'y) 178m SE site 9m SE Station >100m from Airport/M1 SE 148 Station Quarter 1.48 -375 - SD 390m N

Sundon Park N/DC 907m Lloyds Pharmacy on site Purley Centre Dental on Cheynes Infant School Wauluds Primary 306m S Lea Manor High 124m EM1 site 1082m W Futures Fun Factory Purley Centre (Freeman's Sherd Close Marsh Farm Gill Blowers Nursery Not ELR site Adjacent to Purway Leagrave 1272m S On site Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 561m S Marsh Farm Central Area / CERC and W; [FUTURE: 48.7% site 572m W NE within site Green) 30m S & Lea Manor Recreation 509m SW Close/The Moakes >100m from Airport/M1 149 6.61 - 21 - B2 Purley Centre within Purley Centre Ground (both Amenity) (Marsh Fm) DC] adj High Town NC 251m Boots Chemist 247m SW Maeer Dental Surgery Crawley Green Infant St Matthews 1ary 554m N Barnfield Skills Academy EM1 site 13m SE; KR1 Hightown Community Manor Road 215m SE Windmill Rd Island Hart Hill Nursery 363m 100% of site is part of Adjacent to St Mary's Luton 40m N 2m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2233m NW; within TC 361m SW 792m NE 387m N site 610m SE Sports and Arts Centre (Amenity) 12m SW NE Power Court ELR Red Church >100m from Airport/M1 SE 150 Power Court 7.23 - 600 - B2 415m N site

TC 287m N Dr McGill GP 302m NW Maeer Dental Surgery Hillborough Infant & Surrey St 1ary 144m E Barnfield Skills Academy EM1 site 380m NE; EM2 Stockwood District Park Hibbert St 53m NW Windmill Rd Island Rothesay Rd Nursery 91.8% of site is part of Tracey Ct/Hibbert St Luton 932m N 360m W Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2472m E 509m N Nursery 789m W 1271m N site 495m SE; CA 287m N 526m SW (Amenity) 11m NW 882m NW Telmere Ind Estate ELR 35m NW >100m from Airport/M1 151 Telmere Industrial Estate 0.43 - 15 - B1-2 Red site

Bury Park DC 600m SE Woodland Ave Surgery Marsh Rd Dental 318m Denbigh Infant 185m E Denbigh Junior 185m E Denbigh High 879m E 97.9% within EM1 site Hightown Community Blundell Rd 46m NE Blundell Rd Rec Gill Blowers Nursery 96.3% within Leagrave Adjacent to Millfield Leagrave 1211m NW 848m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1418m 125m NE NW Sports and Arts Centre (Amenity) 51m NE 1855m NW Rd North ELR Amber site Rd/Leagrave Rd >100m from Airport/M1 NW 152 Leagrave Road 3.07 - 154 - B1 2188m SE

Sundon Park N/DC 58m Rowlands Pharmacy Sundon Park Dental 27m Cheynes Infant School Sundon Park Junior Lealands High 234m SE 99.7% within EM1 site Futures Fun Factory Grampian Way 629m E Chestnut Ave (Amenity) Gill Blowers Nursery 89.7% within Sundon Ind Adjacent to Ashwell Leagrave 1898m SE 360m N Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 1291m SE SE 539m SE SE 659m E 389m NE 1279m E 273m N 1329m SE Estate ELR Amber site Ave/Sundon Park Rd >100m from Airport/M1 153 Sundon Industrial Estate 2.81 - 141 - B2

Sundon Park N/DC 102m Rowlands Pharmacy Sundon Park Dental Cheynes Infant School Sundon Park Junior Lealands High 232m NE 99.9% within EM1 site Futures Fun Factory Grampian Way 513m E Toddington Rd Gill Blowers Nursery Within Park Ave Trading Hill Rise/Sundon Park Rd Leagrave 1460m SE 717m SE Not ALC1/2/3 (ALC2 17m PDL >50m from AQMA, SPZ3 Waulud's Bank 942m SE E 188m E 124m SE 621m NE 578m NE 1212m E (Allotment) 38m S 957m S Est ELR Amber site; adj 89m E SW >100m from Airport/M1 154 Park Avenue Trading Estate 2.39 - 120 - B2 to Luton E'prise Park ELR Green site Bury Park DC 134m E; TC Acorn Chemist 64m NW Jaspal Mandair Dental Whipperly Infant 832m Dallow 1ary 114m SE Denbigh High 995m N EM1 site 313m W; CA Hightown Community Brantwood Park Brantwood N'hood Park Rothesay Rd Nursery 98.7% within Guardian Adjacent to Newcombe Luton 895m E 17m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 345m E 325m NE SW 345m E Sports and Arts Centre (Amenity) 316m SE (Amenity) 192m SE 610m SE Estate ELR Amber site Rd/Dallow Rd >100m from Airport/M1 155 Guardian Estate, Dallow Road 1.58 - 64 - B2 1358m E

High Town NC 781m Boots Chemist 585m W Maeer Dental Surgery Crawley Green Infant Surrey Street 1ary 543m Barnfield Skills Academy 98.8% within EM1 site; Hightown Community Manor Road 45m SW Manor Rd N'hd Park Hart Hill Nursery 456m N 95.8% of site within Thistle Rd/Windmill Rd Luton 558m NW 296m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Someries Castle 2030m NW; TC 76m NW 604m W 794m NE SW 757m NW EM2 site 945m S; KR1 Sports and Arts Centre (Urban P&G) 11m SW Windmill Trading Estate 0.7m SW >100m from Airport/M1 SE 156 Windmill Trading Estate, Thistle Road 1.46 - 73 - B8 site 449m E; CA 76m NW 802m NW ELR Green site

Marsh Rd DC 760m NW Makan MPS Dispensing Marsh Rd Dental 403m N St Josephs Infant 487m Norton Road Primary Challney High School for 100% within EM1 site; Futures Fun Factory Blundell Rd 215m NE Blundell Rd Rec Gill Blower's Nursery - 1.4% within Selbourne Wingate Rd Arundel Rd Leagrave 1240m NW 886m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 and 3 Waulud's Bank 1481m Chemist; Mr M Makan N 557m N Boys 1377m W 2511m N (Amenity) 219m NE Mossdale Site 1902m Road Green ELR site 6m E >100m from Airport/M1 NW 157 Arundel Road - COMPOSITE 0.93 - 47 - B2 414m SW NW

Marsh Rd DC 1378m N Lister House Surgery Leagrave Dental Foxdell Infant 909m SE Downside Primary 96m Challney High School for 99.9% within EM1 site Lewsey Sports Park Foxdell 380m S Chaul End Gill Blower's Nursery - 99.9% within Chaul End Hatters Way Retail Park Leagrave 1623m N 60m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 and 2 Waulud's Bank 1915m N 249m NE Sedation Clinic 541m W Boys 902m NW 2207m NW Neighbourhood Park Mossdale Site 2031m Lane South and 98% 58m S >100m from Airport/M1 159 Chaul End Lane - COMPOSITE 0.93 - 39 - B1-2 NW (Amenity) 56m N NW within Chaul End Lane North Amber ELR site Stopsley DC 754m N Ashcroft Pharmacy 432m Vogue Dental 777m SE Someries Infant 1055m E Ramridge 1ary 353m NE Stopsley High 942m NW EM1 1267m SE; KR1 Stopsley Common 988m Abbotswood Rd 608m S Vauxhall Green (Amenity) Hart Hill Nursery 1161m 98.3% of site within Deep Denes/Hitchin Rd Luton 1405m SW 999m N Not ALC1/2/3 PDL >50m from AQMA, SPZ3 None within 3km Moreton Park Estate, Moreton Road NE 1342m S; LLA1 1520m N 29m NE S Moreton Park ELR 89m W >100m from Airport/M1 160 0.83 - 18 - B2 South SE; BA1 1721m N; CA Amber site 1370m SW High Town NC 239m Dr Saleh''s GP 464m W Vogue Dental 854m E Crawley Green Infant St Matthews 1ary 351m Barnfield Skills Academy EM1 856m S; CA 577m Hightown Community Abbotswood Rd 388m E Hitch Rd / Pomfret Ave Hart Hill Nursery 523m 99.6% within Oxen Rd Jubilee St/Hitchin Rd Luton 623m SW 755m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2804m SW; TC 577m SW 904m SE W 308m SW SW Sports and Arts Centre (ANG) 42m SE SE Ind Estate ELR Amber 101m SW >100m from Airport/M1 SE 161 Oxen Industrial Estate, Oxen Road 0.60 - 48 - B2 293m SW site

High Town NC 807m SW Ashcroft Pharmacy 699m Vogue Dental 756m SE Crawley Green Infant Ramridge 1ary 626m NE Barnfield Skills Academy EM1 1223m SE; KR1 Hightown Community Abbotswood Rd 450m S Vauxhall Way (Amenity) Hart Hill Nursery 940m S 99.8% within Sunrise Turner's Rd Sth/Hitchin Luton 1126m SW 1178m N Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Someries Castle 2977m NE 1078m SE 816m SW 1258m SE; LLA1 1555m Sports and Arts Centre 301m NE Estate ELR Amber site Rd 15m >100m from Airport/M1 SE 162 Sunrise Trading Estate 0.29 - 14 - B2 SE; BA1 1968m N; CA 793m SW 1091m SW Marsh Rd DC 1556m NE Lister House Surgery Leagrave Dental Foxdell Infant 1169m SE Downside 1ary 264m E Challney High School for EM1 89m S Lewsey Sports Park Foxdell 521m SE 0.2% within Bradley Rd Gill Blowers Nursery Not ELR site Rd/Leicester Leagrave 1677m N 85m S Not ALC1/2/3 Not PDL >50m from AQMA, SPZ1 Waulud's Bank 1968m N 1.21 - 42 - D2 / open 681m E Sedation Clinic 282m N Boys 608m NW 1806m NW (Allotments); contains 189m N Arms 235m N >100m from Airport/M1 164 Bradley Road Recreation Ground space Bradley Rd Open Space (Amenity) High Town NC 683m W; Dr Saleh''s GP 823m W Vogue Dental 408m E Crawley Green Infant Wenlock Junior (CofE) Barnfield Skills Academy EM1 site 757m SE; KR1 Hightown Community Abbotswood Rd on site 64% of site is Abbots Hart Hill Nursery 492m S Not ELR site Kernow Ct/Abbotswood Luton 885m SW 984m SW Not ALC1/2/3 Partially PDL >50m from AQMA, SPZ2 Someries Castle 2498m TC 823m SW 578m SE 518m SE 609m W site 764m SE; CA 823m Sports and Arts Centre Wood Rd OS (Amenity); Rd 28m S >100m from Airport/M1 SE 168 Abbotswood Road 0.69 - 28 - D2 SW 615m W Hitchin Rd / Pomfret Ave (ANG) 232m W Bury Park DC 903m N; Kamsons Pharmacy 307m Integrated Dental Hillborough Infant & Hillborough Junior 110m Barnfield Skills Academy EM1 986m SE; EM2 986m Stockwood District Park Windsor St 201m NE Rothesay Cemetery Rothesay Rd Nursery Not ELR site Russel Rise/Meyrick Ave Luton 1111m NE 304m E Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 551m NE NE Holdings 488m N Nursery 112m SW SW 1558m NE SE 325m S (C'yds&Cmys) 217m N 338m N 94m N >100m from Airport/M1 169 Russel Rise 0.55 - 28 - wasteland

Marsh Rd DC 939m N Makan MPS Dispensing Marsh Rd Dental 598m N St Joseph's Infants 674m Maidenhall Primary 473m Challney High School for EM1 site 10m N; Lewsey Sports Park Kingsway Recreation Kingswood Rec Gill Blowers Nursery - 12.9% within Wingate Rd Wingate Rd/Opposite Leagrave 1362m NW 513m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1627m Chemist; Mr M Makan N E Boys 1280m W 2482m W Ground 255m SE Neighbourhood Park Mossdale Site 1967m ELR Green site Arundel Rd 5m N >100m from Airport/M1 NW 174 Land at Caleb Close (1) 2.60 - 98 - B2 85m SW (Urban P and G) 101m S NW

High Town NC 102m NW Royal Pharmacy; Mr T J Maeer Dental Crawley Green Infant St Matthews Primary Barnfield Skills Academy EM1 site 506m SE; Hightown Community Bell's Close 599m N St Mary's Church Hart Hill Nursery 538m E Midland Rd ELR Amber Luton Centre Dunstable Luton 9m W 143m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2741m Car parks at Police Station and Court Careways Ltd; Mr N Shah Surgery 525m SW 1088m E 415m N 285m NE Sports and Arts Centre (Churchyards and site 11m N Place 0.4m SE >100m from Airport/M1 SE 175 0.29 - 41 - SG House, 12 Dunstable Place 238m N 922m NE Cemeteries) 278m S

Bury Park DC 23m NW Lea Vale Medical Sharing Smiles 231m S Hillborough Infant and Dallow Primary 386m N Barnfield Skills Academy EM1 site 882m W Hightown Community Brantwood Park 489m The Moor (Amenity Rothesay Road Nursery Mill Street Green site Villa Link/Old Bedford Luton 292m E 37m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Practice 136m SW Nursery 1116m S 791m E Sports and Arts Centre SW Greenspace) 101m N 603m S ELR 64m NE Road. On the site >100m from Airport/M1 176 Car Park off Telford Way (7) 0.52 - 39 - SG 774m E

Round Green NC 310m Ashcroft Pharmacy 847m Village Dental Practice Someries Infant 1479m E Sacred Heart Primary Stopsley High 547m N EM1 site 1755m SE; Stopsley Common 715m Ashcroft Road 878m NE 56.9% within St Martin's Hart Hill Nursery 1460m Moreton Park Amber site Sunningdale/Birchen Rd Luton 1422m S 634m N Not ALC1/2/3 Not PDL >50m from AQMA, SPZ3 None within 3km SE; Stopsley DC 641m E 877m NE 607m NE N (Natural and Semi- S ELR 397m SE 31m N >100m from Airport/M1 177 Land at Birchen Grove (3) 1.70 - 36 - D2 NE natural Greenspace)

Hockwell Ring NC 362m Dr Mirza 300m NE Hockwell Surgery 531m The Ferrars Academy Leagrave Primary 167m Challney High School for EM1 site 752m E; Lewsey Sports Park 593m Mayne Avenue 501.5m Lewsey Park 57m SW Gill Blowers Nursery Sedgewick 65m N Leagrave 1150m E 61m SW Not ALC1/2/3 PDL 67.9m NE of M1 SPZ2 Waulud's Bank 1243m NE; Sundon Park NC NE 640m SW SE Girls 569m SE SW NE 588m NE Road/Progress Wat NE 179 Land to Rear of Bank Close (12) 0.32 - 12 - D2 1330m N Green ELR site 1005m N

Burt Park DC 299m NE; Acorn Chemist 213m SE Beech Hill Dental Whipperley Infant 772m Beech Hill Primary 282m Denbigh High 999m NE EM1 Site adj; CA1 site Stockwood District Park Cohen's Yard 281m NW Ferndale Allotments Rothesay Road Nursery 99.3% within Dalroad Bedfordshire Yeoman Luton 1226m E 5m N Not ALC1/2/3 PDL >50m from AQMA, SPZ2 None within 3km Market Square, Farley Practice 363m NW SW N 698m E 1539m SE 130m SW 959m SE Green ELR site 49m W >100m from Airport/M1 180 Dalroad Industrial Estate (6) 0.79 - 32 - B2 NC 775m S

Sundon Park NC 277m S Rowlands Pharmacy Sundon Park Dental Cheynes Infant 503m E Sundon Park Junior Lealands High 135m SE None within 3km Futures Fun Factory Grampian Way 480m SE Chestnut Ave (Amenity) Gill Blowers Nursery - SKF Green ELR site 93m Adjacent to WellField Leagrave 1803m SE 432m N Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 1175m SE 456m S Practice 460m S 254m NE 1122m E 395m N Leabank Site 1196m SE SW Ave/Ashwell Ave >100m from Airport/M1 181 1-9 Ashwell Parade (11) 0.25 - 13 - A1

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 1 / 12 SEA Objectives C25 Impact on Listed C26 Impact on historic C27 Impact on C28 Impact on AONB C29 Impact on SSSI C30 Impact on AGLV C31 Impact on ALLI C32 Impact on Green C33 Impact on LNR C34 Impact on CWS C35 Impact on other C36 Impact on open C37 Impact on C38 Impact on Lea C39 Impact on Flood SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Building P&G Conservation Area Belt SNCI space allotment tributaries Zone None None None 500m 400m 400m 400m 20m 20m 20m 20m 20m 20m 20m FZ1 <14 Site Name ID Guildford St No. 50 (GII) Wardown Park (GII) 734m 22.3% within High Town 2444m N None within 3km 1125m SW Hart Hill 347m E 1787m SE None within 3km River Lea 330m W River Lea DWS 129m W The Moor (Amenity) Harthill Ln 674m E ENV20 264m W Not FZ2/3 144m S NW 325m W 0 0 +/- 0 0 + - + 0 +/- ++ 0 ++ +/- Midland Road West, High Town Block A 136

George II Pub, Bute St Wardown Park (GII) 962m High Town 113m NW; 2493m N None within 3km 1362m W Hart Hill 136m E 1602m N None within 3km River Lea 495m SE River Lea DWS 156m S St Mary's Church Harthill Ln 450m E ENV14 488m SE Not FZ2/3 (GII) 162m SW NW Plaiters Lea 118 SW (Ch'yard/Cem'y) 278m S 0 0 +/- 0 0 + 0 + 0 +/- + 0 ++ + Midland Road East, High Town Block B 137

High Town Methodist Wardown Park (GII) 724m 1.6% within High Town 2325m N None within 3km 1242m SW Hart Hill 360m E 1852m SE None within 3km River Lea 411m W River Lea DWS 244m S Peoples Park (Urban Harthill Ln 691m E ENV20 352m W Not FZ2/3 Church (GII) 74m NE NW P&G) 305m N 0 0 +/- 0 0 + - + 0 +/- + 0 ++ + Albion Road, High Town Block D 139

Guildford St No. 50 (GII) Wardown Park (GII) 535m High Town 43m E 2267m N None within 3km 1079m SW Hart Hill 466m E 1903m SE None within 3km River Lea 214m W River Lea DWS 83m SW The Moor (Amenity) Harthill Ln 795m E ENV20 173m W Not FZ2/3 167m S NW 214m W Old Bedford Road Block, High Town 0 0 +/- 0 0 + 0 + 0 +/- ++ 0 ++ +/- 140 Block E

High Town Methodist Wardown Park (GII) 688m 10.4% within High Town 2204m N None within 3km 1069m N Hart Hill 343m SE 1885m N None within 3km Peoples Park CWS 435m River Lea DWS 350m SW Peoples Park (Urban Harthill Ln 665m SE ENV20 424m W Not FZ2/3 Church Hall (GII) 6m E NW N P&G) 181m N 0 0 - 0 0 + - + 0 +/- ++ 0 + + Wenlock Street, High Town Block F 141

The Painters Arms (GII) Wardown Park (GII) 784m 2.8% within High Town 2167m N None within 3km 1147m N Hart Hill 202m SE 1814m SE None within 3km Peoples Park CWS 425m Hitchin Road Spinney Peoples Park (Urban Harthill Ln 516m SE ENV20 576m W Not FZ2/3 11m N NW N DWS 224m E P&G) 211m NW 0 0 - 0 0 + - + 0 +/- ++ 0 + + Back Street Block, High Town Block G 142

Gates, Dwarf Wall And Wardown Park (GII) 796m 3.1% within High Town 2258m N None within 3km 1229m N Hart Hill 89m SE 1666m SE None within 3km Peoples Park CWS 499m Hitchin Road Spinney Hitchin Rd / Pomfret Ave Harthill Ln 409m SE ENV20 455m W Not FZ2/3 Railings To High Town NW N DWS 209m E (ANG) 209m E 0 0 +/- 0 0 + - + 0 +/- ++ 0 ++ +/- Duke Street, High Town Block H 143 Methodist Church (GII) 22m NW The Painters Arms (GII) Wardown Park (GII) 878m High Town 76m NE 2231m N None within 3km 1218m N Hart Hill 95m SE 1729m SE None within 3km Peoples Park CWS 488m Hitchin Road Spinney Hitchin Rd / Pomfret Ave Harthill Ln 407m SE ENV14 651m S; ENV20 Not FZ2/3 110m NW NW N DWS 160m E (ANG) 160m E 652m W 0 0 - 0 0 + 0 + 0 +/- ++ 0 + + Brunswick Street, High Town Block J 144

The Painters Arms (GII) Wardown Park (GII) 785m High Town 10m SW 2004m N None within 3km 1019m N Hart Hill 87m SE 1683m N None within 3km Peoples Park CWS 299m Hitchin Road Spinney Hitchin Rd / Pomfret Ave Harthill Ln 417m SE ENV20 670m W Not FZ2/3 58m SW NW NW DWS 47m SE (ANG) 53m SE 0 0 - 0 0 + 0 + 0 +/- ++ 0 + + Concorde Street, High Town Block K 145

The Painters Arms (GII) Wardown Park (GII) 984m High Town 194m NW 2235m N None within 3km 1042m N Hart Hill 62m SE 1672m SE None within 3km Peoples Park CWS 508m Hitchin Road Spinney Hitchin Rd / Pomfret Ave Harthill Ln 378m SE ENV14 584m S Not FZ2/3 229m NW NW N DWS 70m E (ANG) 70m E 0 0 +/- 0 0 + 0 + 0 +/- + 0 ++ + Hitchin Road, High Town Block L 146

Gates, Dwarf Wall And Wardown Park (GII) 971m High Town 152m NW 2418m N None within 3km 1397m N Hart Hill 97m E 1629m SE None within 3km River Lea CWS 521m SE River Lea DWS 195m S Hitchin Rd / Pomfret Ave Harthill Ln 427m E ENV14 513m SE; ENV20 Not FZ2/3 Railings To High Town NW (ANG) 283m NE 521m SE 0 0 +/- 0 0 + 0 + 0 +/- + 0 ++ +/- Burr Street, High Town Block M 147 Methodist Church (GII) 187m NW George II Pub, Bute St Wardown Park (GII) 931m 10.9% within Plaiters Lea 2567m N None within 3km 1209m W Hart Hill 181m E 1528m SE None within 3km River Lea CWS 445m SE River Lea DWS 29m S St Mary's Church Harthill Ln 486m E ENV14 440m SE; ENV20 FZ2/3 27m S (GII) 7m S NW (Ch'yard/Cem'y) 178m SE 445m SE 0 0 +/- 0 0 + - + 0 +/- ++ 0 ++ + Station Quarter 148

Little Bramingham None within 3km None within 3km 1134m N Galley & Warden Hills None within 3km None within 3km 573m N Leagrave Common & Bramingham Wood CWS River Lea DWS 859m S Sherd Close Marsh Farm Willow Way 906m S ENV20 672m SW Not FZ2/3 Farmhouse (GII) 649m E 2020m E Wauluds Bank Proposed 210m NE & Lea Manor Recreation Marsh Farm Central Area / CERC and 0 +/- +/- 0 0 + 0 + 0 +/- ++ 0 + + 149 LNR 329m W Ground (both Amenity) Purley Centre adj Parish Church of St Mary Wardown Park (GII) Plaiters Lea 26m W 2628m N None within 3km 1374m W Hart Hill 119m NE 1110m SE None within 3km River Lea CWS 21m S 0.7% of site is part of Windmill Rd Island Harthill Ln 276m NE ENV14 13m S (ENV20 0.9% of site is FZ2; 0.8% (GI) 40m SW 1109m NW River Lea DWS (Amenity) 12m SW 21m S) of site is FZ3 +/- 0 +/- - 0 + +/- + 0 +/- ++ 0 ++ + Power Court 150

Baptist Union Church Luton Hoo (GII*) 884m Luton South 289m W None within 3km None within 3km 1329m NW Stockwood Park 526m 895m SE None within 3km River Lea CWS 520m E River Lea DWS 489m E Windmill Rd Island London Rd 532m SW ENV20 519m E Not FZ2/3 (GII) 313m NW SE SW (Amenity) 11m NW 0 0 - 0 0 + 0 + 0 +/- ++ 0 +/- + Telmere Industrial Estate 151

Church of St Andrew Wardown Park (GII) Rothesay 1548m SE 2128m SW Galley & Warden Hills 1161m S Hart Hill 2341m SE 1690m SW Leagrave Common & Biscot Churchyard CWS River Lea DWS 911m N Blundell Rd Rec Limbury 1005m N ENV20 929m N Not FZ2/3 (GII) 643m E 1139m E 2668m NE Wauluds Bank Proposed 664m NE (Amenity) 51m NE 0 0 - 0 0 + 0 + 0 +/- ++ 0 +/- +/- Leagrave Road 152 LNR 1374m NW

Church of St Mary (GI) None within 3km None within 3km 1092m NE Sundon Chalk Quarry None within 3km None within 3km 295m N Leagrave Common & Sundon Wood CWS River Lea DWS 1264m SE Chestnut Ave (Amenity) Toddington Rd 519m S ENV20 1163m SE Not FZ2/3 1041m N 927m NW Wauluds Bank Proposed 712m NE 273m N 0 0 - 0 0 + 0 + 0 - ++ 0 +/- +/- Sundon Industrial Estate 153 LNR 781m E

Church of St Mary (GI) None within 3km None within 3km 1470m N Sundon Chalk Quarry None within 3km None within 3km 536m SW Leagrave Common & Leagrave Common CWS River Lea DWS 707m SE Grampian Way (Amenity) Toddington Rd ENV20 711m SE Not FZ2/3 1461m N 1318m NW Wauluds Bank Proposed 682m SE 461m E (Allotment) 38m S 0 0 - 0 0 + 0 + 0 - ++ 0 +/- +/- Park Avenue Trading Estate 154 LNR 699m E

Former Bingo Hall (GII) Wardown Park (GII) 881m Rothesay 157m SE 2368m W None within 3km 247m S Stockwood Park 1277m S 1212m SW None within 3km Dallow Downs CWS River Lea DWS 490m NE Brantwood N'hood Park Ferndale 397m W ENV20 569m NE Not FZ2/3 156m NE NE 246m S (Amenity) 192m SE 0 0 - 0 0 + 0 + 0 +/- ++ 0 + +/- Guardian Estate, Dallow Road 155

Gas Lamps at 2&32 Hart Luton Hoo (GII*) 887m S Plaiters Lea 481m NW 2972m N None within 3km 1727m SE Hart Hill 214m NE 861m SE None within 3km River Lea CWS 15m SW River Lea DWS 11m SW Manor Rd N'hd Park Gypsy Ln 231m SE ENV20 15m SW FZ2/3 15m SW Hill Drive (GII)255m N (Urban P&G) 11m SW +/- 0 +/- 0 0 + 0 + 0 +/- ++ 0 + - Windmill Trading Estate, Thistle Road 156

Holy Trinity Church (GII) Wardown Park (GII) Rothesay 1957m SE 1909m SW Galley & Warden Hills 1375m S Hart Hill 2903m SE 1474m SW 'Leagrave Common & Biscot Churchyard CWS River Lea DWS 1039m N Blundell Rd Rec Limbury 1140m N ENV20 1067m N Not FZ2/3 934m NE 1677m E 2844m NE Wauluds Bank Proposed 841m NE (Amenity) 219m NE 0 0 - 0 0 + 0 + 0 - ++ 0 +/- - Arundel Road - COMPOSITE 157 LNR 1434m NW; Galley & Warden Hills 2844m Chaul End Farmhouse Wardown Park (GII) Rothesay 1949m SE 854m W Blow's Down 2061m W 710m S Stockwood Park 2899m 370m SW Leagrave Common & The Linces CWS 467m Hatters Way DWS 48m S Chaul End Bradley Road Allotment ENV20 1721m NW Not FZ2/3 (GII) 849m SW 2269m E SE Wauluds Bank Proposed SW Neighbourhood Park 257m W 0 0 - 0 0 + 0 + 0 +/- ++ 0 - +/- Chaul End Lane - COMPOSITE 159 LNR 1857m N; Cottage (Amenity) 56m N Bottom Fields 2589m SW St Christopher's Church Wardown Park (GII) High Town 1085m SW 1411m NW Galley & Warden Hills 785m W Hart Hill 1027m SW 986m N Galley & Warden Hills The Chase CWS 242m Un-named ENV5 242m Vauxhall Green (Amenity) Stockingstone Rd 715m ENV20 1276m W Not FZ2/3 (GII) 134m W 1138m W 2911m NW 2911m NW NW NW (at The Chase) 29m NE W Moreton Park Estate, Moreton Road 0 0 - 0 0 + 0 + 0 + ++ 0 +/- - 160 South

Hart Lane Water Tower Wardown Park (GII) 903m High Town 338m SW 1917m N None within 3km 961m N Hart Hill 247m S 1579m N None within 3km People's Park CWS 283m Hitchin Road Spinney Hitch Rd / Pomfret Ave Harthill Ln 505m S ENV14 931m S Not FZ2/3 (GII) 201m E W NW DWS 42m SE (ANG) 42m SE 0 0 - 0 0 + 0 + 0 +/- ++ 0 +/- +/- Oxen Industrial Estate, Oxen Road 161

St Christopher's Church Wardown Park High Town 808m SW 1630m N None within 3km 795m NW Hart Hill 754m S 1172m N None within 3km The Chase CWS 394m N Un-named ENV5 394m N Turners Knoll 24m S Stockingstone Rd 638m ENV20 1136m W Not FZ2/3 (GII) 121m NW (GII)1043m W (at The Chase) W 0 0 - 0 0 + 0 + 0 - + 0 +/- - Sunrise Trading Estate 162

Chaul End Farmhouse Wardown Park (GII) Rothesay 2280m SE 582m SW Blow's Down 1759m W 877m SE None within 3km 218m SW Leagrave Common & Dunstable to Luton Hatters Way DWS 71m S 0.2% within Bradley Rd 0.2% within Bradley Rd ENV20 1438m NW Not FZ2/3 (GII) 711m SW 2739mm E Wauluds Bank Proposed disused railway CWS (Allotments); contains (Allotments); contains - - - 0 0 +/- 0 + 0 -- ++ 0 +/- + Bradley Road Recreation Ground 164 LNR 1909m N 258m W Bradley Rd Open Space Bradley Rd Open Space (Amenity) (Amenity) Hart Lane Water Tower Wardown Park (GII) High Town 690m W 2115m N None within 3km 1204m NW Hart Hill 458m SW 1657m N None within 3km People's Park CWS 649m Un-named ENV5 site at 64% of site is Abbots Harthill Ln 508m S ENV14 1016m SW Not FZ2/3 (GII) 113m W 1288m W NW Hart Lane 108m W Wood Rd Open Space - -- - 0 0 +/- 0 + 0 + ++ 0 +/- + Abbotswood Road 168

Former Chapel Langley Luton Hoo (GII*) 1504m Luton South 154m E 2482m W None within 3km 535m NW Stockwood Park 325m S 1070m SW None within 3km Dallow Downs CWS Stockwood Park DWS North Drift Way 181m London Rd 430m S ENV14 1108m N Not FZ2/3 School (GII) 222m NE SE 544m NW 325m S NE 0 0 - 0 0 + 0 + 0 + ++ 0 +/- + Russel Rise 169

Holy Trinity Church (GII) Wardown Park (GII) Rothesay 1940m SE 1630m SW Blow's Down 2783m W 1059m S Stockwood Park 2832m 1129m SW Leagrave Common and Biscot Churchyard CWS Hatters Way DWS 785m Kingswood Rec Bradley Rd Allotments ENV20 1262m N Not FZ2/3 1095m NE 1754m E SE Wauluds bank 1573m 1005m NE SW Neighbourhood Park 945m W 0 0 - 0 0 + 0 + 0 - ++ 0 +/- - Land at Caleb Close (1) 174 NW (Urban P and G) 101m S

George II Public House Wardown Park (GII) 961m High Town 113m NW 2929m W None within 3km 1362m W Hart Hill 136m E 1646m SW None within 3km River Lea CWS 495m SE River Lea DWS 156m S St Mary's Church Harthill Lane Allotments ENV14 488m SE Not FZ2/3 (GII) 175m SW NW (Churchyards and 450m E Car parks at Police Station and Court 0 0 +/- 0 0 + 0 + 0 + ++ 0 ++ + 175 Cemeteries) 278m S House, 12 Dunstable Place

No 7 New Bedford Road Wardown Park (GII) 645m Town Centre 201m SE 2563m N None within 3km 742m SW Hart Hill 776m E 1790m SW None within 3km River Lea CWS 117m SE River Lea DWS 60m S The Moor (Amenity Ferndale Allotments ENV14 95m N 55% of site is FZ2 (GII) 132m SE N Greenspace) 101m N 1031m W 0 0 +/- - 0 + 0 + 0 + ++ 0 ++ + Car Park off Telford Way (7) 176

St Christopher's Church Wardown Park (GII) 606m High Town 1085m S 967m N Galley and Warden Hills 227m W Hart Hill 1191m S 636m N Galley and Warden Hills The Chase CWS 124m E Mixes Hill DWS 172m NE 56.9% within St Martin's Stockington Road 278m ENV20 814m W Not FZ2/3 (GII) 351m SE W 2419m NW 2419m NW (Natural and Semi- SW - -- - 0 0 +/- 0 + 0 - ++ 0 +/- + Land at Birchen Grove (3) 177 natural Greenspace)

Church of St Luke (GII) None within 3km None within 3km 1577m S Blow's Down 1842m SW 2615m SE None within 3km 680m NW Leagrave Common & River Lea CWS 87.8m SE Lewsey Park DWS 57.3m Lewsey Park 57m SW Ravenhill Way 146m W ENV 20 93m SE Not FZ2/3 606m E Wauluds Bank Proposed SW 0 0 - 0 0 + 0 + 0 - + 0 + + Land to Rear of Bank Close (12) 179 LNR 1039m NE; 'Cottage Bottom Fields 2989mSW No127 Dunstable Road, Wardown Park (GII) Rothesay 409m SE 2155m SW None within 3km 130m SW Stockwood Park 1537m 1072m SW None within 3km Dallow Downs CWS River Lea DWS 767m E St Peter's Park 34.2m S Ferndale Allotments ENV 20 845m E Not FZ2/3 Former Bingo Hall (GII) 1008m NE SE 144m W 130m SW 0 0 +/- 0 0 + 0 + 0 +/- ++ 0 + - Dalroad Industrial Estate (6) 180 414m E

Church of St Mary (GII) None within 3km None within 3km 1120m N Sundon Chalk Quarry None within 3km None within 3km 429m NW Leagrave Common & Leagrave Common CWS River Lea DWS 1192m S Chestnut Ave (Amenity) Toddington Road 563m ENV 20 1083m SE Not FZ2/3 1185m N 1189m NW Wauluds Bank Proposed 626m E 395m N S 0 0 - 0 0 + 0 + 0 -- + 0 +/- - 1-9 Ashwell Parade (11) 181 LNR 625m E Galley and Warden Hills 2985m E

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 2 / 12 Luton Possible Allocations Site Assessment Criteria (as amended) C1 Dist to centres C2 Dist to health C3 Dist to dental C4 Distance to infant C5 Dist to junior C6 Dist to 2ary C7 Dist to emp C8 Dist to sports C9 Dist to play C10 Dist to open space C15 Dist crèche C16 Loss of emp C17 Dist to bus C18 Dist to train C19 Dist to cycle C20 Loss of agric C21 Use of PDL C22 Dist to AP source C23 Impact on SPZ C24 Impact on SAM

Stopsley DC 591m E; TC PJ Ward and Partners - Village Dental Practice Someries Infant 1479m E Stopsley Community Stopsley High 292m NE EM1 site 1781m Stopsley Common 394m Wardown Park 936m SW The Chase/Mixes Hill Hart Hill Nursery 1817m Moreton Park Amber Fair Oak Drive 212m SE Luton 1703m S 221m N Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Dray's Ditches 2873m N 1677m S; Round Green Rd 779m N 849m E Primary 790m E NE Wood (Natural and Semi- S ELR site 818m SE >100m from Airport/M1 182 69 Felstead Way (4) 0.79 - 58 - D2 NC 727m N natural Green Space) 111m NE High Town NC 829m N Castle Street Surgery Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 227m NE, EM2 Stockwood District Park Hibbert St 241m SW Windmill Road Island Rothesay Road Nursery Flowers Industrial Estate Essex Close 100m SE Luton 667m N 158m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2483m E 245m W Surgery 299m NW Nursery 931m W 237m SE 1004m N 784m S; CA1 site 21m N 848m SW 220m SW 853m W Green ELR site 13m SW >100m from Airport/M1 183 12 Albert Road 0.08 - 41 - A4

High Town NC 30.4m Royal Pharmacy; Sharing Smiles 365m SW Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 860m SE; CA1 Hightown Community Bell's Close 524m NE The Moor (Amenity) Rothesay Road Nursery 50.3% within Midland Villa Rd/Old Bedford Rd Luton 73m SE 33m W Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Careways Ltd 297m NE Nursery 1302m SW 458m NE 521m NE site 1.9m S Sports and Arts Centre 282m W 833m SW Road Amber ELR site 30m W >100m from Airport/M1 188 142-144 Midland Road 0.08 - 46 - B2 501m E

High Town NC 250m N; Boots the Chemists Ltd Mr T J Maeer Dental Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 390m SE Hightown Community Manor Road 592m SE St Mary's Church Hart Hill Nursery 692m Power Court Red ELR Church St/St Mary's Luton 202m N 76m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2708m E 100% within TC; 150m SW Surgery 275m SW Nursery 1172m SW 700m N 555m NE Sports and Arts Centre (Churchyards and NE site 80m NE Church 94m SE >100m from Airport/M1 189 4-6 Melson Street 0.02 - 16 - B2 579m N Cemeteries) 112m SE

High Town NC 197m NE; Boots the Chemists Ltd Sharing Smiles 187m W Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 445m SE Hightown Community Manor Road 654m SE St Mary's Church Rothesay Road Nursery Guildford St Green ELR Adjacent to 'Silver Luton 106m NE 6.5m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2777m Extension to Mall, Arndale Centre, 100% within TC; 73m S Nursery 1032m SW 621m NE 532m NE Sports and Arts Centre (Churchyards and 622m SW site 10m NE St/Arndale Centre >100m from Airport/M1 SE 190 2.4 - 124 - A5 Northern Gateway 545m NE Cemeteries) 170m SE

TC1 350m NW; High Boots the Chemists Ltd Vogue Dental Practice Crawley Green Infant Wenlock Junior (CofE) Barnfield Skills Academy 7.6% within EM1 site; Hightown Community Manor Road 283m W Crawley Green Road Hart Hill Nursery 531m 7.5% within Kimpton Rd Adjacent to The Luton Airport Parkway 130m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Someries Castle 1236m Napier Park, Vauxhall Motors, Kimpton Town NC 1082m NW 918m W 677m N 206m N 264m SW 1007m NW EM2 site 738m SW; Sports and Arts Centre Cemetery (Churchyards NW Green ELR site Shops/Kimpton Rd 1.7m SW >100m from Airport/M1 SE 191 22.27 - 600 - B2 Road 40.7% within KR1 site; 1053m NW and Cemeteries) 3.4m LLA1 site 317m E; CA1 NW Marsh Road DC 922m Oakley Surgery 26m SW Leagrave Dental Practice The Ferrars Academy Barnfield Moorlands Challney High School for EM1 site 89m E; Lewsey Sports Park Addington Way 2 146m Addington Way Play area Gill Blower's Nursery - Empress Rd Green ELR Ousley Close/Addington Leagrave 761m NE 602m W Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 991m NE Capwell Grange Nursing Home, NE; Hockwell Ring NC 292m N 967m W Primary 192m W Girls 263m SW 1167m W S 101m S Mossdale Site 776m N site 874m NE Way 7m SE >100m from Airport/M1 192 0.12 - 75 - C2 Addington Way 600m NW

0.1% within Marsh Rd Leagrave Medical Centre Leagrave Dental Practice St Joseph's Infants 670m Beechwood Primary Challney High School for EM1 site 560m SE Futures Fun Westmorland Avenue Limbury Riverside Park Gill Blower's Nursery - 99% within Sarum Road Archway Rd/Marsh Rd Leagrave 349m NW 333m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 536m NW DC; Calverton Rd NC 351m SW 476m SE SE 392m SW Girls 1228m SW Factory1616m N 540m NE 309m NE Leabank Site 999.8m N Red ELR site 28m NE >100m from Airport/M1 193 Marlborough Works, Archway Road 0.08 - 11 - B2 783m NE

Bury Park DC 941m E Makan MPS Dispensing Beech Hill Dental Denbigh Infant 775m E Maidenhall Primary 339m Denbigh High 1407m E EM1 site 295m N Hightown Community Kingsway Recreation Kingswood Rec Rothesay Road Nursery Caleb Close Red ELR Arundel Rd/Dunstable Leagrave 1663m NW 534m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1928m Chemist 230m W Practice 816m SE E Sports and Arts centre Ground 165m SE Neighbourhood Park 2186m SE Site 72m W Rd 80m SW >100m from Airport/M1 NW 194 4-8 Arundel Road 0.31 - 11 - C3 2631m E (Urban P and G) 88m S

High Town NC 8.8m NW; Royal Pharmacies, Sharing Smiles 728m SW Crawley Green Infant St Matthews Primary Barnfield Skills Academy EM1 site 773m SE; CA1 Hightown Community Bell's Close 321m N Hitchin Rd/Pomfret Ave Hart Hill Nursery 578m York St and Taylor ST St Matthews Primary Luton 224m SW 404m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2883m CA1 209m SW Careways Ltd 84m W 1093m E 152m N 87m SE site 210m SW Sports and Arts Centre (Natural and Semi- SE Red ELR site 9m NE School/ High Town Rd >100m from Airport/M1 SE 195 Car park, Brunswick Street 0.32 - 40 - car park 49m E natural Greenspace) 105m N 235m E Bury Park DC 344m N; Cardiff Road Surgery Integrated Dental Hillborough Infant and Dallow Primary 360m Barnfield Skills Academy Em1 site 860m NW; CA1 Stockwood District Park Brantwood Park 174m W Brantwood Rothesay Road Nursery Upper George St Green Liverpool Rd/Dunstable Luton 661m NE 299m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 136m NE; High Town 24m NE Holdings 57m SW Nursery 688m S NW 1174m NE 136m NE 963m S Neighbourhood Park 173m S ELR site 148m NE Rd 151m N >100m from Airport/M1 197 14 Cardiff Road 0.14 - 64 - B1 NC 729m NE (Amenity) 105m W

Bury Park DC 883m NW; Medici 38m SW Mr T J Maeer Dental Hillborough Infant and Tennyson Road Primary Barnfield Skills Academy EM1 site 591m NE; EM2 Stockwood District Park Windsor St 204m W Windmill Rd Island Rothesay Road Nursery Holly St Green ELR site Elizabeth sty/Chapel St Luton 833m N 6m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2883m TC 219m NE; High Town Surgery 374m NE Nursery 518m SW 418m S 1216m NE site 863m SE; CA1 site 622m S (Amenity) 215m SE 472m NW 120m E 18m SW >100m from Airport/M1 SE 198 R/o 66-76 Castle Street 0.21 - 11 - B8 NC 929m N 219m NE

High Town NC 781m N; Castle Street Surgery Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 534m E; EM2 Stockwood District Park Windsor St 286m SW Windmill Rd Island Rothesay Road Nursery Holly St Green ELR site Adjacent to New Luton 682m N 6m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2833m E TC 68m NE; 85m SE Surgery 238m NE Nursery 635m SW 521m SE 1072m NE site 968m SE; CA1 site 776m S (Amenity) 292m SE 476m W 135m E St/Chapel St >100m from Airport/M1 199 27-37 Chapel Street 0.14 - 30 - C3 68m NE

Bury Park DC 773m NW; Castle Street Surgery Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 581m E; CA1 Stockwood District Park Windsor St 296m SW Windmill Rd Island Rothesay Road Nursery Kings St Green ELR New St/Chapel St 18m Luton 676m N 4m SE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2895m E TC 65m NE; High Town 154m SE Surgery 245m NE Nursery 649m SW 590m SE 1071m NE 65m NE; 803m SW (Amenity) 363m SE 463m W site198m N SE >100m from Airport/M1 200 62-64 Chapel Street 0.01 - 12 - A1 NC 773m N

High Town NC 759m N; Castle Street Surgery Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 534m E; CA1 Stockwood District Park Windsor St 312m SW Windmill Rd Island Rothesay Road Nursery Holly St Green ELR site New St/Chapel St on the Luton 660m N 5m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2851m E TC 43m NE; 114m SE Surgery 210m NE Nursery 663m SW 550m SE 1046m NE 43m NE; 804m S (Amenity) 326m SE 482m W 159m E site >100m from Airport/M1 201 Development site, 21-25 Chapel Street 0.08 - 14 - B8

High Town NC 302m N; Boots the Chemist Ltd Luton Dental Practice Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 527m SE; CA1 Hightown Community Windsor St 718m SW St Mary's Church Rothesay Road Nursery Guildford St Green ELR Luton Centre Luton 198m N 63m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2631m 100% within TC 118m S 238m SW Nursery 1073m SW 685m N 591m NE 2m S Sports and Arts Centre (Churchyards and 705m SW site 99m N Cheapside/ John St 2m >100m from Airport/M1 SE 202 37-47 Cheapside 0.11 - 59 - B1 604m NE Cemeteries) 256m SE E

Bury Park DC 72m NW; Lea Vale Medical Associated Dental Hillborough Infant and Dallow Primary 341m W Barnfield Skills Academy EM1 site 868m W Hightown Community Brantwood Park 395m Brantwood Rothesay Road Nursery Guildford St Green ELR Dallow Rd/Dunstable Rd Luton 457m E 63m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 100% within TC; High Practice 35m SW Practice 191m S Nursery 1012m S 961m E Sports and Arts Centre SW Neighbourhood Park 499m SW site 99m N 110m SW >100m from Airport/M1 203 45-47 Collingdon Street 0.04 - 14 - B1 Town NC 474m NE 945m E (Amenity) 222m W

Bury Park DC 468m N; Bute House Medical Integrated Dental Hillborough Infant and Dallow Primary 367m N Barnfield Skills Academy EM1 site 704m NW; CA1 Stockwood District Park Brantwood Park104m N 0.1% within Rothesay Rothesay Road Nursery Guardian Estate Amber Bert Collins Ct/Wolston Luton 912m NE 414m N Not ALC1/2/3 PDL >50m from AQMA, SPZ2 None within 3km Proposed development, 15-19 Downs TC 378m NE; Market Centre 174m NE Holdings 171m E Nursery 622m S 1429m NE 378m NE 889m S Cemetery (churchyards 231m E site 360m NW Cl 158m SW >100m from Airport/M1 205 0.16 - 13 - C3 Road Square, Farley NC 781m and Cemeteries) W Bury Park DC 517m N; Bute House Medical Integrated Dental Hillborough Infant and Dallow Primary 412m N Denbigh High 1484m N EM1 site 662m NW; CA1 Stockwood District Park Brantwood Park 175m Rothesay Cemetery Rothesay Road Nursery Guardian Estate Amber Bert Collins Ct/Wolston Luton 1002m NE 471m N Not ALC1/2/3 Not PDL >50m from AQMA, SPZ2 None within 3km TC465m NE; Market Centre 263m NE Holdings 251m NE Nursery 599m S 466m NE; 859m S NE (churchyards and 276m E site 361m N Cl 67m SW >100m from Airport/M1 206 Land r/o 31-37 Downs Road 0.26 - 14 - C3 Square, Farley NC 678m Cemeteries) adjacent W High Town NC 35m SE; Royal Pharmacy; Sharing Smiles 470m SW Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 904m SE Hightown Community Bell's Close 409m NE The Moor (Amenity Hart Hill Nursery 899m E Dudley Street Amber Elgar Path/North St Luton 135m S 128m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 90m S; Careways Ltd 214m E Nursery 1405m SW 356m NE 451m E Sports and Arts Centre Greenspace) 310m W Site adjacent 103m NW >100m from Airport/M1 207 41-43 Dudley Street 0.13 - 25 - car park 425m E

Bury Park DC 73m N; TC Lea Vale Medical Associated Dental Hillborough Infant and Dallow Primary 156m W Denbigh High 1064m N EM1 site 700m W; CA1 Hightown Community Brantwood Park 257m Brantwood Rothesay Road Nursery Upper George St Green Vestry Cl/Dallow Rd 10m Luton 593m E 22m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 25m E; High Town NC Practice 84m E Practice 168m SE Nursery 950m S 25m E Sports and Arts Centre SW Neighbourhood Park 440m S ELR site 249m SE S >100m from Airport/M1 208 13-31 Dunstable Road 0.25 - 124 - C3 614m NE 1085m E (Amenity) 65m SW

Bury Park DC 400m E; Medina 109m SW Beech Hill Dental Denbigh Infant 587m NE Maidenhall Primary 185m Denbigh High 949m E EM1 site 208m SW Hightown Community Kingsway Recreation Kingsway Rec Rothesay Road Nursery Commerce Park Green Lincoln Rd/Dunstable Rd Luton 1740m SE 365m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Wauluds Bank 2431m Biscot Rd/Blenheim Cres Practice 257m SE NW Sports and Arts Centre Ground 376m W Neighbourhood Park 1641m SE ELR site 293m W 2m SW >100m from Airport/M1 NW 209 326-340 Dunstable Road 0.23 - 24 - SG NC 653m NE 2078m E (Urban P and G) 295m W

High Town NC 653m N; Town Centre Surgery Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 322m E; EM2 Stockwood District Park Hibbert St 335m S St Mary's Church Rothesay Road Nursery Chapel St Green ELR site Crown Ct/Flowers Way Luton 543m N 88m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2667m E Land Opposite Whitbread House, Flower 100% within TC 98m NW Surgery 64m N Nursery 825m SW 429m SE 903m NE site 953m S 900m S (Churchyards and 623m W 329m NW 5.5m NE >100m from Airport/M1 210 0.44 - 202 - car park Way Cemeteries) 251m NE

Bury Park DC 321m N; Bute House Medical Integrated Dental Hillborough Infant and Dallow Primary 305m Barnfield Skills Academy EM1 site 798m NW; CA1 Stockwood District Park Brantwood Park 120m W Brantwood Rothesay Road Nursery Upper George St Green Liverpool Rd/Dunstable Luton 697m NE 265m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 2167m NE; High Centre 10m SW Holdings 38m SW Nursery 706m S NW 1213m NE site 167m NE 983m S Neighbourhood Park 195m S ELR site 196m E Rd 158m NE >100m from Airport/M1 212 1 Grove Road 0.12 - 21 - 2 Town NC 757m NE (Amenity) 48m W

High Town NC 254m N; Boots the Chemists Ltd Mr T J Maeer Dental Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 491m SE; Hightown Community Manor Road 692m SE St Mary's Church Hart Hill Nursery 723m E Power Court-Pondwicks Luton Bus Station/ Bute Luton 131m N 256m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2803m 100% within TC 185m S Surgery 321m S Nursery 1188m SW 621m N 503m NE Sports and Arts Centre (Churchyards and Red ELR site 110m E St 66.8m N >100m from Airport/M1 SE 213 33 Guildford Street 0.01 - 11 - D1 520m NE Cemeteries) 214m SE

High Town NC 251m N; Boots the Chemists Ltd Mr T J Maeer Dental Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 485m SE; Hightown Community Manor Road 686m SE St Mary's Church Hart Hill Nursery 728m E Power Court-Pondwicks Luton Centre Luton 131m N 8.9m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2798m 100% within TC 170m S Surgery 307m S Nursery 1172m SW 621m N 505m NE Sports and Arts Centre (Churchyards and Red ELR site 115m E Cheapside/ John St 62m >100m from Airport/M1 SE 214 35 Guildford Street 0.04 - 14 - C2 522m NE Cemeteries) 208m SE W

High Town NC 160m Royal Pharmacy; Mr T J Maeer Dental Crawley Green Infant St Matthews Primary Barnfield Skills Academy EM1 site 550m SE; CA1 Hightown Community Bell's Close 526m N Hitchin Rd/Pomfret Ave Hart Hill Nursery 511m E 99.6% within Gillam Midland Rd/Church St Luton 102m W 222m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2761m NW; TC 41m SW Careways Ltd 222m NW Surgery 605m SW 1058m E 340m N 195m NE site 41m SW Sports and Arts Centre (Natural and Semi- St/Burr St Amber ELR 60m S >100m from Airport/M1 SE 215 15 Hitchin Road 0.11 - 53 - B1 215m N Natural Greenspace) site 286m NE High Town NC 295m W; Boots the Chemists Ltd Mr T J Maeer Dental Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 449m SE Hightown Community Manor Road 650m SE St Mary's Church Hart Hill Nursery 720m E Power Court-Pondwicks Luton Centre Luton 164m W 45m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2765m TC 41m SW 153m SW Surgery 287m S Nursery 1168m SW 656m N 528m NE Sports and Arts Centre (Churchyards and Red ELR site 101m E Cheapside/ John St 83m >100m from Airport/M1 SE 218 39-51 John Street 0.03 - 58 - B2 548m NE Cemeteries) 171m SE W

Bury Park DC 132m E; TC Acorn Dispensing Jaspal Mandair Dental Foxdell Infant 1169m SE Beech Hill Primary 205m Denbigh High 850m NE EM1 site 104m W; CA1 Hightown Community Cohen's Yard 366m W Cohen's Rothesay Road Nursery Dallow Rd Green ELR Clifton Rd/Luton Town Luton 1022m E 13m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Luton Town Football Club, Kenilworth 511m SE; Biscot Chemist (PLC.) 176m NE 230m NE NW site 511m SE Sports and Arts Centre Yard/Shaftesbury Rd 838m SE site 30.5m W Football Club 139m W >100m from Airport/M1 220 1.5 - 75 - D2 Road Rd/Blenheim Cres 730m 1453m E (Amenity) 289m NW N High Town NC 595m N; Chemist Express Luton Dental Practice Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 614m E; 100% Stockwood District Park Windsor St 383m SW Rothesay Cemetery Rothesay Road Nursery Kings St Green ELR Luton Centre Regent Luton 500m N 116m SE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2971m E 100% within TC (distance selling) 26m NE 65m N Nursery 737m SW 714m SE 934m NE within CA1 site 933m S (Churchyards and 413m SE site11.2m NW Link/Chapel St 66m SE >100m from Airport/M1 221 Midland House, 41 King Street 0.09 - 27 - B1 Cemeteries) 401m W

High Town NC 800m N; Castle Street Surgery Mr T J Maeer Dental Hillborough Infant and Surrey St primary 277m Barnfield Skills Academy EM1 site 256m NE; EM2 Stockwood District Park Hibbert St 233m S Windmill Rd Island Rothesay Road Nursery Flowers Industrial Estate Latimer Rd/Holly St Luton 652m N 180m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2532m E TC 12.5m N 178m W Surgery 245m NW Nursery 875m W SE 996m N 814m S; 13m to CA1 site. 832m SW (Amenity) 209m S 783m W Green ELR site 12m S 101m S >100m from Airport/M1 222 Crescent House, 1-5 Latimer Road 0.17 - 80 - B2

Town Centre 729m N Medici 468m N Mr T J Maeer Dental Hillborough Infant and Tennyson Road Primary Barnfield Skills Academy EM1 site 521m SE; EM2 Stockwood District Park Memorial Park 376m S London Road Rothesay Road Nursery Telmere Industrial Estate Whitehill Ave/ London Luton 1357m N 92m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Someries Castle 2815m E Surgery 879m N Nursery 510m NW 159m NE 1715m N 521m SE; CA1 site 729m 114m S (Allotments and Leisure 868m NW Red ELR site 409m NE Rd 34m S >100m from Airport/M1 224 46 London Road 0.11 - 13 - C3 N Gardens) 113m S

High Town NC 167m NE; Lea Valley Medical Sharing Smiles 334m W Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 869m SE; 100% Hightown Community Bell's Close 660m NE The Moor (Amenity Rothesay Road Nursery 7.5% within Kimpton Rd Shuttle Link/Luton Luton 136m E 17m E Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 100% within TC Practice 334m W Nursery 1177m S 595m NE 639m E within CA1 site Sports and Arts Centre Greenspace) 227m NW 700m SW Green ELR site Station Interchange >100m from Airport/M1 229 Phoenix House, 2-4 Mill Street 0.08 - 38 - D1 625m NE 4.3m SW

Bury Park DC 682m NE; Whipperley Medical Integrated Dental Whipperley Infant 418m Dallow Primary 595m NE Denbigh High 1486m NE EM1 site 341m N; CA1 Stockwood District Park Farley Community Winsdon Hill (Natural Rothesay Road Nursery Dalroad Green ELR site Ferndale Luton 1385m N 505m N Not ALC1/2/3 PDL >50m from AQMA, SPZ2 None within 3km TC 818m E; Market Centre 345m SW Holdings 717m E SW site 818m E 1189m SE Centre 432m SW and Semi-natural 792m E 339m N Rd/Ashburnham Rd >100m from Airport/M1 230 30 Mulberry Close 0.14 - 24 - B8 Square Farley NC 407m Greenspace) adjacent to 123m NW SW S Marsh Road DC 968m N Lister House Surgery Leagrave Dental St Josephs Infant 995m Downside Primary 355m Challney High School for EM1 site 193m S Lewsey Sports Park Morgan Close 594m NW Chaul End Lane Gill Blowers Nursery - Chaul End Amber ELR Newbury Cl/Oakley Rd Leagrave Rd 1211m N 658m S Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 1502m N 291m SE Sedation Clinic 465m W NE S Boys 778m W 2017m W Neighbourhood Park Mossdale Site 1680m site 329m S 56m SW >100m from Airport/M1 232 Land r/o 34-46 Oakley Road 0.43 - 14 - B1 (Amenity) 207m S NW

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 3 / 12 SEA Objectives C25 Impact on Listed C26 Impact on historic C27 Impact on C28 Impact on AONB C29 Impact on SSSI C30 Impact on AGLV C31 Impact on ALLI C32 Impact on Green C33 Impact on LNR C34 Impact on CWS C35 Impact on other C36 Impact on open C37 Impact on C38 Impact on Lea C39 Impact on Flood SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Building P&G Conservation Area Belt SNCI space allotment tributaries Zone Summerhouse at Wardown Park (GII) 458m High Town 1380m S 565m N Galley and Warden Hills None within 3km Hart Hill 1530m S 251m N Galley and Warden Hills Honeygate and Crick Mixes Hill DWS adjacent The Chase/Mixes Hill Stockingstone Rd 424m ENV 20 629m W Not FZ2/3 Wardown Park (GII) 645m W 1968m NW 1968m NW Hills CWS adjacent Wood (Natural and Semi- S - 0 +/- 0 0 + 0 + 0 + ++ 0 - +/- 69 Felstead Way (4) 182 SW natural Green Space) 111m NE 27 and 29 Park Street Luton Hoo (GII) 1032m Town Centre 237m NW None within 3km None within 3km 1327m W Hart Hill 720m NE 1032m SE None within 3km River Lea CWS 413m NE River Lea DWS 430m NE Windmill Road Island Gypsy Ln Allotments ENV 20 413m NE Not FZ2/3 West (GII) 169m NW SE 220m SW Windmill Road 636m E 0 0 +/- 0 0 + 0 + 0 ++ ++ 0 ++ + 12 Albert Road 183

50 Guildford St (GII) Wardown Park (GII) 687m High Town 106m E 2425m N None within 3km 1098m SW Hart Hill 527m E 1926m SE None within 3km River Lea CWS 285.6m W River Lea DWS 100m W The Moor (Amenity) Harthill Ln Allotments ENV 20 221m W Not FZ2/3 172m S NW 282m W 858m E 0 0 +/- 0 0 + 0 + 0 + ++ 0 ++ +/- 142-144 Midland Road 188

53 Cheapside (GII) 132m Wardown Park (GII) 100% within Plaiters Lea 2778m N None within 3km 1228m W Hart Hill 337m NE 1448m SE None within 3km River Lea CWS 403m SE River Lea DWS 53m W St Mary's Church Harthill Ln Allotments ENV 14 401m SE Not FZ2/3 NW 1176m NW (Churchyards and 597m NE 0 0 +/- 0 0 + - + 0 +/- ++ 0 ++ + 4-6 Melson Street 189 Cemeteries) 112m SE

53 Cheapside (GII) Wardown Park (GII) 866m 64.7% within Plaiters Lea 2629m N None within 3km 1011m W Hart Hill 386m NE 1486m SE None within 3km River Lea CWS 290m NW 0.2% of site is part of St Mary's Church Harthill Ln Allotments ENV 20 321m NW Not FZ2/3 Within site NW River Lea DWS (Churchyards and 681m E Extension to Mall, Arndale Centre, - 0 +/- 0 0 + - + 0 +/- ++ 0 ++ + 190 Cemeteries) 170m SE Northern Gateway

Vauxhall Motors Kimpton Luton Hoo (GII) 300m S Plaiters Lea 811m NW 2909m N None within 3km 938m E Hart Hill 330m NW 189m S None within 3km Church Cemetery, Luton Luton Parkway Verges Crawley Green Road Gypsy Ln Allotments ENV 20 244m W Not FZ2/3 Road 18.6m N CWS 3.4m NW DWS 113m S Cemetery (Churchyards Windmill Road 149m SW Napier Park, Vauxhall Motors, Kimpton +/- +/- 0 0 0 + 0 + 0 + ++ 0 ++ +/- 191 and Cemeteries) 3.4m Road NW Church of St Luke (GII) None within 3km None within 3km 1422m S Blow's Down 2030m SW 2105m SE None within 3km 1271m S Leagrave Common & River Lea CWS 455m NW River Lea DWS 441m NW Addington Way 75m S Ravenhill Way 883m NW ENV 20 459m NW Not FZ2/3 194m N Wauluds Bank Proposed (Amenity) Capwell Grange Nursing Home, 0 0 +/- 0 0 + 0 + 0 +/- ++ 0 + + 192 LNR 921m NE Addington Way

Leagrave High St Church Wardown Park (GII) None within 3km 2225m SW Galley and Warden Hills 2401m S None within 3km 1937m SW Leagrave Common & River Lea CWS 335m NE River Lea DWS 309m NE Limbury Riverside Park Limbury 368m NE ENV 20 340m NE Not FZ2/3 of St Luke (GII) 832m W; 2381m E 2636m NE Wauluds Bank Proposed (Natural and Semi- 0 0 0 0 0 + 0 + 0 - + 0 ++ + Marlborough Works, Archway Road 193 57 Compton Ave (GII) LNR 490m NW; Galley Natural) 309m NE 638m W and Warden Hills 2636m Church of St Andrew Wardown Park (GII) Rothesay 1652m SE 1749m W Blow's Down 2924m W 1025m S Hart Hill 2749m E 1184m SW 'Leagrave Common & Dallow Downs CWS Hatter's Way DWS 872m Kingswood Rec Bradley Rd Allotments ENV 20 1552m N Not FZ2/3 (GII)1232m E 1700m E Wauluds Bank Proposed 1024m S SW Neighbourhood Park 1080m W 0 0 +/- 0 0 + 0 + 0 +/- + 0 +/- + 4-8 Arundel Road 194 LNR 1873m NW (Urban P and G) 88m S

The Painters Arms (GII) Wardown Park (GII) 829m High Town 25m NW 2317m N None within 3km 1200m N Hart Hill 205m SE 1819m SE None within 3km People's Park CWS 474m Hitchin Road Spinney Hitchin Rd/Pomfret Ave Harthill Lane Allotments ENV 20 607m W Not FZ2/3 56m NW NW N DWS 228m E (Natural and Semi- 518m SE 0 0 +/- 0 0 + +/- + 0 + ++ 0 ++ + Car park, Brunswick Street 195 Natural Greenspace) 235m E Central Block St Mary's Wardown Park (GII) Rothesay 53m SW 2703m W None within 3km 473m W Stockwood Park 946m S 1443m SW None within 3km Dallow Downs CWS River Lea DWS 511m NE Brantwood N'hood Park Ferndale Allotments ENV 14 555m NE Not FZ2/3 Hospital 151m N 1081m N 473m W (Amenity) 105m W 917m W 0 0 +/- 0 0 + 0 + 0 ++ ++ 0 ++ + 14 Cardiff Road 197

The Painters Arms (GII) Luton Hoo 1255m SE Luton South 157m SW 2994m W None within 3km 926m W Stockwood Park 613m S 1263m SE None within 3km River Lea CWS 769m NE Stockwood Park DWS North Drift Way London Road 613m S ENV 20 769m NE Not FZ2/3 56m NW 613m S (Amenity) 170m W 0 0 +/- 0 0 + 0 + 0 ++ + 0 + + R/o 66-76 Castle Street 198

Baptist Union Church Luton Hoo 1325m SE Town Centre 75m NE None within 3km None within 3km 949m W Stockwood Park 768m S 1331m SE None within 3km River Lea CWS 697m E River Lea DWS 464m N North Drift Way London Road 768m S ENV 20 697m E Not FZ2/3 (GII) 97m E (Amenity) 245m SW 0 0 +/- 0 0 + 0 + 0 ++ ++ 0 ++ + 27-37 Chapel Street 199

George St West (GII) Luton Hoo 1396m SE Town Centre 73m NE None within 3km None within 3km 938m W Stockwood Park 801m S 1401m SE None within 3km River Lea CWS 736m E River Lea DWS 458m N North Drift Way London Road 801m S ENV 20 736m E Not FZ2/3 120m N (Amenity) 255m SW 0 0 +/- 0 0 + 0 + 0 ++ + 0 ++ + 62-64 Chapel Street 200

Baptist Union Church Luton Hoo 1356m SE Town Centre 51m NE None within 3km None within 3km 959m W Stockwood Park 795m S 1361m SE None within 3km River Lea CWS 690m E River Lea DWS 441m N North Drift Way London Road 795m S ENV 20 690m E Not FZ2/3 (GII) 92m SE (Amenity) 271m SW 0 0 +/- 0 0 + 0 + 0 ++ + 0 ++ + Development site, 21-25 Chapel Street 201

53 Cheapside (GII) 10m Wardown Park (GII) 100% within Plaiters Lea 2750m N None within 3km 1126m W Hart Hill 431m NE 1560m SE None within 3km River Lea CWS 559m SE River Lea DWS 15m NW St Mary's Church Harthill Ln Allotments ENV 20 523m NW Not FZ2/3 NE 1059m NW (Churchyards and 724m E 0 0 +/- 0 0 + - + 0 +/- ++ 0 ++ + 37-47 Cheapside 202 Cemeteries) 256m SE

Central Block St Mary's Wardown Park (GII) 781m Town Centre 163m SE 2711m N None within 3km 666m SW Hart Hill 938m E 1793m SW None within 3km River Lea CWS 265m N River Lea DWS 210m NE Brantwood N'hood Park Ferndale Allotments ENV 14 246m NE Not FZ2/3 Hospital 121m SW N (Amenity) 222m W 995m W 0 0 +/- 0 0 + 0 + 0 + + 0 ++ + 45-47 Collingdon Street 203

Central Block St Mary's Wardown Park (GII) 100% within Rothesay None within 3km None within 3km 222m W Stockwood Park 875m S 2880m NE None within 3km Dallow Downs CWS River Lea DWS 728m NE 0.1% within Rothesay Ferndale Allotments ENV 14 761m NE Not FZ2/3 Hospital 333m NE 1235m N 222m W Cemetery (Churchyards 703m W Proposed development, 15-19 Downs +/- 0 +/- 0 0 + - + 0 ++ + 0 +/- + 205 and Cemeteries) Road

Central Block St Mary's Wardown Park (GII) 99.5% within Rothesay 2330m W None within 3km 122m W Stockwood Park 847m S 1075m SW None within 3km Dallow Downs CWS River Lea DWS 811m NE Adj Rothesay Cemetery Ferndale Allotments ENV 14 841 NE Not FZ2/3 Hospital 443m NE 1299m N 131m W (Churchyards and 629m NW +/- +/- - 0 0 +/- - + 0 + + 0 +/- + Land r/o 31-37 Downs Road 206 Cemeteries)

High Town Methodist Wardown Park (GII) 627m High Town 107m SE 2312m N None within 3km 1179m SW Hart Hill 493m E 1986m SE None within 3km River Lea CWS 310m W River Lea DWS 194m SW The Moor (Amenity Harthill Ln Allotments ENV 20 260m W Not FZ2/3 Church (GII) 174.5m E NW Greenspace) 310m W 824m E 0 0 +/- 0 0 + 0 + 0 - ++ 0 + + 41-43 Dudley Street 207

Central Block St Mary's Wardown Park (GII) 825m Rothesay 54m SW 2755m SW None within 3km 501m SW Hart Hill 1067m E 1553m SW None within 3km River Lea CWS 371m NE River Lea DWS 327m NE Brantwood N'hood Park Ferndale Allotments ENV 14 367m NE Not FZ2/3 Hospital 18.4m SE N (Amenity) 65m SW 810m W 0 0 +/- 0 0 + 0 + 0 + ++ 0 ++ + 13-31 Dunstable Road 208

Church of St Andrew Wardown Park (GII) Rothesay 1137m SE 2060m W None within 3km 667m S Hart Hill 2185m E 1320m SW Leagrave Common & Dallow Downs CWS River Lea DWS 1148m E Kingsway Rec Ferndale Allotments ENV 20 1179m E Not FZ2/3 (GII) 829.5m NE 1202m E Wauluds Bank Proposed 667m S Neighbourhood Park 748m S 0 0 - 0 0 + 0 + 0 - ++ 0 + + 326-340 Dunstable Road 209 LNR 667m S (Urban P and G) 295m W

Castle St Red Lion Luton Hoo (GII) 1232m Town Centre 10.2m W None within 3km None within 3km 1101m W Hart Hill 669m NE 1233m SE None within 3km River Lea CWS 474m E River Lea DWS 340m N St Mary's Church Gypsy Lane Allotments ENV 20 474m E Not FZ2/3 Hotel/Brookes 22.9m N; SE (Churchyards and Windmill Road 807m E Land Opposite Whitbread House, Flower 0 0 +/- 0 0 + +/- + 0 ++ ++ 0 ++ + 210 27 and 29 Park St West Cemeteries) 251m NE Way (GII) 30m N Central Block St Mary's Wardown Park (GII) Rothesay 30m W 2663m W None within 3km 427m W Stockwood Park 965m S 1415m SW None within 3km Dallow Downs CWS River Lea DWS 523m NE Brantwood N'hood Park Ferndale Allotments ENV 14 562m NE Not FZ2/3 Hospital 137.8m N 1068m E 427m W (Amenity) 48m W 859m W 0 0 +/- 0 0 + 0 + 0 ++ ++ 0 ++ + 1 Grove Road 212

George II Public House Wardown Park (GII) 100% within Plaiters Lea 2695m N None within 3km 1253m W Hart Hill 334m NE 1552m SE None within 3km River Lea CWS 499m SE River Lea DWS 9m S St Mary's Church Harthill Ln Allotments ENV 14 496m SE Not FZ2/3 (GII) 67.8m NW; 53 1073m NW (Churchyards and 629m E +/- 0 +/- 0 0 + - + 0 - + 0 ++ + 33 Guildford Street 213 Cheapside (GII) 74m W Cemeteries) 215m SE

53 Cheapside (GII) 56m Wardown Park (GII) 100% within Plaiters Lea 2695m N None within 3km 1239m W Hart Hill 338m NE 1544m SE None within 3km River Lea CWS 495m SE 0.1% within River Lea St Mary's Church Harthill Ln Allotments ENV 14 491m SE 4.2% of site within FZ2; W 1066m NW DWS (Churchyards and 635m E 3.8% within FZ3 +/- 0 +/- - 0 + - + 0 - + 0 ++ + 35 Guildford Street 214 Cemeteries) 208m SE

Gates, Dwarf Wall and Wardown Park (GII) 992m High Town 173m NW 2429m N None within 3km 1409m W Hart Hill 100m E 1655m SE None within 3km River Lea CWS 549m SE River Lea DWS 234m S Hitchin Rd/Pomfret Ave Harthill Ln Allotments ENV 14 541m SE Not FZ2/3 Railings to High Town NW (Natural and Semi- 431m E 0 0 +/- 0 0 + 0 + 0 - ++ 0 ++ +/- 15 Hitchin Road 215 Methodist Church 208m Natural Greenspace) NW 286m NE 53 Cheapside (GII) 79m Wardown Park (GII) 100% within Plaiters Lea 2733m N None within 3km 1259m W Hart Hill 340m NE 1507m SE None within 3km River Lea CWS 459m SE River Lea DWS 3m N St Mary's Church Harthill Ln Allotments ENV 14 457m SE 16% of site is FZ2 W 1111m NW (Churchyards and 625m E +/- 0 +/- - 0 + - + 0 - ++ 0 ++ + 39-51 John Street 218 Cemeteries) 171m SE

Dunstable Road Former Wardown Park (GII) 838m Rothesay 365m SE 2352m SW None within 3km 332m SW Hart Hill 1501m E 1275m SW None within 3km Dallow Downs CWS River Lea DWS 561m E St Peter's Park (Amenity) Ferndale Allotments ENV 20 639m E Not FZ2/3 Bingo Hall (GII) 208m E NW 336m SW 210m SW 332m W Luton Town Football Club, Kenilworth 0 0 - 0 0 + 0 + 0 - ++ 0 + + 220 Road

39 King's St (GII) within Wardown Park (GII) 100% within Town Centre None within 3km None within 3km 884m W Hart Hill 757m NE 1527m SE None within 3km River Lea CWS 697m N River Lea DWS 302m NE North Drift Way London Rod 947m S ENV 20 642m N Not FZ2/3 site 1224m N (Amenity) 346m SW 0 0 +/- 0 0 + - + 0 + ++ 0 ++ + Midland House, 41 King Street 221

27 and 29 Park Street Luton Hoo (GII) 1079m Town Centre 178m NW None within 3km None within 3km 1258m W Hart Hill 729m NE 1080m SE None within 3km River Lea CWS 440m NE River Lea DWS 467m E Windmill Rd Island Gypsy Lane Allotments ENV 20 440m NE Not FZ2/3 West (GII) 122m N SE (Amenity) 209m S Windmill Road 684m E 0 0 +/- 0 0 + 0 + 0 + ++ 0 ++ + Crescent House, 1-5 Latimer Road 222

Whitehill Durler Gardens Luton Hoo (GII) 1054m 0.4% within Luton South 2926m W None within 3km 1188m NW Stockwood Park 113m S 863m S None within 3km Stockwood Park CWS Stockwood Park DWS Stockwood District Park London Rd (Allotments ENV 20 1008m NE Not FZ2/3 (GII) 149m NW SE 523m S 114m S (Major sports and Leisure and Leisure Gardens) 0 0 +/- 0 0 + - + 0 +/- + 0 +/- + 46 London Road 224 site) 114m S 113m S

7 New Bedford Road Wardown Park (GII) 731m Town Centre 163m S 2549m N None within 3km 966m SW Hart Hill 620m E 1908m SE None within 3km River Lea CWS 240m NW River Lea DWS 11m N The Moor (Amenity Harthill Ln Allotments ENV 20 170m NW 100% of site within FZ2; (GII) 108m S N Greenspace) 227m NW 939m E 12.6% within FZ3 0 0 +/- -- 0 + 0 + 0 + ++ 0 ++ +/- Phoenix House, 2-4 Mill Street 229

Dunstable Road Former Wardown Park (GII) Rothesay 237m E 1973m SW None within 3km Adjacent to site Stockwood Park 1189m 795m SW None within 3km Adjacent to Dallow River Lea DWS 1046m 'Winsdon Hill (Natural Ferndale Allotments ENV 20 1121m NE Not FZ2/3 Bingo Hall (GII) 717m NE 1425m NE SE Downs CWS NE and Semi-natural 157m NW - +/- +/- 0 0 + 0 + 0 +/- ++ 0 +/- + 30 Mulberry Close 230 Greenspace) adjacent to S Leagrave High St Church Wardown Park (GII) Rothesay 2230m SE 1287m SW Blow's Down 2340m W 1281m S None within 3km 944m SW Leagrave Common and Dunstable to Luton Hatter's Way DWS 660m Chaul End Lane Bradley Road Allotments ENV 20 1376m N Not FZ2/3 of St Luke (GII) 1094m 2304m E Wauluds bank Proposed disused railway CWS S Neighbourhood Park 598m SW 0 0 +/- 0 0 + 0 + 0 - + 0 +/- + Land r/o 34-46 Oakley Road 232 NW; 57 Compton Ave LNR 1444m N 958m SW (Amenity Greenspace) (GII) 1062m NW 207m S

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 4 / 12 Luton Possible Allocations Site Assessment Criteria (as amended) C1 Dist to centres C2 Dist to health C3 Dist to dental C4 Distance to infant C5 Dist to junior C6 Dist to 2ary C7 Dist to emp C8 Dist to sports C9 Dist to play C10 Dist to open space C15 Dist crèche C16 Loss of emp C17 Dist to bus C18 Dist to train C19 Dist to cycle C20 Loss of agric C21 Use of PDL C22 Dist to AP source C23 Impact on SPZ C24 Impact on SAM

High Town NC 32m E; Royal Pharmacy; Sharing Smiles 367m SW Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 886m SE; CA1 Hightown Community Bell's Close 518m NE The Moor (Amenity Rothesay Road Nursery Adjacent to Midland Rd Villa Rd/Old Bedford Rd Luton 99m SE 20m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 16m SW Careways Ltd 299m NE Nursery 1305m SW 457m NE 525m E site 16m SW Sports and Arts Centre Greenspace) 246m W 831m SW Amber ELR site 0.4m W >100m from Airport/M1 233 6-14 Old Bedford Road 0.09 - 37 - B1 505m E

High Town NC 97m E; Royal Pharmacy; Sharing Smiles 357m S Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 925m SE; CA1 Hightown Community Bell's Close 552m NE The Moor (Amenity Rothesay Road Nursery Midland Rd Amber ELR Villa Rd/Old Bedford Rd Luton 140m SE 11m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 4m N Careways Ltd 360m E Nursery 1296m S 505m NE 590m E site 4m S Sports and Arts Centre Greenspace) 222m W 817m SW site 42m E 10m E >100m from Airport/M1 235 7A Old Bedford Road 0.03 - 14 - B2 569m E

High Town NC 798m E; Castle Street Surgery Mr T J Maeer Dental Hillborough Infant and Surrey St Primary 339m Barnfield Skills Academy EM1 site 336m E; EM2 Stockwood District Park Hibbert St 234m S Windmill Rd Island Rothesay Road Nursery Holly Street Green ELR Latimer Rd/Holly St 98m Luton 672m N 223m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2622m E TC 48m NE 110m W Surgery 216m N Nursery 816m SW SE 1021m N site 852m SE; CA1 site 815m SW (Amenity) 200m S 710m SW site 27m SW S >100m from Airport/M1 237 9-15 Oxford Road 0.06 - 12 - A1 48m NE

High Town NC 627m N; Boots the Chemists Ltd Mr T J Maeer Dental Hillborough Infant and Surrey St Primary 452m S Barnfield Skills Academy EM1 site 203m E;100% Hightown Community Hibbert Street 442m S St Mary's Church Hart Hill Nursery 816m Cumberland Street Park Square/University of Luton 464m N 12m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2567m E 100% within TC 220m S Surgery 179m W Nursery 1026m SW 806m N within CA1 site Sports and Arts Centre (Churchyards and NE Green ELR site 110m SE Bedfordshire 17m NE >100m from Airport/M1 238 42-44 Park Street 0.02 - 17 - SG 836m N Cemeteries) 113m NE

Bury Park DC 607m N; Kamson's Pharmacy Luton Dental Centre Hillborough Infant and Hillborough Junior 522m Barnfield Skills Academy EM1 site 824m E; CA1 Stockwood District Park Windsor St 208m S Rothesay Cemetery Rothesay Road Nursery Kings St Green ELR site Princess St/Dumfries St Luton 707m NE 248m SE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 177m NE 264m SE 294m NE Nursery 528m SW SW 1174m NE site 177m NE 765m S (Churchyards and 186m W 236m NE 45m S >100m from Airport/M1 240 51-55 Princess Street 0.06 - 12 - C3 Cemeteries) 159m W

High Town NC 316m Dr I Saleh's Practice Vogue Dental Care Crawley Green Infant St Matthews Primary Barnfield Skills Academy CA1 site 647m S Hightown Community Bells Close 258m W People's Park 35m W Hart Hill Nursery 772m Oxen Road Estate Kingston Rd 43m N Luton 661m S 858m W Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km SW; TC 647m S 405m SW 1059m E 1151m SE 268m SW 399m S Sports and Arts Centre SE Amber ELR site 151m SE >100m from Airport/M1 241 43 Ridgway Road 0.22 - 18 - B8 355m S

High Town NC 745m Boots the Chemists Ltd Mr T J Maeer Dental Crawley Green Infant Surrey St Primary 589m Barnfield Skills Academy 0.1% within EM1 site; Hightown Community Manor Road 148m S Windmill Rd Island Hart Hill Nursery 483m Windmill Trading Thistle Rd/Windmill Rd Luton 521m NW 301m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Someries Castle 2209m NW; TC 37m NW 555m W Surgery 580m W 862m NE SW 729m N KR1 site 602m E; CA1 Sports and Arts Centre (Amenity) 29m W NE Estate/Thistle Rd Green 116m SE >100m from Airport/M1 SE 245 7 Windmill Road 0.08 - 10 - C3 site 37m NW 773m N ELR site 16m SE

High Town NC 294m N; Boots the Chemists Ltd Mr T J Maeer Dental Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 482m SE; 100% Hightown Community Manor Road 687m SE St Mary's Church Hart Hill Nursery 773m E Guildford Street Green Luton Centre Luton 181m N 54m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2806m 100% within TC 124m S Surgery 261m S Nursery 1124m SW 669m N 560m NE within CA1 site Sports and Arts Centre (Churchyards and ELR site 129m NW Cheapside/John Street >100m from Airport/M1 SE 246 15-19 John Street 0.05 - 19 - C3 576m NE Cemeteries) 203m SE 27m W

Marsh Rd DC 1182m N; Lister House Surgery Leagrave Dental Foxdell Infant 1131m SE Downside Primary 184m Challney High School for EM1 site 80m E Lewsey Sports Park Addington Way 1 734m Chaul End Lane Gill Blower's Nursery - Chaul End Amber ELR Oakley Rd/PC World Leagrave 1419m N 480m S Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank1710m N Biscot Rd/Blenheim Cres 272m E Sedation Clinic 461m W SW Boys 831m W '2091m NW NW Neighbourhood Park Mossdale Site 1846m site 153m S 43m W >100m from Airport/M1 248 566-568 Dunstable Road 0.16 - 10 - C2 1671m E (Amenity) 30m S NW

High Town NC 103m SE; Dr I Saleh's Practice Sharing Smiles 496m SW Hillborough Infant and St Matthews Primary Barnfield Skills EM1 site 977m SE; CA1 Hightown Community Bells Close 393m NE The Moor (Amenity Rothesay Road Nursery 97.3% within Dudley Rd Elgar Path/North St 12m Luton 199m SE 148m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Proposed Development, 20/20A North TC 142m SW 247m E Nursery 1434m SW 365m NE Academy494m E site 142m SW Sports and Arts Centre Greenspace) 274m W 956m SW Amber ELR site NW >100m from Airport/M1 250 0.17 - 52 - B2 Street and 61-67 Dudley Street 463m E

High Town NC 672m N; Boots the Chemists Ltd Mr T J Maeer Dental Hillborough Infant and Surrey St Primary 393m S Barnfield Skills Academy EM1 site 159m E; EM2 Hightown Community Hibbert St 388m S St Mary's Church Hart Hill Nursery 808m Cumberland Street Central Baptist Luton 497m N 11m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2522m E 0.05 - 15 - vacant car 100% within TC 268m NW Surgery 204m NW Nursery 1001m SW 831m N site 944m S; KR1 site Sports and Arts Centre (Churchyards and NE Green ELR site 62m SE Church/Cumberland St >100m from Airport/M1 295 R/o 46-52 Park Street park 974m E; 100% within CA1 863m N Cemeteries) 112m NE 44m SE

High Town NC 264m N; Superdrug Stores 158m Luton Dental Centre Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 614m SE; 100% Hightown Community Windsor St 733m SW St Mary's Church Rothesay Road Nursery Guildford St Green ELR Silver St/Arndale Centre Luton 166m N 44m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2941m 100% within TC S 245m SW Nursery 1084m SW 664m NE 607m NE within CA1 site Sports and Arts Centre (Churchyards and 683m SW site 48m NE 30m SW >100m from Airport/M1 SE 298 47-53 Bute Street 0.09 - 12 - D2 614m NE Cemeteries) 338m SE

Bury Park DC 290m SW; Blenheim MC 178m N Jaspal Mandair Dental Denbigh Infant 583m Beech Hill Primary 555m Denbigh High 189m E EM1 site 289m W; CA1 Hightown Community Wardown Park 592m E Wardown Park (Urban P Rothesay Road Nursery Britannia Estate Green Dorrington Close/Biscot Leagrave 1201m SE 443m E Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Waulud's Bank 2786m TC 891m SE; Biscot Surgery 519m S NW SW site 890m SE Sports and Arts Centre and G) 451m E 1472m S ELR site 289m W Rd 32m S >100m from Airport/M1 NW 300 Chaucer House, 134 Biscot Road 0.14 - 14 - B1 Rd/Blenheim Cres NC 1417m SE 81m NW Bury Park DC 382m N TC Cardiff Road Surgery Associated Dental Hillborough Infant and Dallow Primary 460m Barnfield Skills Academy EM1 site 933m E; CA1 Stockwood District Park Brantwood Park 287m W Rothesay Cemetery Rothesay Road Nursery Upper George St Green Dunstable Place/Stuart Luton 596m NE 331m E Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 75m NE; High Town NC 61m NW Practice 115m NW Nursery 683m S NW 1102m NE site 75m NE 946m S (Churchyards and 191m SW ELR site 87m NE St 123m E >100m from Airport/M1 301 18-22 Rothesay Road 0.10 - 14 - C3 678m NE Cemeteries) 176m SW

Marsh Road DC 927m W; Bishopscote Dispensing Leagrave Dental Practice William Austin infant Icknield Primary 384m Icknield High 741m NE EM1 site 800m SW; Stopsley Common Solway Road 358m SW Nunnery Lane 154m NE Grasmere Children's Leagrave Road Amber African Caribbean Leagrave 1469m SE 86m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1412m Birdsfoot Lane South NC Chemist 481m S 829m W 540m E NE 2043m NE Centre 1653m N ELR site 808m SW Centre/Trinity Rd 20m S >100m from Airport/M1 NW 302 18 Trinity Road 0.20 - 11 - C3 530m N

Bury Park DC481m N TC Cardiff Road Surgery Integrated Dental Hillborough Infant and Hillborough Junior 542m Barnfield Skills Academy EM1 site 902m E; CA1 Stockwood District Park Windsor St 299m S Rothesay Cemetery Rothesay Road Nursery Upper George St Green Princess St/Dumfries St Luton 650m NE 349m SE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 133m NE; High Town 148m NW Holdings 182m NW Nursery 559m S S 1147m NE site 133m NE 820m S (Churchyards and 95m SW ELR site 165m N 140m S >100m from Airport/M1 303 Car park adj 69 Adelaide Street 0.13 - 11 - C3 NC 737m NE Cemeteries) 99m SW

High Town NC 785m Boots the Chemists Ltd Mr T J Maeer Dental Hillborough Infant and Surrey St Primary 325m S Barnfield Skills Academy EM1 site 4.9m NE; EM2 Hightown Community Manor Rd 231m E Manor Rd N'hd Park Hart Hill Nursery751m Gloucester Rd/Bolton Rd Presentation Ct/Manor Luton 579m N 7m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2334m E NW; TC 35m NW 441m NW Surgery 394m NW Nursery 1140m W 879m N site 869m S; KR1 site Sports and Arts Centre (Urban P&G) 66m SE NE Green ELR site 17m NE Rd 64m SE >100m from Airport/M1 304 89-93 Park Street 0.08 - 13 - A1 799m E; CA1 site 35m 917m N NW High Town NC 573m Boots the Chemists Ltd Mr T J Maeer Dental Crawley Green Infant Wenlock Junior (C of E) Barnfield Skills Academy EM1 site 149m S; KR1 Hightown Community Manor Road 405m S Harthill Ln Allotments Hart Hill Nursery 180m 96.7% within Crescent Rd Auction House/Crescent Luton 390m W 368m W Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Someries Castle 2257m NW; TC 121m SW 631m W Surgery 717m SW 635m E 591m E 463m NW site 622m SE; CA1 site Sports and Arts Centre (Allotments and Leisure NE Green ELR site Rd 32m S >100m from Airport/M1 SE 305 34-38 Crescent Road 0.57 - 74 - B1 121m SW 509m NW Gdns) 93m NE

High Town NC 10m NW; Royal Pharmacy; Sharing Smiles 420m SW Hillborough Infant and St Matthews Primary Barnfield Skills Academy EM1 site 826m SE; CA1 Hightown Community Bell's Close 497m NE The Moor (Amenity Hart Hill Nursery 876m E 99.6% within Dudley St Rail Station Luton 55m S 98m W Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 14m S Careways Ltd 241m NE Nursery 1347m SW 412m NE 459m E site 14m S Sports and Arts Centre Greenspace) 340m W Amber ELR site Entrance/Midland Rd >100m from Airport/M1 306 1 Dudley Street 0.03 - 10 - B2 442m E 67m SE

Bury Park DC 401m N; Cardiff Road Surgery Associated Dental Hillborough Infant and Dallow Primary 461m Barnfield Skills Academy EM1 site 950m E; CA1 Stockwood District Park Brantwood Park 281m W Rothesay Cemetery Rothesay Road Nursery Upper George St Green Dunstable Place 148m E Luton 626m NE 359m E Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 104m NE 63m NW Practice129m N Nursery 674m S NW 1131m NE site 104m NE 938m S (Churchyards and 177m SW ELR site 116m NE >100m from Airport/M1 307 GT House, 24-26 Rothesay Road 0.04 - 12 - B1 Cemeteries) 163m SW

Sundon Park NC 985m Khanchandani and Hockwell Surgery 561m E The Ferrars Academy Pirton Hill Primary 226m Challney High School for EM1 site 480m N Lewsey Sports Park 623m Mayne Avenue 543m E 67.4% within Ickley Close Gill Blower's Nursery - Sedgewick Butley Rd/opp Liston Cl Leagrave 1281m E 0.8m N 100% is ALC2 Not PDL 3% of site is within 100m SPZ2 Waulud's Bank 1279m 2.90 - 56 - D2/open NE Partners _ Hockwell Ring 868m S NE Girls 941m SE SW OS; Spider Park Mossdale Site 575m E Road/Progress Way 44m E of M1 NE 309 Open space at Ickley Close space 324m E (Amenity) 74m E Green ELR site 1481m N

Marsh Road DC 1468m Luton and Dunstable Leagrave Dental The Ferrars Academy Barnfield Moorlands Challney High School for EM1 site 583m NE Lewsey Sports Park 973m Addington Way (2) 379m 98.9% within Farringdon Gill Blower's Nursery - Craddock Road Green Luton and Dunstable Leagrave 1320m NE 638m NW Not ALC1/2/3 Not PDL 0.2% of site is within 50m SPZ3 Waulud's Bank 1551m NE; Hockwell Ring Hospital 220m SW Sedation Clinic 582m E 589m W Primary 473m N Boys 234mm E NW NE Rd (Amenity); Addington Mossdale Site 1208m N ELR site 714m SW Hospital 222m W of AQMA NE 310 Potential site east of Farringdon Road 0.6 - 30 - open space (FUTURE SITE) NC 983m Way Sports Field N (Amenity) 200m N High Town NC 498m N; Chemist Express Luton Dental Practice Hillborough Infant and Surrey St Primary 738m Barnfield Skills Academy EM1 site 577m E; 100% Hightown Community Windsor St 507m SW St Mary's Church Rothesay Road Nursery King St Green ELR Site Luton Centre Upper Luton 403m N 34.4m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2940m 100% within TC (distance selling) 57m 29m W Nursery 861m SW SE 830m NE within CA1 site Sports and Arts Centre (Churchyards and 508m W 79m SW George St 110m NW >100m from Airport/M1 SE 319 7-11 King Street 0.05 - 14 - B2 SW 842m NE Cemeteries) 370m E

High Town NC 71m SE; Dr I Saleh's Practice Sharing Smiles 721m SW Crawley Green Infant St Matthews Primary Barnfield Skills Academy CA1 site 312m S Hightown Community Bells Close 140m NE People's Park61m NE Hart Hill Nursery 867m Dudley Street Amber St Matthews Primary Luton 348m S 376m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 312m S 130m SE 1368m E 145m E 375m SE Sports and Arts Centre SE Site 190m SW School 72m NE >100m from Airport/M1 320 111 North Street 0.16 - 14 - B1 328m SE

Bury Park DC 881m SE; Woodland Ave Surgery Marsh Rd Dental Practice Denbigh Infant534m E Maidenhall Primary 389m Denbigh High 1233m E EM1 site 12m N Hightown Community Blundell Rd 367m N Blundell Rd Rec Gill Blower's Nursery - Selbourne Rd Green ELR Selbourne Rd/Wingate Leagrave 1559m NW 845m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1787m 437m E 686m NW S Sports and Arts Centre (Amenity) 292m N Mossdale Site 2228m N site 51m NE Rd within site >100m from Airport/M1 NW 321 Petrol Station, 116-124 Wingate Road 0.32 - 13 - SG 2527m SE

Marsh Road DC 36m NE; Leagrave Surgery 296m Leagrave Dental Practice St Josephs Infant 705m Beechwood Primary Challney High School for EM1 site 572m SE Futures Fun Factory Westmoreland Ave 585m Limbury Riverside Park Gill Blower's Nursery - 0.1% within Sarum Archway Rd/Marsh Rd Leagrave 312m NW 370m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 522m NW SW 499m SE SE 342m SW Girls 1170m SW 1627m N NE 344m NE Leabank Site 998m N Memorial Road Red ELR 75m NE >100m from Airport/M1 323 5 Empress Road 0.11 - 14 - B2 site

Wigmore DC 728m SE; Ashcroft Pharmacy 772m Village Dental Practice Someries Infant 164m Someries Junior 174m Ashcroft High 520m S EM1 site 956m SE Wigmore Valley 1133m Raynham Way Crawley Green Rec Hart Hill Nursery 2094m Wigmore Place Green Handcross Rd/Hayling Dr Luton 2556m SW 317m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Someries Castle 2905m S W 1295m NW SW SW SE Community Centre (Amenity) 149m S SW ELR site 956m SE within site >100m from Airport/M1 324 Land at Burfield Court, Handcross Road 0.12 - 12 - C3 1061m S

TC 1641m N Medici 1449m N Mr T J Maeer Dental Hillborough Infant and Surrey St Primary 892m Barnfield Skills Academy EM1 site 282m NE; EM2 Adjacent to Stockwood Stockwood Park 406m N Memorial Rothesay Road Nursery Capability Green Green 201m Luton Airport Parkway 256m NW Partly within ALC3 Not PDL Part of site is within 50m Not SPZ1/2/3 Someries Castle 2750m E Land north west of J10a M1 (SA1 18.63 - 932 - Surgery 1826m N Nursery 1341m N NE 2624m N site 282m NE; District Park Neighbourhood Park 1814m N ELR site 282m NE NW 1802m NE of the M1 325 Stockwood Park) - COMPOSITE agricultural (Urban P and G) 515m N

Stopsley DC 261m NE; Lloyds Pharmacy 563m Village Dental Practice Someries Infant 1264m E Sacred Heart Primary Stopsley High 136m NE Em1 site 1741m SE; KR1 site Stopsley Common 157m Ashcroft Road 498m NE 33.9% within The Hart Hill Nursery 1582m Moreton Park Amber Lynwood Ave/Hitchin Rd Luton 1708m S 6.4m N Not ALC1/2/3 Not PDL >50m from AQMA, SPZ3 Dray's Ditches 2656m N 7.77 - 175 - open Round Green NC 402m S NE 498m NE 296m E 1823m S; LLA1 1980m SE; NE Chase/Mixes Wood S ELR site 357m S 89m NE >100m from Airport/M1 326 Land at Lynwood Avenue space BA1 site 1169m NE; CA1 (ANG); Bradgers Hill site 1693m S (ANG 8m N) Marsh Road DC 709m Makan MPS Dispensing Marsh Road Dental St Josephs Infant 414m Norton Road Primary Challney High School for Partly within EM1 site Lewsey Sports Park Blundell Rd 176m NE Blundell Rd Rec Gill Blower's Nursery - Partly within Covent Wingate Rd Arundel Rd Leagrave 1206m NW 824m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1438m Cawleys, 1 Covent Garden Close - NW Chemist 313m S Practice 343m N N 485m N Boys 1247m W 2430m W (Amenity) 183m NE Mossdale Site 1858m Garden Close, Arundel, 16m SW >100m from Airport/M1 NW 327 1.72 - 62 - B2 COMPOSITE NW Selbourne and Wingate Rd Green ELR site Wigmore DC 934m NE Asda Stores (Pharmacy) Vogue Dental Care 588m Crawley Green Infant Wenlock Junior (C of E) Ashcroft High 862m N 100% within EM1 site; Wigmore Valley 1030m E Raynham Way Polzeath Close (Amenity) Hart Hill Nursery 1054m Prospect Way/Airport Adjacent to Airport Luton Airport Parkway 1276m SW Not ALC1/2/3 PDL LLA1 62m SE SPZ3 Someries Castle 1503m 1088m NE NW 504m W 563m W KR1 site 276m SW; LLA1 Community Centre 688m 23m N W Percival Way South 2 Carparkz P&R 1086m SW SE 328 Vauxhall Trailer Park, Eaton Green Road 2.39 - 95 - B8 site 62m SE NE Green ELR site 32m SE

Sundon Park NC 1457m Moakes Medical Centre Purley Centre Dental Cheynes Infant 1037m Whitefield Primary 634m Lea Manor High 400m S Em1 site 1072m E Lea Manor Recreation Whitfield 634m SW 98.4% within White Gill Blower's Nursery - Bramingham Business Underwood Leagrave2082m S within site 100% is ALC2 Not PDL >50m from AQMA, SPZ3 Dray's Ditches 819m NE SW; Purley Centre 751m S 751m S SW SW centre 408m S Horse Vale (ANG) ; Leabank Site 1307m S Park Green ELR site Cl/Whitehorse Vale 4m >100m from Airport/M1 329 Land at Whitehorse Vale 2.12 - 80 - open space (Marsh Farm) (FUTURE Bramingham Wood 1157m E W SITE) DC 556m S (ANG) 14m S Bury Park DC 1420m NE; PJ Ward and Partners - Integrated Dental Whipperley Infant 286m St Margaret's of Scotland Denbigh High 2195m NE Em1 site 910m N Stockwood District Park Farley Community 52.2% within Castle Croft Rothesay Road Nursery Dalroad Green ELR site Rotherham Ave/South Luton 1983m NE 835m SE 100% is ALC3 Not PDL >50m from AQMA, SPZ3 None within 3km 2.40 - 108 - open Market Square, Farley Bushmead Rd 218m NE Holdings 1231m NE NE Primary 75m SE 702m SE Centre 299m NE CWS (ANG); Whipperley 927m NE 926m NE Drift Way 87m NE >100m from Airport/M1 330 Land at Roebuck Close space NC (FUTURE SITE) 143m Way (Amenity) 109m NE NE Marsh Rd DC 199m SE Leagrave Surgery 609m Leagrave Dental Practice St Josephs Infant 1067m Wauluds Primary 675m N Woodlands Secondary Em1 site 826m SW Futures Fun Factory Marsh House 184m NW 73.6% within Willow Way Gill Blower's Nursery - Empress Rd Green ELR Leagrave Railway Leagrave 208m S 9m NW Not ALC1/2/3 Not PDL >50m from AQMA, SPZ2 Waulud's Bank 73m NW S 710m SW SE 1079m NE 1194m N (Allotments); adj to Leabank Site 540m N site 395m SE Station/Bramingham Rd >100m from Airport/M1 331 Land at Willow Way 0.48 - 24 - open space Limbury Riverside Park 19m NW (ANG) TC 964m N Medici 760m N Mr T J Maeer Dental Hillborough Infant and Tennyson Road Primary Barnfield Skills Academy EM1 site 300m SE; EM2 Stockwood District Park Memorial Park 134m SE Memorial Rothesay Road Nursery Capability Green Green The Mount/London Rd Luton Airport Parkway 183m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Someries Castle 2732m E Surgery 1131m N Nursery 735m NW 356m N 1947m N site 300m SE; CA1 site 18m W Neighbourhood Park 1162m NW ELR site 300m SE 11m W 1496m E >100m from Airport/M1 332 The Mount, 136, Tennyson Road 0.34 - 17 - C2 964m N (Urban P and G) 11m SE

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 5 / 12 SEA Objectives C25 Impact on Listed C26 Impact on historic C27 Impact on C28 Impact on AONB C29 Impact on SSSI C30 Impact on AGLV C31 Impact on ALLI C32 Impact on Green C33 Impact on LNR C34 Impact on CWS C35 Impact on other C36 Impact on open C37 Impact on C38 Impact on Lea C39 Impact on Flood SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Building P&G Conservation Area Belt SNCI space allotment tributaries Zone 50 Guildford St (GII) Wardown Park (GII) 662m High Town 113m E 2415m N Blow's Down 2340m W 1079m SW Hart Hill 536m E 1956m SE None within 3km River Lea CWS 250m W River Lea DWS 84m SW The Moor (Amenity Harthill Ln Allotments ENV 20 186m W Not FZ2/3 196m S NW Greenspace) 246m W 866m E 0 0 +/- 0 0 + 0 + 0 + ++ 0 ++ + 6-14 Old Bedford Road 233

50 Guildford St (GII) Wardown Park (GII) 645m High Town 177m E 2429m N None within 3km 1052m SW Hart Hill 599m E 1984m SE None within 3km River Lea CWS 228m W River Lea DWS 67m SW The Moor (Amenity Harthill Ln Allotments ENV 20 162m W Not FZ2/3 209m S NW Greenspace) 2223m W 928m E 0 0 +/- 0 0 + 0 + 0 + + 0 ++ + 7A Old Bedford Road 235

Baptist Union Church Luton Hoo (GII) 1148m Town Centre 145m NW None within 3km None within 3km 1185m W Hart Hill 776m NE 1151m SE None within 3km River Lea CWS 514m NE River Lea DWS 497m N Windmill Rd Island Gypsy Lane Allotments ENV 20 514m W Not FZ2/3 (GII) 65m W SE (Amenity) 200m S Windmill Road 776m E 0 0 +/- 0 0 + 0 + 0 + + 0 ++ + 9-15 Oxford Road 237

The Cock Public House Luton Hoo (GII) 1209m Town Centre 128m W None within 3km None within 3km 1307m W Hart Hill 553m NE 1208m SE None within 3km River Lea CWS 333m E River Lea DWS 328m NE St Mary's Church Gypsy Lane Allotments ENV 20 333m E Not FZ2/3 (GII) 5m NW SE (Churchyards and Windmill Road 704m SE 0 0 +/- 0 0 + +/- + 0 + ++ 0 ++ + 42-44 Park Street 238 Cemeteries) 113m NE

93 Wellington St (GII) Wardown Park (GII) Rothesay 76m W 2818m W None within 3km 664m W Stockwood Park 765m S 1472m SW None within 3km Dallow Downs CWS River Lea DWS 541m NE Rothesay Cemetery London Road 826m S ENV 20 752m N Not FZ2/3 40m S 1317m N 677m W (Churchyards and 0 0 +/- 0 0 + 0 + 0 + + 0 ++ + 51-55 Princess Street 240 Cemeteries) 159m W

Church of St Matthew Wardown Park (GII) 701m High Town 314m W 1794m N None within 3km 803m N Hart Hill 432m S 1483m N None within 3km People's Park CWS 85m Hitchin Road Spinney People's Park (Urban P Stockingstone Road ENV 20 744m W Not FZ2/3 (GII) 336m SW W NW DWS 290m SE and G) 35m W 498m NW 0 0 - 0 0 + 0 + 0 - ++ 0 +/- + 43 Ridgway Road 241

Parish Church of St Mary Luton Hoo (GII) 1057m Plaiters Lea 446m NW 2966m N None within 3km 1714m W Hart Hill 268m NE 1050m SE None within 3km River Lea CWS 29m S River Lea DWS 68m NW Windmill Rd Island Harthill Ln Allotments ENV 20 29m S Not FZ2/3 (GI) 278m W, Park St (GII) SE (Amenity) 30m W 391m NE 0 0 +/- 0 0 + 0 + 0 + + 0 ++ + 7 Windmill Road 245 288m SW

53 Cheapside (GII) 26m Wardown Park (GII) 100% within Plaiters Lea 2741m N None within 3km 1205m W Hart Hill 388m NE 1528m SE None within 3km River Lea CWS 501m SE River Lea DWS adjacent St Mary's Church Harthill Ln Allotments ENV 14 499m SE 2.7% of site within FZ2; W 1085m NW to North (Churchyards and 679m E FZ3 0.5m N +/- 0 +/- - 0 + - + 0 + ++ 0 ++ + 15-19 John Street 246 Cemeteries) 203m SE

Leagrave High St Church Wardown Park (GII) Rothesay 2146m SE 1183m SW Blow's Down 2299m W 1106m S None within 3km 803m SW Cottage Bottom Fields Dunstable to Luton Hatter's Way DWS 485m Chaul End Lane Bradley Road Allotments ENV 20 1569m NW Not FZ2/3 of St Luke (GII) 1250m 2366m E 2981m SW disused railway CWS S Neighbourhood Park 484m SW 0 0 +/- 0 0 + 0 + 0 -- + 0 -- + 566-568 Dunstable Road 248 NW; 57 Compton Ave 851m SW (Amenity) 30m S (GII) 1242m NW High Town Methodist Wardown Park (GII) 538m High Town 178m SE 2268m N None within 3km 1168m SW Hart Hill 555m SE 1945m N None within 3km River Lea CWS 274m W River Lea DWS 206m SW The Moor (Amenity Harthill Ln Allotments ENV 20 237m SW Not FZ2/3 Church (GII) 212m E NW Greenspace) 274m W 885m E Proposed Development, 20/20A North 0 0 +/- 0 0 + 0 + 0 + ++ 0 + +/- 250 Street and 61-67 Dudley Street

The Cock Public House Luton Hoo (GII) 1158m Town Centre 157m NW None within 3km None within 3km 1314m W Hart Hill 563m NE 1158m SE None within 3km River Lea CWS 303m E River Lea DWS 314m NE St Mary's Church Gypsy Lane Allotments ENV 20 303m E Not FZ2/3 (GII) 51m NW SE (Churchyards and Windmill Road 776m E 0 0 +/- 0 0 + 0 + 0 ++ ++ 0 ++ + R/o 46-52 Park Street 295 Cemeteries) 112m NE

47 Guildford St 46m E; Wardown Park (GII) 978m 100% within Plaiters Lea 2707m N None within 3km 1076m W Hart Hill 478m E 1645m SE None within 3km River Lea CWS 505m W River Lea DWS 30m SE St Mary's Church Harthill Ln Allotments ENV 20 435m NW Not FZ2/3 Bute St (GII) 52m NE NW (Churchyards and 781m E 0 0 +/- 0 0 + - + 0 +/- + 0 ++ + 47-53 Bute Street 298 Cemeteries) 338m SE

Church of St Andrew Wardown Park (GII) 451m Rothesay 1031m S 2059m NE Galley and Warden Hills 1067m SW Hart Hill 1573m SE 1771m NE Leagrave Common and River Lea CWS 453m E River Lea DWS 427m E Wardown Park (Urban P New Bedford Road 844m ENV 20 453m E Not FZ2/3 (GII) 213m N E 2877m N Wauluds bank Proposed and G) 451m E NE 0 0 - 0 0 + 0 + 0 -- + 0 +/- + Chaucer House, 134 Biscot Road 300 LNR 2749m NW

Christ Church(GII) 142m Wardown Park (GII) Rothesay 25m SW 2794m W None within 3km 575m W Stockwood Park 936m S 1514m SW None within 3km Dallow Downs CWS River Lea DWS 466m NE Rothesay Cemetery Ferndale Allotments ENV 14 552m N Not FZ2/3 NE 1103m N 575m W (Churchyards and 1031m W 0 0 +/- 0 0 + 0 + 0 + + 0 + + 18-22 Rothesay Road 301 Cemeteries) 176m SW

Holy Trinity Church (GII) Wardown Park (GII) Rothesay 2546m S 1785m NE Galley and Warden Hills 1798m E Hart Hill 2944m SE 1785m E Leagrave Common and Biscot Church Yard CWS River Lea DWS 132m NE Limbury Riverside Park Nunnery Lane 154m NE ENV 20 250m NE Not FZ2/3 36m SW 1326m SE 1789m NE Wauluds bank Proposed 12m SW (Natural and Semi- 0 0 +/- 0 0 + 0 + 0 +/- + 0 +/- + 18 Trinity Road 302 LNR 1447m W Natural) 3249m N

93 Wellington sty (GII) Wardown Park (GII) 0.3% within Rothesay 2747m W None within 3km 564m W Stockwood Park 810m S 1435m SW None within 3km Dallow Downs CWS River Lea DWS 524m NE Rothesay Cemetery London Road 912m S ENV 14 644m N Not FZ2/3 138m SE 1200m N 571m W (Churchyards and 0 0 +/- 0 0 + +/- + 0 + + 0 + + Car park adj 69 Adelaide Street 303 Cemeteries) 99m SW

101 Park St (GII) 16m SE Luton Hoo (GII) 1001m Town Centre 347m NW None within 3km None within 3km 1499m W Hart Hill 520m NE 1001m SE None within 3km River Lea CWS 192m NE River Lea DWS 205m E Manor Rd N'hd Park Gypsy Lane Allotments ENV 20 192m NE Not FZ2/3 SE (Urban P&G) 66m SE Windmill Road 471m SE 0 0 +/- 0 0 + 0 + 0 + + 0 + + 89-93 Park Street 304

Gas lamps at 10&32 Hart Luton Hoo (GII) 1268m S Plaiters Lea 437m W 2648m N None within 3km 1677m N Site adjacent to Hart Hill 1213m SE None within 3km Church Cemetery, Luton River Lea DWS 252m SW Crawley Green Road Harthill Ln Allotments ENV 14 280m SW Not FZ2/3 Hill Drive (GII)6m NE CWS 120m SE Cemetery (Churchyards 93m NE +/- 0 +/- 0 0 + +/- + 0 +/- ++ 0 ++ - 34-38 Crescent Road 305 and Cemeteries) 119m SE 50 Guildford St (GII) Wardown Park (GII) 714m High Town 43m E 2526m N None within 3km 1164m SW Hart Hill 465m E 1903m SE None within 3km River Lea CWS 343m W River Lea DWS 166m SW The Moor (Amenity Harthill Ln Allotments ENV 20 281m W Not FZ2/3 182m S NW Greenspace) 340m W 795m E 0 0 +/- 0 0 + 0 + 0 +/- + 0 ++ +/- 1 Dudley Street 306

Christ Church(GII) 152m Wardown Park (GII) Rothesay 11m SW None within 3km None within 3km 2782m W Stockwood Park 927m S 1502m SW None within 3km Dallow Downs CWS River Lea DWS 495m NE Rothesay Cemetery Ferndale Allotments ENV 20 582m N Not FZ2/3 NE 1127m N 566m W (Churchyards and 1025m W 0 0 +/- 0 0 + 0 + 0 + + 0 ++ + GT House, 24-26 Rothesay Road 307 Cemeteries) 164m SW

Leagrave High St Church None within 3km None within 3km 1862m S Blow's Down 2028m S 2988m SE None within 3km 108m W Leagrave Common and River Lea CWS 2.2m N Lewsey Park DWS 353m 67.4% within Ickley Close Ravenhill Way 72m SW ENV 20 7.6m N 10.3% within FZ2; FZ3 of St Luke (GII) 873m SE Wauluds bank Proposed S OS; Spider Park 6m N ------0 -- 0 + 0 - ++ 0 + + Open space at Ickley Close 309 LNR 941m NE (Amenity) 74m E

Leagrave High St Church None within 3km None within 3km 771m S Blow's Down 1423m SW 1754m SE None within 3km 682m S Leagrave Common and River Lea CWS 626m N River Lea DWS 613m N 98.9% within Farringdon Bradley Road Allotments ENV 20 625m N Not FZ2/3 of St Luke (GII) 733m NE Wauluds bank Proposed Rd (Amenity); Addington 741m SE +/- -- -- 0 0 +/- 0 + 0 - ++ 0 - + Potential site east of Farringdon Road 310 LNR 1479m NE; Cottage Way Sports Field Bottom Fields LNR (Amenity) 200m N 63 George St South side Wardown Park (GII) 100% within Town Centre 2171m N None within 3km 959m W Hart Hill 660m NE 1543m SE None within 3km River Lea CWS 643m NW River Lea DWS 198m NE St Mary's Church Harthill Ln Allotments ENV 20 581m N Not FZ2/3 (GII) 14m NW 1157m N (Churchyards and 934m NE 0 0 +/- 0 0 + - + 0 +/- + 0 ++ + 7-11 King Street 319 Cemeteries) 370m E

Church of St Matthew Wardown Park (GII) 545m High Town 132m SE 2064m N None within 3km 1026m N Hart Hill 501m SE 1744m N None within 3km People's Park CWS 296m River Lea DWS 437m SW People's Park (Urban P Stockingstone Road ENV 20 452m W Not FZ2/3 (GII) 89m SE NW N and G) 61m NE 699m N 0 0 +/- 0 0 + 0 + 0 + + 0 +/- + 111 North Street 320

Holy Trinity Church (GII) Wardown Park (GII) Rothesay 1771m SE 2044m SW Galley and Warden Hills 1254m S Hart Hill 2670m SE 1526m SW Leagrave Common and Biscot Churchyard CWS Hatter's Way DWS Blundell Rd Rec Nunnery Lane 1230m NE ENV 20 1309m N Not FZ2/3 992m N 1489m E 2865m NE Wauluds bank Proposed 896m NE 1194m SW (Amenity) 292m N 0 0 +/- 0 0 + 0 + 0 - + 0 - + Petrol Station, 116-124 Wingate Road 321 LNR 1741m NW

Leagrave High St Church Wardown Park (GII) None within 3km 2174m SW Galley and Warden Hills 2375m S None within 3km 1891m SW Leagrave Common and River Lea CWS 372m NE River Lea DWS 344m NE Limbury Riverside Park Limbury 404m NE ENV 20 378m NE Not FZ2/3 of St Luke (GII) 580m W 2420m E 2681m NE Wauluds bank Proposed (Natural and Semi- 0 0 0 0 0 + 0 + 0 - + 0 ++ + 5 Empress Road 323 LNR 478m NW Natural) 344m NE

Cassel's Cottage (GII) Putteridge Bury (GII) High Town 2311m SE 1790m N None within 3km 1946m W Hart Hill 2073m SW 309m NE None within 3km Slaughter's Wood and Great Hayes Wood DWS Crawley Green Rec Wigmore Lane 218m W ENV 20 2612m W Not FZ2/3 971m NE 644m N Green Lane CWS 50.3m 966m N (Amenity) 149m S 0 0 +/- 0 0 + 0 + 0 -- + 0 + + Land at Burfield Court, Handcross Road 324 E

Church of St Andrew Luton Hoo (GII) 164m SE Luton South 515m N 2451m SW None within 3km 1849m N Adjacent to Stockwood 0.1% within green belt None within 3km Adjacent to Stockwood Partly within un-named Adjacent to Stockwood London Road 555m N ENV 20 1529m NE Not FZ2/3 (GII) 231m SW Park Park CWS ENV5 site District Park (Major Land north west of J10a M1 (SA1 -- +/- -- 0 0 -- 0 + 0 -- ++ 0 -- + 325 sports and leisure sites) Stockwood Park) - COMPOSITE

St Christopher's Church Wardown Park (GII) 602m High Town 1360m SW 315m N Galley and Warden Hills 0.7% within AGLV (ENV2) Hart Hill 1385m S 7.4m N Galley and Warden Hills 50.6% within The Chase 48.5% within Mixes Hill 33.9% within The Stockingstone Road ENV 20 742m W Not FZ2/3 (GII) 426m S SW 1784m NW 1783m NW CWS; 3.8% within DWS Chase/Mixes Wood 559m SW -- -- - 0 0 +/- 0 + 0 - ++ 0 + +/- Land at Lynwood Avenue 326 Honeygate and Crick (ANG); Bradgers Hill Hills CWS (ANG 8m N) Holy Trinity Church 899m Wardown Park (GII) Rothesay 1979m SE 1769m SW Galley and Warden Hills 1385m S Hart Hill 2942m SE 1350m SW Leagrave Common and Biscot Churchyard CWS River Lea DWS 973m N Blundell Rd Rec Bradley Road Allotments ENV 20 997m N Not FZ2/3 NE 1748m E 2797m NE Wauluds bank Proposed 792m NE (Amenity) 183m NE 1070m SW Cawleys, 1 Covent Garden Close - 0 0 +/- 0 0 + 0 + 0 +/- ++ 0 - - 327 LNR 1392m NW COMPOSITE

Vauxhall Motors Kimpton Luton Hoo (GII) 1373m S High Town 1634m W 2875m NW None within 3km 1259m SE Hart Hill 918m W 1039m S None within 3km Wigmore Park CWS Dairyborn Scarp DWS Polzeath Close (Amenity) Harthill Ln Allotments ENV 20 1308m SW Not FZ2/3 Road 953m SW 980m E; ENV5 32m SE 8m E 23m N 1003m W 0 0 - 0 0 + 0 + 0 - ++ 0 + + Vauxhall Trailer Park, Eaton Green Road 328

Great Bramingham None within 3km None within 3km 551m N Galley and Warden Hills None within 3km None within 3km 0.2m N Leagrave Common and Bramingham Wood CWS Great Bramingham Park 98.4% within White Willow Way 1696m S ENV 20 1315m SE Not FZ2/3 Farmhouse (GII) 699m 1846m E Wauluds bank Proposed 13m SE DWS 728m E Horse Vale (ANG) ; - -- - 0 0 - 0 + 0 - ++ 0 +/- + Land at Whitehorse Vale 329 NE LNR 900m SW Bramingham Wood (ANG) 14m S Church of All Saints (GII) Wardown Park (GII) Rothesay 923m NE 1217m W None within 3km 385m NW Stockwood Park 702m SE 2% within green belt Cottage Bottom Fields 98.1% within Castle Croft 98.1% Castle Croft within 52.2% within Castle Croft Ferndale Allotments ENV 14 1829m NE Not FZ2/3 1130m SW 2173m NE 2900m W And Bluebell Wood SNCI CWS (ANG); Whipperley 723m NE ------0 0 - 0 + 0 - ++ 0 - + Land at Roebuck Close 330 CWS Way (Amenity) 109m NE

57 Compton Ave (GII) Wardown Park (GII) None within 3km 2412m SW Galley and Warden Hills 2788m S None within 3km 1692m W Leagrave Common and 0.5% within River Lea 99.3% within River Lea 73.6% within Willow Way 73.6% within Willow Way Adjacent to ENV20 3.7% within FZ2; 2.6% 613m SW 2723m SE 2614m NE Wauluds bank Proposed CWS DWS (Allotments); adj to (Allotments and Leisure within FZ3 ------0 +/- +/- + 0 +/- ++ 0 +/- + Land at Willow Way 331 LNR 29m NW Limbury Riverside Park Gdns) (ANG) Bailey Hill Water Tower Luton Hoo (GII) 860m SE Luton South 32m NE 2963m W None within 3km 1433m NW Stockwood Park 18m W 556m SE None within 3km Stockwood Park CWS Stockwood Park DWS Memorial London Rd 40m W ENV 20 1094m NE Not FZ2/3 (GII) 139m NE 198m S 18m S Neighbourhood Park +/- 0 +/- 0 0 + 0 + 0 +/- ++ 0 +/- + The Mount, 136, Tennyson Road 332 (Urban P and G) 11m SE

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 6 / 12 Luton Possible Allocations Site Assessment Criteria (as amended) C1 Dist to centres C2 Dist to health C3 Dist to dental C4 Distance to infant C5 Dist to junior C6 Dist to 2ary C7 Dist to emp C8 Dist to sports C9 Dist to play C10 Dist to open space C15 Dist crèche C16 Loss of emp C17 Dist to bus C18 Dist to train C19 Dist to cycle C20 Loss of agric C21 Use of PDL C22 Dist to AP source C23 Impact on SPZ C24 Impact on SAM

Marsh Rd DC 1059m S; Moakes Medical Centre Purley Centre Dental Cheynes Infant 846m W Wauluds Primary 259m Woodlands Secondary EM1 Site 1282m W Futures Fun Factory Purley Centre (Freeman's Adjacent to Sherd Close Gill Blower's Nursery - Sarum Road Red ELR site Sherd Cl/Lygetun Dr Leagrave 1157m S 2m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank480m SW Purley Centre (Marsh 187m NW 187m NW SW 215m NE 355m NW Green) 118m NW Marsh Farm (Amenity) Leabank Site 473m SW 1228m S 113m SE >100m from Airport/M1 333 Sherd Lodge, Sherd Close 0.29 - 15 - C2 Farm) (FUTURE SITE) DC 123m N High Town NC 740m N; 69m S Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site347m E; EM2 Stockwood District Park Hibbert St 284m Windmill Road Island Rothesay Road Nursery Holly St Green ELR site Crown Ct/Flowers Way Luton 626m N 125m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2661m E Land & buildings at Castle Street/Oxford TC 13m NE Surgery 150m N Nursery753m SW 393m SE 983m NE site 906m S; CA1 site 824m S (Amenity) 248m S 611m W 43m SE 83m NE >100m from Airport/M1 335 0.27 - 45 - D1 Road and Park Viaduct 13m NE

Wigmore DC 727m NW Asda Stores (Pharmacy) Vogue Dental Care Someries Infant 1792m Wigmore Primary 1026m Ashcroft High 1617m 100% within EM1 site; Wigmore Valley 82m W Malthouse Green 273m Adjacent to Wigmore Hart Hill Nursery 2751m 98.8% within Wigmore Bowbrook Vale/Hedley Luton Airport Parkway 1m W 87.4% is ALC3 Not PDL Adjacent to LLA1 SPZ3 Someries Castle 1540m Wigmore employment area, Eaton Green 43.09 - 2155 - 766m NW 2103m W NW NW NW 100% within EM3 site; NW Valley Park Natural W /Century Park Green ELR Rise 423m NW 2531m W SW 336 Road agricultural adjacent to LLA1 site Space (Natural and Semi- site natural Greenspace) Bury Park DC 1889 N; TC PJ Ward and Partners - Integrated Dental Hillborough Infant and St Margaret's of Scotland Barnfield Skills Academy EM1 Site 1315m E; EM2 Stockwood District Park Homestead Way 235m Tinsley Close/Farley Rothesay Road Nursery Capability Green Green Farley Farm/Farley Hill Luton 2206m NE 288m SE 97.7% is ALC3 Not PDL >50m from AQMA, SPZ2 None within 3km 1669m NE; Market Market Square 958m N Holdings 1529m NE Nursery 961m NE Primary 568m N 2673m NE site 1316m E; CA1 site 11m E NE Farm Road 76m N 1409m NE ELR site 1316m E 187m NE >100m from Airport/M1 337 Land west of Newlands Road 2.5 - 125 - C3/pasture Square, Farley NC 1668m NE (FUTURE SITE) 860m N Stopsley DC 666m SE Acorn Dispensing Village Dental Practice Warden Hill Infant 1282m Bushmead Primary 453m Stopsley High 469m SE BA1 site 549m E; Stopsley Common 152m Bushmead Park (Heron 13.4% w/in Bushmead Park Grasmere Children's Butterfield Green Green Harveys Hill/Bushmead Luton 2450m S within site 100% is ALC3 Not PDL >50m from AQMA, SPZ2 Dray's Ditches 1660m N 11.47 - 280 - Chemist (PLC.) 1190m W 853m SE W W SE Drive) 206m W (ANG); 2.9% w/in Bradgers Hill Centre 1650m NW ELR site 549m E Road 64m W >100m from Airport/M1 338 Land east of Bushmead (ANG); 0.2% w/in Cromer Way agricultural (Amenity); Stopsley Common (ANG) 74m SE Stopsley DC 773m NE Ashcroft Pharmacy 836m Village Dental Practice Crawley Green Infant Sacred Heart Primary Stopsley High 761m N EM1 site 1507m S; KR1 Hightown Community Bell's Close 703m SW St Martin's (Natural and Hart Hill Nursery 1150m Greenwood Ct Green Preston Luton 1184m S 841m N Not ALC1/2/3 Partially PDL >50m from AQMA, SPZ3 None within 3km E 1010m NE 1365m SE 682m NE site 1552m SE; LLA1 site Sports and Arts Centre semi-natural greenspace) S ELR site 256m SE Gdns/Stockingstone Rd >100m from Airport/M1 339 Land at Stockingstone Road 2.02 - 101 - D2 1873m SE; BA1 site 868m S 106m N 11m W 1752m NE; CA1 site High Town NC 815m N; Castle St Surgery 99m W Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 362m E; EM2 Stockwood District Park Hibbert St 225m S Windmill Road Island Rothesay Road Nursery Holly Street Green ELR Latimer Rd/Holly St 93m Luton 690m N 226m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 1540m TC 66m NE Surgery 231m N Nursery 802m SW 349m SE 1039m N site 850m S; CA1 site 798m S (Amenity) 189m S 707m W site 10m SW S >100m from Airport/M1 SW 340 Land at Union Street/ Oxford Road 0.03 - 12 - SG 66m NE

Stopsley DC 2262m SE; Warden Hill Chemist Sanjiv Jagsi Dental Warden Hill Infant 424m Warden Hill Jnr 487m Cardinal Newman EM1 site 542m NW Stopsley Common Lancaster Ave 203m N 99.3% within Weybourne Grasmere Children's Bramingham Business Weybourne Dr 166m W Leagrave 2769m SW within site Not ALC1/2/3 Not PDL >50m from AQMA, SPZ3 Dray's Ditches826m N Freeman Ave NC 364m NW surgery 455m SW SW SW Catholic 442m N 1630m SE Drive (ANG); Lancaster Centre 529m W Park Green ELR site >100m from Airport/M1 341 Land at Weybourne Drive 0.44 - 10 - open space (FUTURE SITE) 925m W Ave (Amenity) 112m NW 579m NW

Marsh Rd DC 845m NE Oakley Surgery 129m S Leagrave Dental Practice The Ferrars Academy Barnfield Moorlands Challney High School for EM1 site174m SE; Lewsey Sports Park Addington Way 2 242m Addington Way Sports Gill Blower's Nursery - Empress Rd Green ELR Orchard Way/Mayne Ave Leagrave 672m NE 533m W Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 870m NE 156m NE 958m SW Primary 164m SW Girls 310m SW 1112m W S Field (Amenity) 149m SW Mossdale Site 604m N site 829m E 92m NW >100m from Airport/M1 342 The Laurels, Ely Way 0.53 - 27 - C2

Marsh Rd DC 985m NE Oakley Surgery 135m SE Leagrave Dental Practice The Ferrars Academy Barnfield Moorlands Challney High School for EM1 site 232m E Lewsey Sports Park 960m Addington Way 2 217m Addington Way Sports Gill Blower's Nursery - Empress Rd Green ELR Adjacent to Leagrave 801m NE 383m W Not ALC1/2/3 PDL M1 80m SW SPZ2 Waulud's Bank 984m NE Westlea Old Peoples Home, 121 High 280m NE 811m SW Primary 26.3m SW Girls 208m S W SE Field (Amenity) 12m SW Mossdale Site 624m N site 959m E Westlea/High St 343 0.82 - 41 - C2 Street

Marsh Rd DC 717m W Bishopscote Dispensing Marsh Rd Dental Practice St Joseph's Infant 294m St Joseph's Junior 218m Icknield High 1088m NE EM1 site 472m SW Futures Fun Factory Solway Road 96m SE Adjacent to Alder Cres Gill Blower's Nursery - Leagrave Road Amber Blundell Rd/ Rd Leagrave 1293m W 430m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1363m Chemist 347m SE 542m W W W 2142m NW (Amenity Grassland) Leabank Site 1736m NW ELR site 479m SW 89m N >100m from Airport/M1 NW 345 Milan Day Centre, Solway Road North 0.20 - 10 - D1

Bury Park DC 3m S; TC Verghese & Partners - Associated Dental Hillborough Infant and Dallow Primary 376m SW Denbigh High 899m N EM1 site 4841m W; CA1 Hightown Community Brantwood Park 521m The Moor (Amenity) 82m Rothesay Road Nursery Mill St Green ELR site Bury Park/Sainsbury's Luton 450m E 84m E Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 38m SE Liverpool Rd 193m S Practice 358m S Nursery 1179m S site 38m SE Sports and Arts Centre SW NE 665m S 200m E Store 127m W >100m from Airport/M1 348 27 Crawley Road 0.04 - 11 - SG 888m E

Marsh Rd DC 717m W Oakley Surgery 164m SE Leagrave Dental Practice The Ferrars Academy Barnfield Moorlands Challney High School for EM1 site 231m SE Lewsey Sports Park Addington Way 2 258m Addington Way Sports Gill Blower's Nursery - Empress Rd Green ELR Westlea/High St 27m W Leagrave 754m NE 461m W Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 939m NE 234m NE 906m SW Primary 117m SW Girls 291m S 1042m W S Field (Amenity)104m SW Mossdale Site 601m N site 918m E >100m from Airport/M1 349 97 High Street 0.31 - 12 - C3

Bury Park DC 1798m N; PJ Ward and Partners - Integrated Dental Hillborough Infant and St Margaret's of Scotland Barnfield Skills Academy EM1 site 1364m E; EM2 Stockwood District Park Homestead Way 165m Tinsley Close/Farley Rothesay Road Nursery Capability Green Green Farley Farm/Farley Hill Luton 2131m NE 424m NE 100% is ALC3 PDL >50m from AQMA, SPZ2 None within 3km TC 1601m NE Market Square 936m N Holdings 1444m NE Nursery 893m NE Primary 568m NW 2603m NE site 1364m E; CA1 site 19m SE NE Farm Road 62m NW 1328m NE ELR site 1364m E 122m NE >100m from Airport/M1 350 The Barn Owl, Leyhill Drive 0.39 - 14 - A4 1601m NE

Bury Park DC355m NW; Cardiff Road Surgery Maple Dental Clinic 1m E Hillborough Infant and Dallow Primary 536m Barnfield Skills Academy EM1 site 824m E; 100% Hightown Community Brantwood Park 428m W Rothesay Cemetery Rothesay Road Nursery Upper George St Green Luton Centre Dunstable Luton 427m NE 167m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 100% within TC 190m W Nursery 799m S NW 932m NE within CA1 Sports and Arts Centre (Churchyards and 337m SW ELR site 58m NW Place 39m SE >100m from Airport/M1 351 27A Upper George Street 0.11 - 26 - D2 930m NE cemeteries) 334m SW

Bury Park DC 99m NW; Lea Vale Medical Sharing Smiles 179m S Hillborough Infant and Dallow Primary 425m W Barnfield Skills Academy EM1 site 941m W Hightown Community Brantwood Park 483m The Moor (Amenity) Rothesay Road Nursery Mill St Green ELR site Villa Link/Old Bedford Luton 306m E 59m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 100% within TC Practice 126m SW Nursery 1066m S 810m E Sports and Arts Centre SW 192m N 559m S 90m NE Road 31m N >100m from Airport/M1 352 40-58 Collingdon Street 0.22 - 88 - B8 795m E

Bury Park DC 253m N; Acorn Chemist (PLC.) Beech Hill Dental Foxdell Infant 673m W Beech Hill Primary 226m Denbigh High 959m NE EM1 site 36m SW Stockwood District Park Cohen's Yard 61m W Cohen's Rothesay Road Nursery Dalroad Green ELR site Clifton Rd/Luton Town Luton 1212m E 14m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 2914m TC 690 241m S Practice 195m N N 1628m S Yard/Shaftesbury Rd 971m SE 20m SW Football Club 0.5m SW >100m from Airport/M1 NW 353 Car park adj to 95 Maple Road East 0.65 - 49 - B2 (Amenity) 7m NW

Marsh Rd DC 1235m W; Birdsfoot Lane Pharmacy Sanjiv Jagsi Dental Warden Hill Infant 749m Icknield Primary 181m S Icknield High 432m E EM1 site 1120m N; Lea Manor Recreation Rumfold Ave 286m W Adjacent to Birdsfoot Grasmere Children's Bramingham Business Parys Road/Birdsfoot Leagrave 1674m W 236m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1410m W 98.6% within Birdsfoot within the site surgery 737m NE NE centre 1699m NW Lane (amenity) Centre 1019m N Park Green ELR site Lane within site >100m from Airport/M1 354 Shops 247-259 Birdsfoot Lane 0.36 - 13 - A1 Lane South NC (FUTURE 1142m N SITE) Marsh Rd DC 423m N Lloyds Pharmacy 187m Marsh Road Dental St Joseph's Infant 356m Norton Road Primary Challney High School for 100% within EM1 site Futures Fun Factory Blundell Rd 282m E Blundell Road Rec 219m Gill Blower's Nursery - 100% within Waller Ave Waller Ave/Marsh Rd Leagrave 900m NW 759m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1138m NE Practice 134m NE NE 317m NE Boys 1207m W 2189m N E Mossdale Site 1564m Green ELR site 124m NE >100m from Airport/M1 NW 355 Telephone Exchange, 177 Waller Avenue 1.60 - 120 - B2 NW

Marsh Rd DC 402m NW Lloyds Pharmacy 139m N Marsh Road Dental St Joseph's Infant 301m Norton Road Primary Challney High School for 100% within EM1 site Futures Fun Factory Blundell Rd 214m E Blundell Road Rec 147m Gill Blower's Nursery - 100% within Waller Ave Waller Ave/Marsh Rd Leagrave 900m NW 720m N Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1128m Practice 139m N NE 265m NE Boys 1290m W 2160m N E Mossdale Site 1584m Green ELR site 67m NE >100m from Airport/M1 NW 356 187-189 Waller Avenue 0.94 - 71 - B8 NW

87.6% within Bury Park Sai Luton Limited Mrs Jaspal Mandair Dental Denbigh Infant 1212m Dallow Primary 237m S Denbigh High 740m N CA1 site 280m SE Hightown Community Brantwood Park 502m S The Moor (Amenity) Rothesay Road Nursery Guardian Estate Amber Kenilworth Rd/Luton Luton 724m E 177m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km DC; TC 280m SE Thanki 18m NW Surgery 185m NW NW Sports and Arts Centre 115m N 750m S ELR site 213m SW Town football Club 27m >100m from Airport/M1 357 68-80 Dunstable Road 0.24 - 18 - A1 1124m E W

Bury Park DC 1398m E Lister House Surgery Leagrave Dental Foxdell Infant 541m SE Foxdell Junior 282m W Challney High School for EM1 site 10m SW Lewsey Sports Park Foxdell 249m W Foxdell Neighbourhood Rothesay Road Nursery Bilton Way Green ELR Easingwold Gdns/Dallow Leagrave 1991m N 8m N Not ALC1/2/3 Not PDL >50m from AQMA, SPZ1 Waulud's Bank 2282m N 1.79 - 90 - scrub (no 503m N Sedation Clinic 382m Boys 1235m NW 2480m NW Park (Amenity 2239m SE site 10m SW Rd 94m S >100m from Airport/M1 358 Land east of Aldi and B&Q, Dallow Road access) NW Greenspace) 206m W

Marsh Rd DC 321m S Calverton Pharmacy Purley Centre 846m N St Joseph's Infant 982m The Meads Primary 468m Woodlands Secondary EM1 site 1011m S Futures Fun Factory Marsh House 345m W Adjacent to Limbury Gill Blower's Nursery - Sarum Road Red ELR site Wauluds Bank Leagrave 445m SW 1m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 108m NW 385m E SE NE 821m N 1017m N Riverside Park (Natural Leabank Site 476m NW 487m S Drive/Bramingham Road >100m from Airport/M1 359 Bramingham Centre, Weltmore Road 1.40 - 70 - D2 and semi-natural 46m NW greenspace) Wigmore DC 982m NE Asda Stores (Pharmacy) Vogue Dental Care 501m Crawley Green infant Wenlock Jnr (C of E) Ashcroft High 843m N EM1 site 27m SE; KR1 Wigmore Valley 1102m E Raynham Way Falconers Rd (Amenity) Hart Hill Nursery1038m Prospect Way/Airport Adjacent to Brendon Luton Airport Parkway 1260m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Someries Castle 1705m 1147m NE NW 499m W 548m W site 420m SW; LLA1 site Community Centre 754m 2m W W Percival Way South 2 Ave/Eaton Green 1261m SW >100m from Airport/M1 SE 360 International House, Eaton Green Road 0.37 - 18 - C3 204m SE NE Green ELR site 175m SE

Marsh Rd DC 1039m N Makan MPS Dispensing Marsh Road Dental St Joseph's Infant 852m Downside Primary 564m Challney High School for EM1 site131m N Lewsey Sports Park Kingsway Recreation Kingsway Rec Gill Blower's Nursery - 99.7% within Caleb Close Dunstable Rd/Big Yellow Leagrave 1432m NW 552m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1705m Chemist; Mr M Makan Practice 726m N N SW Boys 1221m W 2456m W Ground 354m SE Neighbourhood Park Mossdale Site 2006m Red ELR site Storage 10m SW >100m from Airport/M1 NW 361 2-32 Beechwood Road 0.61 - 15 - B2 70m SW (Urban P and G) 185m SE NW

Wigmore DC 738m W Asda Stores (Pharmacy) Vogue Dental Care Someries Infant 1755m Wigmore Primary 1011m Ashcroft High 1634m W Em1 site 13m SE; EM3 Wigmmore Valley 128m Malthouse Green 209m 100% within Wigmore Hart Hill Nursery 2948m Wigmore/Century Park Bowbrook Vale/Hedley Luton Airport Parkway 8m SE 100% is ALC3 Not PDL >50m from AQMA, SPZ3 Someries Castle 2198m 782m W 2231m W NW W site 13m SE; LLA1 site W NW Valley Park (ANG); W Green ELR site 13m SE Rise 355m NW 2889m SW >100m from Airport/M1 SW 362 Land south of Eaton Green Road 0.26 - 13 - open space 593m S Malthouse Green (Amenity) 151m N Marsh Rd DC 19m NE Leagrave Surgery 327m Leagrave Dental Practice St Josephs Infant 611m Beechwood Primary Challney High School for EM1 site 492m SE Futures Fun Factory Westmorland Avenue Limbury Riverside Park Gill Blower's Nursery - 100% within Sarum Road Memorial Rd/Hail and Leagrave 383m NW 371m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank591m NW SW 409m SE SE 353m SW Girls 1213m SW 1678m N 557m NE (Natural and semi-natural Leabank Site 1065m N Red ELR site Ride 32m SE >100m from Airport/M1 363 Royal Mail, Sarum Road 0.40 - 20 - B8 greenspace) 352m N

Bury Park DC 1091m E Makan MPS Dispensing Marsh Road Dental Denbigh Infant 911m E Maidenhall Primary 490m Challney High School for EM1 site 193m W Lewsey Sports Park Kingsway Recreation Kingsway Rec Gill Blower's Nursery - 99.7% within Caleb Close Arundel Rd/Beechwood Leagrave 1566m NW 525m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1840m Chemist; Mr M Makan Practice 852m N E Boys 1293m W 2536m W Ground 277m SE Neighbourhood Park Mossdale Site 2128m Red ELR site Rd within site >100m from Airport/M1 NW 364 10-12 Caleb Close 0.31 - 24 - B8 73m W (Urban P and G) 120m S NW

High Town NC 914m Castle St Surgery472m W Mr T J Maeer Dental Hillborough Infant and Surrey St Primary 202m Barnfield Skills Academy EM1 site 25m E; EM2 site Stockwood District Park Manor Rd 261m NE Manor Rd N'hd Park Hart Hill Nursery 857m Osbourne Rd Green ELR Bailey St/Manor Park Luton 711m N 8m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2226m E NW; TC 140m NW Surgery 485m NW Nursery 1135m W SW 1011m N 704m S; KR1 site 775m E; 950m SW (Urban P&G) 43m NE NE site 24m E within site >100m from Airport/M1 365 146-158 Park Street 0.24 - 29 - car park CA1 site 140m NW

Sundon Park NC 236m Rowlands Pharmacy Sundon Park Dental Cheynes Infant 508m E Sundon Park Junior Lealands High 93m S EM1 site 17m SW Futures Fun Factory Grampian Way 472m E chestnut Ave 468m N Gill Blower's Nursery - SKF2 Green ELR site Ashwell Ave/Sundon Pk Leagrave 1576m SE 509m N Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 1145m SE SE (Sundon Park Pharmacy) Practice 411m S 299m NE 1132m E Leabank Site 1175m SE 93m SW within site >100m from Airport/M1 366 The Favourite, 298 Sundon Park Road 0.35 - 14 - A4 415m S

Sundon Park NC 859m Rowlands Pharmacy Sundon Park Dental Cheynes Infant 1185m E Sundon Park Junior Lealands High 771m S 99.9% within EM1 site Futures Fun Factory Grampian Way 1168m SE chestnut Ave365m NE Gill Blower's Nursery - 100% within Camford Camford Way/Camford Leagrave 2387m SE 590m E 100% is ALC2 PDL >50m from AQMA, SPZ3 Waulud's Bank 1814m SE SE (Sundon Park Pharmacy) Practice 1010m SE 834m E 1789m E Leabank Site 1865m SE Way Cluster Green ELR Depot 97m SE >100m from Airport/M1 367 166 Camford Way 0.34 - 17 - B2 1044m SE site

Sundon Park NC 14m NE Rowlands Pharmacy Sundon Park Dental Cheynes Infant 533m NE Sundon Park Junior Lealands High 134m N 100% within EM1 site Futures Fun Factory Grampian Way 435m E Toddington Rd Gill Blower's Nursery - Within Scott Rd Green Hill Rise/Sundon Shops Leagrave 1525m SE 698m E Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 948m SE Vacant land between Sundon Park Road (Sundon Park Pharmacy) Practice 145m SE 498m NE 1138m E (Allotment) 230m SW Leabank Site 1020m SE ELR site 67m SE >100m from Airport/M1 368 0.60 - 30 - vacant and Scott Road - COMPOSITE 176m SE

Stopsley DC 1040m W Stopsley Village Practice Village Dental Practice Someries Infant 693m Putteridge Primary 516m Putteridge High 584m EM1 site 1359m SE; EM3 Stopsley Common Ashcroft Road 1061m W 86% within Wandon Hart Hill Nursery 2595m Jansel House Green ELR Telscombe Way/Hayling None within 3km Within site Not ALC1/2/3 Not PDL >50m from AQMA, SPZ3 None within 3km 1013m W 1207m W SW NW NW site 1963m SE; LLA1 Site 1063m NW Close (Amenity); adj to SW site 995m W Dr 92m SE >100m from Airport/M1 369 Open space, Wandon Close 1.01 - 51 - open space 1540m S; BA1 1070m NW Selsey Drive (ANG)

Marsh Road DC 677m Jardines Pharmacy 129m Leagrave Dental Practice The Ferrars Academy Barnfield Moorlands Challney High School for EM1 site 203m SE Lewsey Sports Park Addington Way 2 411m Addington Way Sports Gill Blower's Nursery - Empress Rd Green ELR Torquay Dr/High St 11m Leagrave 493m NE 618m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 701m NE NE SE 23m N 1167m SW Primary 373m SW Girls 513m SW 1291m W S Field 357m SW Mossdale Site 565m NW site 665m E W >100m from Airport/M1 370 Leagrave Service Station, High Street 0.28 - 21 - vacant

Marsh Rd DC 1317m SW; Petros Medical Practice Bramingham Dental Warden Hill Infant 513m Warden Hill Jnr 504m SE Woodlands Secondary EM1 site 398m NE Lea Manor Recreation Grasmere Avenue 267m 100% within Bramingham Grasmere Children's Bramingham Business Marsom Grove/Newbold Leagrave 1621m SW 150m NW 100% is ALC2 Not PDL >50m from AQMA, SPZ2 Waulud's Bank 1134m Freeman Ave 346m NW 183m N Clinic 434m NW E 647m W Centre 1000m NW NE Rd/Icknield Way Centre 329m NE Park 400m NE Rd 110m N >100m from Airport/M1 SW 371 Open space (Barton Hills), Icknield Way 1.61 - 81 - open space (FUTURE SITE) (Amenity); Newbold Rd (ANG) 113m NE

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 7 / 12 SEA Objectives C25 Impact on Listed C26 Impact on historic C27 Impact on C28 Impact on AONB C29 Impact on SSSI C30 Impact on AGLV C31 Impact on ALLI C32 Impact on Green C33 Impact on LNR C34 Impact on CWS C35 Impact on other C36 Impact on open C37 Impact on C38 Impact on Lea C39 Impact on Flood SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Building P&G Conservation Area Belt SNCI space allotment tributaries Zone Little Bramingham None within 3km None within 3km 1550m N Galley and Warden Hills None within 3km None within 3km 1002m N Leagrave Common and Leagrave Common CWS River Lea DWS 708m S Adjacent to Sherd Close Willow Way 750m S ENV 20 622m SW Not FZ2/3 Farmhouse (GII) 737m E 2108m E Wauluds bank Proposed 482m W Marsh Farm (Amenity) 0 +/- +/- 0 0 + 0 + 0 +/- ++ 0 + +/- Sherd Lodge, Sherd Close 333 LNR 482m W

Castle St Baptist Union Luton Hoo (GII) 1201m Town Centre 60m NW None within 3km None within 3km 1087m W Hart Hill 743m NE 1202m SE None within 3km River Lea CWS 515m NE River Lea DWS 429m N Windmill Road Island Gypsy Ln Allotments ENV 20 515m NE Not FZ2/3 Chapel (GII) within site SE (Amenity) 248m S Windmill Road 808m E Land & buildings at Castle Street/Oxford 0 0 +/- 0 0 + +/- + 0 ++ ++ 0 ++ + 335 Road and Park Viaduct

Wandon End Farmhouse Putteridge Bury (GII) None within 3km None within 3km None within 3km 345m S Hart Hill 2620m W Adjacent to the site None within 3km Adjacent to Winch Hill Dairyborn Scarp DWS Adjacent to Wigmore Wigmore Valley Park ENV 20 2772m SW Not FZ2/3 (GII) 301m NE 2027m NW Wood CWS 1316m W Valley Park Natural Allotment 249m NW Wigmore employment area, Eaton Green - +/- -- 0 0 - 0 + 0 +/- ++ 0 -- - 336 Space (Natural and Semi- Road natural Greenspace) Stockwood House Stable Luton Hoo (GII) 1463m Luton South 1117m NE 1741m W None within 3km 1125m N Stockwood Park 12m E Adjacent to the site None within 3km Stockwood Park CWS Stockwood Park DWS Stockwood District Park London Rd 792m NE ENV 14 2172m NE Not FZ2/3 Block (GII) 535m E SE 12m E 416m E (Major sports and Leisure +/- 0 -- +/- 0 - 0 + 0 + ++ 0 - - Land west of Newlands Road 337 site) 11m E

111 Butterfield Green Wardown Park (GII) High Town 2127m S 75% within Chilterns Galley and Warden Hills 312m S Hart Hill 2270m S 79.6% within green belt Galley and Warden Hills 19% within Bradger's Hill Hay Wood and Stopsley 13.4% w/in Bushmead Park New Bedford Road 976m ENV 20 917m W Not FZ2/3 Road 829m E 1039m SW AONB 872m NW 872m NW CWS Common DWS 156m SE (ANG); 2.9% w/in Bradgers Hill SW (ANG); 0.2% w/in Cromer Way ------0 0 - 0 + 0 +/- ++ 0 - + Land east of Bushmead 338 (Amenity); Stopsley Common (ANG) 74m SE St Christopher's Church Wardown Park (GII) 673m High Town 837m SW 1193m N Galley and Warden Hills 315m NW Hart Hill 895m S 842m N Galley and Warden Hills The Chase CWS 178m Stockingstone Hill DWS St Martin's (Natural and Stockingstone Rd 249m ENV 20 821m W Not FZ2/3 (GII) 179m E W 2619m N 2619m N NE 249m W semi-natural greenspace) W 0 0 -- 0 0 +/- 0 + 0 +/- ++ 0 - - Land at Stockingstone Road 339 106m N

Castle St Baptist Union Luton Hoo (GII) 1159m Town Centre 152m NW None within 3km None within 3km 1181m W Hart Hill 796m NE 1162m SE None within 3km River Lea CWS539m NE River Lea DWS 512m N Windmill Road Island Gypsy Ln Allotments ENV 20 539m NE Not FZ2/3 Chapel (GII) 64m NW SE (Amenity) 189m S Windmill Road 798m E 0 0 +/- 0 0 + 0 + 0 ++ + 0 + + Land at Union Street/ Oxford Road 340

Little Bramingham Wardown Park (GII) None within 3km 5.1m NE Adjacent to 'Galley and 1940m SE None within 3km 49m E Adjacent to 'Galley and Adjacent to 'Galley and Great Bramingham Park 99.3% within Weybourne Riddy Lane 1417m S ENV 20 853m S Not FZ2/3 Farmhouse (GII) 1239m 2323m S Warden Hills Warden Hills SSSI Warden Hills CWS DWS 1112m NW Drive (ANG); Lancaster -- -- - 0 0 +/- 0 + 0 +/- + 0 +/- + Land at Weybourne Drive 341 W Ave (Amenity) 112m NW

Church of St Luke (GII) None within 3km None within 3km 1509m S Blow's Down 2065m SW 2226m SE None within 3km 1267m NW Leagrave Common and River Lea CWS 313m NW River Lea DWS 308m NW Addington Way Sports Knapps Farm 732m N ENV 20 319m NW Not FZ2/3 49m NE Wauluds bank Proposed Field (Amenity) 149m SW 0 0 +/- 0 0 + 0 + 0 - ++ 0 + + The Laurels, Ely Way 342 LNR 789m N

Church of St Luke (GII) None within 3km None within 3km 1421m S Blow's Down 1933m SW 2222m SE None within 3km 1179m NW Leagrave Common and River Lea CWS 270m NW River Lea DWS 246m NW Addington Way Sports Ravenhill Way 660m NW ENV 20 273m NW Not FZ2/3 179m NE Wauluds bank Proposed Field (Amenity) 12m SW Westlea Old Peoples Home, 121 High 0 0 - 0 0 + 0 + 0 - ++ 0 + + 343 LNR 882m NE Street

Holy Trinity Church (GII) Wardown Park (GII) Rothesay 2389m SE 2134m NE Galley and Warden Hills 1976m E Hart Hill 2958m SE 2039m E Leagrave Common and Biscot Churchyard CWS River Lea DWS 481m NE Adjacent to Alder Cres Nunnery Lane 496m NE ENV 20 583m NE Not FZ2/3 227m NE 1417m E 2136m NE Wauluds bank Proposed 132m NE (Amenity) 0 +/- +/- 0 0 + 0 + 0 +/- + 0 +/- + Milan Day Centre, Solway Road North 345 LNR 1341m NW

Central Block St Mary's Wardown Park (GII) 602m Rothesay 316m SW 2542m N None within 3km 750m SW Hart Hill 927m E 1802m SW None within 3km River Lea CWS 113m NE River Lea DWS 80mNE The Moor (Amenity) 82m Ferndale Allotments ENV 20 116m NE 100% within FZ2 Hospital 250m SW N NE 1003m W 0 0 - -- 0 + 0 + 0 +/- + 0 + + 27 Crawley Road 348

Church of St Luke (GII) None within 3km None within 3km 1503m S Blow's Down 2025m SW 2260m SE None within 3km 1208m NW Leagrave Common and River Lea CWS 270m NW River Lea DWS 255m NW Addington Way Sports Ravenhill Way 711m W ENV 20 275m NW Not FZ2/3 146m NE Wauluds bank Proposed Field (Amenity)104m SW 0 0 +/- 0 0 + 0 + 0 - + 0 + + 97 High Street 349 LNR 841m NE

Stockwood House Stable Luton Hoo (GII) 1643m Luton South 1079m E 1821m W None within 3km 1054m N Stockwood Park 20m SE 69m SW None within 3km Stockwood Park CWS Stockwood Park DWS Stockwood District Park London Rd 758m E ENV 14 2088m NE Not FZ2/3 Block (GII) 616m E SE 20m SE 500m E (Major sports and Leisure +/- 0 - 0 0 +/- 0 + 0 +/- + 0 - +/- The Barn Owl, Leyhill Drive 350 site) 20m SE

Christ Church (GII) 37m Wardown Park (GII) 65.3% within Town 2542m N None within 3km None within 3km Hart Hill 826m E 1671m SW None within 3km River Lea CWS 491m N River Lea DWS 300m NE Rothesay Cemetery London Rd 1101m S ENV 20 2451m N Not FZ2/3 NW 1025m N Centre (Churchyards and 0 0 +/- 0 0 + - + 0 - ++ 0 ++ + 27A Upper George Street 351 cemeteries) 334m SW

7 New Bedford Road Wardown Park (GII) 739m Town Centre 170m SE 2630m N None within 3km 757m SW Hart Hill 789m E 1792m SW None within 3km River Lea CWS 207m N River Lea DWS 113m N The Moor (Amenity) Ferndale Allotments ENV 20 170m N 28% within FZ2 (GII) 103m SE N 192m N 1077m W 0 0 +/- - 0 + 0 + 0 +/- ++ 0 ++ + 40-58 Collingdon Street 352

Former Bingo Hall (GII) Wardown Park (GII) 977m Rothesay 492m S 2112m W None within 3km 264m S Stockwood Park 1618m S 1126m SW Leagrave Common and Dallow Downs CWS River Lea DWS 748m E Cohen's Ferndale Allotments ENV 20 826m E Not FZ2/3 398m E NE Wauluds bank Proposed 264m S Yard/Shaftesbury Rd 294m SW +/- +/- +/- 0 0 + 0 + 0 +/- ++ 0 + + Car park adj to 95 Maple Road East 353 LNR 2865m NW (Amenity) 7m NW

Moat House (GII) 435m S Wardown Park (GII) High Town 2968m SE 1231m NE Galley and Warden Hills 1833m SE None within 3km 1273m NE Leagrave Common and Adjacent to Icknield River Lea DWS 184m SW Adjacent to Birdsfoot Riddy Lane 275m S ENV 20 223m SW Not FZ2/3 1618m SE 1216m NE Wauluds bank Proposed School CWS Lane (amenity) +/- +/- +/- 0 0 + 0 + 0 - + 0 +/- + Shops 247-259 Birdsfoot Lane 354 LNR 1494m W; Galley and Warden Hills SSSI Holy Trinity Church (GII) Wardown Park (GII) Rothesay 2304m SE 1909m SW Galley and Warden Hills 1697m S None within 3km 1560m SW Leagrave Common and River Lea CWS 766m N River Lea DWS 735m N Blundell Road Rec Limbury 835m N ENV 20 775m N Not FZ2/3 910m NE 1896m E 2779m NE Wauluds bank Proposed (Amenity) 219m E 0 0 +/- 0 0 + 0 + 0 - ++ 0 +/- - Telephone Exchange, 177 Waller Avenue 355 LNR 1091m NW

Holy Trinity Church (GII) Wardown Park (GII) Rothesay 2332m SE 2010m SW Galley and Warden Hills 1751m S None within 3km 1666m SW Leagrave Common and River Lea CWS 726m N River Lea DWS 698m N Blundell Road Rec Limbury 798m N ENV 20 734m N Not FZ2/3 833m NE 1831m E 2724m NE Wauluds bank Proposed (Amenity) 147m E 0 0 +/- 0 0 + 0 + 0 - ++ 0 +/- - 187-189 Waller Avenue 356 LNR 1091m NW

Former Bingo Hall (GII) Wardown Park (GII) 559m Rothesay 323m S 2646m NE None within 3km 604m SW Hart Hill 1190m E 1616m SW None within 3km River Lea CWS 306m E River Lea DWS 232m E The Moor (Amenity) Ferndale Allotments ENV 20 308m E Not FZ2/3 25m SW NE 115m E 725m W 0 0 +/- 0 0 + 0 + 0 +/- ++ 0 + + 68-80 Dunstable Road 357

Chaul End Farmhouse Wardown Park (GII) Rothesay 1661m E 986m W Blow's Down 2355m W 389m S Stockwood Park 2497m 339m SW Leagrave Common and Dallow Downs CWS Dallow Lane DWS 221m Foxdell Neighbourhood Bradley Road Allotments ENV 20 2047m NW Not FZ2/3 (GII) 961m W 2195m E SE Wauluds bank Proposed 389m S W Park (Amenity 589m W 0 0 - 0 0 +/- 0 + 0 - ++ 0 +/- + Land east of Aldi and B&Q, Dallow Road 358 LNR 2223m N; Cottage Greenspace) 206m W Bottom Fields 2676m SW 57 Compton Ave (GII) Wardown Park (GII) None within 3km 2256m N Galley and Warden Hills 2925m S None within 3km 1658m N Leagrave Common and River Lea CWS 5m S 11.2% within River Lea Adjacent to Limbury Willow Way 10m S ENV 20 7m S 0.1% within FZ2; FZ3 6m 860m SW 2358m SE 2282m NE Wauluds bank Proposed DWS Riverside Park (Natural S - +/- +/- +/- 0 + +/- + 0 - ++ 0 + + Bramingham Centre, Weltmore Road 359 LNR 157m NW and semi-natural greenspace) Hart Lane Water Tower Luton Hoo (GII) 1565m S High Town 1588m W 2792m NW None within 3km 1464m SE Hart Hill 929m W 1234m S None within 3km Un-named ENV5 site Dairyborn Scarp DWS Falconers Rd (Amenity) Hart Hill Ln Allotments ENV 20 1389m SW Not FZ2/3 (GII)1067m W 175m SE 116m E 2mW 1005m W 0 +/- +/- 0 0 + 0 + 0 - ++ 0 +/- +/- International House, Eaton Green Road 360

Holy Trinity Church (GII) Wardown Park (GII) Rothesay 1835m SE 1598m SW Blow's Down 2733m W 1134m S Stockwood Park 2922m 1122m SW Leagrave Common and Dallow Downs CWS Hatter's Way DWS 769m Kingsway Rec Bradley Road ENV 20 1395m SW Not FZ2/3 1302m NE 1912m E SE Wauluds bank Proposed 1127m S SW Neighbourhood Park Allotments906m SW 0 0 +/- 0 0 + 0 + 0 - ++ 0 +/- + 2-32 Beechwood Road 361 LNR 1650m NW (Urban P and G) 185m SE

Wandon End Farmhouse Putteridge Bury (GII) None within 3km None within 3km None within 3km 1305m S Hart Hill 2833m W 82m E None within 3km Wigmore Park CWS 8m Dairyborn Scarp DWS 100% within Wigmore Wigmore Valley Park None within 3km Not FZ2/3 (GII) 384m NE 1984m NW SE 1506m W Valley Park Natural space Allotment 255m W - -- -- 0 0 - 0 + 0 - + 0 - + Land south of Eaton Green Road 362 (Natural and semi-natural greenspace) 57 Compton Ave (GII) Wardown Park (GII) None within 3km 2183m SW Galley and Warden Hills 2335m S None within 3km 1887m SW Leagrave Common and River Lea CWS 374m NE River Lea DWS 352m N Limbury Riverside Park Limbury 408m NE ENV 20 378m NE Not FZ2/3 642m W 2329m E 2650m NE Wauluds bank Proposed (Natural and semi-natural 0 0 +/- 0 0 + 0 + 0 +/- ++ 0 + + Royal Mail, Sarum Road 363 LNR 547m NW greenspace) 352m N

Church of St Andrew Wardown Park (GII) Rothesay 1761m SE 1619m SW Blow's Down 2777m W 1077m S Stockwood Park 2854m 1118m SW Leagrave Common and Dallow Downs CWS Hatter's Way DWS 768m Kingsway Rec Bradley Road Allotments ENV 20 1522m N Not FZ2/3 (GII) 1376m E 1846m E SE Wauluds bank Proposed 1069m S SW Neighbourhood Park 937m W 0 0 +/- 0 0 + 0 + 0 - ++ 0 - + 10-12 Caleb Close 364 LNR 1784m NW (Urban P and G) 120m S

101 Park St (GII) 71m NW Luton Hoo (GII) 828m SE Town Centre 433m NW None within 3km None within 3km 1556m W Hart Hill 636m N 827m SE None within 3km River Lea CWS 191m E River Lea DWS 224m NE Manor Rd N'hd Park Gypsy Lane Allotments ENV 20 194m E Not FZ2/3 (Urban P&G) 43m NE Windmill Rd 384m E 0 0 +/- 0 0 + 0 + 0 +/- ++ 0 +/- + 146-158 Park Street 365

Church of St Mary (GII) None within 3km None within 3km 1195m N Sundon Chalk Quarry None within 3km None within 3km 500m N Leagrave Common and Leagrave Common CWS River Lea DWS 1149m SE Grampian Way (Amenity) Toddington Road 487m ENV 20 1041m SE Not FZ2/3 1257m N 1205m NW Wauluds bank Proposed 628m E 456m E S 0 0 +/- 0 0 + 0 + 0 - + 0 - + The Favourite, 298 Sundon Park Road 366 LNR 628m E

Church of St Mary (GII) None within 3km None within 3km 1167m NE Sundon Chalk Quarry None within 3km None within 3km 10m N Leagrave Common and Sundon Chalk Pits CWS River Lea DWS 1724m SE Chestnut Ave 365m NE Toddington Road 953m ENV 20 1516m S Not FZ2/3 901m N 576m NW Wauluds bank Proposed 580m NW SE 0 0 - 0 0 +/- 0 + 0 -- ++ 0 - - 166 Camford Way 367 LNR 1308m E

Church of St Mary (GI) None within 3km None within 3km 1439m N Sundon Chalk Quarry None within 3km None within 3km 742m N Leagrave Common and Leagrave Common CWS River Lea DWS 880m SE Grampian Way (Amenity) Toddington Road 230m ENV 782m SE Not FZ2/3 1498m N 1399m NW Wauluds bank Proposed 621m E 392m E SW Vacant land between Sundon Park Road 0 0 +/- 0 0 + 0 + 0 - ++ 0 +/- - 368 LNR 620m E and Scott Road - COMPOSITE

Dovecote at Home Farm Adjacent to Putteridge High Town 2740m SW 1211m NW None within 3km 1966m W Hart Hill 2588m SW Adjacent to site None within 3km 17.1% within Wandon Great Hayes Wood DWS 86% within Wandon Wigmore Ln 691m SW ENV 20 2756m W Not FZ2/3 (GII) 600m N Bury (GII) End Park CWS 360m NW Close (Amenity); adj to -- -- - 0 0 +/- +/- + 0 -- ++ 0 +/- +/- Open space, Wandon Close 369 Selsey Drive (ANG)

Church of St Luke (GII) None within 3km None within 3km 1687m S Blow's Down 2274m SW 2302m S None within 3km 1335m NW Leagrave Common and River Lea CWS 385m W River Lea DWS 380m NW Addington Way Knapps Farm 628m N ENV 20 393m W Not FZ2/3 55m SW Wauluds bank Proposed (Amenity) 338m S 0 0 +/- 0 0 + 0 + 0 - ++ 0 +/- + Leagrave Service Station, High Street 370 LNR 630m NE

Little Bramingham Wardown Park (GII) None within 3km 938m E Galley and Warden Hills 2398m SE None within 3km 985m E Leagrave Common and Bramingham Wood CWS River Lea DWS 561m S 100% within Bramingham Limbury 894m SW ENV 20 23m SE 2.6% within FZ2; 0.7% Farmhouse (GII) 310m N 2328m SE 931m E Wauluds bank Proposed 213m NW Rd/Icknield Way within FZ3 +/------0 -- 0 + 0 - ++ 0 +/- + Open space (Barton Hills), Icknield Way 371 LNR 1201m W; Galley (Amenity) and Warden Hills SSSI

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 8 / 12 Luton Possible Allocations Site Assessment Criteria (as amended) C1 Dist to centres C2 Dist to health C3 Dist to dental C4 Distance to infant C5 Dist to junior C6 Dist to 2ary C7 Dist to emp C8 Dist to sports C9 Dist to play C10 Dist to open space C15 Dist crèche C16 Loss of emp C17 Dist to bus C18 Dist to train C19 Dist to cycle C20 Loss of agric C21 Use of PDL C22 Dist to AP source C23 Impact on SPZ C24 Impact on SAM

Sundon Park NC 289m Dr KM Swan's Practice Sundon Park Dental Cheynes Infant 817m NE Pirton Hill Primary 469m Lealands High 463m NE 100% within EM1 site Futures Fun Factory Grampian Way 700m NE Adjacent to Toddington Gill Blower's Nursery - 99.9% within Sedgewick Harry Scott Court/Os 10 Leagrave 1409m SE 653m S 15.3% is ALC2 PDL >50m from AQMA, SPZ3 Waulud's Bank 975m E Units 5-8, North Luton Industrial Estate, NE 327m E Practice 259m NE S 1381m E Rd (Allotments) Mossdale Site 830m SE Rd Green ELR site 15m SE >100m from Airport/M1 372 1.60 - 80 - B8 Sedgwick Road

Sundon Park NC 1360m Pastures Way 587m S Tomlinson Orthodontic The Ferrars Academy Southfield Primary 416m Barnfield West Academy EM1 site 726m N Lewsey Sports Park 565m Lewsey Park 655m S Ravenhill Way (Amenity) Pastures Way Nursery Bay Close Green ELR Adjacent to Coltsfoot Leagrave 1728m E 6m NW 100% is ALC2 Not PDL >50m from AQMA, SPZ2 Waulud's Bank 1696m E NE: St Dominic's Sq NC Centre 849m SW 985m SE SW 1000m S S 112m NE 423m SW site 726m N Green/ Kestrel Way >100m from Airport/M1 373 Aerial Site, Kestrel Way 1.24 - 62 - open space 732 SW (FUTURE SITE)

Sundon Park NC 1166m Khanchandani and Hockwell Surgery 720m E The Ferrars Academy Pirton Hill Primary 408m Challney High School for EM1 site 646m N Lewsey Sports Park 512m Lewsey Park 630m SW 100% within Ravenhill Pastures Way Nursery Sedgewick Rd/Progress Goldcrest Leagrave 1428m E Within site 100% is ALC2 Not PDL M1 87m NE SPZ2 Waulud's Bank1453m E 2.12 - 106 - open NE: Hockwell Ring NC Partners _ Hockwell Ring 829m S NE Girls 1017m SE S Way (Amenity); Ickley Cl 629m SW Way Green Elf site 646m Close/Ravenhill Way 15m 374 Amenity land (1) adj M1, Ravenhill Way space 506m E (FUTURE SITE) 501m NE (Amenity) 71m NE N NW

Sundon Park NC 1373m Pastures Way 408m W Hockwell Surgery 699m The Ferrars Academy Leagrave Primary 305m E Challney High School for EM1 site 889m E Lewsey Sports Park 336m Lewsey Park 435m SW 99.8% w/in Lewsey Park Pastures Way Nursery Sedgewick Rd/Progress Heacham Cl/Ravenhill Leagrave 1327m E 44m NE 54.3% is ALC2 Not PDL >50m from AQMA, SPZ2 Waulud's Bank1431m NE 2.28 - 114 - open NE: Hockwell Ring NC NE 459m S Girls 651m SE W (Urban P&G); adj to 647m W Way Green Elf site 977m Way 137m N >100m from Airport/M1 375 Amenity land (2) adj M1, Ravenhill Way space 494m NE (FUTURE SITE) Ravenhill Way N (Allotment) Marsh Rd DC 1961m N Lister House Surgery Leagrave Dental Foxdell Infant 1065m E Foxdell Jnr 252m E Challney High School for 100% within EM1 site Lewsey Sports Park Foxdell 299m SE Foxdell Neighbourhood Gill Blower's Nursery - 100% within Cosgrove Cosgrove Rd/Dallow Rd Leagrave 2104m N 189m N 100% is ALC3 PDL M1 71m SW SPZ1 Medieval Village 100m 929m NE Sedation Clinic 720m N Boys 1027m N 2130m NW Park (Amenity Mossdale Site 2337m N Way Green ELR site 297m E west of Zouches Farm 376 Land west of 23 Cosgrove Way 0.21 - 10 - B2/8 Greenspace) 150m SE 1930m W

Bury Park DC 787m E Medina 380m NE Beech Hill Dental Foxdell Infant 164m SW Maidenhall Primary 600m Denbigh High 1421m NE 100% within EM1 site Stockwood District Park Runley Rd 192m S Dallow Downs 183m S Rothesay Road Nursery 100% within Finway Foxdell Infant Luton 1927m E 85m N Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 2657m N Practice 520m E N 2022m SE 1568m SE Green ELR site School/Dallow Rd 107m >100m from Airport/M1 377 96 Kingsway 0.93 - 46 - B2 S

Marsh Rd DC 721m NW Lloyds Pharmacy 428m N Marsh Road Dental St Joseph Infant 421m N Norton Rd Primary 495m Challney High School for 100% within EM1 site Futures Fun Factory Blundell Rd 174m NE Blundell Road Rec Gill Blower's Nursery - 0.1% Arundel Road Avenue Leagrave 1223m NW 996m N Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1451m Practice 355m NW N Boys 1391m W 2459m N (Amenity) 182m NE Mossdale Site 1891m Amber ELR site Grimaldi/Leagrave Rd >100m from Airport/M1 NW 378 81 Arundel Road 0.48 - 24 - vacant NW 131m E

Bury Park DC 1175m E; Makan MPS Dispensing Beech Hill Dental Foxdell Infant 281m SE Foxdell Jnr 530m W Challney High School for 100% within EM1 site Stockwood District Park Runley Rd 496m SE Dallow Downs (natural Rothesay Road Nursery 100% within Bilton Way Warren Rd/Dallow Rd Leagrave 2229m N 155m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Waulud's Bank 2515m N TC 1819m E Chemist; Mr M Makan Practice 896m E Boys 1562m NW 2311m SE and semi-natural 1963m SE Green ELR site 143m SW >100m from Airport/M1 379 10-12 Bilton Way 0.27 - 14 - B2 683m N greenspaces) 417m S

Wigmore DC 610m NE Asda Stores (Pharmacy) Vogue Dental Care 949m Crawley Green Infant Wigmore Primary 779m Ashcroft High 826m N 100% within EM1 site; Wigmore Valley 598m Raynham Community Raynham Way 237m NE Hart Hill Nursery 1569m 99.9% within Airport Frank Lester Way10m SW Luton Airport Parkway 1079m E Not ALC1/2/3 PDL Airport 21m S SPZ3 Someries Castle 1544m S 715m NE W 1024m W NE KR1 site 814m SW; LLa1 NE Centre 316m NE W Executive Park Green 1603m SW 380 De Havilland House, President Way 0.53 - 26 - B2 site 20.5m S ELR site

TC 462m NW Boots the Chemists Ltd Mr T J Maeer Dental Crawley Green Infant Surrey St Primary 649m Barnfield Skills Academy 100% within EM1 site; Hightown Community Manor Rd 302m NW Crawley Green Rd Hart Hill Nursery 764m N Kimpton Rd Green ELR Central Car Park Luton Airport Parkway 388m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Someries Castle 1727m Car storage area adjacent to 2-20 960m NW Surgery 946m W 866m NE W 1138m NW EM2 site 730m S; KR1 Sports and Arts Centre Cemetery (Cemeteries site 20m N entrance/Kimpton Rd 292m SE >100m from Airport/M1 SE 381 0.34 - 17 - vacant Kimpton Road site 282m NE; LLa1 site 1184m NW and Churchyards) 156m 35m NE 832m E; CA1 site 462m N TC 518m NW Castle St Surgery 778m Mr T J Maeer Dental Crawley Green Infant Surrey St Primary 352m Barnfield Skills Academy EM1 site 33m N; EM2 Stockwood District Park Manor Rd 415m N Manor Road Hart Hill Nursery 1027m Osbourne Rd Green ELR Alton Road/Cutenhoe Luton Airport Parkway 7m SW Not ALC1/2/3 Partially PDL >50m from AQMA, SPZ3 Someries Castle 1721m E NW Surgery 855m NW 1184m NE W 1327m N site 373m S; KR1 site 989m SW Neighbourhood Park N site 33m N Rd 47m S 347m E >100m from Airport/M1 382 Land r/o 2-26 Osborne Road 1.70 - 85 - vacant 554m NE; LLA1 881m E; 296m NW CA1 site 518m NW TC 602m NW; Castle Street Surgery Mr T J Maeer Dental Crawley Green Infant Surrey Street Primary Barnfield Skills Academy EM1 34m NE; EM2 479m Stockwood District park Manor Road 404m NW Crawley Green road Hart Hill Nursery 925m N Osbourne Road ELR Griffin House/Osbourne Luton Airport Parkway 183m SW 0.4% of site is ALC3 Not PDL >50m from AQMA, SPZ3 Someries Castle 1575m E 2.52 - 126 - open 958m W Surgery 992m NW 1012m NE 546m W 1285m NW S; KR1 387m NE; LLA1 1183m W Cemetery 319m N Green 65m NW Rd 65m NW 167m E >100m from Airport/M1 383 Land south of Gypsy Lane space 716m E; CA1 602 NW

St Dominic's Square NC Halfway Chemist 497m Leagrave Dental Clinic The Ferrars Academy Ferrars Junior 743m N Benfield West Academy 100% within EM1 Lewsey Park Pool 1043m Cradock Road 2m W 100% within Cradock Pastures Way Nursery site is 100% within Shelley Rd/Dunstable Rd Leagrave 2153m NE 297m S Not ALC1/2/3 Not PDL >50m from AQMA, SPZ2 Medieval village 100m 1509m NW NE 1206m E 676m N 884m NW N Road (Amenity); Poet's 1380m NW Craddock Road ELR 118m N >100m from Airport/M1 west of Zouches Farm 384 Cradock Road Play Area 0.22 - 11 - open space Green (Amenity) 432m Green 1057m SW NW St Dominic's Square NC Halfway Chemist 493m E Leagrave Dental Clinic The Ferrars Academy Ferrars Junior 667m N Benfield West Academy 100% within EM1 Lewsey Park Pool 958m Cradock Road 78m S Adjacent to Cradock Pastures Way Nursery site is 100% within Shelley Rd/Dunstable Rd Leagrave 2113m NE 370m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Medieval village 100m Land behind The Stadium Estate, 1390m NW 1214m E 599m N 760m NW N Road (Amenity) 1289m NW Craddock Road ELR 42m N >100m from Airport/M1 west of Zouches Farm 385 0.41 - 20 - vacant Cradock Road Green 1045m SW

Marsh Road DC 1856m Petros Medical Practice Bramingham Dental Warden Hill Infant 479m Bramingham Primary Cardinal Newman EM1 3m NE: Lea Manor Recreation Grasmere Avenue 36m 100% w/in Bramingham Grasmere Children’s Bramingham Business Adjacent to Grasmere Leagrave 2177m SW 175m W 100% of site is ALC2 Not PDL >50m from AQMA, SPZ2 None within 3km SW (FUTURE; Freeman 134m NW Clinic 388m NW SE 425m NW Catholic 622m NE Centre 1298m W SE Rd / Icknield Way Centre 68m SE Park ELR Green 6m NE Nursery/Icknield Way >100m from Airport/M1 386 Barton Hills Open Space, Icknield Road 0.77 - 39 - open space Avenue NC 288m NW) (Amenity); adj to Newbold Rd (ANG) High Town NC 895m W; Royal Pharmacy 1011m Vogue Dental Care 449m Crawley Green Infant Wenlock Junior (CofE) Barnfield Skills Academy EM1 337m SE; EM2 Hightown Community Abbotswood Road 425m Powdrill's Field (Amenity) Hart Hill Nursery 350m No ELR site Abbots Wood Rd/St Luton 911m W 941m SW Not ALC1/2/3 Not PDL >50m from AQMA, SPZ3 Someries Castle 2071m TC 679m SW; W NE 143m SE 75m SE 770m W 1686m S; KR1 333m SE; Sports and Arts Centre N 95m NE NW Anne's Parish Church >100m from Airport/M1 SE 387 124 Crawley Green Road 0.30 - 15 - D2 LLA1 767m E; CA1 679m 802m W 18m NW SW High Town NC 1801m Castle Street Surgery Mr T J Maeer Dental Crawley Green Infant Surrey Street Primary Barnfield Skills Academy EM1 34m NE; EM2 646m Hightown Community Manor Road 908m NW Crawley Green Rd Hart Hill Nursery 1311m Kimpton Rd ELR Green Luton Airport Railway Luton Airport Parkway 10m SW 20% of site is ALC3 PDL >50m from AQMA, Not SPZ1/2/3 Someries Castle 1055m E NW; TC 1077m W; 1479m W Surgery 1510m NW 1178m N 991m W 1739m NW SW; KR1 426m N; LLA1 Sports and Arts Centre Cemetery (Cemetery) NW site 50m NE Station 118m NW 133m NW >100m from Airport/M1 388 Vauxhall Storage Land, Parkway Road 1.17 - 59 - B8 299m NE 1785m NW 733m NW

Wigmore DC 1588m NE; ASDA Pharmacy 1655m Vogue Dental Care Crawley Green Infant Wenlock Junior (CofE) Ashcroft High 1710m N KR1 390m NW; 135% Wigmore Valley 1416m Raynham Way Polzeath Close (Amenity) Hart Hill Nursery 1438m 100% within Barratt Proctor Way / Percival Luton Airport Parkway 660m SW Not ALC1/2/3 PDL 13.5% within Luton Not SPZ1/2/3 Someries Castle 812m SE TC 1399m W; NE 1359m NW 1038m NW 1103m NW within LLA1 NE Community Centre 880m N NW Industrial Park ELR Green Way 268m N 703m W Airport 389 Mondi Packaging, Airport Way 1.15 - 58 - car park 1285m NE site.

Wigmore DC 1367m NE; ASDA Pharmacy 1445m Vogue Dental Care Crawley Green Infant Wenlock Junior (CofE) Ashcroft High 1470m N 33% within EM1; KR1 Wigmore Valley 1235m Raynham Way Polzeath Close (Amenity) Hart Hill Nursery 1351m 64% within Airport Proctor Way / Percival Luton Airport Parkway 949m SW Not ALC1/2/3 PDL 67% within Luton Airport SPZ3 Someries Castle 990m SE TC 1390m W; NE 1156m NW 881m NW 949m NW 390m NW; 67% within NE Community Centre 645m N NW Percival Way South ELR Way 55m NE 869m SW 390 Land around 113 Proctor Way 0.86 - 43 - B1 LLA1 1065m NE Green site

Wigmore DC 1369m NE; ASDA Pharmacy 1472m Vogue Dental Care Crawley Green Infant Wenlock Junior (CofE) Ashcroft High 1392m N 97% within EM1; KR1 Wigmore Valley 1320m Raynham Way Falconers Road Hart Hill Nursery 1225m 0.2% within Airport Proctor Way / Percival Luton Airport Parkway 828m SW Not ALC1/2/3 PDL 2.7% within Luton Airport SPZ3 Someries Castle 990m SE TC 1274m W; NE 1002m NW 725m NW 794m W 250m W; 3% within LLA1 NE Community Centre (Amenity) 534m N W Percival Way South ELR Way 196m NE 737m SW 391 Land at south-west end of Proctor Way 1.99 - 100 - vacant 1076m NE Green site

Wigmore DC 1115m NE; ASDA Pharmacy 1273m Vogue Dental Care 805m Crawley Green Infant Wenlock Junior (CofE) Ashcroft High 1137m N EM1 28m NW; KR1 Wigmore Valley 1166m Raynham Way Polzeath Close (Amenity) Hart Hill Nursery 1166m 99% within Airport Vauxhall Gate 3/Airport Luton Airport Parkway 1152m SW Not ALC1/2/3 PDL 100% within Luton SPZ3 Someries Castle 1348m TC 1301m W; NE NW 631m W 698m W 241m W; 100% within NE Community Centre 870m 289m N W Percival Way South ELR Way 192m NW 1012m SW Airport SE 392 Vacant land at former 140 Prospect Way 0.30 - 15 - vacant LLA1 NE Green site

Wigmore DC 1113m NE; ASDA Pharmacy 1268m Vogue Dental Care 582m Crawley Green Infant Wenlock Junior (CofE) Ashcroft High 911m N 100% within EM1; KR1 Wigmore Valley 1191m Raynham Way Falconers Road Hart Hill Nursery 1020m Kimpton Rd ELR Green Vauxhall Gate 3/Airport Luton Airport Parkway 59m SW Not ALC1/2/3 PDL Luton Airport 41m E SPZ3 None within 3km TC 1191m W NE NW 470m W 531m W 123m W; LLA1 41m E NE Community Centre 867m (Amenity) 94m N W site 32m W Way 21m W 521m W 393 Land adj Vauxhall Way 7.57 - 379 - car park NE

Sundon Park NC 793m W EMC Ward and Partners - Purley Centre 128m E Cheynes Infant 491m W Wauluds Primary 323m S Woodlands Secondary EM1 site 963m W Futures Fun Factory Berry Leys 96m W Wauluds Bank Drive Gill Blowers Nursery - Scott Rd Green ELR site Fitzwarin Cl/Wauluds Leagrave 1265m S 95m E Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 554m S Garage blocks at Sylam Close - Marsh Farm 128m E 474m E 148m NE (Amenity) 12m W Leabank Site 467m S 963m W Bank Rd 43m NW >100m from Airport/M1 394 0.20 - 10 - car park COMPOSITE

Sundon Park NC EMC Ward and Partners - Purley Centre 690m S Cheynes Infant 644m SW Whitefield Primary 254m Lea Manor High 550m SE EM1 site 1116m W Lea Manor Recreation Whitefield 363m S Luxemburg Close 72m Gill Blowers Nursery - SKF Green ELR site Whitefield Junior School Leagrave 1951m S 103m SW Partly within ALC3 PDL >50m from AQMA, SPZ3 Waulud's Bank 1246m S Garage blocks at Winchester Gardens - 1062mm SW; Purley Marsh Farm 690m S SW Centre 473m SE SW Leabank Site 1152m S 1156m SW 133m S >100m from Airport/M1 395 0.21 - 11 - car park COMPOSITE Centre (Marsh Farm) DC (FUTURE SITE) Marsh Rd DC 1092m E Dr Mizra 55m NW Hockwell Dentist Surgery The Ferrars Academy Leagrave 1ary 200m S Challney High School for EM1 606m SE Lewsey Sports Park 850m Mayne Ave 213m NE Adj to Green Court Gill Blowers Nursery - Not ELR site Strangers Way/Hockwell Leagrave 876m E 295m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 956m NE [FUTURE: Hockwell Ring 243m NE 858m SW Girls 553m S SW (Amenity) Mossdale 308m NE Ring 45m W >100m from Airport/M1 396 Garage blocks r/o 1-47 Strangers Way 0.24 - 12 - car park NC 78m NE]

Marsh Road DC 888m S Moakes Medical Centre Purley Centre 275m N Cheynes Infant 822m NW Wauluds Primary 109m Woodlands Secondary EM1 site 1200m W Futures Fun Factory Purley Centre (Freemans Sherd Close Marsh Farm Gill Blowers Nursery - Sarum Road Red ELR site Sherd Cl/Lygetun Dr Leagrave 984m S 23m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 321m SW Garage blocks at Flint Close - 275m N W 337m NE 447m N Green) 184m N (Amenity) 10m N Leabank Site 320m SW 1059m S 92m E >100m from Airport/M1 397 0.28 - 14 - car park COMPOSITE

Sundon Park NC 748m W EMC Ward and Partners - Purley Centre 268m SE Cheynes Infant 361m W Whitefield Primary 199m Lea Manor High 424m E EM1 site 888m W Futures Fun Factory Whitefield 35m NW Whitefield (Amenity) 10m Gill Blowers Nursery - Scott Rd Green ELR site Copenhagen Leagrave 1417m S 27m E Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 719m S Garage blocks at Waleys Close - Marsh Farm 267m E NW 137m E NW Leabank Site 619m S 888m W Cl/Wauluds Bank Dr 44m >100m from Airport/M1 398 0.28 - 14 - car park COMPOSITE W

Marsh Road DC 698m S Lloyds Pharmacy 447m N Purley Centre 447m N Cheynes Infant 855m NW Wauluds Primary 99m N Woodlands Secondary EM1 site 1077m W Futures Fun Factory Purley Centre (Freemans Wauluds Bank Drive Gill Blowers Nursery - Sarum Road Red ELR site Axe Close/Lygetun Dr Leagrave 751m S 29m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Waulud's Bank 54m SW Garage blocks at Arrow Close - 564m NW 610m N Green) 359m N (Amenity) 20m NE Leabank Site 99m W 914m S 59m E >100m from Airport/M1 399 0.61 - 31 - car park COMPOSITE

Stopsley DC 851m SE PJ Ward & Partners (GP) Village Dental Practice William Austin Infant Bushmead 1ary 148m Stopsley High 631m SE EM1 1930m NW; BA1 Stopsley Common 367m Bushmead Community 99.7% of site is Cromer Grasmere Children's Not ELR site Adjacent to Faiford Ave Luton 2485m S 379m SE 30.4% of site is ALC3 Not PDL >50m from AQMA, SPZ2 Dray's Ditches 2175m N 73m N 1039m E 1142m W NW 1141m NE SE Centre 316m N Way (Amenity); Centre 1844m NW Roundabout/Bushmead >100m from Airport/M1 400 Open space, Bushmead Road 0.70 - 35 - open space Bushmead Park (ANG) Rd 122m NE High Town NC 581m N; Boots Chemist 130m N Maeer Dental Surgery Hillborough Infant & Surrey St 1ary 461m SE Barnfield Skills Academy EM1 295m E; EM2 996m Hightown Community Hibbert St 389m S St Mary's Church Rothesay Road Nursery Not ELR site Crown Court / Flowers Luton 459m N 46m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2658m E within TC 49m NW Nursery 888m SW 813m NE S Sports and Arts Centre (Ch'yard/Cem'y) 169m 680m W Way 6m SW >100m from Airport/M1 401 Whitbread House, Flowers Way 0.40 - 134 - B1(a) 837m N NE

Marsh Rd DC 1010m NE Oakley Surgery 294m SE Leagrave Dental Practice The Ferrars Academy Leagrave 1ary 116m SW Challney High School for EM1 378m SE Lewsey Sports Park 865m Addington Way 374m SE Green Court (Amenity) Gill Blowers Nursery - Not ELR site Westlea/High St 54m SE Leagrave 816m NE 283m W Not ALC1/2/3 PDL M1 44m SW SPZ2 Waulud's Bank 971m NE [FUTURE: Hockwell Ring 300m E 772m SW Girls 338m S W 127m NW Mossdale 511m N 402 The Orchard Centre, Strangers Way 0.90 - 67 - D1 NC 296m N]

High Town NC 249m N; Boots Chemist 193m S Luton Dental Practice Hillborough Infant & St Matthews 1ary 633m N Barnfield Skills Academy EM1 575m SE; within Hightown Community Bell's Cl 761m N St Mary's Church Rothesay Road Nursery Guildford St ELR Green Hat Factory / Bute St Luton 145m N 9m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km within TC 300m SW Nursery 1139m SW 551m NE CA1 Sports and Arts Centre (Ch'yard/Cem'y) 296m SE 757m SW site 55m NW 35m N >100m from Airport/M1 403 47 Guildford Street 0.02 - 10 - B1(a) 561m NE

Bury Park DC 478m N; Cardiff Rd Surgery 124m Integrated Dental Hillborough Infant & Dallow 1ary 484m NW Barnfield Skills Academy EM1 955m NW; CA1 Stockwood District Park Brantwood Park 255m Rothesay Cemetery Rothesay Road Nursery Not ELR site Dunstable Pl / Stuart St Luton 715m NE 436m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 194m NE N Holdings 102m NW Nursery 592m S 1220m NE 194m NE 864m S NW (Ch'yard/Cem'y) 73m SW 81m SW 229m NE >100m from Airport/M1 404 Napier House, 17-21 Napier Road 0.02 - 17 - B1(a)

Bury Park DC 264m N; Sainsbury Pharmacy 77m Associated Dental Hillborough Infant & Dallow 1ary 419m NW Barnfield Skills Academy EM1 945m SE; within Hightown Community Brantwood Park 344m W Brantwood N'hood Park Rothesay Road Nursery Upper George St ELR Liverpool Rd / Dunstable Luton 477m NE 242m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km within TC NW Practice 76m NW Nursery 843m S 992m NE CA1 Sports and Arts Centre (Amenity) 251m W 343m SW Green site 29m S Rd 75m N >100m from Airport/M1 405 2 Dunstable Road 0.03 - 15 - B1(a) 986m NE

Bury Park DC 347m N; Cardiff Rd Surgery 77m Associated Dental Hillborough Infant & Dallow 1ary 463m NW Barnfield Skills Academy EM1 896m E; CA1 13m Stockwood District Park Brantwood Park 315m W Rothesay Cemetery Rothesay Road Nursery Upper George St ELR Dunstable Pl / Stuart St Luton 533m NE 272m E Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 13m NE W Practice 106m NW Nursery 723m S 1039m NE NE 982m S (Ch'yard/Cem'y) 220m 236m SW Green site 25m NE 78m E >100m from Airport/M1 406 Unity House, 111 Stuart Street 0.17 - 58 - B1(a) SW

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 9 / 12 SEA Objectives C25 Impact on Listed C26 Impact on historic C27 Impact on C28 Impact on AONB C29 Impact on SSSI C30 Impact on AGLV C31 Impact on ALLI C32 Impact on Green C33 Impact on LNR C34 Impact on CWS C35 Impact on other C36 Impact on open C37 Impact on C38 Impact on Lea C39 Impact on Flood SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Building P&G Conservation Area Belt SNCI space allotment tributaries Zone Church of St Luke (GII) None within 3km None within 3km 1737m N Sundon Chalk Quarry None within 3km None within 3km 376m W Leagrave Common and River Lea CWS 647m S River Lea DWS 726m SE Ickley Cl 403m SW Adjacent to Toddington ENV 20 651m S Not FZ2/3 1416m SE 1501m NW Wauluds bank Proposed Rd Units 5-8, North Luton Industrial Estate, 0 +/- - 0 0 +/- 0 + 0 - ++ 0 +/- - 372 LNR 674m SE Sedgwick Road

Church of St Luke (GII) None within 3km None within 3km 1921m S Blow's Down 1956m S None within 3km None within 3km 36m NW Leagrave Common and River Lea CWS 298m NE Lewsey Park DWS 575m Site is publicly accessible Ravenhill Way 269m SE ENV20 299m NE Not FZ2/3 1322m E Wauluds bank Proposed SE open space 0 0 -- 0 0 -- 0 + 0 - ++ 0 - + Aerial Site, Kestrel Way 373 LNR 1340m NE

Church of St Luke (GII) None within 3km None within 3km 1819m S Blow's Down 1944m S None within 3km None within 3km 138m NW Leagrave Common and River Lea CWS 150m N Lewsey Park DWS 373m 100% within Ravenhill Adjacent to Ravenhill ENV 20 155m N Not FZ2/3 992m E Wauluds bank Proposed S Way (Amenity) Way +/- -- -- 0 0 -- 0 + 0 - ++ 0 - + Amenity land (1) adj M1, Ravenhill Way 374 LNR 1270m E

Church of St Luke (GII) None within 3km None within 3km 1453m S Blow's Down 1636m SW 2654m SE None within 3km 551m NW Leagrave Common and River Lea CWS 84m S 4.3% within Lewsey Park 99.8% within Lewsey Park Adjacent to Ravenhill ENV 20 89m S Not FZ2/3 768m E Wauluds bank Proposed DWS (Urban P and G) Way - -- -- 0 0 -- 0 + 0 - ++ 0 - + Amenity land (2) adj M1, Ravenhill Way 375 LNR 1163m NE; Cottage Bottom Fields 2789m SW Chaul End Farmhouse Wardown Park (GII) Rothesay 2182m E 523m SW Blow's Down 1780m W 622m SE Stockwood Park 2879m 5.6m SW Leagrave Common and The Linces CWS 103m W Adjacent to Dallow Lane Foxdell Neighbourhood Bradley Rd Allotments ENV 14 1854m NW Not FZ2/3 (GII) 482m SW 2790m E SE Wauluds bank Proposed DWS Park (Amenity 327m N +/- 0 -- 0 0 +/- 0 + 0 - + 0 -- - Land west of 23 Cosgrove Way 376 LNR 2336m N; Cottage Greenspace) 150m SE Bottom Fields 2223m SW Former Bingo Hall (GII) Wardown Park (GII) Rothesay 992m SE 1561m W Blow's Down 2980m W 250m SE Stockwood Park 2022m 693m SW Leagrave Common and Dallow Downs CWS Foxdell DWS 808m W Dallow Downs CWS Ferndale Allotments ENV 20 1529m E Not FZ2/3 1114m E 1596m E SE Wauluds bank Proposed 249m S 183m S 510m SE 0 0 +/- 0 0 + 0 + 0 - ++ 0 - - 96 Kingsway 377 LNR 26902m N

Holy Trinity Church (GII) Wardown Park (GII) Rothesay 2121m SE 1960m SW Galley and Warden Hills 1552m S None within 3km 1568m SW Leagrave Common and Biscot Churchyard CWS River Lea DWS 984m N Blundell Road Rec Limbury 1083m N ENV 20 1007m N Not FZ2/3 899m NE 1740m E 2798m NE Wauluds bank Proposed 793m NE (Amenity) 182m NE 0 0 +/- 0 0 + 0 + 0 - ++ 0 - + 81 Arundel Road 378 LNR 2458m N

Chaul End Farmhouse Wardown Park (GII) Rothesay 1384m SE 1229m W Blow's Down 2634m W 417m S Stockwood Park 2311m 484m SW Leagrave Common and Dallow Downs CWS Foxdell DWS 472m W Dallow Downs 417m S Ferndale Allotments ENV 20 1940m E Not FZ2/3 (GII) 1208m W 1977m E SE Wauluds bank Proposed 417m S 910m E 0 0 +/- 0 0 + 0 + 0 - + 0 - - 10-12 Bilton Way 379 LNR 1417m S

Wigmore Hall Luton hood (GII) 1775m High Town 2112m W None within 3km None within 3km 1277m S Hart Hill 1445m W 1278m S None within 3km Wigmore Park CWS Dairyborn Scarp DWS Raynham Way 237m NE Wigmore Valley ENV 20 1871m SW Not FZ2/3 Farmhouse (GII) 914m SW 531m E 137m W Allotments 964m NE 0 0 - 0 0 + 0 + 0 +/- ++ 0 +/- - De Havilland House, President Way 380 NE

Vauxhall Motors Kimpton Luton hood (GII) 589m S Plaiter's Lea 877m NW None within 3km None within 3km 1430m E Hart Hill 500m N 539m SE None within 3km Church Cemetery, Luton River Lea DWS 234m W Crawley Green Rd Gypsy Lane Allotments ENV 20 238m W Not FZ2/3 Road (GII) 458m E CWS 156m N Cemetery (Cemeteries Windmill Road 47m SW Car storage area adjacent to 2-20 0 0 +/- 0 0 + 0 + 0 + ++ 0 + + 381 and Churchyards) 156m Kimpton Road N 101 Park St (GII) 452m Luton hood (GII) 347m Luton South 702m SW None within 3km None within 3km 1449m E Hart Hill 762m N 345m SE None within 3km 4.2% is within River Lea 95.6% is within River Lea Manor Rd N'hd Park Gypsy Lane Allotments ENV 20 5m N Not FZ 2/3 NW SE CWS DWS (Urban P&G) 296m NW Windmill Road 207m NE -- 0 +/- 0 0 + 0 + 0 + ++ 0 +/- + Land r/o 2-26 Osborne Road 382

Office Block, Vauxhall Luton Hoo (GII*) 322m S Luton South 873m SW None within 3km None within 3km 1292m E Hart Hill 660m N 309m SE None within 3km Adjacent River Lea S River Lea DWS 30m SW Site is open space Gypsy Lane 62m NW ENV20 14m SW FZ2/3 13m SW; Motors (GII) 345m E (Vauxhall Rec Ground) +/- 0 0 0 0 - 0 + 0 +/- ++ 0 +/- + Land south of Gypsy Lane 383

Chaul End Farmhouse None within 3km None within 3km 228m S Blow's Down 651m SW 1937m SE None within 3km 193m S Cottage Bottom Fields Un-named ENV5 site Un-named ENV5 site 100% within Cradock Bradley Road 1157m E ENV20 919m N Not FZ2/3 (GII) 1179m SE 1690m SW 1937m SE; Dunstable to 2265m NE; River Lea Road (Amenity) - -- +/- 0 0 +/- 0 + 0 - + 0 - - Cradock Road Play Area 384 Luton disused railway DWS 892m N 188m S; Un-named ENV5 Chaul End Farmhouse None within 3km None within 3km 310m S Blow's Down 566m SW 1999m SE None within 3km 279m S Cottage Bottom Fields Un-named ENV5 site Un-named ENV5 site Adjacent to Cradock Bradley Road 1188m E ENV20 839m N Not FZ2/3 (GII) 1256m SE 1684m SW 1999m SE; Dunstable to 2212m NE; River lea Road (Amenity) Land behind The Stadium Estate, 0 +/- +/- 0 0 + 0 + 0 - ++ 0 - - 385 Luton disused railway DWS 811m N Cradock Road 272m S; Un-named ENV5 Little Bramingham Wardown Park (GII) None within 3km 631m E Galley & Warden Hills 2412m SE None within 3km 684m E Galley & Warden Hills Un-named ENV5 site Un-named ENV5 site 100% within Bramingham Riddy Lane 1250m S ENV20 333m SW Not FZ2/3 Farmhouse (GII) 529m W 2475m S 635m E 635m E 558m W; Bramingham 635m SW; Great Road / Wicknield Way - -- +/- 0 0 -- 0 + 0 - ++ 0 - + Barton Hills Open Space, Icknield Road 386 Wood 550m W; Un- Bramingham Park DWS (Amenity) named ENV5 site 809m S 816m N Gas Lamps Outside Nos. Luton Hoo (GII*) 1464m S High Town 909m W 2505m N None within 3km 1654m NE Hart Hill 280m SW 1322m SE None within 3km Un-named ENV5 site Hitchin Road Spinney Abbotts Wood Road Harthill Lane 351m SW ENV14 832m SW Not FZ2/3 10 And 32 Hart Hill Drive 529m SW; Church 581m NW; Un-named (Amenity) 16m NW 0 +/- - 0 0 +/- 0 + 0 - ++ 0 +/- + 124 Crawley Green Road 387 (GII) 476.7m SW Cemetery 529m SW; Un- ENV5 site 325m NW named ENV5 site 850m Office Block, Vauxhall Luton Hoo (GII*) 80m S Luton South 1256m W None within 3km None within 3km 797m E Hart Hill 1072m NW 31m SE None within 3km Un-named ENV5 site 9.7% within Luton Crawley Green Rd Gypsy Lane 563m NW ENV20 214m SW Not FZ2/3 Motors (GII) 224m N 733m NW; Luton Hoo Parkway Verges DWS Cemetery (Cemetery) - - 0 0 0 - 0 + 0 -- ++ 0 - + Vauxhall Storage Land, Parkway Road 388 Park 59m S; Un-named 733m NW ENV5 site 214m SW Office Block, Vauxhall Luton Hoo (GII*) 678m Plaiters Lea 1881m W None within 3km None within 3km 510m SE Hart Hill 1256m NW 314m S None within 3km Un-named ENV5 site Dairyborn Scarp DWS Polzeath Close (Amenity) Gypsy Lane 1082m W ENV20 956m SW Not FZ2/3 Motors (GII) 542m SW SW 956m SW; Un-named 123m W; Un-named 880m N 0 0 +/- 0 0 + 0 + 0 -- ++ 0 -- - Mondi Packaging, Airport Way 389 ENV5 site 183m NW; ENV5 site 1580m NW Luton Hoo Park 674m Office Block, Vauxhall Luton Hoo (GII*) 966m Plaiters Lea 1872m W None within 3km None within 3km 742m SE Hart Hill 1186m NW 592m SW None within 3km Un-named ENV5 site Dairyborn Scarp DWS Polzeath Close (Amenity) Gypsy Lane 1173m W ENV20 1152m SW Not FZ2/3 Motors (GII) 695m SW SW 1152m SW; Un-named 114m W; Un-named 645m N 0 0 - 0 0 + 0 + 0 -- ++ 0 - - Land around 113 Proctor Way 390 ENV5 site 1444m NW; ENV5 site 1445m NW Luton Hoo Park 964m Office Block, Vauxhall Luton Hoo (GII*) 861m Plaiters Lea 1756m W None within 3km None within 3km 701m SE Hart Hill 1063m W 486m SW None within 3km Un-named ENV5 site Adjacent to Dairyborn Falconers Rd (Amenity) Gypsy Lane 1045m W ENV20 1020m SW Not FZ2/3 Motors (GII) 563m SW SW adjacent Scarp DWS 534m N +/- 0 - 0 0 + 0 + 0 -- ++ 0 - +/- Land at south-west end of Proctor Way 391

Office Block, Vauxhall Luton Hoo (GII*) 1242m Plaiters Lea 1756m W None within 3km None within 3km 1100m SE Hart Hill 1013m W 887m S None within 3km Un-named ENV5 site Adjacent to Dairyborn Polzeath Close (Amenity) Harthill Lane 1098m W ENV20 1287m SW Not FZ2/3 Motors (GII) 856m SW SW adjacent Scarp DWS 289m N +/- 0 - 0 0 + 0 + 0 -- ++ 0 -- - Vacant land at former 140 Prospect Way 392

Office Block, Vauxhall Luton Hoo (GII*) 625m High Town 1604m W 2885m NW None within 3km 676m SE Hart Hill 880m W 272m S None within 3km Un-named ENV5 site 4.8% of site is within Falconers Rd (Amenity) Gypsy Lane 892m W ENV20 792m SW Not FZ2/3 Motors (GII) 356m W SW adjacent Dairyborn Scarp DWS 94m N - - - 0 0 + 0 + 0 -- ++ 0 - + Land adj Vauxhall Way 393

Little Bramingham None within 3km None within 3km 1395m N Sundon Chalk Quarry None within 3km None within 3km 741m N Leagrave Common and Leagrave Common CWS River Lea DWS 906m S Wauluds Bank Drive Willow Way 942m S ENV 20 624m S Not FZ2/3 Farmhouse (GII) 990m E 2195m NW Wauluds bank Proposed 213m W (Amenity) 12m W Garage blocks at Sylam Close - 0 0 +/- 0 0 + 0 + 0 +/- + 0 + + 394 LNR 213m W COMPOSITE

Little Bramingham None within 3km None within 3km 674m N Sundon Chalk Quarry None within 3km None within 3km 34m NW Leagrave Common and Bramingham Wood CWS Great Bramingham Park Luxemburg Close 72m Toddington Road 1435m ENV 20 1301m S Not FZ2/3 Farmhouse (GII) 1220m E 1904m W Wauluds bank Proposed 276m E DWS 1284m E SW SW Garage blocks at Winchester Gardens - 0 0 - 0 0 +/- 0 + 0 +/- + 0 +/- +/- 395 LNR 284m W COMPOSITE

Church of St Luke (GII) None within 3km None within 3km 1713m S Blow's Down 2054m SW 2599m SE None within 3km 805m NW Leagrave Common & River Lea CWS 5m SE 41.8% of site is within Adj to Green Court Ravenhill Way 412m W ENV20 8m SE FZ2 3m E; FZ3 6m SE 401m E Wauluds Bank Proposed River Lea DWS (Amenity) - - +/- - 0 + 0 + 0 - + 0 +/- + Garage blocks r/o 1-47 Strangers Way 396 LNR 749m NE

Little Bramingham Wardown Park (GII) None within 3km 1692m N Galley and Warden Hills None within 3km None within 3km 1103m N Leagrave Common and Leagrave Common CWS River Lea DWS 535m S Sherd Close Marsh Farm Willow Way 579m S ENV 20 462m SW Not FZ2/3 Farmhouse (GII) 812m 2913m SE 2210m E Wauluds bank Proposed 350m W (Amenity) 10m N Garage blocks at Flint Close - 0 +/- +/- 0 0 + +/- + 0 +/- + 0 + +/- 397 NE LNR 349m W COMPOSITE

Little Bramingham None within 3km None within 3km 1180m N Sundon Chalk Quarry None within 3km None within 3km 506m N Leagrave Common and Leagrave Common CWS River Lea DWS 1081m S Whitefield (Amenity) 10m Toddington Road 1039m ENV 20 768m S Not FZ2/3 Farmhouse (GII) 1051m E 2007m NW Wauluds bank Proposed 171m SW NW SW Garage blocks at Waleys Close - 0 +/- +/- 0 0 + 0 + 0 +/- + 0 + + 398 LNR 171m SW COMPOSITE

Little Bramingham Wardown Park (GII) None within 3km 1869m N Galley and Warden Hills None within 3km None within 3km 1236m N Leagrave Common and Leagrave Common CWS River Lea DWS 353m S Wauluds Bank Drive Willow Way 579m S ENV 20 208m SW Not FZ2/3 Farmhouse (GII) 1033m 2916m SE 2336m E Wauluds bank Proposed 91m SW (Amenity) 20m NE Garage blocks at Arrow Close - 0 0 +/- 0 0 + - + 0 +/- ++ 0 + + 399 NE LNR 105m SW COMPOSITE

Wardown Park House Wardown Park (GII) 984m High Town 2175m S 254m E Galley & Warden Hills 433m SE Hart Hill 2355m S 153m SE Galley & Warden Hills Bradger's Hill CWS 124m Honeygate & Crick Hills Site is open space New Bedford Rd 808m ENV20 642m W Not FZ2/3 Entrance Gate & S 1256m NW 1256m NW NE CWS 433m SE (Cromer Way (Amenity)) SW - -- +/- 0 0 -- 0 + 0 - ++ 0 +/- +/- Open space, Bushmead Road 400 Outbuildings (GII) 1177m S 21 & 23 Park St West (G?) Luton Hoo (GII*) 1256m Town Centre 2m NW None within 3km None within 3km 1158m W Hart Hill 578m NE 1255m SE None within 3km River Lea CWS 419m E River Lea DWS 286m N St Mary's Church Harthill Ln 782m NE ENV20 419m E Not FZ2/3 12m SE SE (Ch'yard/Cem'y) 169m 0 0 +/- 0 0 + +/- + 0 + ++ 0 ++ + Whitbread House, Flowers Way 401 NE

Church of St Luke (GII) None within 3km None within 3km 1519m S Blow's Down 1934m SW 2379m SE None within 3km 1025m NW Leagrave Common & River Lea CWS 124m NW River Lea DWS 104m NW Green Court (Amenity) Ravenhill Way 515m W ENV20 129m NW Not FZ2/3 215m E Wauluds Bank Proposed 127m NW 0 0 +/- 0 0 + 0 + 0 - ++ 0 +/- + The Orchard Centre, Strangers Way 402 LNR 835m NE

Site is 47 Guildford St Wardown Park (GII) Within Plaiters Lea 2802m N None within 3km 1162m W Hart Hill 414m E 1620m SE None within 3km River Lea CWS 562m NW River Lea DWS 54m SW St Mary's Church Harthill Ln 717m E ENV20 492m NW Not FZ2/3 (GII) Listed Building 1013m NW (Ch'yard/Cem'y) 296m SE 0 0 +/- 0 0 + - + 0 +/- + 0 ++ + 47 Guildford Street 403

93 Wellington St (GII) Wardown Park (GII) Within Rothesay 2702m W None within 3km 505m W Stockwood Park 849m S 1410m SW None within 3km Dallow Downs CWS River Lea 585m NE Rothesay Cemetery London Rd 973m S ENV14 667m N Not FZ2/3 244m SE 1209m N 505m W (Ch'yard/Cem'y) 73m SW 0 0 - 0 0 + - + 0 + ++ 0 + + Napier House, 17-21 Napier Road 404

Christ Church Upper Wardown Park (GII) 970m Town Centre 5m SE 2879m N None within 3km 652m W Hart Hill 910m E 1634m SW None within 3km River Lea CWS 441m N River Lea DWS 341m NE Brantwood N'hood Park Ferndale 1051m W ENV14 412m N Not FZ2/3 George St (GII) 17m SE N (Amenity) 251m W 0 0 +/- 0 0 + +/- + 0 +/- ++ 0 ++ + 2 Dunstable Road 405

Christ Church Upper Wardown Park (GII) Town Centre 38m NE 2834m W None within 3km 611m W Hart Hill 930m E 1559m SW None within 3km River Lea CWS 529m N River Lea DWS 404m NE Rothesay Cemetery Ferndale 1056m W ENV14 500m N Not FZ2/3 George St (GII) 62m NE 1058m N (Ch'yard/Cem'y) 220m 0 0 +/- 0 0 + 0 + 0 + ++ 0 + + Unity House, 111 Stuart Street 406 SW

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 10 / 12 Luton Possible Allocations Site Assessment Criteria (as amended) C1 Dist to centres C2 Dist to health C3 Dist to dental C4 Distance to infant C5 Dist to junior C6 Dist to 2ary C7 Dist to emp C8 Dist to sports C9 Dist to play C10 Dist to open space C15 Dist crèche C16 Loss of emp C17 Dist to bus C18 Dist to train C19 Dist to cycle C20 Loss of agric C21 Use of PDL C22 Dist to AP source C23 Impact on SPZ C24 Impact on SAM

High Town NC 682m N; Boots Chemist 293m NW Maeer Dental Surgery Hillborough Infant & Surrey St 1ary 360m S Barnfield Skills Academy EM1 129m E; EM2 915m Hightown Community Manor Rd 380m E St Mary's Church Hart Hill Nursery 805m Cumberland St ELR Central Baptist Church / Luton 504m N 11m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2482m E within TC 246m W Nursery 1039m SW 837m N S; KR1 948m E Sports and Arts Centre (Ch'yard/Cem'y) 115m NE Green site 13m SE Cumberland St 3m SW >100m from Airport/M1 407 56 Park Street 0.10 - 21 - B1(a) 869m N NE

High Town NC 186m Royal Pharmacy 253m Maeer Dental Surgery Crawley Green Infant St Matthews 1ary 363m N Barnfield Skills Academy EM1 526m SE; CA1 75m Hightown Community Bell's Cl 533m N Hitchin Rd / Pomfret Ave Hart Hill Nursery 454m E 96.5% of site is part of Crescent Rise/Veolia Luton 141m SW 255m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2715m NW; TC 75m SW NW 641m SW 1001m E 158m N SW Sports and Arts Centre (ANG) 232m NE Abbeygate Business Water 61m SE >100m from Airport/M1 SE 408 Abbeygate Business Centre, Hitchin Road 0.16 - 12 - B1 189m N Centre ELR Red site

Wigmore DC 448m S Larkside GP 167m SE Vogue Dental Care Someries Infant 791m W Wigmore 1ary 437m SW Ashcroft High 885m SW EM1 521m S; LLA1 766m Wigmore Valley 706m S Wigmore Valley Park 99.7% of site is Rochford Hart Hill Nursery 2517m Not ELR site Wigmore Luton Airport Parkway 68m N 100% ALC3 Not PDL >50m from AQMA, SPZ3 Someries Castle 2715m S 1701m SW S 804m S Drive (Amenity); SW Church/Crawley Green 2863m SW >100m from Airport/M1 409 Open space at Rochford Drive 0.25 - 12 - open space Copthorne (Amenity) Rd 126m SE 116m W Marsh Rd DC 1036m S Moakes Medical Centre Purley Centre Dental Cheynes Infant 821m NW Wauluds 1ary 220m SW Woodlands 2ary 276m EM1 1239m W Futures Fun Factory Purley Centre (Freeman's 99.9% of site is Sherd Gill Blowers Nursery Not ELR site Sherd Cl/Lygetun Dr Leagrave 1129m S 20m W Not ALC1/2/3 Not PDL >50m from AQMA, SPZ3 Waulud's Bank 449m SW Open space to the south-west of Sherd [FUTURE: Purely Centre 192m NW 192m NW NE 363m N Green) 113m NW Close Marsh Farm (Leabank) 436m SW 117m SE >100m from Airport/M1 410 0.20 - 10 - open space Lodge (Marsh Farm) DC 136m (Amenity); Wauluds Bank N] Dr (Amenity) 129m SE Bury Park DC 967m N; Medici GP 29m N Maeer Dental Surgery Hillborough Infant & Tennyson Rd 1ary 3009m Barnfield Skills Academy EM1 705m NE; EM2 Stockwood District Park Windsor St 189m NW Windmill Rd Island Rothesay Road Nursery Not ELR site Chapel St Nursery/Farley Luton 932m N 57m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2864m E TC 314m NE 474m NE Nursery 430m W SE 1315m NE 789m SE; CA1 314m NE 475m S (Amenity) 271m E 508m NW Hill 38m SW >100m from Airport/M1 411 14a-36 South Road 0.23 - 23 - vacant

Marsh Rd DC 922m N Makan MPS Dispensing Marsh Rd Dental 606m N St Josephs Infant 735m Maidenhall 1ary 612m SE Challney High School for EM1 12m NE Lewsey Sports Park Kingsway Recreation Kingsway Rec N'hd Park Gill Blowers Nursery 0.3% within Beechwood Wingate Rd/Opposite Leagrave 1330m NW 691m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1598m 179m S N Boys 1229m W 2431m W Ground 446m SE (Urban P&G) 312m S (Mossdale) 1925m NW Rd ELR Red site Arundel Rd 73m E >100m from Airport/M1 NW 412 38a Wingate Road 0.60 - 15 - A1

Stopsley DC 2m S Krish Chemist 35m S Village Dental Practice Someries Infant 1222m Stopsley Community Stopsley High 717m W BA1 553m N Stopsley Common 91m Ashcroft Road250m S Ashcroft Road (Urban Hart Hill Nursery 2360m 99.6% within Plaza 668 Jansel House/Putteridge Luton 2547m SW 649m W Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Dray's Ditches 2876m 163m SW SE 1ary 236m SW NW P&G) 195m S S ELR Red site Rd 65m S >100m from Airport/M1 NW 413 Plaza 668 Hitchin Road 0.35 - 13 - B1(a)

Sundon Park N/DC P&I Smith Ltd (Pharmacy) Thomlinson Ave Dental The Ferrars Academy Chantry 1ary 535m E Barfield West Academy EM11722m SE Lewsey park Pool 1120m Lewsey Green 206m SE Wheatfield Rd (ANG) Pastures Way Nursery Not ELR site Regis Rd/Wheatfield Rd Leagrave 2963m E 295m N Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Dunstable Priory 1887m 2632m NE; [FUTURE: St 350m E Practice 556m E 1563m E 983m SE E 15m NW 861m E within site >100m from Airport/M1 SW 414 The Unicorn, 165 Wheatfield Road 0.27 - 14 - A4 - PDL Dominic's Sq NC 291m E] Bury Park DC 638m NW; Chemist Express 166m Luton Dental Practice Hillborough Infant & Hillborough Junior 602m Barnfield Skills Academy EM1 701m E; CA1 71m Stockwood District Park Windsor St 247m SW Rothesay Cemetery Rothesay Road Nursery Not ELR site Princess St/Dumfries St Luton 632m N 146m SE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 71m NE NE 202m NE Nursery 597m SW SW 1074m NE NE 806m S (Ch'yard/Cem'y) 101m 313m W 126m SW >100m from Airport/M1 415 22-36 Hastings Street 0.06 - 18 - B1 SW

Bury Park DC 329m NW; SE Morgan Pharmacy Sharing Smiles 25m NE Hillborough Infant & Dallow 1ary 544m W Barnfield Skills Academy EM1 821m SE; within Hightown Community Brantwood Park 481m W Brantwood N'hood Park Rothesay Road Nursery Inkerman St ELR Green Luton Centre Upper Luton 368m SE 115m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km within TC 196m W Nursery 893m SW 875m NE CA1 Sports and Arts Centre (Amenity) 388m W 431m SW site 50m N George St 83m SE >100m from Airport/M1 416 Link House, 49 Alma Street 0.04 - 12 - B1 873m NE

Bury Park DC 304m N; Cardiff Rd Surgery 36m Associated Dental Hillborough Infant & Dallow 1ary 379m NW Barnfield Skills Academy EM1 908m W; CA1 60m Stockwood District Park Brantwood Park 176m W Brantwood N'hood Park Rothesay Road Nursery Upper George St ELR Liverpool Rd / Dunstable Luton 585m NE 287m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 60m NE SW Practice 30m N Nursery 757m S 1099m NE NE 1025m S (Amenity) 176m W 247m S Green site 74m E Rd 95m N >100m from Airport/M1 417 The Albany, 4 Cardiff Road 0.05 - 12 - B1

Bury Park DC 390m N; Bute Hse Medical Centre Integrated Dental Hillborough Infant & Dallow 1ary 374m NW Barnfield Skills Academy EM1 854m NW; CA1 Stockwood District Park Brantwood Park 158m W Rothesay Cemetery Rothesay Road Nursery Not ELR site Liverpool Rd / Dunstable Luton 716m NE 335m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 192m NE 60m NW Holdings 15m SW Nursery 659m S 1229m NE 192m NE 937m S (Ch'yard/Cem'y) 71m SW 146m S Rd 206m N >100m from Airport/M1 418 26-30 Cardiff Road 0.04 - 17 - B1

Bury Park DC 435m N; Cardiff Rd Surgery 80m Integrated Dental Hillborough Infant & Dallow 1ary 464m NW Barnfield Skills Academy EM1 951m NW; CA1 Stockwood District Park Brantwood Park 252m Rothesay Cemetery Rothesay Road Nursery Not ELR site Dunstable Pl / Stewart St Luton 678m NE 401m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km TC 155m NE N Holdings 295m NW Nursery 616m S 1185m NE 155m NE 885m S NE (Ch'yard/Cem'y) 101m 113m SW 197m NE >100m from Airport/M1 419 40-44 Rothesay Road 0.07 - 18 - B1 SW

High Town NC 750m N; Castle Street Surgery Maeer Dental Surgery Hillborough Infant & Surrey Street 1ary 511m Barnfield Skills Academy EM1 485m E; EM2 984m Stockwood District Park Hibbert St 346m SE Windmill Rd Island Rothesay Road Nursery Not ELR site New St / Chapel St 40m Luton 646m N 42m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2803m E TC 23m N 90m S 180m NE Nursery 705m SW SE 1021m NE SE; CA1 23m NE 831m S (Amenity) 304m SE 529m W W >100m from Airport/M1 420 Victoria House, Victoria Street 0.07 - 12 - B1

Sundon Park NC 1173m Lloyds Pharmacy 600m S Purley Centre Dentists Cheynes Infant 755m SW Whitefield 1ary 351m SW Lea Manor High 341m SE EM1 1278m W Lea Manor Recreation Whitfield 371m SW Within Lea Manor Gill Blowers Nursery - Not ELR site Olympic Cl / Whitehorse Leagrave 1915m S 215m W 50% within ALC Grade 2 Not PDL >50m from AQMA, SPZ3 Waulud's Bank 1199m S SW [FUTURE: Purley 600m S Centre 317m S Recreation Ground Leabank 1117m S Vale on site >100m from Airport/M1 421 Lea Manor Playing Fields ?0.58? - 29 - OS Centre (Marsh Farm) 447m S] C1 Dist to centres C2 Dist to health C3 Dist to dental C4 Distance to infant C5 Dist to junior C6 Dist to 2ary C7 Dist to emp C8 Dist to sports C9 Dist to play C10 Dist to open space C15 Dist crèche C16 Loss of emp C17 Dist to bus C18 Dist to train C19 Dist to cycle C20 Loss of agric C21 Use of PDL C22 Dist to AP source C23 Impact on SPZ C24 Impact on SAM

Key to the High Level Assessment Matrix ++ Likely strong positive effect + Likely positive effect 0 Neutral/no effect - Likely adverse effect -- Likely strong adverse effect +/- Mixed or uncertain effects SEA Objectives 1 Maintain and enhance biodiversity, habitat and landscape 2 Conserve, restore and enhance green infrastructure 3 Protect and enhance air, soil and water resources 4 Protect areas that are at risk from flooding and reduce flood risk 5 Reduce carbon emissions 6 Increase resource efficiency and reduce resource use and waste 7 Identify, protect, maintain and enhance heritage assets and their setting 8 Reduce poverty and inequality and promote social inclusion 9 Reduce crime and fear of crime 10 Encourage healthier lifestyles and reduce adverse health impacts of new developments 11 Provide decent, affordable and safe homes for all 12 Support vitality and viability of centres 13 Provide and encourage the use of sustainable integrated transport systems, improve access and mobility 14 Promote employment, learning, skills and innovation

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 11 / 12 SEA Objectives C25 Impact on Listed C26 Impact on historic C27 Impact on C28 Impact on AONB C29 Impact on SSSI C30 Impact on AGLV C31 Impact on ALLI C32 Impact on Green C33 Impact on LNR C34 Impact on CWS C35 Impact on other C36 Impact on open C37 Impact on C38 Impact on Lea C39 Impact on Flood SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Building P&G Conservation Area Belt SNCI space allotment tributaries Zone The Cock PH, 38 Park St Luton Hoo (GII*) 1009m Town Centre 197m NW None within 3km None within 3km 1365m W Hart Hill 561m NE 1109m SE None within 3km River Lea CWS 287m E River Lea DWS 305m NE St Mary's Church Gypsy Ln 619m E ENV20 287m E Not FZ2/3 (GII) 76m NW SE (Ch'yard/Cem'y) 115m 0 0 +/- 0 0 + 0 + 0 + ++ 0 ++ + 56 Park Street 407 NE

Gates, Dwarf Wall And Wardown Park (GII) High Town 215m NW 2415m N None within 3km 1403m N Hart Hill 44m E 1625m SE None within 3km River Lea CWS 534m S Hitchin Rd Spinney DWS Hitchin Rd / Pomfret Ave Harthill Lane 375m E ENV14 525m S Not FZ2/3 Railings To High Town 1025m NW 232m NE (ANG) 232m NE 0 0 +/- 0 0 + 0 + 0 +/- + 0 ++ + Abbeygate Business Centre, Hitchin Road 408 Methodist Church (GII) 244m NW Cassels Cottage (GII) Putteridge Bury (GII) High Town 2851m W 2185m NW None within 3km 2248m S Hart Hill 2455m SW 68m N None within 3km Slaughter's Wood & Un-named ENV5 site Site is open space Wigmore Valley Park ENV20 2993m SW Not FZ2/3 611m N 972m NW Green Ln CWS 42m NW 168m S (Rochford Drive 780m SE - -- +/- 0 0 -- 0 + 0 +/- + 0 + + Open space at Rochford Drive 409 (Amenity))

Little Bramingham None within 3km None within 3km 1586m N Galley & Warden Hills None within 3km None within 3km 1028m N Galley & Warden Hills Leagrave Common CWS River Lea DWS 685m S Site is open space (Sherd Willow Way 723m S ENV20 590m SW Not FZ2/3 Farmhouse (GII) 785m E 2160m E 2063m NE 432m W Close Farm (Amenity)) Open space to the south-west of Sherd - -- +/- 0 0 +/- +/- + 0 - + 0 +/- +/- 410 Lodge

Former Chapel Langley Luton Hoo (GII*) 1250m Luton South 12m SW 2936m W None within 3km 929m NW Stockwood Park 466m S 1221m S None within 3km River Lea CWS 884m NE Stockwood Park DWS North Drift Way London Rd 466m S ENV20 884m NE Not FZ2/3 School (GII) 30m NW SE 466m S (Amenity) 1676m NW 0 0 - 0 0 + +/- + 0 + ++ 0 +/- + 14a-36 South Road 411

Holy Trinity Church (GII) Wardown Park (GII) Rothesay 1937m SE 1651m SW Blow's Down 2770m W 1267m S None within 3km 1217m SW Leagrave Common & Biscot Churchyard CWS Hatters Way DWS 847m Kingsway Rec N'hd Park Bradley Rd 955m SW ENV20 1275m N Not FZ2/3 1200m NE 1901m E Wauluds Bank Proposed 1107m NE SW (Urban P&G) 312m S 0 0 - 0 0 + 0 + 0 - ++ 0 - + 38a Wingate Road 412 LNR 1543m NW

Butterfield Green Rd Putteridge Bury (GII) High Town 2204m SW 794m W Galley & Warden Hills 902m W Hart Hill 2202m S 91m NW Galley & Warden Hills The Chase 657m SW Hay Wood & Stopsley Stopsley Common 91m Wigmore Lane 911m SE ENV20 1732m W Not FZ2/3 (GII) 516m N 912m NE 2133m NW 2133m NW Common DWS 191m W NW 0 0 - 0 0 + 0 + 0 +/- + 0 - + Plaza 668 Hitchin Road 413

Vane Cottage (GII) 862m None within 3km None within 3km 1671m SE Blow's Down 1681m SE None within 3km None within 3km 36m NW Cottage Bottom Fields Dog Kennel Down CWS River Lea DWS 1162m E Wheatfield Rd (ANG) Ravenhill Way 1483m E ENV20 1188m E Not FZ2/3 NW 2574m S 1066m W 15m NW 0 +/- +/- 0 0 + 0 + 0 - + 0 - +/- The Unicorn, 165 Wheatfield Road 414

Former Ceylon Baptist Wardown Park (GII) Town Centre 79m NE 2944m W None within 3km 791m W Stockwood Park 806m S 1540m SE None within 3km River Lea CWS 778m N River Lea DWS 441m NE North Drift way (Amenity) London Rd 831m S ENV20 732m N Not FZ2/3 Church Hall, Wellington 1312m N 213m SW 0 0 +/- 0 0 + 0 + 0 ++ ++ 0 ++ + 22-36 Hastings Street 415 St (G?) 15m NW

Christ Church Upper Wardown Park (GII) 966m Town Centre adjacent 2833m N None within 3km 789m W Hart Hill 777m E 1755m SW None within 3km River Lea CWS 433m N River Lea DWS 240m NE Brantwood N'hood Park Harthill Lane 1081m E ENV20 388m N Not FZ2/3 George St (GII) 56m W N (Amenity) 388m W 0 0 +/- 0 0 + +/- + 0 - + 0 ++ + Link House, 49 Alma Street 416

Christ Church Upper Wardown Park (GII) Town Centre 72m NE 2793m W None within 3km 550m W Hart Hill 1007m E 1535m SW None within 3km River Lea CWS 515m N River Lea DWS 444m NE Brantwood N'hood Park Ferndale 982m W ENV14 492m N Not FZ2/3 George St (GII) 107m NE 1032m N (Amenity) 176m W 0 0 +/- 0 0 + 0 + 0 + + 0 ++ + The Albany, 4 Cardiff Road 417

Central Block of St Wardown Park (GII) Rothesay 11m SW 2667m W None within 3km 422m W Stockwood Park 918m S 1403m SW None within 3km Dallow Downs CWS River Lea 570m NE Rothesay Cemetery Ferndale 900m W ENV14 611m N Not FZ2/3 Mary's Hospital (GII) 1131m N 422m S (Ch'yard/Cem'y) 71m SW 0 0 +/- 0 0 + 0 + 0 + ++ 0 + + 26-30 Cardiff Road 418 200m N

Christ Church Upper Wardown Park (GII) 99.5% within Rothesay 2724m W None within 3km 518m W Stockwood Park 872m S 1438m SW None within 3km Dallow Downs CWS River Lea 546m NE Rothesay Cemetery London Rd 987m S ENV14 622m N Not FZ2/3 George St (GII) 203m NE 1165m N 518m S (Ch'yard/Cem'y) 101m 0 0 - 0 0 + - + 0 + ++ 0 + + 40-44 Rothesay Road 419 SW

Baptist Union Church Luton Hoo (GII*) 1320m Town Centre 30m NE None within 3km None within 3km 1006m W Hart Hill 803m NE 1324m SE None within 3km River Lea CWS 642m E River Lea DWS 427m N Windmill Rd Island London Rd 822m S ENV20 642m E Not FZ2/3 (GII) 47m SE SE (Amenity) 304m SE 0 0 +/- 0 0 + +/- + 0 + + 0 ++ + Victoria House, Victoria Street 420

Little Bramingham None within 3km None within 3km 744m N Sundon Chalk Quarry None within 3km None within 3km 186m N Leagrave Common and Adjacent to Bramingham Great Bramingham Park Within Lea Manor Toddington Road 1535m ENV 20 1246m S Not FZ2/3 Farmhouse (GII) 962m SE 2123m W Wauluds bank Proposed Wood CWS (E) DWS 1048m E Recreation Ground SW +/ - -- 0 0 - 0 + 0 +/- ++ 0 +/- +/- Lea Manor Playing Fields 421 LNR 627m SW

C25 Impact on Listed C26 Impact on historic C27 Impact on C28 Impact on AONB C29 Impact on SSSI C30 Impact on AGLV C31 Impact on ALLI C32 Impact on Green C33 Impact on LNR C34 Impact on CWS C35 Impact on other C36 Impact on open C37 Impact on C38 Impact on Lea C39 Impact on Flood SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Building P&G Conservation Area Belt SNCI space allotment tributaries Zone

++ Likely strong positive effect + Likely positive effect 0 Neutral/no effect - Likely adverse effect -- Likely strong adverse effect +/- Mixed or uncertain effects SEA Objectives 1 Maintain and enhance biodiversity, habitat and landscape 2 Conserve, restore and enhance green infrastructure 3 Protect and enhance air, soil and water resources 4 Protect areas that are at risk from flooding and reduce flood risk 5 Reduce carbon emissions 6 Increase resource efficiency and reduce resource use and waste 7 Identify, protect, maintain and enhance heritage assets and their setting 8 Reduce poverty and inequality and promote social inclusion 9 Reduce crime and fear of crime 10 Encourage healthier lifestyles and reduce adverse health impacts of new developments 11 Provide decent, affordable and safe homes for all 12 Support vitality and viability of centres 13 Provide and encourage the use of sustainable integrated transport systems, improve access and mobility 14 Promote employment, learning, skills and innovation

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Long 12 / 12 Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

Appendix G: Site Assessments and High Level Assessment for Short List

Please see insert.

J Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

This page is intentionally blank.

K Luton Preferred Site Allocations Site Assessment Criteria (as amended) C1 Dist to centres C2 Dist to health C3 Dist to dental C4 Distance to infant C5 Dist to junior C6 Dist to 2ary C7 Dist to emp C8 Dist to sports C9 Dist to play C10 Dist to open space C15 Dist crèche C16 Loss of emp C17 Dist to bus C18 Dist to train C19 Dist to cycle C20 Loss of agric C21 Use of PDL C22 Dist to AP source C23 Impact on SPZ C24 Impact on SAM C25 Impact on Listed C26 Impact on historic Building P&G ID Site Name Size/Capacity/Use Green = 1km 1km 1km 1km 1km 1km 1km 1km 200m 300m 1km Red 200m 400m 200m Not ALC1/2/3 Y >50m and >100m Not SPZ1/2/3 None None None Bury Park DC 134m E; TC Acorn Chemist 64m NW Jaspal Mandair Dental Whipperly Infant 832m Dallow 1ary 114m SE Denbigh High 995m N EM1 site 313m W; CA Hightown Community Brantwood Park Brantwood N'hood Park Rothesay Rd Nursery 98.7% within Guardian Adjacent to Newcombe Luton 895m E 17m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Former Bingo Hall (GII) Wardown Park (GII) 881m 345m E 325m NE SW 345m E Sports and Arts Centre (Amenity) 316m SE (Amenity) 192m SE 610m SE Estate ELR Amber site Rd/Dallow Rd >100m from Airport/M1 156m NE NE 155 Guardian Estate, Dallow Road 1.58 - 64 - B2 1358m E

High Town NC 239m SW; Dr Saleh''s GP 464m W Vogue Dental 854m E Crawley Green Infant St Matthews 1ary 351m Barnfield Skills Academy EM1 856m S; CA 577m Hightown Community Abbotswood Rd 388m E Hitch Rd / Pomfret Ave Hart Hill Nursery 523m 99.6% within Oxen Rd Jubilee St/Hitchin Rd Luton 623m SW 755m SW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2804m Hart Lane Water Tower Wardown Park (GII) 903m TC 577m SW 904m SE W 308m SW SW Sports and Arts Centre (ANG) 42m SE SE Ind Estate ELR Amber 101m SW >100m from Airport/M1 SE (GII) 201m E W 161 Oxen Industrial Estate, Oxen Road 0.60 - 48 - B2 293m SW site

Marsh Rd DC 939m N Makan MPS Dispensing Marsh Rd Dental 598m N St Joseph's Infants 674m Maidenhall Primary 473m Challney High School for EM1 site 10m N; Lewsey Sports Park Kingsway Recreation Kingswood Rec Gill Blowers Nursery - 12.9% within Wingate Rd Wingate Rd/Opposite Leagrave 1362m NW 513m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1627m Holy Trinity Church (GII) Wardown Park (GII) Chemist; Mr M Makan N E Boys 1280m W 2482m W Ground 255m SE Neighbourhood Park Mossdale Site 1967m ELR Green site Arundel Rd 5m N >100m from Airport/M1 NW 1095m NE 1754m E 174 Land at Caleb Close (1) 2.60 - 98 - B2 85m SW (Urban P and G) 101m S NW

High Town NC 102m NW Royal Pharmacy; Mr T J Maeer Dental Crawley Green Infant St Matthews Primary Barnfield Skills Academy EM1 site 506m SE; Hightown Community Bell's Close 599m N St Mary's Church Hart Hill Nursery 538m E Midland Rd ELR Amber Luton Centre Dunstable Luton 9m W 143m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2741m George II Public House Wardown Park (GII) 961m Car parks at Police Station and Court Careways Ltd; Mr N Shah Surgery 525m SW 1088m E 415m N 285m NE Sports and Arts Centre (Churchyards and site 11m N Place 0.4m SE >100m from Airport/M1 SE (GII) 175m SW NW 175 0.29 - 41 - SG House, 12 Dunstable Place 238m N 922m NE Cemeteries) 278m S

Bury Park DC 23m NW Lea Vale Medical Sharing Smiles 231m S Hillborough Infant and Dallow Primary 386m N Barnfield Skills Academy EM1 site 882m W Hightown Community Brantwood Park 489m The Moor (Amenity Rothesay Road Nursery Mill Street Green site Villa Link/Old Bedford Luton 292m E 37m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km No 7 New Bedford Road Wardown Park (GII) 645m Practice 136m SW Nursery 1116m S 791m E Sports and Arts Centre SW Greenspace) 101m N 603m S ELR 64m NE Road. On the site >100m from Airport/M1 (GII) 132m SE N 176 Car Park off Telford Way (7) 0.52 - 39 - SG 774m E

Burt Park DC 299m NE; Acorn Chemist 213m SE Beech Hill Dental Whipperley Infant 772m Beech Hill Primary 282m Denbigh High 999m NE EM1 Site adj; CA1 site Stockwood District Park Cohen's Yard 281m NW Ferndale Allotments Rothesay Road Nursery 99.3% within Dalroad Bedfordshire Yeoman Luton 1226m E 5m N Not ALC1/2/3 PDL >50m from AQMA, SPZ2 None within 3km No127 Dunstable Road, Wardown Park (GII) Market Square, Farley Practice 363m NW SW N 698m E 1539m SE 130m SW 959m SE Green ELR site 49m W >100m from Airport/M1 Former Bingo Hall (GII) 1008m NE 180 Dalroad Industrial Estate (6) 0.79 - 32 - B2 NC 775m S 414m E

Stopsley DC 591m E; TC PJ Ward and Partners - Village Dental Practice Someries Infant 1479m E Stopsley Community Stopsley High 292m NE EM1 site 1781m Stopsley Common 394m Wardown Park 936m SW The Chase/Mixes Hill Hart Hill Nursery 1817m Moreton Park Amber ELR Fair Oak Drive 212m SE Luton 1703m S 221m N Not ALC1/2/3 PDL >50m from AQMA, SPZ3 Dray's Ditches 2873m N Summerhouse at Wardown Park (GII) 458m 1677m S; Round Green Bushmead Rd 779m N 849m E Primary 790m E NE Wood (Natural and Semi- S site 818m SE >100m from Airport/M1 Wardown Park (GII) 645m W 182 69 Felstead Way (4) 0.79 - 58 - D2 NC 727m N natural Green Space) SW 111m NE High Town NC 829m N Castle Street Surgery Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 227m NE, EM2 Stockwood District Park Hibbert St 241m SW Windmill Road Island Rothesay Road Nursery Flowers Industrial Estate Essex Close 100m SE Luton 667m N 158m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2483m E 27 and 29 Park Street Luton Hoo (GII) 1032m 245m W Surgery 299m NW Nursery 931m W 237m SE 1004m N 784m S; CA1 site 21m N 848m SW 220m SW 853m W Green ELR site 13m SW >100m from Airport/M1 West (GII) 169m NW SE 183 12 Albert Road 0.08 - 41 - A4

Bury Park DC 344m N; Cardiff Road Surgery Integrated Dental Hillborough Infant and Dallow Primary 360m NW Barnfield Skills Academy Em1 site 860m NW; CA1 Stockwood District Park Brantwood Park 174m W Brantwood Rothesay Road Nursery Upper George St Green Liverpool Rd/Dunstable Luton 661m NE 299m N Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Central Block St Mary's Wardown Park (GII) TC 136m NE; High Town 24m NE Holdings 57m SW Nursery 688m S 1174m NE 136m NE 963m S Neighbourhood Park 173m S ELR site 148m NE Rd 151m N >100m from Airport/M1 Hospital 151m N 1081m N 197 14 Cardiff Road 0.14 - 64 - B1 NC 729m NE (Amenity) 105m W

High Town NC 781m N; Castle Street Surgery Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 534m E; EM2 Stockwood District Park Windsor St 286m SW Windmill Rd Island Rothesay Road Nursery Holly St Green ELR site Adjacent to New Luton 682m N 6m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2833m E Baptist Union Church Luton Hoo 1325m SE TC 68m NE; 85m SE Surgery 238m NE Nursery 635m SW 521m SE 1072m NE site 968m SE; CA1 site 776m S (Amenity) 292m SE 476m W 135m E St/Chapel St >100m from Airport/M1 (GII) 97m E 199 27-37 Chapel Street 0.14 - 30 - C3 68m NE

Bury Park DC 73m N; TC Lea Vale Medical Associated Dental Hillborough Infant and Dallow Primary 156m W Denbigh High 1064m N EM1 site 700m W; CA1 Hightown Community Brantwood Park 257m Brantwood Rothesay Road Nursery Upper George St Green Vestry Cl/Dallow Rd 10m Luton 593m E 22m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Central Block St Mary's Wardown Park (GII) 825m 25m E; High Town NC Practice 84m E Practice 168m SE Nursery 950m S 25m E Sports and Arts Centre SW Neighbourhood Park 440m S ELR site 249m SE S >100m from Airport/M1 Hospital 18.4m SE N 208 13-31 Dunstable Road 0.25 - 124 - C3 614m NE 1085m E (Amenity) 65m SW

High Town NC 653m N; Town Centre Surgery Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 322m E; EM2 Stockwood District Park Hibbert St 335m S St Mary's Church Rothesay Road Nursery Chapel St Green ELR site Crown Ct/Flowers Way Luton 543m N 88m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2667m E Castle St Red Lion Luton Hoo (GII) 1232m Land Opposite Whitbread House, Flower 100% within TC 98m NW Surgery 64m N Nursery 825m SW 429m SE 903m NE site 953m S 900m S (Churchyards and 623m W 329m NW 5.5m NE >100m from Airport/M1 Hotel/Brookes 22.9m N; SE 210 0.44 - 202 - car park Way Cemeteries) 251m NE 27 and 29 Park St West (GII) 30m N Bury Park DC 132m E; TC Acorn Dispensing Jaspal Mandair Dental Foxdell Infant 1169m SE Beech Hill Primary 205m Denbigh High 850m NE EM1 site 104m W; CA1 Hightown Community Cohen's Yard 366m W Cohen's Rothesay Road Nursery Dallow Rd Green ELR Clifton Rd/Luton Town Luton 1022m E 13m S Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Dunstable Road Former Wardown Park (GII) 838m Luton Town Football Club, Kenilworth 511m SE; Biscot Chemist (PLC.) 176m NE 230m NE NW site 511m SE Sports and Arts Centre Yard/Shaftesbury Rd 838m SE site 30.5m W Football Club 139m W >100m from Airport/M1 Bingo Hall (GII) 208m E NW 220 1.5 - 75 - D2 Road Rd/Blenheim Cres 730m 1453m E (Amenity) 289m NW N High Town NC 595m N; Chemist Express Luton Dental Practice Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site 614m E; 100% Stockwood District Park Windsor St 383m SW Rothesay Cemetery Rothesay Road Nursery Kings St Green ELR Luton Centre Regent Luton 500m N 116m SE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2971m E 39 King's St (GII) within Wardown Park (GII) 100% within TC (distance selling) 26m NE 65m N Nursery 737m SW 714m SE 934m NE within CA1 site 933m S (Churchyards and 413m SE site11.2m NW Link/Chapel St 66m SE >100m from Airport/M1 site 1224m N 221 Midland House, 41 King Street 0.09 - 27 - B1 Cemeteries) 401m W

High Town NC 800m N; Castle Street Surgery Mr T J Maeer Dental Hillborough Infant and Surrey St primary 277m Barnfield Skills Academy EM1 site 256m NE; EM2 Stockwood District Park Hibbert St 233m S Windmill Rd Island Rothesay Road Nursery Flowers Industrial Estate Latimer Rd/Holly St 101m Luton 652m N 180m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2532m E 27 and 29 Park Street Luton Hoo (GII) 1079m TC 12.5m N 178m W Surgery 245m NW Nursery 875m W SE 996m N 814m S; 13m to CA1 site. 832m SW (Amenity) 209m S 783m W Green ELR site 12m S S >100m from Airport/M1 West (GII) 122m N SE 222 Crescent House, 1-5 Latimer Road 0.17 - 80 - B2

High Town NC 740m N; 69m S Mr T J Maeer Dental Hillborough Infant and Surrey Street Primary Barnfield Skills Academy EM1 site347m E; EM2 Stockwood District Park Hibbert St 284m Windmill Road Island Rothesay Road Nursery Holly St Green ELR site Crown Ct/Flowers Way Luton 626m N 125m NW Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2661m E Castle St Baptist Union Luton Hoo (GII) 1201m Land & buildings at Castle Street/Oxford TC 13m NE Surgery 150m N Nursery753m SW 393m SE 983m NE site 906m S; CA1 site 824m S (Amenity) 248m S 611m W 43m SE 83m NE >100m from Airport/M1 Chapel (GII) within site SE 335 0.27 - 45 - D1 Road and Park Viaduct 13m NE

Bury Park DC 1889 N; TC PJ Ward and Partners - Integrated Dental Hillborough Infant and St Margaret's of Scotland Barnfield Skills Academy EM1 Site 1315m E; EM2 Stockwood District Park Homestead Way 235m Tinsley Close/Farley Rothesay Road Nursery Capability Green Green Farley Farm/Farley Hill Luton 2206m NE 288m SE 97.7% is ALC3 Not PDL >50m from AQMA, SPZ2 None within 3km Stockwood House Stable Luton Hoo (GII) 1463m 1669m NE; Market Market Square 958m N Holdings 1529m NE Nursery 961m NE Primary 568m N 2673m NE site 1316m E; CA1 site 11m E NE Farm Road 76m N 1409m NE ELR site 1316m E 187m NE >100m from Airport/M1 Block (GII) 535m E SE 337 Land west of Newlands Road 2.5 - 125 - C3/pasture Square, Farley NC 1668m NE (FUTURE SITE) 860m N Stopsley DC 773m NE Ashcroft Pharmacy 836m Village Dental Practice Crawley Green Infant Sacred Heart Primary Stopsley High 761m N EM1 site 1507m S; KR1 Hightown Community Bell's Close 703m SW St Martin's (Natural and Hart Hill Nursery 1150m Greenwood Ct Green Preston Luton 1184m S 841m N Not ALC1/2/3 Partially PDL >50m from AQMA, SPZ3 None within 3km St Christopher's Church Wardown Park (GII) 673m E 1010m NE 1365m SE 682m NE site 1552m SE; LLA1 site Sports and Arts Centre semi-natural greenspace) S ELR site 256m SE Gdns/Stockingstone Rd >100m from Airport/M1 (GII) 179m E W 339 Land at Stockingstone Road 2.02 - 101 - D2 1873m SE; BA1 site 868m S 106m N 11m W 1752m NE; CA1 site Marsh Rd DC 845m NE Oakley Surgery 129m S Leagrave Dental Practice The Ferrars Academy Barnfield Moorlands Challney High School for EM1 site174m SE; Lewsey Sports Park Addington Way 2 242m S Addington Way Sports Gill Blower's Nursery - Empress Rd Green ELR Orchard Way/Mayne Ave Leagrave 672m NE 533m W Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 870m NE Church of St Luke (GII) None within 3km 156m NE 958m SW Primary 164m SW Girls 310m SW 1112m W Field (Amenity) 149m SW Mossdale Site 604m N site 829m E 92m NW >100m from Airport/M1 49m NE 342 The Laurels, Ely Way 0.53 - 27 - C2

Marsh Rd DC 985m NE Oakley Surgery 135m SE Leagrave Dental Practice The Ferrars Academy Barnfield Moorlands Challney High School for EM1 site 232m E Lewsey Sports Park 960m Addington Way 2 217m Addington Way Sports Gill Blower's Nursery - Empress Rd Green ELR Adjacent to Leagrave 801m NE 383m W Not ALC1/2/3 PDL M1 80m SW SPZ2 Waulud's Bank 984m NE Church of St Luke (GII) None within 3km Westlea Old Peoples Home, 121 High 280m NE 811m SW Primary 26.3m SW Girls 208m S W SE Field (Amenity) 12m SW Mossdale Site 624m N site 959m E Westlea/High St 179m NE 343 0.82 - 41 - C2 Street

Bury Park DC355m NW; Cardiff Road Surgery Maple Dental Clinic 1m E Hillborough Infant and Dallow Primary 536m NW Barnfield Skills Academy EM1 site 824m E; 100% Hightown Community Brantwood Park 428m W Rothesay Cemetery Rothesay Road Nursery Upper George St Green Luton Centre Dunstable Luton 427m NE 167m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Christ Church (GII) 37m Wardown Park (GII) 100% within TC 190m W Nursery 799m S 932m NE within CA1 Sports and Arts Centre (Churchyards and 337m SW ELR site 58m NW Place 39m SE >100m from Airport/M1 NW 1025m N 351 27A Upper George Street 0.11 - 26 - D2 930m NE cemeteries) 334m SW

Bury Park DC 99m NW; Lea Vale Medical Sharing Smiles 179m S Hillborough Infant and Dallow Primary 425m W Barnfield Skills Academy EM1 site 941m W Hightown Community Brantwood Park 483m The Moor (Amenity) Rothesay Road Nursery Mill St Green ELR site Villa Link/Old Bedford Luton 306m E 59m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km 7 New Bedford Road Wardown Park (GII) 739m 100% within TC Practice 126m SW Nursery 1066m S 810m E Sports and Arts Centre SW 192m N 559m S 90m NE Road 31m N >100m from Airport/M1 (GII) 103m SE N 352 40-58 Collingdon Street 0.22 - 88 - B8 795m E

Bury Park DC 253m N; Acorn Chemist (PLC.) Beech Hill Dental Foxdell Infant 673m W Beech Hill Primary 226m Denbigh High 959m NE EM1 site 36m SW Stockwood District Park Cohen's Yard 61m W Cohen's Rothesay Road Nursery Dalroad Green ELR site Clifton Rd/Luton Town Luton 1212m E 14m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 2914m Former Bingo Hall (GII) Wardown Park (GII) 977m TC 690 241m S Practice 195m N N 1628m S Yard/Shaftesbury Rd 971m SE 20m SW Football Club 0.5m SW >100m from Airport/M1 NW 398m E NE 353 Car park adj to 95 Maple Road East 0.65 - 49 - B2 (Amenity) 7m NW

Marsh Rd DC 321m S Calverton Pharmacy Purley Centre 846m N St Joseph's Infant 982m The Meads Primary 468m Woodlands Secondary EM1 site 1011m S Futures Fun Factory Marsh House 345m W Adjacent to Limbury Gill Blower's Nursery - Sarum Road Red ELR site Wauluds Bank Leagrave 445m SW 1m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 108m NW 57 Compton Ave (GII) Wardown Park (GII) 385m E SE NE 821m N 1017m N Riverside Park (Natural Leabank Site 476m NW 487m S Drive/Bramingham Road >100m from Airport/M1 860m SW 2358m SE 359 Bramingham Centre, Weltmore Road 1.40 - 70 - D2 and semi-natural 46m NW greenspace) Marsh Rd DC 1039m N Makan MPS Dispensing Marsh Road Dental St Joseph's Infant 852m Downside Primary 564m Challney High School for EM1 site131m N Lewsey Sports Park Kingsway Recreation Kingsway Rec Gill Blower's Nursery - 99.7% within Caleb Close Dunstable Rd/Big Yellow Leagrave 1432m NW 552m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1705m Holy Trinity Church (GII) Wardown Park (GII) Chemist; Mr M Makan Practice 726m N N SW Boys 1221m W 2456m W Ground 354m SE Neighbourhood Park Mossdale Site 2006m Red ELR site Storage 10m SW >100m from Airport/M1 NW 1302m NE 1912m E 361 2-32 Beechwood Road 0.61 - 15 - B2 70m SW (Urban P and G) 185m SE NW

Bury Park DC 1091m E Makan MPS Dispensing Marsh Road Dental Denbigh Infant 911m E Maidenhall Primary 490m Challney High School for EM1 site 193m W Lewsey Sports Park Kingsway Recreation Kingsway Rec Gill Blower's Nursery - 99.7% within Caleb Close Arundel Rd/Beechwood Leagrave 1566m NW 525m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1840m Church of St Andrew (GII) Wardown Park (GII) Chemist; Mr M Makan Practice 852m N E Boys 1293m W 2536m W Ground 277m SE Neighbourhood Park Mossdale Site 2128m Red ELR site Rd within site >100m from Airport/M1 NW 1376m E 1846m E 364 10-12 Caleb Close 0.31 - 24 - B8 73m W (Urban P and G) 120m S NW

High Town NC 914m Castle St Surgery472m W Mr T J Maeer Dental Hillborough Infant and Surrey St Primary 202m Barnfield Skills Academy EM1 site 25m E; EM2 site Stockwood District Park Manor Rd 261m NE Manor Rd N'hd Park Hart Hill Nursery 857m Osbourne Rd Green ELR Bailey St/Manor Park Luton 711m N 8m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2226m E 101 Park St (GII) 71m NW Luton Hoo (GII) 828m SE NW; TC 140m NW Surgery 485m NW Nursery 1135m W SW 1011m N 704m S; KR1 site 775m E; 950m SW (Urban P&G) 43m NE NE site 24m E within site >100m from Airport/M1 365 146-158 Park Street 0.24 - 29 - car park CA1 site 140m NW

High Town NC 581m N; Boots Chemist 130m N Maeer Dental Surgery Hillborough Infant & Surrey St 1ary 461m SE Barnfield Skills Academy EM1 295m E; EM2 996m Hightown Community Hibbert St 389m S St Mary's Church Rothesay Road Nursery Not ELR site Crown Court / Flowers Luton 459m N 46m NE Not ALC1/2/3 PDL >50m from AQMA, SPZ1 Someries Castle 2658m E 21 & 23 Park St West (G?) Luton Hoo (GII*) 1256m within TC 49m NW Nursery 888m SW 813m NE S Sports and Arts Centre (Ch'yard/Cem'y) 169m 680m W Way 6m SW >100m from Airport/M1 12m SE SE 401 Whitbread House, Flowers Way 0.40 - 134 - B1(a) 837m N NE

Marsh Rd DC 1010m NE Oakley Surgery 294m SE Leagrave Dental Practice The Ferrars Academy Leagrave 1ary 116m SW Challney High School for EM1 378m SE Lewsey Sports Park 865m Addington Way 374m SE Green Court (Amenity) Gill Blowers Nursery - Not ELR site Westlea/High St 54m SE Leagrave 816m NE 283m W Not ALC1/2/3 PDL M1 44m SW SPZ2 Waulud's Bank 971m NE Church of St Luke (GII) None within 3km [FUTURE: Hockwell Ring 300m E 772m SW Girls 338m S W 127m NW Mossdale 511m N 215m E 402 The Orchard Centre, Strangers Way 0.90 - 67 - D1 NC 296m N]

Bury Park DC 347m N; Cardiff Rd Surgery 77m Associated Dental Hillborough Infant & Dallow 1ary 463m NW Barnfield Skills Academy EM1 896m E; CA1 13m Stockwood District Park Brantwood Park 315m W Rothesay Cemetery Rothesay Road Nursery Upper George St ELR Dunstable Pl / Stuart St Luton 533m NE 272m E Not ALC1/2/3 PDL >50m from AQMA, SPZ1 None within 3km Christ Church Upper Wardown Park (GII) TC 13m NE W Practice 106m NW Nursery 723m S 1039m NE NE 982m S (Ch'yard/Cem'y) 220m 236m SW Green site 25m NE 78m E >100m from Airport/M1 George St (GII) 62m NE 1058m N 406 Unity House, 111 Stuart Street 0.17 - 58 - B1(a) SW

Marsh Rd DC 922m N Makan MPS Dispensing Marsh Rd Dental 606m N St Josephs Infant 735m Maidenhall 1ary 612m SE Challney High School for EM1 12m NE Lewsey Sports Park Kingsway Recreation Kingsway Rec N'hd Park Gill Blowers Nursery 0.3% within Beechwood Wingate Rd/Opposite Leagrave 1330m NW 691m S Not ALC1/2/3 PDL >50m from AQMA, SPZ2 Waulud's Bank 1598m Holy Trinity Church (GII) Wardown Park (GII) 179m S N Boys 1229m W 2431m W Ground 446m SE (Urban P&G) 312m S (Mossdale) 1925m NW Rd ELR Red site Arundel Rd 73m E >100m from Airport/M1 NW 1200m NE 1901m E 412 38a Wingate Road 0.60 - 15 - A1

C1 Dist to centres C2 Dist to health C3 Dist to dental C4 Distance to infant C5 Dist to junior C6 Dist to 2ary C7 Dist to emp C8 Dist to sports C9 Dist to play C10 Dist to open space C15 Dist crèche C16 Loss of emp C17 Dist to bus C18 Dist to train C19 Dist to cycle C20 Loss of agric C21 Use of PDL C22 Dist to AP source C23 Impact on SPZ C24 Impact on SAM C25 Impact on Listed C26 Impact on historic Building P&G Key to the High Level Assessment Matrix ++ Likely strong positive effect + Likely positive effect 0 Neutral/no effect - Likely adverse effect -- Likely strong adverse effect +/- Mixed or uncertain effects SEA Objectives 1 Maintain and enhance biodiversity, habitat and landscape 2 Conserve, restore and enhance green infrastructure 3 Protect and enhance air, soil and water resources 4 Protect areas that are at risk from flooding and reduce flood risk 5 Reduce carbon emissions 6 Increase resource efficiency and reduce resource use and waste 7 Identify, protect, maintain and enhance heritage assets and their setting 8 Reduce poverty and inequality and promote social inclusion 9 Reduce crime and fear of crime 10 Encourage healthier lifestyles and reduce adverse health impacts of new developments 11 Provide decent, affordable and safe homes for all 12 Support vitality and viability of centres 13 Provide and encourage the use of sustainable integrated transport systems, improve access and mobility 14 Promote employment, learning, skills and innovation

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Short 1 / 2 SEA Objectives C27 Impact on C28 Impact on AONB C29 Impact on SSSI C30 Impact on AGLV C31 Impact on ALLI C32 Impact on Green C33 Impact on LNR C34 Impact on CWS C35 Impact on other C36 Impact on open C37 Impact on C38 Impact on Lea C39 Impact on Flood SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Conservation Area Belt SNCI space allotment tributaries Zone None 500m 400m 400m 400m 20m 20m 20m 20m 20m 20m 20m FZ1 <14 Site Name ID Rothesay 157m SE 2368m W None within 3km 247m S Stockwood Park 1277m S 1212m SW None within 3km Dallow Downs CWS River Lea DWS 490m NE Brantwood N'hood Park Ferndale 397m W ENV20 569m NE Not FZ2/3 246m S (Amenity) 192m SE 0 0 - 0 0 + 0 + 0 +/- ++ 0 + +/- Guardian Estate, Dallow Road 155

High Town 338m SW 1917m N None within 3km 961m N Hart Hill 247m S 1579m N None within 3km People's Park CWS 283m Hitchin Road Spinney Hitch Rd / Pomfret Ave Harthill Ln 505m S ENV14 931m S Not FZ2/3 NW DWS 42m SE (ANG) 42m SE 0 0 - 0 0 + 0 + 0 +/- ++ 0 +/- +/- Oxen Industrial Estate, Oxen Road 161

Rothesay 1940m SE 1630m SW Blow's Down 2783m W 1059m S Stockwood Park 2832m 1129m SW Leagrave Common and Biscot Churchyard CWS Hatters Way DWS 785m Kingswood Rec Bradley Rd Allotments ENV20 1262m N Not FZ2/3 SE Wauluds bank 1573m 1005m NE SW Neighbourhood Park 945m W 0 0 - 0 0 + 0 + 0 - ++ 0 +/- - Land at Caleb Close (1) 174 NW (Urban P and G) 101m S

High Town 113m NW 2929m W None within 3km 1362m W Hart Hill 136m E 1646m SW None within 3km River Lea CWS 495m SE River Lea DWS 156m S St Mary's Church Harthill Lane Allotments ENV14 488m SE Not FZ2/3 (Churchyards and 450m E Car parks at Police Station and Court 0 0 +/- 0 0 + 0 + 0 + ++ 0 ++ + 175 Cemeteries) 278m S House, 12 Dunstable Place

Town Centre 201m SE 2563m N None within 3km 742m SW Hart Hill 776m E 1790m SW None within 3km River Lea CWS 117m SE River Lea DWS 60m S The Moor (Amenity Ferndale Allotments ENV14 95m N 55% of site is FZ2 Greenspace) 101m N 1031m W 0 0 +/- - 0 + 0 + 0 + ++ 0 ++ + Car Park off Telford Way (7) 176

Rothesay 409m SE 2155m SW None within 3km 130m SW Stockwood Park 1537m 1072m SW None within 3km Dallow Downs CWS River Lea DWS 767m E St Peter's Park 34.2m S Ferndale Allotments ENV 20 845m E Not FZ2/3 SE 144m W 130m SW 0 0 +/- 0 0 + 0 + 0 +/- ++ 0 + - Dalroad Industrial Estate (6) 180

High Town 1380m S 565m N Galley and Warden Hills None within 3km Hart Hill 1530m S 251m N Galley and Warden Hills Honeygate and Crick Mixes Hill DWS adjacent The Chase/Mixes Hill Stockingstone Rd 424m ENV 20 629m W Not FZ2/3 1968m NW 1968m NW Hills CWS adjacent Wood (Natural and Semi- S - 0 +/- 0 0 + 0 + 0 + ++ 0 - +/- 69 Felstead Way (4) 182 natural Green Space) 111m NE Town Centre 237m NW None within 3km None within 3km 1327m W Hart Hill 720m NE 1032m SE None within 3km River Lea CWS 413m NE River Lea DWS 430m NE Windmill Road Island Gypsy Ln Allotments ENV 20 413m NE Not FZ2/3 220m SW Windmill Road 636m E 0 0 +/- 0 0 + 0 + 0 ++ ++ 0 ++ + 12 Albert Road 183

Rothesay 53m SW 2703m W None within 3km 473m W Stockwood Park 946m S 1443m SW None within 3km Dallow Downs CWS River Lea DWS 511m NE Brantwood N'hood Park Ferndale Allotments ENV 14 555m NE Not FZ2/3 473m W (Amenity) 105m W 917m W 0 0 +/- 0 0 + 0 + 0 ++ ++ 0 ++ + 14 Cardiff Road 197

Town Centre 75m NE None within 3km None within 3km 949m W Stockwood Park 768m S 1331m SE None within 3km River Lea CWS 697m E River Lea DWS 464m N North Drift Way London Road 768m S ENV 20 697m E Not FZ2/3 (Amenity) 245m SW 0 0 +/- 0 0 + 0 + 0 ++ ++ 0 ++ + 27-37 Chapel Street 199

Rothesay 54m SW 2755m SW None within 3km 501m SW Hart Hill 1067m E 1553m SW None within 3km River Lea CWS 371m NE River Lea DWS 327m NE Brantwood N'hood Park Ferndale Allotments ENV 14 367m NE Not FZ2/3 (Amenity) 65m SW 810m W 0 0 +/- 0 0 + 0 + 0 + ++ 0 ++ + 13-31 Dunstable Road 208

Town Centre 10.2m W None within 3km None within 3km 1101m W Hart Hill 669m NE 1233m SE None within 3km River Lea CWS 474m E River Lea DWS 340m N St Mary's Church Gypsy Lane Allotments ENV 20 474m E Not FZ2/3 (Churchyards and Windmill Road 807m E Land Opposite Whitbread House, Flower 0 0 +/- 0 0 + +/- + 0 ++ ++ 0 ++ + 210 Cemeteries) 251m NE Way

Rothesay 365m SE 2352m SW None within 3km 332m SW Hart Hill 1501m E 1275m SW None within 3km Dallow Downs CWS River Lea DWS 561m E St Peter's Park (Amenity) Ferndale Allotments ENV 20 639m E Not FZ2/3 336m SW 210m SW 332m W Luton Town Football Club, Kenilworth 0 0 - 0 0 + 0 + 0 - ++ 0 + + 220 Road

100% within Town Centre None within 3km None within 3km 884m W Hart Hill 757m NE 1527m SE None within 3km River Lea CWS 697m N River Lea DWS 302m NE North Drift Way London Rod 947m S ENV 20 642m N Not FZ2/3 (Amenity) 346m SW 0 0 +/- 0 0 + - + 0 + ++ 0 ++ + Midland House, 41 King Street 221

Town Centre 178m NW None within 3km None within 3km 1258m W Hart Hill 729m NE 1080m SE None within 3km River Lea CWS 440m NE River Lea DWS 467m E Windmill Rd Island Gypsy Lane Allotments ENV 20 440m NE Not FZ2/3 (Amenity) 209m S Windmill Road 684m E 0 0 +/- 0 0 + 0 + 0 + ++ 0 ++ + Crescent House, 1-5 Latimer Road 222

Town Centre 60m NW None within 3km None within 3km 1087m W Hart Hill 743m NE 1202m SE None within 3km River Lea CWS 515m NE River Lea DWS 429m N Windmill Road Island Gypsy Ln Allotments ENV 20 515m NE Not FZ2/3 (Amenity) 248m S Windmill Road 808m E Land & buildings at Castle Street/Oxford 0 0 +/- 0 0 + +/- + 0 ++ ++ 0 ++ + 335 Road and Park Viaduct

Luton South 1117m NE 1741m W None within 3km 1125m N Stockwood Park 12m E Adjacent to the site None within 3km Stockwood Park CWS Stockwood Park DWS Stockwood District Park London Rd 792m NE ENV 14 2172m NE Not FZ2/3 12m E 416m E (Major sports and Leisure +/- 0 -- +/- 0 - 0 + 0 + ++ 0 - - Land west of Newlands Road 337 site) 11m E

High Town 837m SW 1193m N Galley and Warden Hills 315m NW Hart Hill 895m S 842m N Galley and Warden Hills The Chase CWS 178m Stockingstone Hill DWS St Martin's (Natural and Stockingstone Rd 249m ENV 20 821m W Not FZ2/3 2619m N 2619m N NE 249m W semi-natural greenspace) W 0 0 -- 0 0 +/- 0 + 0 +/- ++ 0 - - Land at Stockingstone Road 339 106m N

None within 3km 1509m S Blow's Down 2065m SW 2226m SE None within 3km 1267m NW Leagrave Common and River Lea CWS 313m NW River Lea DWS 308m NW Addington Way Sports Knapps Farm 732m N ENV 20 319m NW Not FZ2/3 Wauluds bank Proposed Field (Amenity) 149m SW 0 0 +/- 0 0 + 0 + 0 - ++ 0 + + The Laurels, Ely Way 342 LNR 789m N

None within 3km 1421m S Blow's Down 1933m SW 2222m SE None within 3km 1179m NW Leagrave Common and River Lea CWS 270m NW River Lea DWS 246m NW Addington Way Sports Ravenhill Way 660m NW ENV 20 273m NW Not FZ2/3 Wauluds bank Proposed Field (Amenity) 12m SW Westlea Old Peoples Home, 121 High 0 0 - 0 0 + 0 + 0 - ++ 0 + + 343 LNR 882m NE Street

65.3% within Town 2542m N None within 3km None within 3km Hart Hill 826m E 1671m SW None within 3km River Lea CWS 491m N River Lea DWS 300m NE Rothesay Cemetery London Rd 1101m S ENV 20 2451m N Not FZ2/3 Centre (Churchyards and 0 0 +/- 0 0 + - + 0 - ++ 0 ++ + 27A Upper George Street 351 cemeteries) 334m SW

Town Centre 170m SE 2630m N None within 3km 757m SW Hart Hill 789m E 1792m SW None within 3km River Lea CWS 207m N River Lea DWS 113m N The Moor (Amenity) Ferndale Allotments ENV 20 170m N 28% within FZ2 192m N 1077m W 0 0 +/- - 0 + 0 + 0 +/- ++ 0 ++ + 40-58 Collingdon Street 352

Rothesay 492m S 2112m W None within 3km 264m S Stockwood Park 1618m S 1126m SW Leagrave Common and Dallow Downs CWS River Lea DWS 748m E Cohen's Ferndale Allotments ENV 20 826m E Not FZ2/3 Wauluds bank Proposed 264m S Yard/Shaftesbury Rd 294m SW +/- +/- +/- 0 0 + 0 + 0 +/- ++ 0 + + Car park adj to 95 Maple Road East 353 LNR 2865m NW (Amenity) 7m NW

None within 3km 2256m N Galley and Warden Hills 2925m S None within 3km 1658m N Leagrave Common and River Lea CWS 5m S 11.2% within River Lea Adjacent to Limbury Willow Way 10m S ENV 20 7m S 0.1% within FZ2; FZ3 6m 2282m NE Wauluds bank Proposed DWS Riverside Park (Natural S - +/- +/- +/- 0 + +/- + 0 - ++ 0 + + Bramingham Centre, Weltmore Road 359 LNR 157m NW and semi-natural greenspace) Rothesay 1835m SE 1598m SW Blow's Down 2733m W 1134m S Stockwood Park 2922m 1122m SW Leagrave Common and Dallow Downs CWS Hatter's Way DWS 769m Kingsway Rec Bradley Road ENV 20 1395m SW Not FZ2/3 SE Wauluds bank Proposed 1127m S SW Neighbourhood Park Allotments906m SW 0 0 +/- 0 0 + 0 + 0 - ++ 0 +/- + 2-32 Beechwood Road 361 LNR 1650m NW (Urban P and G) 185m SE

Rothesay 1761m SE 1619m SW Blow's Down 2777m W 1077m S Stockwood Park 2854m 1118m SW Leagrave Common and Dallow Downs CWS Hatter's Way DWS 768m Kingsway Rec Bradley Road Allotments ENV 20 1522m N Not FZ2/3 SE Wauluds bank Proposed 1069m S SW Neighbourhood Park 937m W 0 0 +/- 0 0 + 0 + 0 - ++ 0 - + 10-12 Caleb Close 364 LNR 1784m NW (Urban P and G) 120m S

Town Centre 433m NW None within 3km None within 3km 1556m W Hart Hill 636m N 827m SE None within 3km River Lea CWS 191m E River Lea DWS 224m NE Manor Rd N'hd Park Gypsy Lane Allotments ENV 20 194m E Not FZ2/3 (Urban P&G) 43m NE Windmill Rd 384m E 0 0 +/- 0 0 + 0 + 0 +/- ++ 0 +/- + 146-158 Park Street 365

Town Centre 2m NW None within 3km None within 3km 1158m W Hart Hill 578m NE 1255m SE None within 3km River Lea CWS 419m E River Lea DWS 286m N St Mary's Church Harthill Ln 782m NE ENV20 419m E Not FZ2/3 (Ch'yard/Cem'y) 169m 0 0 +/- 0 0 + +/- + 0 + ++ 0 ++ + Whitbread House, Flowers Way 401 NE

None within 3km 1519m S Blow's Down 1934m SW 2379m SE None within 3km 1025m NW Leagrave Common & River Lea CWS 124m NW River Lea DWS 104m NW Green Court (Amenity) Ravenhill Way 515m W ENV20 129m NW Not FZ2/3 Wauluds Bank Proposed 127m NW 0 0 +/- 0 0 + 0 + 0 - ++ 0 +/- + The Orchard Centre, Strangers Way 402 LNR 835m NE

Town Centre 38m NE 2834m W None within 3km 611m W Hart Hill 930m E 1559m SW None within 3km River Lea CWS 529m N River Lea DWS 404m NE Rothesay Cemetery Ferndale 1056m W ENV14 500m N Not FZ2/3 (Ch'yard/Cem'y) 220m 0 0 +/- 0 0 + 0 + 0 + ++ 0 + + Unity House, 111 Stuart Street 406 SW

Rothesay 1937m SE 1651m SW Blow's Down 2770m W 1267m S None within 3km 1217m SW Leagrave Common & Biscot Churchyard CWS Hatters Way DWS 847m Kingsway Rec N'hd Park Bradley Rd 955m SW ENV20 1275m N Not FZ2/3 Wauluds Bank Proposed 1107m NE SW (Urban P&G) 312m S 0 0 - 0 0 + 0 + 0 - ++ 0 - + 38a Wingate Road 412 LNR 1543m NW

C27 Impact on C28 Impact on AONB C29 Impact on SSSI C30 Impact on AGLV C31 Impact on ALLI C32 Impact on Green C33 Impact on LNR C34 Impact on CWS C35 Impact on other C36 Impact on open C37 Impact on C38 Impact on Lea C39 Impact on Flood SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Conservation Area Belt SNCI space allotment tributaries Zone

++ Likely strong positive effect + Likely positive effect 0 Neutral/no effect - Likely adverse effect -- Likely strong adverse effect +/- Mixed or uncertain effects SEA Objectives 1 Maintain and enhance biodiversity, habitat and landscape 2 Conserve, restore and enhance green infrastructure 3 Protect and enhance air, soil and water resources 4 Protect areas that are at risk from flooding and reduce flood risk 5 Reduce carbon emissions 6 Increase resource efficiency and reduce resource use and waste 7 Identify, protect, maintain and enhance heritage assets and their setting 8 Reduce poverty and inequality and promote social inclusion 9 Reduce crime and fear of crime 10 Encourage healthier lifestyles and reduce adverse health impacts of new developments 11 Provide decent, affordable and safe homes for all 12 Support vitality and viability of centres 13 Provide and encourage the use of sustainable integrated transport systems, improve access and mobility 14 Promote employment, learning, skills and innovation

UE-0130 Luton LP HLA_9_140212.xlsx Site Assessment - Short 2 / 2 Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

Appendix H: Justification for Preferred Sites

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L Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

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M <4 red SA 0 significant Viability SHLAA # >24 site impacts on Name Source of #Dwellings Type of development is not Allocate? Reason ID Dwellings units? assessment SA red? criteria? objectives? 100% housing (1,2 and 3- 155 Guardian Estate 64 Call for Sites response and planning application Yes Yes Yes Yes Yes Size, SA and viability bed units) 100% housing (2 and 3-bed 161 Oxen Industrial Estate, Oxen Road 48 2013 ELR Yes Yes Yes Yes Yes Size, SA and viability units) Poor SA score based on poor access to public transport and part of site containing Mixed retail, employment 75dph on half the site allowing the other half to good quality employment land. Allocated 174 Land at Caleb Close 98 and housing. 2 and 3-bed Yes No Yes Yes Yes support employment/ other uses as new centre in vicinity should improve units access to services and majority of contains poor quality employment land. Viability likely to improve later in plan 175 Car Parks on Dunstable Place 41 Planning permission Flats and hotel Yes Yes Yes No Yes period. Mixed retail, employment 150 dph on half the site, allowing other half for 176 Car Park off Telford Way 39 and housing. 1, 2 and 3- Yes Yes Yes Yes Yes Size, SA and viability other uses such as employment bed units likely to be flats 100% housing (1,2 and 3- 180 Dalroad Industrial Estate 32 Local plan allocation Yes Yes Yes Yes Yes Size, SA and viability bed units) 100% housing (3 and 4-bed 182 69 Felstead Way 58 Planning permission Yes Yes Yes Yes Yes Size, SA and viability units) 183 12 Albert Road 41 Planning application 07/01110/FUL One and two-bed flats Yes Yes Yes Yes Yes Size, SA and viability Application for 13 units on part of site 100% housing (1 and 2-bed 197 14 Cardiff Road 64 2013 town centre office study identifies capacity for Yes Yes Yes Yes Yes Size, SA and viability flats) 64 units on all of site 199 27-37 Chapel Street 30 Planning permission 100% housing (1-bed flats) Yes Yes Yes Yes Yes Size, SA and viability 100% housing (1 and 2-bed Viability likely to improve later in plan 208 13-31 Dunstable Road 124 Planning permission Yes Yes Yes No Yes flats) period. 1 and 2-bed flats with hotel 210 Land opposite Whitbread House, Flowers Way 202 Planning permission Yes Yes Yes Yes Yes Size, SA and viability and retail 100% housing (2 and 3-bed 220 Luton Town Football Club, Kenilworth Road 75 50dph Yes Yes Yes Yes Yes Size, SA and viability units) 221 Midland House, 41 King Street 27 Planning permission 100% housing (1-bed flats) Yes Yes Yes Yes Yes Size, SA and viability 222 Crescent House 1-5 Latimer Road 80 Planning permission Flats and offices Yes Yes Yes Yes Yes Size, SA and viability Land & Buildings At Castle Street/Oxford Road Student accommodation 335 45 Planning permission Yes Yes Yes Yes Yes Size, SA and viability and Park Viaduct and doctor's surgery Refers to developent at Roebuck Close as an Poor SA score, though offers significant 100% housing (2 and 3-bed 337 Land to the west of Newlands Road 54 examplar. Newlands Road site is approx. half the Yes Yes No Yes Yes potential that could be made to work with units) area of Roebuck Close site suitable mitigation Poor SA score though capable of mitigation 50dph on half of site allowing other half for leisure/ Leisure and residential (2 339 Land at Stockingtstone Road 50 Yes Yes No Yes Yes and close to Round Green neighbourhood other uses and 3-bed units) centre Too small but allocation will support the 100% housing (2 and 3-bed 342 The Laurels, Ely Way 20 Pre-application discussion with outline plan, 2013 No Yes Yes Yes Yes release of this public-sector land for units) residential uses 100% housing (2 and 3-bed 343 Westlea Old Peoples Home, 121 High Street 57 2013 planning application Yes Yes Yes Yes Yes Size, SA and viability units) 351 27A Upper George Street 26 Planning permission 100% housing (1-bed flats) Yes Yes Yes Yes Yes Size, SA and viability 1 and 2-bed flats with 352 40-58 Collingdon Street 88 Planning permission Yes Yes Yes No Yes Viability likely to improve later in plan period offices 100% housing (2 and 3-bed 353 Car Park adjacent to 95 Maple Road East 49 75dph (2013 urban capacity work) Yes Yes Yes Yes Yes Size, SA and viability units) 100% housing (2 and 3-bed 359 Bramingham Centre, Weltmore Road 70 50dph Yes Yes Yes Yes Yes Size, SA and viability units)

App H - Draft Allocations for UE_3_140212.xlsx Housing Allocations 1 / 2 <4 red SA 0 significant Viability SHLAA # >24 site impacts on Name Source of #Dwellings Type of development is not Allocate? Reason ID Dwellings units? assessment SA red? criteria? objectives? Mixed retail, employment Too small and poor SA score but allocation 50dph on half of site allowing other half for 361 2 to 32 Beechwood Road 15 and housing. 2 and 3-bed No No Yes Yes Yes should assist comprehensive development employment/ other uses units around Caleb Close Mixed retail, employment Too small and poor SA score but allocation 364 10 to 12, Caleb Close 24 75dph (2013 urban capacity work) and housing. 2 and 3-bed No No Yes Yes Yes should assist comprehensive development units around Caleb Close 365 146 to 158 Park Street 29 Planning permission Student accommodation Yes Yes Yes Yes Yes Size, SA and viability Mixed use offices and 401 Whitbread House, Flowers Way 134 2013 town centre office study and 2009 application Yes Yes Yes Yes Yes Size, SA and viability residential 100% housing (2 and 3-bed 402 The Orchard Centre, Strangers Way 67 75dph Yes Yes Yes Yes Yes Size, SA and viability units) 406 Unity House, 111 Stuart Street 58 2013 town centre office study 100% housing (1-bed flats) Yes Yes Yes Yes Yes Size, SA and viability Mixed retail, employment Too small and poor SA score but allocation 50dph on half of site allowing other half for 412 38a Wingate Road. 15 and housing. 2 and 3-bed No No Yes Yes Yes should assist comprehensive development employment/ other uses units around Caleb Close

App H - Draft Allocations for UE_3_140212.xlsx Housing Allocations 2 / 2 Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

Appendix I: High Level Assessment of Policies

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N Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

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O Luton Borough Local Plan SEA Objectives Proposed Policies SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 ID Spatial Strategy LP1 Presumption in Favour of Sustainable Development + + + + + + + + + + + + + +

LP2 Spatial Development Strategy +/- +/- +/- +/- - +/- +/- + +/- +/- + + +/- +

LP3 Luton Town Centre Strategy + + - - - - - + + + + ++ + +

LP4 Green Belt + + + 0 0 + + 0 0 + 0 + + 0 ID Strategic Allocations LP5 Land south of Stockwood Park - with football club -- + - 0 - - 0 + 0 + 0 - +/- ++

LP6 London Luton Airport (including Century Park 43ha) -- + - 0 -- - - + 0 + 0 - +/- +

LP7 Butterfield Technology Park -- + - 0 - - - + 0 + 0 - +/- ++

LP8 Napier Park +/- + - 0 - - 0 + + + + + + +

LP9 Power Court +/- + - - - - - + + + + + + +

LP10 High Town - + - - 0 + + + ++ + + + + +

LP11 Creative Quarter +/- + - - 0 + +/- + + 0 + + + +

LP12 Marsh Farm - + - 0 0 + + + + + 0 + + 0 ID Economy LP13 Economic Strategy 0 0 +/- 0 +/- +/- 0 + 0 0 0 + +/- ++

LP14 Existing Employment Areas and Sites 0 0 0 0 0 + 0 + 0 0 + + 0 + ID Housing LP15 Housing Provision 0 0 +/- 0 0 + 0 + 0 0 ++ + + 0

LP16 Affordable Housing 0 0 0 0 0 0 0 ++ 0 0 ++ + 0 0

LP17 Houses in Multiple Occupation 0 0 0 0 0 + 0 + 0 0 + 0 0 0

LP18 Older People's Housing 0 0 0 0 0 0 + + 0 0 + 0 + 0

LP19 Extensions to Dwellings and Annexes 0 0 0 0 0 0 0 + 0 0 + 0 0 0

UE-0130 Luton LP HLA_8_131213 HLA 1 / 4 Luton Borough Local Plan SEA Objectives Proposed Policies SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14

LP20 Gypsies, Travellers and Travelling Showpeople 0 0 0 0 0 + 0 + 0 0 + 0 + 0 ID Vitality & Viability of Centres LP21 Centre Hierarchy 0 0 + 0 + 0 0 + 0 0 0 ++ ++ 0

LP22 Primary & Secondary Shopping Areas & Frontages 0 0 + 0 + 0 0 + 0 + 0 ++ ++ 0

LP23 District & Neighbourhood Centres & Shopping Parades 0 0 + 0 + 0 0 + 0 + 0 ++ ++ 0 ID Community & Education Facilities LP24 Community & Education Facilities - - 0 0 0 + 0 + + +/- 0 0 + + ID High Quality Design LP25 High Quality Design + + 0 0 + + + + + + + + + 0

LP26 Advertisements and Signage + 0 0 0 0 0 + 0 0 0 0 0 0 0 ID Natural & Historic Environment LP27 Open Space and Natural Greenspace ++ ++ + 0 0 + + + 0 ++ 0 + + 0

LP28 Biodiversity and Nature Conservation and Geology ++ + 0 0 0 0 0 0 0 + 0 + 0 0 Landscape Conservation, Trees, Rights of Way and Countryside LP29 ++ + 0 0 0 0 + + 0 + 0 + + 0 Access LP30 Historic Environment 0 0 0 0 0 + ++ + 0 0 0 + 0 0 ID Transport, Communications & Climate Change LP31 Sustainable Transport Strategy 0 0 + 0 +/- 0 0 0 0 + 0 + ++ 0

LP32 Parking 0 0 +/- 0 +/- 0 0 0 0 + 0 + + 0

LP33 Freight 0 0 +/- 0 +/- 0 0 0 0 0 0 + + 0

LP34 Public Safety Zones 0 0 0 0 0 0 0 0 0 + 0 0 0 0

LP35 Communications 0 0 0 0 0 0 0 0 0 0 0 + + +

LP36 Flood Risk + + + ++ 0 0 0 0 0 + + + 0 0

LP37 Climate Change, Carbon Reduction and Sustainable Energy 0 0 + + ++ ++ 0 0 0 0 + 0 0 0

UE-0130 Luton LP HLA_8_131213 HLA 2 / 4 Luton Borough Local Plan SEA Objectives Proposed Policies SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14

LP38 Pollution and Contamination + + ++ 0 0 + 0 0 0 + 0 0 0 0 ID Infrastructure Delivery & Monitoring the Local Plan LP39 Infrastructure Delivery & Developer Contributions 0 + + + 0 0 0 + + + 0 + + 0

SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14 Key to the High Level Assessment Matrix ++ Likely strong positive effect + Likely positive effect 0 Neutral/no effect - Likely adverse effect -- Likely strong adverse effect +/- Uncertain effects SEA Objectives 1 Maintain and enhance biodiversity, habitat and landscape 2 Conserve, restore and enhance green infrastructure 3 Protect and enhance air, soil and water resources 4 Protect areas that are at risk from flooding and reduce flood risk 5 Reduce carbon emissions 6 Increase resource efficiency and reduce resource use and waste 7 Identify, protect, maintain and enhance heritage assets and their setting 8 Reduce poverty and inequality and promote social inclusion 9 Reduce crime and fear of crime 10 Encourage healthier lifestyles and reduce adverse health impacts of new developments 11 Provide decent, affordable and safe homes for all 12 Support vitality and viability of centres 13 Provide and encourage the use of sustainable integrated transport systems, improve access and mobility 14 Promote employment, learning, skills and innovation

UE-0130 Luton LP HLA_8_131213 HLA 3 / 4 Luton Borough Local Plan SEA Objectives Proposed Policies SA1 SA2 SA3 SA4 SA5 SA6 SA7 SA8 SA9 SA10 SA11 SA12 SA13 SA14

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UE-0130 Luton LP HLA_8_131213 HLA 4 / 4 Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

Appendix J: Detailed Assessment Matrices

Please see insert.

P Sustainability Report on the Draft Luton Local Plan June 2014 UE-130 Draft Luton LP SA Report_7_140603

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Q DETAILED ASSESSMENT MATRIX Policy LP3 - Luton Town Centre - regeneration, including c.1,723 dwellings, job creation, 3,700m2 convenience, 12,200m2 comparison, hotel, leisure, open space, de-culverting, university expansion Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? TC regeneration aims for substantial Reconfiguration should seek to retain & environmental improvements and townscape increase coverage of trees, hedges & other enhancement, including opening-up of natural features, especially TPO & veteran Maintain and enhance biodiversity, habitat and culverted R Lea and new greenspaces. These 1 + ++ Ongoing Operation Sub-Regional Med Low Moderate Positive Yes trees. Opportunities to create wetland habitats landscape are likely to be of general benefit to a range of linked with de-culverting and SuDS (where wildlife and may improve the value of, and suitable in relation to SPZ) should be views from Hart Hill Area of Local Landscape maximised. Interest. Greenspace is limited at present, being largely restricted to St Mary's Church Gardens, non- Opportunities to provide new greenspaces, Conserve, restore and enhance green culverted sections of the Lea, and occasional 2 + ++ Ongoing Operation Sub-Regional Med Low Moderate Positive Yes parkland and town squares, street trees, green infrastructure gardens and groups of trees. Significant walls/roofs should be explored. benefits can be expected if the policy's objectives are met.

Protections for R Lea are included within policy, Following site investigations, design of but scale of additional residential, employment remediation strategies should include CEMPs and retail development likely to worsen air to reduce and manage risk of mobilising quality despite transport measures and contaminants. Impacts may result from a Protect and enhance air, soil and water provision for car-free developments. Limited Construction 3 -- -- - Ongoing Local High Med Moderate Negative Yes number of sites within TC; a strategic approach resources impacts on soil, but probability of & Operation to remediation / surface water management contamination high on old industrial sites, may be appropriate. leading to potential mobilisation of The policy already promotes sustainable contaminants into surface and ground waters; transport measures. TC is entirely within SPZ1.

Parts of TC close to R Lea are liable to fluvial New and re- developments should be required flood risk, particularly to the north-east of TC. to separate foul and surface water drainage The majority of TC is at low to medium risk of outfalls to reduce pressure on sewer capacity. Protect areas that are at risk from flooding and sewer flooding, especially in the central and Construction De-culverting proposals will help to reduce 4 - - - Ongoing Local Med Med Minor Negative Yes reduce flood risk eastern sections. Site selection for residential & Operation flood risk upstream by creating more space for development in particular will need to take water, but adjacent land uses will need to be account of these constraints to avoid increasing water compatible or made flood resilient. hazards of flooding. SuDS may not be suitable given SPZ1.

District heating type initiatives could be Proposals will need to comply with LP37 on particularly suitable for larger strategic sites carbon reduction & sustainable energy. But such as Power Court, Creative Quarter and scale of potential development and associated Construction, University Campus. Design of other sites should 5 Reduce carbon emissions traffic emissions likely to lead to minor -- - Initial early Local Med Med Minor Negative Yes consider use of renewable energy (e.g. solar significant impacts, particularly during Operation thermal/PV, micro wind, ground source heat, construction phases and before initiatives such CHP etc.). Areas of tree cover (carbon sink, as district heating come on line. urban cooling) should be retained / re-provided where possible.

Waste materials produced during demolition Policy seeks to make the most efficient use of and groundworks should be re-used on site land and regenerate the TC, and will need to wherever possible, or re-processed off site for Increase resource efficiency and reduce 6 comply with LP37. But use of resources likely to - - Initial Construction Local Med Low Minor Negative Yes future use in aggregates. Designs should resource use and waste increase in short-medium term during incorporate adequate storage space for construction. recycling, and consider providing communal composting facilities.

SEA Objectives SEA As required by LP30, it should be possible to TC includes several listed buildings, Plaiter's reduce negative effects via a high quality Lea and Town Centre conservation areas, and design which responds to and enhances the sites archaeological importance within Luton setting of historical features, and uses an medieval town. Policy accepts the need to Identify, protect, maintain and enhance appropriate selection of materials. Heritage 7 protect the fabric and setting of known assets, - - Initial Construction Local Med Low Minor Negative Yes heritage assets and their setting Statements should be prepared and, where and maximise their contribution to evidence points to potential presence of regeneration, but impacts possible through remains, mitigation will be required (e.g. loss/damage of buried assets particularly in investigative trenching, watching brief, recovery early stages. & interpretation of remains).

UE-0130 Luton LP DAM_6_131213 LP3 1 / 62 SEA Objectives SEA DETAILED ASSESSMENT MATRIX Policy LP3 - Luton Town Centre - regeneration, including c.1,723 dwellings, job creation, 3,700m2 convenience, 12,200m2 comparison, hotel, leisure, open space, de-culverting, university expansion Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Construction phase will provide local and Opportunities to provide work-based training accessible employment opportunities; Reduce poverty and inequality and promote Construction during construction should be explored; 8 operation phase will provide job opportunities ++ ++ ++ Ongoing Local High Med Moderate Positive Yes social inclusion & Operation provision for business incubator and/or through retail, offices, creative industries, live/work units may be suitable. education, training and leisure.

Improvements to street scene, enhanced pedestrian environment, new public spaces, and extended night time economy is likely to 9 Reduce crime and fear of crime + ++ ++ Ongoing Operation Local High Med Moderate Positive No increase activity and extent of active, overlooked space, thereby reducing fear of crime. As above, improvements to street scene and Opportunities to provide play space, pockets Encourage healthier lifestyles and reduce walking & cycling routes may help to 10 + + Ongoing Operation Local Low Low Negligible Positive Yes parks or improved access to cycle routes should adverse health impacts of new developments encourage more active lifestyles, with health be explored. benefits. TC housing provision will provide dwellings in accordance with LP16,35&37 regarding Provide decent, affordable and safe homes for 11 affordability, design & sustainability; sites likely + ++ ++ Ongoing Operation Local High Med Moderate Positive No all to yield 20% affordable units or financial contribution. Enhancing the vitality and viability of the Town Centre is what this policy is all about. 12 Support vitality and viability of centres + ++ ++ Ongoing Operation Sub-Regional High Med Major Positive No Significant benefits can be expected if policy objectives are met.

Provide and encourage the use of sustainable The guided busway, rail interchange, improved 13 integrated transport systems, improve access walking & cycling routes and car free + + + Ongoing Operation Sub-Regional Med Med Moderate and mobility developments all contribute to this objective.

Construction phase will provide local and Opportunities to provide work-based training accessible employment opportunities; Promote employment, learning, skills and Construction during construction should be explored; 14 operation phase will provide job opportunities ++ ++ ++ Ongoing Local High Med Moderate Positive Yes innovation & Operation provision for business incubator and/or through retail, offices, creative industries, live/work units may be suitable. education, training and leisure.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 LP3 2 / 62 DETAILED ASSESSMENT MATRIX Policy LP5 - Land south of Stockwood Park - 2.5ha football stadium (inc. 0.7ha conference, in/outdoor training; 0.3 enabling retail); 2ha P&R with improved links to TC; 9.5ha B1 office Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Ecological surveys and assessment will be One of the few remaining greenfield sites in the required to establish which (if any) protected borough, currently in arable production but species may be using the site and to design a with treelines and hedges along Newlands Rd, suitable mitigation strategy. Habitats of and treebelts adjacent to Stockwood Park golf greatest interest should be retained e.g. course and the M1 spur. Adjacent to Kidney & woodland, hedgerows and mature/veteran Bull Woods CWS and Stockwood Park CWS, trees should be incorporated into development Maintain and enhance biodiversity, habitat and while majority of north-eastern section of site Construction 1 ------Ongoing Sub-Regional High Med Major Negative Yes layout. New habitats should be created via landscape has Other SNCI designation under current & Operation landscaping plans, both to reduce landscape & Local Plan. Site is sandwiched between visual impacts from north & south, and to Stockwood Park ALLI and Green Belt. Impacts increase robustness of existing habitats. New to protected/notable species (e.g. bats, habitats could include new woodlands, badger) are likely, together with potential loss treebelts and hedgerows, wildflower meadows of mature/veteran trees, while views from the and wetlands associated with sustainable ALLI will be degraded. drainage measures.

Limited GI on site at present but development provides opportunity to link with diverse GI Overall GI provision could be enhanced by offering in Stockwood Park area, which includes creating extensive multifunctional, biodiverse Conserve, restore and enhance green golf, rugby and athletics, to provide high 2 - + ++ Ongoing Operation Sub-Regional Med Low Moderate Positive Yes open spaces, providing a range of health, infrastructure quality integrated sporting/leisure facilities. recreation and ecosystem services through Impacts are likely to be negative during landscaping and habitat creation. construction but, if opportunities are seized, potential for significant positive effects.

Soils within built footprint could be removed prior to development for re-use in landscaping and habitat creation elsewhere on site. Planting Site likely to be subject to air (and noise) of treebelt along M1&spur would help reduce pollution from adjacent M1, and likely to air pollution (and possibly noise attenuation Protect and enhance air, soil and water contribute to this during both construction Construction 3 - - - Ongoing Local Med Med Minor Negative Yes barrier although development not highly resources works & operation (via road traffic). & Operation sensitive). Sustainable transport links and P&R Development will result in loss of soil resources. will help to limit site's contribution to pollution Site not in SPZ1/2/3. via traffic emissions. Opportunity to provide cycle links through golf course to existing cycle routes to Stockwood Park, or via London Road.

Opportunity to create extensive new wetland Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral Yes habitats as part of site-wide sustainable reduce flood risk sewer or groundwater sources. drainage - see also above.

Proposals will need to comply with LP37 on Could be suited to district heating type carbon reduction & sustainable energy. But initiatives to serve sports and office complexes. scale of development, edge-of-centre position Designs should consider use of renewable Construction 5 Reduce carbon emissions and associated traffic emissions likely to lead to -- - - Ongoing Local Med Med Minor Negative Yes energy (e.g. solar thermal/PV, micro wind, & Operation significant impacts, particularly during ground source heat, CHP etc.). Areas of tree construction phases and before initiatives such cover (carbon sink, urban cooling) should be as district heating (if adopted) come on line. retained / re-provided where possible.

Soils within built footprint could be removed SEA Objectives SEA Loss of Grade 3 agricultural land on part of site, prior to development for re-use in landscaping Increase resource efficiency and reduce and land in arable production. Use of resources and habitat creation elsewhere on site. 6 - - Initial Construction Local Med Low Minor Negative Yes resource use and waste likely to increase in short-medium term during Designs should incorporate adequate storage construction. space for recycling, and consider providing communal composting facilities.

None - site is undeveloped and does not feature any known heritage assets (e.g. listed Identify, protect, maintain and enhance 7 building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

UE-0130 Luton LP DAM_6_131213 LP5 3 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Policy LP5 - Land south of Stockwood Park - 2.5ha football stadium (inc. 0.7ha conference, in/outdoor training; 0.3 enabling retail); 2ha P&R with improved links to TC; 9.5ha B1 office Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Construction phase will provide local Opportunities to provide work-based training Reduce poverty and inequality and promote employment opportunities; operation phase Construction during construction should be explored; 8 ++ ++ ++ Ongoing Local High Med Moderate Positive Yes social inclusion will provide job opportunities through stadium & Operation provision for business incubator may be & ancillary facilities, retail and offices. suitable.

9 Reduce crime and fear of crime No significant effect predicted. Neutral No

Health benefits through provision of additional sports/training facilities could be significant, Encourage healthier lifestyles and reduce See recommendations at Objectives 2&3 10 particularly if combined recommended links to ++ ++ Ongoing Operation Sub-Regional Med Med Moderate Positive Yes adverse health impacts of new developments above. facilities at Stockwood Park, green infrastructure and cycle routes.

Provide decent, affordable and safe homes for 11 None - no residential element to scheme. Neutral No all Luton TC may benefit from reduced traffic on match days and increased overall office provision but this is somewhat offset by the site's edge-of-centre location, which may Inter- No effective mitigation available if site is to be 12 Support vitality and viability of centres -- Operation Local Med Low Minor Negative No suppress demand for TC office redevelopment. mittent allocated. Effect unlikely to take hold in short term (scheme will not come forward immediately) and unlikely to be permanent. Policy could be more explicitly ambitious Mixed effects: the site is not in an accessible Provide and encourage the use of sustainable regarding sustainable transport by providing (from Luton) location and is currently best 13 integrated transport systems, improve access +/- +/- Ongoing Operation Local Med Med Minor Mixed Yes for guided busway connections to rail stations served by car, but policy seeks P&R and and mobility and TC, and securing cycle links as enhanced public transport to TC. recommended above (Objective 3).

Construction phase will provide local Opportunities to provide work-based training Promote employment, learning, skills and employment opportunities; operation phase Construction during construction should be explored; 14 ++ ++ ++ Ongoing Sub-Regional High Med Major Positive Yes innovation will provide job opportunities through stadium & Operation provision for business incubator may be & ancillary facilities, retail and offices. suitable.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 LP5 4 / 62 DETAILED ASSESSMENT MATRIX Policy LP6 - London Luton Airport - 284ha strategic allocation, including 43ha Century Park - supports airport expansion, business & industry growth (aviation, engineering, distribution, services), sustainable transport, access and parking. Century Park: aviation-related B1 inc light industry; small-scale affordable B2; B8; small-scale retail, services, leisure; hotel; access via tunnelled extension to Airport Way; landscaping & surface water management Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Recommendations apply mainly to Century Park as it is anticipated that most airport-related Century Park is one of the few remaining development will be within existing built-up greenfield sites in the borough, currently in areas, though principles are transferrable. arable production but with treelines and hedges Ecological surveys and assessment will be along the cycleroute, and flanked by pockets of required to establish which (if any) protected woodland. Century lies adjacent to Winch Hill species may be using the site and to design a Wood CWS and Wigmore Park CWS, while suitable mitigation strategy. Habitats of greatest Maintain and enhance biodiversity, habitat and Dairyborn Scarp DWS is sandwiched between Construction interest should be retained e.g. woodland, 1 ------Ongoing Sub-Regional High Med Major Negative Yes landscape Percival Way, car parking and Vauxhall Way at & Operation hedgerows and mature/veteran trees should be the western end of the airport. Two AGLVs lie incorporated into development layout. New just south of the airport which are also Green habitats should be created via landscaping plans, Belt. Impacts to protected/notable species (e.g. both to reduce landscape & visual impacts from bats, badger, reptiles) are likely, together with east & south, and to increase robustness of potential loss of mature/veteran trees, while existing habitats. New habitats could include views from the countryside will be degraded. new woodlands, treebelts and hedgerows, wildflower meadows and wetlands associated with sustainable drainage measures.

Wigmore Valley Park natural greenspace, sports Overall GI provision could be enhanced by pitches & allotments are sandwiched between creating additional multifunctional, biodiverse Century Park and the airport. Limited GI within open spaces permeating throughout Century the allocation at present but development Park development, providing a range of health, Conserve, restore and enhance green provides opportunity to provide additional 2 - + ++ Ongoing Operation Local High Low Moderate Positive Yes recreation and ecosystem services through infrastructure accessible semi-natural GI alongside landscaping and habitat creation. This would employment uses at Century Park. Impacts are benefit future employees at the site, as well as likely to be negative during construction but local residents already using Wigmore Valley there is potential for significant positive effects if Park. opportunities are maximised.

Soils within Century Park built footprint could be removed prior to development for re-use in landscaping and habitat creation elsewhere on site. Retention/strengthening of treebelt along cycleroute, subject to airport safety Site likely to be subject to air (and noise) considerations, may help reduce air pollution pollution from adjacent airport, and likely to within Century Park (and possibly noise contribute to this during both construction works Construction 3 Protect and enhance air, soil and water resources - - - Ongoing Local Med Med Minor Negative Yes attenuation barrier although development not & operation (via road traffic). Development will & Operation highly sensitive). Century Park benefits from result in loss of soil resources. Largely outside of existing cycle links, which should be improved (but close to) SPZ3. and coupled with cycle storage/repair on site, and links to bus/rail services to airport, which will help to limit site's contribution to pollution via traffic emissions. Opportunity to extend guided bus way to airport should be pursued.

Opportunity to create extensive new wetland Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral Yes habitats as part of site-wide sustainable drainage - reduce flood risk sewer or groundwater sources. see also above.

Proposals will need to comply with LP37 on carbon reduction & sustainable energy. But scale Century Park could be suited to district heating of development, edge-of-centre position and type initiatives to serve office, leisure and hotel associated traffic emissions likely to lead to uses. Designs should consider use of renewable significant impacts, particularly during Construction Local & Inter-

SEA Objectives 5 Reduce carbon emissions ------Ongoing Low Med Major Negative Yes energy (e.g. solar thermal/PV, micro wind, construction phases and before initiatives such & Operation national ground source heat, CHP etc.). Areas of tree as district heating (if adopted) come on line. cover (carbon sink, urban cooling) should be Airport expansion will inevitably lead to retained / re-provided where possible. increased carbon emissions contributing to global climate change.

UE-0130 Luton LP DAM_6_131213 LP6 5 / 62 DETAILED ASSESSMENT MATRIX Policy LP6 - London Luton Airport - 284ha strategic allocation, including 43ha Century Park - supports airport expansion, business & industry growth (aviation, engineering, distribution, services), sustainable transport, access and parking. Century Park: aviation-related B1 inc light industry; small-scale affordable B2; B8; small-scale retail, services, leisure; hotel; access via tunnelled extension to Airport Way; landscaping & surfaceSEA Objectives water management Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Soils within built footprint could be removed Loss of Grade 3 agricultural land on Century Park prior to development for re-use in landscaping Increase resource efficiency and reduce resource part of site, and land in arable production. Use of and habitat creation elsewhere on site. Designs 6 - - Initial Construction Local Med Low Minor Negative Yes use and waste resources likely to increase in short-medium term should incorporate adequate storage space for during construction. recycling, and consider providing communal composting facilities.

Archaeological area HER10808 lies mainly within Century Park. This includes two adjacent circular As required by LP30, it should be possible to cropmarks close to the probable location of a reduce negative effects via a high quality design substantial Roman building. The area has which responds to and enhances the setting of produced late Iron Age and Romano-British Identify, protect, maintain and enhance heritage historical features. Heritage Statements should 7 pottery, flue tiles, a glass bead, metalworking - - Initial Construction Local Med Low Minor Negative Yes assets and their setting be prepared and, where evidence points to fragments, a Licinius (AD316) bronze coin, along potential presence of remains, mitigation will be with fragments of an early 4th century bowl. required (e.g. investigative trenching, watching Impacts likely through loss/damage of buried brief, recovery & interpretation of remains). assets particularly in early stages of development.

Construction phase will provide local Opportunities to provide work-based training Reduce poverty and inequality and promote employment opportunities; operation phase will Construction 8 ++ ++ ++ Ongoing Local High Med Moderate Positive Yes during construction should be explored; social inclusion provide job opportunities through employment, & Operation provisions for business incubator are included. leisure and hotel uses. 9 Reduce crime and fear of crime No significant effect predicted. Neutral No

Encourage healthier lifestyles and reduce Health benefits through expansion of GI could 10 + + Ongoing Operation Local Med Med Minor Positive Yes See recommendations at Objective 2 above. adverse health impacts of new developments be significant, if realised.

11 Provide decent, affordable and safe homes for all None - no residential element to scheme. Neutral No

Luton TC may benefit from increased overall office provision but this is somewhat offset by the site's edge-of-centre location, which may No effective mitigation available if site is to be 12 Support vitality and viability of centres suppress demand for TC office redevelopment. -- Inter-mittent Operation Local Med Low Minor Negative No allocated. Effect unlikely to take hold in short term (scheme will not come forward immediately) and unlikely to be permanent. Policy could be more explicitly ambitious Mixed effects: the site is not in a highly Provide and encourage the use of sustainable regarding sustainable transport by providing for accessible location and is currently best served 13 integrated transport systems, improve access +/- +/- Ongoing Operation Local Med Med Minor Mixed Yes guided busway connections to rail stations and by car, but policy seeks enhanced public and mobility TC, and securing cycle facilities as recommended transport. above (Objective 3). Construction phase will provide local Opportunities to provide work-based training Promote employment, learning, skills and employment opportunities; operation phase will Construction 14 ++ ++ ++ Ongoing Sub-Regional High Med Moderate Positive Yes during construction should be explored; innovation provide job opportunities through employment, & Operation provisions for business incubator are included. leisure and hotel uses.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Major Major The 'Duration' column is noted as: Magnitude of Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives

UE-0130 Luton LP DAM_6_131213 LP6 6 / 62 DETAILED ASSESSMENT MATRIX Policy LP7 - Butterfield Technology Park - c.55,000m2 R&D offices (B1a,b,c) on remaining land (23ha), P&R, cemetery extension, landscaping and rights of way Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site partially developed but ecological surveys and assessment will be required for future phases to establish which (if any) protected Partially in arable production where still species may be using the site and to design a undeveloped but with treelines, gappy hedges suitable mitigation strategy. Habitats of and pond within and at edges of site. greatest interest should be retained as required Adjacent/near to Oaket Wood CWS and Oosey by the policy, e.g. woodland, hedgerows, Hill CWS, and Upshott Wood and Great Hayes ponds and mature/veteran trees should be Maintain and enhance biodiversity, habitat and Wood DWS / Other SNCIs. Site is surrounded Construction 1 ------Ongoing Sub-Regional High Med Major Negative Yes incorporated into development layout. New landscape by AONB and Green Belt. Impacts to & Operation habitats should be created via landscaping protected/notable species (e.g. bats, badger, plans, both to reduce landscape & visual reptiles, amphibians) are likely, together with impacts from west, north and east, and to potential loss of mature/veteran trees, while increase robustness of existing habitats. New views from the AONB and countryside to west, habitats could include new woodlands, north and east will be degraded. treebelts and hedgerows, wildflower meadows and wetlands associated with sustainable drainage measures.

Limited GI on site at present but development Overall GI provision could be enhanced by provides opportunity to link with diverse GI creating additional multifunctional, biodiverse offering at Butterfield Green and Stopsley open spaces permeating throughout Common, including semi-natural greenspace, Butterfield development, providing a range of Conserve, restore and enhance green sports, leisure and Vale Cemetery, thereby 2 - + ++ Ongoing Operation Sub-Regional Med Low Moderate Positive Yes health, recreation and ecosystem services infrastructure extending accessible semi-natural GI alongside through landscaping and habitat creation. This employment uses. Impacts are likely to be would benefit future employees at the site, as negative during construction but there is well as local residents already using Stopsley potential for significant positive effects if Common and Inspire Luton Sports Village. opportunities are maximised.

Soils within built footprint could be removed prior to development for re-use in landscaping Development likely to create air pollution and habitat creation elsewhere on site. during both construction works & operation (via Protect and enhance air, soil and water Construction Sustainable transport links and P&R will help to 3 road traffic). Development will result in loss of - - - Ongoing Local Med Med Minor Negative Yes resources & Operation limit site's contribution to pollution via traffic soil resources. Site outside of but adjacent to emissions. Site benefits from existing cycle SPZ3. links, which should be improved, extended and coupled with cycle storage/repair on site.

Opportunity to create extensive new wetland Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral Yes habitats as part of site-wide sustainable reduce flood risk sewer or groundwater sources. drainage - see also above. Proposals will need to comply with LP37 on carbon reduction, and policy-specific Could be suited to district heating type requirements on high quality design and initiatives to serve office complexes. Designs sustainability. But scale of development, edge- should consider use of renewable energy (e.g. Construction 5 Reduce carbon emissions of-centre position and associated traffic -- - - Ongoing Local Med Med Minor Negative Yes solar thermal/PV, micro wind, ground source & Operation emissions likely to lead to significant impacts, heat, CHP etc.). Areas of tree cover (carbon particularly during construction phases and sink, urban cooling) should be retained / re- before initiatives such as district heating (if provided where possible. adopted) come on line.

Soils within built footprint could be removed

SEA Objectives SEA Loss of Grade 3 agricultural land on part of site, prior to development for re-use in landscaping Increase resource efficiency and reduce and land in arable production. Use of resources and habitat creation elsewhere on site. 6 - - Initial Construction Local Med Low Minor Negative Yes resource use and waste likely to increase in short-medium term during Designs should incorporate adequate storage construction. space for recycling, and consider providing communal composting facilities.

UE-0130 Luton LP DAM_6_131213 LP7 7 / 62 DETAILED ASSESSMENT MATRIX

PolicyObjectives SEA LP7 - Butterfield Technology Park - c.55,000m2 R&D offices (B1a,b,c) on remaining land (23ha), P&R, cemetery extension, landscaping and rights of way Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site includes and is surrounded by several archaeological areas. HER15528 (Romano British pot & tile) within site, earthworks at As required by LP30, it should be possible to Whitehill Farm (now ploughed; HER5474) reduce negative effects via a high quality partially on site. HER12399, a triangular green design which responds to and enhances the shown on 1842 map which has produced setting of historical features. Heritage Identify, protect, maintain and enhance medieval pottery, partially on site. Swifts Green 7 - - Initial Construction Local Med Low Minor Negative Yes Statements should be prepared and, where heritage assets and their setting medieval settlement (HER17099) and evidence points to potential presence of earthworks at Manor Farm (HER 3341) both remains, mitigation will be required (e.g. adjacent to south, HER15527 adjacent to north, investigative trenching, watching brief, recovery and HER15526 nearby to north-west. & interpretation of remains). Impacts likely through loss/damage of buried assets particularly in early stages of development.

Construction phase will provide local Opportunities to provide work-based training Reduce poverty and inequality and promote employment opportunities; operation phase Construction 8 ++ ++ ++ Ongoing Local High Med Moderate Positive Yes during construction should be explored; social inclusion will provide job opportunities through & Operation provisions for business incubator are included. employment uses. 9 Reduce crime and fear of crime No significant effect predicted. Neutral No

Encourage healthier lifestyles and reduce Health benefits through expansion of GI could 10 + + Ongoing Operation Local Med Med Minor Positive Yes See recommendations at Objective 2 above. adverse health impacts of new developments be significant, if realised.

Provide decent, affordable and safe homes for 11 None - no residential element to scheme. Neutral No all Luton TC may benefit from increased overall office provision but this is somewhat offset by the site's edge-of-centre location, which may Inter- No effective mitigation available if site is to be 12 Support vitality and viability of centres suppress demand for TC office redevelopment. -- Operation Local Med Low Minor Negative No mittent allocated. Effect unlikely to take hold in short term (scheme will not come forward immediately) and unlikely to be permanent. Mixed effects: the site is not in a highly Provide and encourage the use of sustainable accessible location and is currently best served Cycle facilities could be enhanced as 13 integrated transport systems, improve access +/- +/- Ongoing Operation Local Med Med Minor Mixed Yes by car, but policy seeks enhanced public recommended above (Objective 3). and mobility transport and P&R. Construction phase will provide local Opportunities to provide work-based training Promote employment, learning, skills and employment opportunities; operation phase Construction 14 ++ ++ ++ Ongoing Local High Med Major Positive Yes during construction should be explored; innovation will provide job opportunities through & Operation provisions for business incubator are included. employment uses.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 LP7 8 / 62 DETAILED ASSESSMENT MATRIX Policy LP8 - Napier Park - c.25ha mixed-use brownfield redevelopment, including 35,000m2 B1a, 20,000m2 B1c, 600 dwellings, 2,500m2 foodstore, 2 hotels, casino, long-stay multi-storey airport parking, neighbourhood centre, public spaces Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Derelict site within the urban area, but adjacent Ecological surveys and assessment will be to Church Cemetery CWS. Dairyborn Scarp required to establish which (if any) protected DWS is c.100m east on the other side of species may be using the site and to design a Vauxhall Motor Works. Impacts to suitable mitigation strategy. Opportunities for Maintain and enhance biodiversity, habitat and protected/notable species (e.g. bats, black Construction 1 - +/- +/- Ongoing Local Med Low Minor Mixed Yes habitat creation could include new woodlands landscape redstart) are possible, together with indirect & Operation to buffer CWS, parkland, tree-lined avenues, effects to adjacent CWS during operation. hedgerows, wildflower meadows and wetlands Nearest sensitive landscape (ALLI) is Hart Hill associated with sustainable drainage measures c.350m west. Redevelopment likely to (SPZ-permitting). significantly improve townscape quality.

Site is within the urban area adjacent to Significant opportunity to extend and enhance Crawley Green Road Cemetery, an important existing GI into the heart of the new and sizeable GI asset in a central location. No neighbourhood by providing multifunctional, Conserve, restore and enhance green negative effects predicted. Significant 2 + ++ Ongoing Operation Local High Low Moderate Positive Yes biodiverse open spaces with a range of health, infrastructure opportunity to create additional GI through recreation and ecosystem services, linking to landscaping plans, both to buffer adjacent CWS tree-lined streets and networks of hedgerow and create new biodiverse greenspaces within permeating through the development. the new neighbourhood.

Site likely to contribute to air pollution during Following site investigation, design of both construction works & operation (via road remediation strategy should include a CEMP to traffic), although policy and location provide for reduce and manage risk of mobilising Protect and enhance air, soil and water Construction 3 sustainable transport choices. Site lies within - - - Ongoing Local Med Med Minor Negative Yes contaminants. Sustainable transport measures resources & Operation SPZ3. Extensive remediation likely to be should be maximised (e.g. onsite cycle facilities, required due to previous industrial uses, which strengthened links to public transport), as risks mobilising contaminants into SPZ. required by policy.

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral Yes SuDS may not be suitable given SPZ2. reduce flood risk sewer or groundwater sources. District heating type initiatives could be Proposals will need to comply with LP37 on particularly suitable for larger strategic sites carbon reduction & sustainable energy. But such as Napier Park. Designs should consider scale of potential development and associated Construction use of renewable energy (e.g. solar thermal/PV, 5 Reduce carbon emissions traffic emissions likely to lead to minor -- - Initial & early Local Med Med Minor Negative Yes micro wind, ground source heat, CHP etc.). significant impacts, particularly during Operation Areas of tree cover (carbon sink, urban cooling) construction phases and before initiatives such should be retained / re-provided where as district heating come on line. possible.

Waste materials produced during demolition and groundworks should be re-used on site Site is an efficient use of PDL, and will need to wherever possible, or re-processed off site for Increase resource efficiency and reduce comply with LP37. But use of resources likely to 6 - - Initial Construction Local Med Low Minor Negative Yes future use in aggregates. Designs should resource use and waste increase in short-medium term during incorporate adequate storage space for construction. recycling, and consider providing communal

composting facilities. SEA Objectives SEA Site c.20m west of Vauxhall Kimpton Rd Office Development proposals should assess scale of Identify, protect, maintain and enhance 7 listed building which may be subject to minor - Initial Construction Local Low Low Negligible Negative Yes potential risk and deploy suitable building heritage assets and their setting dust/vibration impacts during construction. protection measures where necessary.

Construction phase will provide local and accessible employment opportunities; Opportunities to provide work-based training Reduce poverty and inequality and promote operation phase will provide job opportunities Construction during construction should be explored; 8 ++ ++ ++ Ongoing Local High Med Moderate Positive Yes social inclusion through employment, retail and leisure uses, & Operation provision for business incubator and/or while also providing a significant number of live/work units may be suitable. new homes. Development is likely to increase activity and extent of active, overlooked space in 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No comparison to current use, thereby reducing fear of crime.

UE-0130 Luton LP DAM_6_131213 LP8 9 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Policy LP8 - Napier Park - c.25ha mixed-use brownfield redevelopment, including 35,000m2 B1a, 20,000m2 B1c, 600 dwellings, 2,500m2 foodstore, 2 hotels, casino, long-stay multi-storey airport parking, neighbourhood centre, public spaces Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site has good accessibility to health services, public transport and pedestrian/cycle routes, but limited access to sports & open spaces. No Opportunities to provide open spaces (see also Encourage healthier lifestyles and reduce 10 specific positive or negative effects predicted, + + Ongoing Operation Local Low Low Negligible Positive Yes above), play facilities, pockets parks or fitness adverse health impacts of new developments but additional proposals for sustainable trail should be explored. transport links, pedestrian and cycle routes likely to indirectly benefit health.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and re-use will 12 Support vitality and viability of centres make strong contribution to the vitality and ++ ++ Ongoing Operation Local High Med Moderate Positive No viability of Luton. Site accessibility is high with regard to Provide and encourage the use of sustainable education, employment & public transport, Sustainable transport measures should be 13 integrated transport systems, improve access ++ ++ Ongoing Operation Local Med Med Minor Positive Yes with improved PT, walking and cycling links maximised (e.g. onsite cycle facilities). and mobility specifically targeted by policy.

Construction phase will provide local and Opportunities to provide work-based training Promote employment, learning, skills and accessible employment opportunities; Construction during construction should be explored; 14 ++ ++ ++ Ongoing Local High Med Moderate Positive Yes innovation operation phase will provide job opportunities & Operation provision for business incubator and/or through employment, retail and leisure uses. live/work units may be suitable.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 LP8 10 / 62 DETAILED ASSESSMENT MATRIX Policy LP9 - Power Court - c.7ha mixed-use brownfield redevelopment, including c.3,700m2 convenience retail, c.600 dwellings and town centre uses e.g. sport, leisure, cultural, comparison retail, decontamination and de-culverting Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Brownfield site within the urban area, but containing the River Lea which is largely culverted within site but also designated as Ecological surveys and assessment will be CWS and DWS. Limited semi-natural required to establish which (if any) protected vegetation remains following development of species may be using the site and to design a Maintain and enhance biodiversity, habitat and the guided busway which runs along the Construction 1 - +/- + Ongoing Local Med Low Minor Mixed Yes suitable mitigation strategy. Opportunities for landscape northern site boundary. Impacts to River Lea & Operation habitat creation could focus on proposals for are possible, but limited to demolition/ River Lea de-culverting (if feasible) as well as remediation/ construction phase. Nearest new parkland and tree-lined avenues. sensitive landscape (ALLI) is Hart Hill c.120 north-east. Redevelopment likely to significantly improve townscape quality. Site is within the urban area adjacent to St Mary's Churchyard, an important GI asset in a New GI or connections to existing should aim central location (also Windmill Rd Island Conserve, restore and enhance green to provide multifunctional, biodiverse open 2 amenity greenspace). No negative effects + + Ongoing Operation Local Med Low Minor Positive Yes infrastructure spaces with a range of health, recreation and predicted. Opportunity to create additional GI ecosystem services. or high quality connections to existing through landscaping plans.

Site likely to contribute to air pollution during Following site investigation, design of both construction works & operation (via road remediation strategy should include a CEMP to traffic), although location provides for reduce and manage risk of mobilising Protect and enhance air, soil and water Construction 3 sustainable transport choices. Site lies within -- - - Ongoing Local Med Med Minor Negative Yes contaminants. Sustainable transport measures resources & Operation SPZ1. Extensive remediation likely to be should be maximised (e.g. onsite cycle facilities, required due to previous industrial uses, which strengthened links to public transport), risks mobilising contaminants into SPZ. pedestrian and cycle routes.

New and re- developments should be required Site partially subject to fluvial flood risk from to separate foul and surface water drainage River Lea (FZ2/3) and adjacent to area at outfalls to reduce pressure on sewer capacity. Protect areas that are at risk from flooding and medium risk from sewer flooding. Site selection Construction De-culverting proposals will help to reduce 4 - - - Ongoing Local Med Med Minor Negative Yes reduce flood risk for residential development in particular will & Operation flood risk upstream by creating more space for need to take account of these constraints to water, but adjacent land uses will need to be avoid increasing hazards of flooding. water compatible or made flood resilient. SuDS may not be suitable given SPZ1.

District heating type initiatives could be Proposals will need to comply with LP37 on particularly suitable for larger strategic sites carbon reduction & sustainable energy. But such as Power Court. Designs should consider scale of potential development and associated Construction use of renewable energy (e.g. solar thermal/PV, 5 Reduce carbon emissions traffic emissions likely to lead to minor -- - Initial & early Local Med Med Minor Negative Yes micro wind, ground source heat, CHP etc.). significant impacts, particularly during Operation Areas of tree cover (carbon sink, urban cooling) construction phases and before initiatives such should be retained / re-provided where as district heating come on line. possible.

Waste materials produced during demolition and groundworks should be re-used on site Site is an efficient use of PDL, and will need to wherever possible, or re-processed off site for Increase resource efficiency and reduce comply with LP37. But use of resources likely to 6 - - Initial Construction Local Med Low Minor Negative Yes future use in aggregates. Designs should resource use and waste increase in short-medium term during incorporate adequate storage space for

SEA Objectives SEA construction. recycling, and consider providing communal composting facilities.

UE-0130 Luton LP DAM_6_131213 LP9 11 / 62 DETAILED ASSESSMENT MATRIX Policy LP9 - Power Court - c.7ha mixed-use brownfield redevelopment, including c.3,700m2 convenience retail, c.600 dwellings and town centre uses e.g. sport, leisure, cultural, comparison retail, decontamination and de-culverting Mitigation Duration Temporary

SEA Objectives SEA Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? As required by LP30, it should be possible to Site includes part of the Luton medieval town reduce negative effects via a high quality archaeological area, is c.40m north of the design which responds to and enhances the Grade I listed St Mary's Church, and c.25m east setting of historical features, and uses an of Plaiter's Lea conservation area. Policy Identify, protect, maintain and enhance appropriate selection of materials. Heritage 7 accepts the need to protect the fabric and - - Initial Construction Local Med Low Minor Negative Yes heritage assets and their setting Statements should be prepared and, where setting of known assets, and maximise their evidence points to potential presence of contribution to regeneration, but impacts remains, mitigation will be required (e.g. possible through loss/damage of buried assets investigative trenching, watching brief, recovery particularly in early stages. & interpretation of remains).

Construction phase will provide local and Opportunities to provide work-based training accessible employment opportunities; Reduce poverty and inequality and promote Construction during construction should be explored; 8 operation phase will provide job opportunities ++ ++ ++ Ongoing Local High Med Moderate Positive Yes social inclusion & Operation provision for business incubator and/or through retail and town centre uses, while also live/work units may be suitable. providing a significant number of new homes.

Development is likely to increase activity and extent of active, overlooked space in 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No comparison to current use, thereby reducing fear of crime. Site has good accessibility to health services, Opportunities to provide open spaces (see also Encourage healthier lifestyles and reduce sports & open spaces, public transport and 10 + + Ongoing Operation Local Low Low Negligible Positive Yes above), play facilities or pockets parks should adverse health impacts of new developments pedestrian/cycle routes, and may result in be explored. increased sports provision.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within TC and redevelopment will make 12 Support vitality and viability of centres strong contribution to the vitality and viability ++ ++ Ongoing Operation Local High Med Moderate Positive No of Luton. Provide and encourage the use of sustainable Site accessibility is high with regard to Sustainable transport measures should be 13 integrated transport systems, improve access education, employment & public transport, and ++ ++ Ongoing Operation Local Med Med Minor Positive Yes maximised (e.g. onsite cycle facilities), and mobility has good PT, walking and cycling links. strengthened walking and cycling links.

Construction phase will provide local and Opportunities to provide work-based training Promote employment, learning, skills and accessible employment opportunities; Construction during construction should be explored; 14 ++ ++ ++ Ongoing Local High Med Moderate Positive Yes innovation operation phase will provide job opportunities & Operation provision for business incubator and/or through retail and town centre uses . live/work units may be suitable.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 LP9 12 / 62 DETAILED ASSESSMENT MATRIX Policy LP10 - High Town - regeneration of area to be delivered through a range of mixed-sue redevelopment sites, better pedestrian access, more open spaces and improved street environment. Three key sites are targeted: Old Bedford Rd - c.130 dwellings with retail, light industry & public space; East Village - c.240 dwellings, 6,000-8,000m2 employment, 400-600m2 retail, new access; The Path - safety and public realm improvements Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Area is limited in semi-natural habitat, with pockets of greenery generally restricted to gardens and occasional groups of trees. Ecological surveys and assessment will be Maintain and enhance biodiversity, habitat and Impacts to protected/notable species (e.g. bats) Construction required to establish which (if any) protected 1 - - - Ongoing Local Low Low Negligible Negative Yes landscape are possible. Hitchin Road Spinney DWS is & Operation species may be using the sites and to design a adjacent to the east. Hart Hill ALLI is c.100m to suitable mitigation strategy. the east and could be negatively affected by redevelopment.

Area does not contain any GI assets and policy Conserve, restore and enhance green objective to improve public realm and 2 + + Ongoing Operation Local Med Low Minor Positive No infrastructure environmental quality with new and greener open spaces is likely to be of significant benefit.

Following site investigation, design of Area is PDL, not close to major sources of air remediation strategy should include a CEMP to pollution and regeneration is unlikely to reduce and manage risk of mobilising Protect and enhance air, soil and water 3 significantly affect air quality. High Town is - Initial Construction Local Med Low Minor Negative Yes contaminants. Sustainable transport measures resources entirely within SPZ1 which may be at risk during should be maximised (e.g. onsite cycle facilities, remediation of any contaminated sites. strengthened links to public transport), pedestrian and cycle routes.

Parts of High Town are at risk of sewer and New and re- developments should be required surface water flooding. Site selection for Protect areas that are at risk from flooding and Construction to separate foul and surface water drainage 4 residential development in particular will need - - - Ongoing Local Med Med Minor Negative Yes reduce flood risk & Operation outfalls to reduce pressure on sewer capacity. to take account of these constraints to avoid SuDS may not be suitable given SPZ1. increasing hazards of flooding.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition and groundworks should be re-used on site Regeneration of High Town sites is an efficient wherever possible, or re-processed off site for Increase resource efficiency and reduce use of PDL, will need to comply with LP37, and 6 + + Ongoing Operation Local Med High Minor Positive Yes future use in aggregates. Designs should resource use and waste unlikely to lead to significant resource incorporate adequate storage space for consumption. recycling, and consider providing communal composting facilities.

As required by LP30, it should be possible to reduce negative effects via a high quality design which responds to and enhances the High Town contains several listed buildings and setting of historical features, and uses an

SEA Objectives SEA a conservation area, the setting of which is Identify, protect, maintain and enhance appropriate selection of materials. Heritage 7 likely to be improved as a result of - + + Ongoing Operation Local Med Med Minor Positive Yes heritage assets and their setting Statements should be prepared and, where regeneration despite short-term risks during evidence points to potential presence of construction. remains, mitigation will be required (e.g. investigative trenching, watching brief, recovery & interpretation of remains).

Construction phase will provide local and Opportunities to provide work-based training accessible employment opportunities; Reduce poverty and inequality and promote Construction during construction should be explored; 8 operation phase will provide job opportunities + + + Ongoing Local Med Med Minor Positive Yes social inclusion & Operation provision for business incubator and/or through employment and retail uses, while also live/work units is included in policy. providing a number of new homes.

Development is likely to improve street scene and increase footfall and extent of active, 9 Reduce crime and fear of crime + ++ Ongoing Operation Local High Med Moderate Positive No overlooked space, thereby reducing fear of crime.

UE-0130 Luton LP DAM_6_131213 LP10 13 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Policy LP10 - High Town - regeneration of area to be delivered through a range of mixed-sue redevelopment sites, better pedestrian access, more open spaces and improved street environment. Three key sites are targeted: Old Bedford Rd - c.130 dwellings with retail, light industry & public space; East Village - c.240 dwellings, 6,000-8,000m2 employment, 400-600m2 retail, new access; The Path - safety and public realm improvements Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Environmental improvements, additional open Encourage healthier lifestyles and reduce 10 space and enhanced pedestrian cycle links + + Ongoing Operation Local Low Low Negligible Positive No adverse health impacts of new developments could indirectly benefit health.

Sites will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 + + Ongoing Operation Local Med Med Minor Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

High Town is close to TC and regeneration will 12 Support vitality and viability of centres + ++ Ongoing Operation Local High Med Moderate Positive No support the vitality and viability of both areas.

Provide and encourage the use of sustainable High Town has good accessibility to education, Sustainable transport measures should be 13 integrated transport systems, improve access employment & public transport, and has good + + Ongoing Operation Local Med Med Minor Positive Yes maximised (e.g. onsite cycle facilities), and mobility PT, walking and cycling links. strengthened walking and cycling links.

Construction phase will provide local and Opportunities to provide work-based training Promote employment, learning, skills and accessible employment opportunities; Construction during construction should be explored; 14 + + + Ongoing Local Med Med Minor Positive Yes innovation operation phase will provide job opportunities & Operation provision for business incubator and/or through employment and retail uses. live/work units is included in policy.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 LP10 14 / 62 DETAILED ASSESSMENT MATRIX Policy LP11 - Creative Quarter - transformative policy to regenerate underutilised area of historic character. Uses to include A1, A3, A4, D1, D2, C3, B1, with focus on creative industries, arts, media, education, live-work units, night-time economy, improved accessibility and public realm. Includes: Northern Gateway (0.5ha) comprehensive retail-led scheme; Station Gateway (1.5ha) resi-led mixed use; North of St George's Sq mixed uses Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Brownfield site within the urban area, limited in semi-natural habitat. Contains the River Lea which is largely culverted within site but also Ecological surveys and assessment will be designated as DWS. Pockets of greenery mainly required to establish which (if any) protected focused on un-culverted stretch. Impacts to species may be using the site and to design a Maintain and enhance biodiversity, habitat and Construction 1 protected/notable species (e.g. bats) and R Lea - +/- + Ongoing Local Med Low Minor Mixed Yes suitable mitigation strategy. Opportunities for landscape & Operation are possible, but probably limited to habitat creation could focus on proposals for demolition/remediation/ construction phase. River Lea de-culverting (if feasible) as well as Nearest sensitive landscape (ALLI) is Hart Hill new parkland and tree-lined avenues. c.220 north-east. Redevelopment likely to improve townscape quality.

Opportunity to de-culvert R Lea in combination Area does not contain any GI assets and policy with new public square at Bute Street to Conserve, restore and enhance green objective to improve public realm including 2 + + Ongoing Operation Local Med Low Minor Positive Yes provide multifunctional, biodiverse open infrastructure new open spaces is likely to be of significant spaces with a range of health, recreation and benefit if realised. ecosystem services.

Site likely to contribute to air pollution mainly Following site investigation, design of during construction works only due to remediation strategy should include a CEMP to accessible location with sustainable transport reduce and manage risk of mobilising Protect and enhance air, soil and water 3 choices. Site lies within SPZ2. Remediation -- - Initial Construction Local Med Med Minor Negative Yes contaminants. Sustainable transport measures resources likely to be required due to previous industrial should be maximised (e.g. onsite cycle facilities, uses, which risks mobilising contaminants into strengthened links to public transport), SPZ. pedestrian and cycle routes.

New and re- developments should be required Site partially subject to fluvial flood risk from to separate foul and surface water drainage River Lea (FZ2/3) and whole area at medium risk outfalls to reduce pressure on sewer capacity. Protect areas that are at risk from flooding and from sewer flooding. Site selection for Construction De-culverting proposals will help to reduce 4 - - - Ongoing Local Med Med Minor Negative Yes reduce flood risk residential development in particular will need & Operation flood risk upstream by creating more space for to take account of these constraints to avoid water, but adjacent land uses will need to be increasing hazards of flooding. water compatible or made flood resilient. SuDS may not be suitable given SPZ2.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition and groundworks should be re-used on site Regeneration of Creative Quarter sites is an wherever possible, or re-processed off site for Increase resource efficiency and reduce efficient use of PDL, will need to comply with 6 + + Ongoing Operation Local Med High Minor Positive Yes future use in aggregates. Designs should resource use and waste LP37, and unlikely to lead to significant incorporate adequate storage space for resource consumption. recycling, and consider providing communal

composting facilities. SEA Objectives SEA Site adjacent to the Luton medieval town As required by LP30, it should be possible to archaeological area to south & east, is entirely reduce negative effects via a high quality within Plaiters Lea conservation area, and design which responds to and enhances the contains / is adjacent to 9 listed buildings. setting of historical features, and uses an Identify, protect, maintain and enhance Policy accepts the need to respect and appropriate selection of materials. Heritage 7 - + + Ongoing Operation Local Med Med Minor Mixed Yes heritage assets and their setting complement the character of the area, the Statements should be prepared and, where setting of which is likely to be improved as a evidence points to potential presence of result of regeneration despite short-term risks remains, mitigation will be required (e.g. through loss/damage of buried assets during investigative trenching, watching brief, recovery construction. & interpretation of remains).

UE-0130 Luton LP DAM_6_131213 LP11 15 / 62 SEA Objectives SEA DETAILED ASSESSMENT MATRIX Policy LP11 - Creative Quarter - transformative policy to regenerate underutilised area of historic character. Uses to include A1, A3, A4, D1, D2, C3, B1, with focus on creative industries, arts, media, education, live-work units, night-time economy, improved accessibility and public realm. Includes: Northern Gateway (0.5ha) comprehensive retail-led scheme; Station Gateway (1.5ha) resi-led mixed use; North of St George's Sq mixed uses Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Construction phase will provide local and Opportunities to provide work-based training accessible employment opportunities; Reduce poverty and inequality and promote Construction during construction should be explored; 8 operation phase will provide job opportunities ++ ++ ++ Ongoing Local High Med Moderate Positive Yes social inclusion & Operation provision for business incubator and/or through retail and town centre uses, while also live/work units is included in policy. providing a significant number of new homes.

Development is likely to increase activity and extent of active, overlooked space in 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No comparison to current use, thereby reducing fear of crime. Site has generally good accessibility to health Opportunities to provide open spaces (see also Encourage healthier lifestyles and reduce 10 services, sports facilities, public transport and + + Ongoing Operation Local Low Low Negligible Positive Yes above), play facilities or pockets parks should adverse health impacts of new developments pedestrian/cycle routes. be explored.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within TC and redevelopment will make 12 Support vitality and viability of centres strong contribution to the vitality and viability ++ ++ Ongoing Operation Local High Med Moderate Positive No of Luton. Provide and encourage the use of sustainable Site accessibility is high with regard to Sustainable transport measures should be 13 integrated transport systems, improve access education, employment & public transport, and ++ ++ Ongoing Operation Local Med Med Minor Positive Yes maximised (e.g. onsite cycle facilities), and mobility has good PT, walking and cycling links. strengthened walking and cycling links.

Construction phase will provide local and Opportunities to provide work-based training Promote employment, learning, skills and accessible employment opportunities; Construction during construction should be explored; 14 ++ ++ ++ Ongoing Local High Med Moderate Positive Yes innovation operation phase will provide job opportunities & Operation provision for business incubator and/or through retail and town centre uses . live/work units is included in policy.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 LP11 16 / 62 DETAILED ASSESSMENT MATRIX Policy LP12 - Marsh Farm - development to continue regeneration & reconfiguration, incl: 1,000m2 foodstore; improvements for permeability, accessibility, activity/security, amenity space, and public realm, including tree planting; designation of central area as District Centre Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Area is relatively rich in greenspace and, although much of this is amenity greenspace, has a comprehensive network of GI, linking to open countryside (Green Belt) to north. Ecological surveys and assessment will be Impacts to protected/notable species/habitats Maintain and enhance biodiversity, habitat and Construction required to establish which (if any) protected 1 (e.g. bats, birds, reptiles) are possible. Contains - - - Ongoing Local Low Low Negligible Negative Yes landscape & Operation species may be using the sites and to design a or is adjacent to R Lea CWS/DWS, Leagrave suitable mitigation strategy. Common/Wauluds Bank CWS/pLNR, Bramingham Wood CWS. AONB is at least 600m north and unlikely to be significantly affected by scale of proposals.

Area has a comprehensive network of GI, New GI or connections to existing should aim although much of this is amenity greenspace, to provide multifunctional ecosystem services. linking to open countryside (Green Belt) to The current form of the neighbourhood is Conserve, restore and enhance green north, and benefits from a few larger areas of suited to new areas of parkland combining 2 + + Ongoing Operation Local Med Low Minor Positive Yes infrastructure semi-natural greenspace and allotments at its amenity grassland with wildflower meadows fringes, particularly to south and east. and low-density tree-planting, to offer health Enhanced landscaping proposals likely to be of and recreation benefits, urban cooling, benefit. biodiversity and surface water attenuation.

Area is a densely developed suburb, not close Following site investigation, design of to major sources of air pollution. Retail remediation strategy should include a CEMP to construction/operation likely to contribute reduce and manage risk of mobilising Protect and enhance air, soil and water 3 minor air quality impacts. Mainly within SPZ3 - Initial Construction Local Med Low Minor Negative Yes contaminants. Sustainable transport measures resources with a small section of SPZ2 to south which may should be maximised (e.g. onsite cycle facilities, be at risk during remediation of any strengthened links to public transport), contaminated sites. pedestrian and cycle routes.

Area largely absent of flood risk though some Protect areas that are at risk from flooding and 4 very small sections of fluvial FZ2/3 and medium Neutral No reduce flood risk risk of sewer flooding to southern fringe.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Regeneration of Marsh Farm sites is an efficient Waste materials produced during demolition Increase resource efficiency and reduce use of PDL, will need to comply with LP37, and and groundworks should be re-used on site 6 + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste unlikely to lead to significant resource wherever possible, or re-processed off site for consumption. future use in aggregates.

Contains Waulud's Bank SAM (possible As required by LP30, it should be possible to Neolithic henge monument; certain Iron Age reduce negative effects via a high quality

SEA Objectives SEA fortified enclosure), and evidence of a large design which responds to and enhances the Roman village settlement along the Lea to the setting of historical features, and uses an Identify, protect, maintain and enhance south. Further archaeological areas adjacent to appropriate selection of materials. Heritage 7 - + + Ongoing Operation Local Med Med Minor Positive Yes heritage assets and their setting north. Setting of these feature potentially at Statements should be prepared and, where risk, although planned environmental evidence points to potential presence of improvements could enhance them. Short-term remains, mitigation will be required (e.g. risks through loss/damage of buried assets investigative trenching, watching brief, recovery during construction. & interpretation of remains).

Construction phase (foodstore) will provide Opportunities to provide work-based training local and accessible employment Reduce poverty and inequality and promote Construction during construction should be explored; 8 opportunities; benefits during operation largely + + + Ongoing Local Low Low Negligible Positive Yes social inclusion & Operation provision for business incubator and/or related to new DC status and envtl live/work units should be considered. improvements.

UE-0130 Luton LP DAM_6_131213 LP12 17 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Policy LP12 - Marsh Farm - development to continue regeneration & reconfiguration, incl: 1,000m2 foodstore; improvements for permeability, accessibility, activity/security, amenity space, and public realm, including tree planting; designation of central area as District Centre Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Reconfiguration of buildings and street layout, improved permeability, accessibility, natural 9 Reduce crime and fear of crime + ++ Ongoing Operation Local High Med Moderate Positive No surveillance and activity in public spaces will all help to reduce crime / fear of crime.

Area is generally well provided for in terms of Encourage healthier lifestyles and reduce healthcare, sports, open space and public 10 + + + Ongoing Operation Local Medium High Minor Positive No adverse health impacts of new developments transport, which is expected to continue under policy. Site unlikely to provide a significant number of Provide decent, affordable and safe homes for 11 dwellings but could yield 20% affordable units + + Ongoing Operation Local Low Low Negligible Positive No all or financial contribution. Envtl improvements, reconfiguration and DC 12 Support vitality and viability of centres status are all likely to improve the vitality and + ++ Ongoing Operation Local High Med Moderate Positive No viability of Marsh Farm centre. Marsh Farm has good accessibility to Provide and encourage the use of sustainable education, bus, walking and cycling links, but is Sustainable transport measures should be 13 integrated transport systems, improve access more limited in access to employment & rail + + Ongoing Operation Local Med Low Minor Positive Yes maximised (e.g. onsite cycle facilities), and mobility services. Policy is unlikely to radically change strengthened walking and cycling links. this except through DC status. Construction phase (foodstore) will provide Opportunities to provide work-based training local and accessible employment Promote employment, learning, skills and Construction during construction should be explored; 14 opportunities; benefits during operation largely + + + Ongoing Local Low Low Negligible Positive Yes innovation & Operation provision for business incubator and/or related to new DC status and envtl live/work units should be considered. improvements.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 LP12 18 / 62 DETAILED ASSESSMENT MATRIX Policy LP24 and Site ID 382 - Community & education facilities - protecting, sharing and integrating existing facilities, and providing new facilities - including a new 2-form entry 1ary school on site 382 (Land behind 2-26 Osbourne Road) at the Brache Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Ecological surveys and assessment will be Site 382 is part of River Lea DWS and adjacent required to establish which (if any) protected to River Lea CWS. Semi-natural habitats are species may be using the site and to design a present on site so negative effects are suitable mitigation strategy. Habitats of Maintain and enhance biodiversity, habitat and predicted due to habitat loss or direct species greatest interest should be retained where 1 -- - - Ongoing Permanent Regional Med High Moderate Negative Yes landscape impact. However impacts are also possible possible. Development should seek to through disturbance (visitor access / lighting of enhance/protect local wildlife sites for instance the riverine habitats), both during and post by implementation of native planting scheme, construction. improvement of footpath network or provision of interpretation boards.

Semi- natural habitats are present on site. The Maintaining ecological connectivity and intention is to focus development on the Conserve, restore and enhance green Initial and Construction, providing development that is suited to the 2 disused tennis courts but development could - - - Local Medium Medium Minor Negative Yes infrastructure ongoing operation greenfield location will be important result in loss of green infrastructure and open considerations. space. Site is partially PDL but unlikely to be Following site investigation, design of contaminated and not agricultural land. Site is remediation strategy should include a Protect and enhance air, soil and water not close to major air pollution sources (e.g. 3 Neutral No rigorously designed CEMP to reduce and resources AQMA, M1, airport), but is adjacent to R Lea manage risk of mobilising contaminants, and within SPZ3. Site has reasonable particularly during demolition and construction. accessibility to bus and cycle routes. Protect areas that are at risk from flooding and None - site not subject to flood risk by is 4 Neutral No SuDS may not be suitable given SPZ3. reduce flood risk adjacent to River Lea.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Site is partially PDL. Policy in general promotes Increase resource efficiency and reduce 6 the re-use and sharing of facilities, which will ++ ++ ++ Ongoing Operation Local High Med Moderate Positive No resource use and waste increase resource efficiency.

SEA Objectives SEA None - site does not feature any known heritage assets (e.g. listed building, Identify, protect, maintain and enhance 7 conservation area, scheduled monument, Neutral No heritage assets and their setting registered park or garden) though buried assets may be present. Retention of existing and provision of new Reduce poverty and inequality and promote 8 community and education facilities will + + + Ongoing Operation Local Med High Minor Positive No social inclusion enhance social inclusion.

Development is likely to increase activity and 9 Reduce crime and fear of crime extent of overlooked space in comparison to + + Ongoing Operation Local Med Med Minor Positive No current use, thereby reducing fear of crime.

Site has good access to sports facilities and It is recommended that opportunities to re- Encourage healthier lifestyles and reduce open space but will result in a loss of some of 10 +/- +/- Ongoing Operation Local Med Med Minor Mixed Yes provide / enhance sporting and play facilities adverse health impacts of new developments these. Accessibility to children's play area is nearby are explored. limited. Provide decent, affordable and safe homes for 11 Policy does not relate to housing. Neutral No all 12 Support vitality and viability of centres No significant effects predicted. Neutral No Provide and encourage the use of sustainable Site accessibility is high, with good links to 13 integrated transport systems, improve access + + + Ongoing Operation Local Med Med Minor Yes Onsite cycle facilities should be provided. train, bus and cycle infrastructure. and mobility The policy promotes learning and skills Promote employment, learning, skills and development through the provision and 14 ++ ++ ++ Ongoing Operation Local High Med Moderate Positive No innovation retention of community and education facilities.

Key Major negative effect -- Negative Severe Optimal Positive Magnitude of The 'Duration' column is noted as: UE-0130 Luton LP DAM_6_131213 significance is LP24-382 19 / 62 illustrated as: DETAILED ASSESSMENT MATRIX Policy LP24 and Site ID 382 - Community & education facilities - protecting, sharing and integrating existing facilities, and providing new facilities - including a new 2-form entry 1ary school on site 382 (Land behind 2-26 Osbourne Road) at the Brache Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 LP24-382 20 / 62 DETAILED ASSESSMENT MATRIX Housing Site 155: Land at Guardian Estate, Dallow Road. - 100% housing 1,2 and 3-bed units; Call for Sites response and planning application; 64 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide greenspace, pocket Site is within the urban area, not adjacent to Conserve, restore and enhance green parks, new trees, green walls/roofs should be 2 any open space or other GI. No effect Neutral Yes infrastructure explored, particularly given comparatively large predicted size of site. Following site investigation, design of Site is PDL, not close to major air pollution remediation strategy should include a CEMP to Protect and enhance air, soil and water sources (e.g. AQMA, M1, airport), not adjacent Construction reduce and manage risk of mobilising 3 - - - Ongoing Local Med Med Minor Negative Yes resources to R Lea, but within SPZ1. Good bus and cycle & Operation contaminants. Strengthened links to public accessibility but poor access to railway. transport in particular rail network could be considered. Protect areas that are at risk from flooding and Not in FZ 2 or 3, risk of sewer/groundwater 4 Neutral No SuDS may not be appropriate in SPZ1. reduce flood risk flooding unknown

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

SEA Objectives SEA Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored.

Development is likely to increase activity and extent of active, overlooked space in 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No comparison to current use, thereby reducing fear of crime. Site accessibility is good regarding healthcare, education, open space and play facilities. Although nearest sports facilities over 1km Encourage healthier lifestyles and reduce 10 away proximity of other facilities will encourage + + Ongoing Operation Local Med Med Minor Positive No adverse health impacts of new developments use. The proposal has no health, sports, recreation, education, leisure, community or cultural elements.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Bury Road and Town centre are within close 12 Support vitality and viability of centres proximity so considered that development will + + Ongoing Operation Local Med Med Minor Positive No support viability and vitality of these centres.

UE-0130 Luton LP DAM_6_131213 155 21 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 155: Land at Guardian Estate, Dallow Road. - 100% housing 1,2 and 3-bed units; Call for Sites response and planning application; 64 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Site accessibility is good regarding education, Provide and encourage the use of sustainable employment, health facilities, bus transport and 13 integrated transport systems, improve access cycle routes, but limited access to railway + + Ongoing Operation Local Low Med Negligible Positive Yes and mobility routes. This should encourage use of sustainable transport Promote employment, learning, skills and Construction phase will provide local and 14 + Initial Construction Local Med Med Minor Positive No innovation accessible employment opportunities;.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 155 22 / 62 DETAILED ASSESSMENT MATRIX Housing Site 161: Oxen Industrial Estate, Oxen Road. - 100% housing 2 and 3-bed units; 2013 ELR; 48 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide greenspace, new Site is within the urban area, not adjacent to trees, green walls/roofs should be explored, Conserve, restore and enhance green 2 any open space or other GI, but 247m from Neutral Yes particularly given comparatively large size of infrastructure Hart Hill ALLI. site. Survey should be carried out to ensure no visual impact on Hart Hill ALLI. Site is PDL, not close to major air pollution Following site investigation, design of sources (e.g. AQMA, M1, airport), not adjacent remediation strategy should include a CEMP to Protect and enhance air, soil and water Construction 3 to R Lea, but within SPZ1. Good bus - - - Ongoing Local Med Med Minor Negative Yes reduce and manage risk of mobilising resources & Operation accessibility but poor access to railway and contaminants. Strengthened links to cycle cycle routes will encourage car use. network could be considered.

Protect areas that are at risk from flooding and Not within FZ 2 or 3 but within overland flow Construction 4 _ _ _ Ongoing Local Low Med Negligible Negative No SuDS may not be suitable given SPZ1. reduce flood risk flood zone & Operation

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

SEA Objectives SEA Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored.

Development is likely to increase activity and extent of active, overlooked space in 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No comparison to current use, thereby reducing fear of crime. Site accessibility is good regarding healthcare, education, open space and sports facilities, Consideration should be given to nearby Encourage healthier lifestyles and reduce although nearest children's play area facilities 10 + + Ongoing Operation Local Med Med Minor Positive No provision of children's play area as part of the adverse health impacts of new developments 388m E. The proposal has no health, sports, development. recreation, education, leisure, community or cultural elements.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

High Town and Town Centre are within close 12 Support vitality and viability of centres proximity, so considered that development will + + Ongoing Operation Local Med Med Minor Positive No support viability and vitality of these centres.

The site has good links to buses, moderate to Provide and encourage the use of sustainable Sustainable transport measures should be rail and poor with regards access to 13 integrated transport systems, improve access - - Ongoing Operation Local Low Med Negligible Negative Yes maximised (e.g. onsite cycle facilities, cycleroutes. Proximity to health, education and and mobility strengthened links to public transport). employment will discourage car use.

UE-0130 Luton LP DAM_6_131213 161 23 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 161: Oxen Industrial Estate, Oxen Road. - 100% housing 2 and 3-bed units; 2013 ELR; 48 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Construction phase will provide some local and Promote employment, learning, skills and accessible employment opportunities. No 14 + Initial Construction Local Med High Minor Positive No innovation provision within development for employment within site.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 161 24 / 62 DETAILED ASSESSMENT MATRIX Housing Site 174: Land at Caleb Close - Mixed retail, employment and housing (2- and 3-bed units); 75dph on half the site; 98 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site is within the urban area, not close to any Site layout should seek to retain & increase landscape or conservation designations. A coverage of trees, hedges & other natural Maintain and enhance biodiversity, habitat and 1 group of TPO beach trees is present on Caleb - Initial Construction Local Low Low Negligible Negative Yes features wherever possible, especially TPO landscape Close; possibility of minor impacts during trees. Root protected areas to be implemented construction. during construction.

Opportunities to provide greenspace, pocket Site is within the urban area, not adjacent to Conserve, restore and enhance green parks, new trees, green walls/roofs should be 2 any open space or other GI. No effect other Neutral Yes infrastructure explored, particularly given comparatively large than as Objective 1. size of site.

Site is PDL, not close to major air pollution Following site investigation, design of sources (e.g. AQMA, M1, airport), not adjacent remediation strategy should include a CEMP to Protect and enhance air, soil and water to R Lea, but within SPZ2. Good bus Construction reduce and manage risk of mobilising 3 - - - Ongoing Local Med Med Minor Negative Yes resources accessibility but limited access to railway or & Operation contaminants. Sustainable transport measures cycleroutes is likely to increase reliance on car should be maximised (e.g. onsite cycle facilities, travel. strengthened links to public transport).

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ2. reduce flood risk sewer or groundwater sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

Construction phase will provide local and Opportunities to provide work-based training SEA Objectives SEA Reduce poverty and inequality and promote accessible employment opportunities; Construction during construction should be explored; 8 + + + Ongoing Local med Med Minor Positive Yes social inclusion operation phase will provide job opportunities & Operation provision for business incubator and/or through employment and retail uses. live/work units may be suitable.

Development is likely to increase activity and extent of active, overlooked space in 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No comparison to current use, thereby reducing fear of crime.

Site accessibility is good regarding healthcare, but not regarding sports provision, play Opportunities to provide play space, pockets Encourage healthier lifestyles and reduce 10 facilities or cycle routes. The proposal has no - - Ongoing Operation Local Med Med Minor Negative Yes parks or improved access to cycle routes should adverse health impacts of new developments health, sports, recreation, education, leisure, be explored. community or cultural elements.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres. Site accessibility is moderate to good Provide and encourage the use of sustainable Sustainable transport measures should be regarding education, employment, health 13 integrated transport systems, improve access + + Ongoing Operation Local Low Med Negligible Positive Yes maximised (e.g. onsite cycle facilities, facilities & bus transport, but limited access to and mobility strengthened links to public transport). railway or cycleroutes.

UE-0130 Luton LP DAM_6_131213 174 25 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 174: Land at Caleb Close - Mixed retail, employment and housing (2- and 3-bed units); 75dph on half the site; 98 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Development will result in loss of existing employment land. Construction phase will Opportunities to provide work-based training Promote employment, learning, skills and provide local and accessible employment Construction during construction should be explored; 14 +/- +/- +/- Ongoing Local Med Med Minor Mixed Yes innovation opportunities; operation phase will provide job & Operation provision for business incubator and/or opportunities through employment and retail live/work units may be suitable. uses.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 174 26 / 62 DETAILED ASSESSMENT MATRIX Housing Site 176: Car Park off Telford Way. Mixed retail, employment and housing. 1, 2 and 3-bed units likely to be flats; 150 dph on half the site, allowing other half for other uses such as employment; 39 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site is within the urban area, not close to any Site layout should seek to increase coverage of landscape or conservation designations. The Maintain and enhance biodiversity, habitat and trees, hedges & other natural features wherever 1 site is a car park with little or no vegetation + + Ongoing Permanent Local Low Med Negligible Positive Yes landscape possible. It is recommended that native flora is apparent, therefore unlikely to contain habitats used. or species of conservation value.

Site is within the urban area, not close to any Opportunities to provide greenspace such as Conserve, restore and enhance green landscape or conservation designations. 2 + + Ongoing Permanent Local Low Med Negligible Positive Yes new trees and green walls/roofs should be infrastructure Development will not result in the loss of any explored. green infrastructure.

The site has good accessibility to public Due to location within SPZ1, following site transport and cycleroutes which will encourage Protect and enhance air, soil and water Construction investigation, design of remediation strategy 3 their use. Site is PDL, not close to major air - - - Ongoing Local Low Med Negligible Negative Yes resources & Operation should include a CEMP to reduce and manage pollution sources (e.g. AQMA, M1, airport), not risk of mobilising contaminants. adjacent to R Lea, but within SPZ1.

It is recommended that development design 55% of site is within FZ2 and within area with Protect areas that are at risk from flooding and Construction incorporates suitable flood protection 4 minor risk (below 6%) of flooding from sewer - - - Ongoing Local Med Med Minor Negative Yes reduce flood risk & Operation measures. SuDS may not be appropriate due to sources. SPZ1.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL. Site will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though

buried assets may be present. SEA Objectives SEA Construction phase will provide local and Opportunities to provide work-based training Reduce poverty and inequality and promote accessible employment opportunities; Construction during construction should be explored; 8 ++ ++ ++ Ongoing Local High Med Moderate Positive Yes social inclusion operation phase will provide job opportunities & Operation provision for business incubator and/or through employment and/or retail uses. live/work units may be suitable.

Development is in a central, urban location. Likely to increase activity and extent of active, 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No overlooked space in comparison to current use, thereby reducing fear of crime. The site is close to healthcare, sporting facilities and open space, though has poor Consideration could be given to nearby Encourage healthier lifestyles and reduce 10 accessibility to play areas. Good links to public + + Ongoing Operation Local Med Med Minor Positive No provision of children's play area as part of the adverse health impacts of new developments transport and cycleroutes will also help development. encourage healthier lifestyles.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is close to Bury Park DC, development of 12 Support vitality and viability of centres employment on site will also contribute to + + Ongoing Operation Local Med Med Minor Positive No viability of centre.

UE-0130 Luton LP DAM_6_131213 176 27 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 176: Car Park off Telford Way. Mixed retail, employment and housing. 1, 2 and 3-bed units likely to be flats; 150 dph on half the site, allowing other half for other uses such as employment; 39 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? The site has good links to both buses and Provide and encourage the use of sustainable trains, cycleroutes are easily accessible. The 13 integrated transport systems, improve access + + Ongoing Operation Local Med Med Minor Positive No site is within a short distance of education, and mobility healthcare and district centre.

Construction phase will provide local and Opportunities to provide work-based training Promote employment, learning, skills and accessible employment opportunities; Construction during construction should be explored; 14 + + + Ongoing Local Med Med Minor Mixed Yes innovation operation phase will provide job opportunities & Operation provision for business incubator and/or through employment and retail uses. live/work units may be suitable.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 176 28 / 62 DETAILED ASSESSMENT MATRIX Housing Site 180: Dalroad Industrial Estate - 100% housing 1,2 and 3-bed units; Local plan allocation; 32 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site is within the urban area, not close to any landscape or conservation designations. The Site layout should seek to increase coverage of Maintain and enhance biodiversity, habitat and site is hardstanding on an industrial estate, with trees, hedges & other natural features wherever 1 + + Ongoing Permanent Local Low Med Negligible Positive Yes landscape little or no vegetation apparent, therefore possible. It is recommended that native flora is unlikely to contain habitats or species of used. conservation value.

Site is within the urban area, not close to any landscape or conservation designations. Opportunities to provide greenspace such as Conserve, restore and enhance green 2 Development will not result in the loss of any + + Ongoing Permanent Local Low Med Negligible Positive Yes new trees and green walls/roofs should be infrastructure green infrastructure and landscaping could explored. result in the increase of available green space.

The site has good accessibility to public Following site investigation, design of transport and cycleroutes which will encourage remediation strategy should include a CEMP to their use, but access to train station is poor. Site reduce and manage risk of mobilising Protect and enhance air, soil and water Construction 3 is PDL, not land currently used for agriculture or - - - Ongoing Local Med Med Minor Negative Yes contaminants. Sustainable transport measures resources & Operation close to major air pollution sources (e.g. should be maximised (e.g. onsite cycle parking AQMA, M1, airport), not adjacent to R Lea or facilities, strengthened links to public tributaries, but within SPZ2. transport).

The development should include suitable Protect areas that are at risk from flooding and Minor - within an area at low risk (below 6%) of Construction 4 - - - Ongoing Local Negligible Med Negligible Negative No measures to minimise risk and impact of reduce flood risk flooding from sewer sources. & Operation flooding. SuDS may not be suitable given SPZ2.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Site is not in agricultural use and is an efficient Waste materials produced during demolition Increase resource efficiency and reduce use of PDL. Site will need to comply with LP37, and groundworks should be re-used on site 6 + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste though unlikely to lead to significant resource wherever possible, or re-processed off site for consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g.

SEA Objectives SEA Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored.

Development is in a central, urban location. Likely to increase activity and extent of active, 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No overlooked space in comparison to current use, thereby reducing fear of crime. The site is close to healthcare, education and Improved accessibility to sporting facilities and open space, though has poor accessibility to Encourage healthier lifestyles and reduce children's play areas (which could be 10 sporting facilities and play areas. Good links to +/- +/- Ongoing Operation Local Med Med Minor Mixed Yes adverse health impacts of new developments incorporated into design) should be cycleroutes will also help encourage healthier considered. lifestyles.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres.

UE-0130 Luton LP DAM_6_131213 180 29 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 180: Dalroad Industrial Estate - 100% housing 1,2 and 3-bed units; Local plan allocation; 32 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

The site has good links to both buses and Sustainable transport measures should be Provide and encourage the use of sustainable cycleroutes but poor accessibility to trains. The maximised (e.g. onsite cycle facilities such as 13 integrated transport systems, improve access site is within a short distance of education, + + Ongoing Operation Local Med Med Minor Positive Yes bicycle parking and strengthened links to rail and mobility healthcare and district centre which should network). encourage use of buses or cycles..

Promote employment, learning, skills and Construction phase will provide local and 14 + Initial Construction Local Med Med Minor Positive No innovation accessible employment opportunities;.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 180 30 / 62 DETAILED ASSESSMENT MATRIX Housing Site 182: Land at 69 Felstead Way. - 100% Housing 3 and 4 bed units; planning permission; 58 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Ecological surveys and assessment will be Semi-natural habitats present on site and required to establish which (if any) protected impacts to protected/notable species (e.g. bats, species may be using the site and to design a reptiles) are possible. Adjacent to the suitable mitigation strategy. Habitats of Maintain and enhance biodiversity, habitat and Honeygate and Crick Hills CWS and Mixes Hill greatest interest should be retained where 1 -- - - Ongoing Permanent Regional Med High Moderate Negative Yes landscape DWS, though not close to any statutory possible. Development should seek to landscape or conservation designations. enhance/protect local wildlife sites for instance Impacts are possible through habitat loss and by implementation of native planting scheme, disturbance both during and post construction. improvement of footpath network or provision of interpretation boards.

Enhance ecological connectivity in wider area Semi- natural habitats are present on site and for species moving through development from Conserve, restore and enhance green 2 development will result in loss of green -- - - Ongoing Permanent Local High High Moderate Negative Yes adjacent areas of semi-natural habitats and infrastructure infrastructure local wildlife sites through wildlife corridors and connected undeveloped land

Following site investigation, design of Site is not close to major air pollution sources remediation strategy should include a CEMP to (e.g. AQMA, M1, airport), not adjacent to R Lea, Protect and enhance air, soil and water Construction reduce and manage risk of mobilising 3 but within SPZ3. Limited access to railway, bus - - - Ongoing Local Med Med Minor Negative Yes resources & Operation contaminants. Sustainable transport measures or cycleroutes is likely to increase reliance on should be maximised (e.g. onsite cycle facilities, car travel. strengthened links to public transport).

The development should include suitable Protect areas that are at risk from flooding and Minor - within an area at low risk (below 6%) of Construction 4 - - - Ongoing Local Negligible Med Negligible Negative No measures to minimise risk and impact of reduce flood risk flooding from sewer sources. & Operation flooding. SuDS may not be suitable given SPZ3.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during groundworks Site will need to comply with LP37, and unlikely Increase resource efficiency and reduce should be re-used on site wherever possible, or 6 to lead to significant resource consumption. + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste re-processed off site for future use in Site is not on agricultural land aggregates. None - site does not feature any known heritage assets (e.g. listed building,

SEA Objectives SEA Identify, protect, maintain and enhance 7 conservation area, scheduled monument, Neutral No heritage assets and their setting registered park or garden) though buried assets may be present.

Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Negligible Positive Yes social inclusion accessible employment opportunities during construction should be explored;

Development is likely to increase activity and 9 Reduce crime and fear of crime extent of overlooked space in comparison to + + Ongoing Operation Local Med Med Minor Positive No current use, thereby reducing fear of crime.

Site accessibility is good regarding healthcare, sports provision and distance to open space. Consideration should be given to nearby Encourage healthier lifestyles and reduce Though poor in regards the distance to 10 + + Ongoing Operation Local Med Med Minor Negative Yes provision of children's play area as part of the adverse health impacts of new developments dedicated children's play. The proposal has no development. health, sports, recreation, education, leisure, community or cultural elements.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is some distance away from town and 12 Support vitality and viability of centres Neutral No district centres and main employment areas.

UE-0130 Luton LP DAM_6_131213 182 31 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 182: Land at 69 Felstead Way. - 100% Housing 3 and 4 bed units; planning permission; 58 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site accessibility is moderate regarding Provide and encourage the use of sustainable Sustainable transport measures should be education and good regarding health facilities. 13 integrated transport systems, improve access - - Ongoing Operation Local Med Med Minor Negative Yes maximised (e.g. onsite cycle facilities, Access to bus transport and cycleroutes is and mobility strengthened links to public transport). moderate though distance to railway is poor

Promote employment, learning, skills and Construction phase will provide some local and 14 + Initial Construction Local Med High Minor Positive No innovation accessible employment opportunities

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 182 32 / 62 DETAILED ASSESSMENT MATRIX Housing Site 220: Luton Town Football Club, Kenilworth Road Luton. - 100% housing 2 and 3-bed units; 50dph; 75 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to increase coverage of Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any trees, hedges & other natural features wherever 1 Neutral Yes landscape landscape or conservation designations. possible through sensitive planting scheme and provision of wildlife habitat.

Opportunities to provide greenspace, pocket Site is within the urban area, not adjacent to Conserve, restore and enhance green parks, new trees, green walls/roofs should be 2 any open space or other GI. No anticipated Neutral Yes infrastructure explored, particularly given comparatively large effects size of site.

Site is PDL and not close to major air pollution sources (e.g. AQMA, M1, airport), not adjacent Following site investigation, design of to R Lea, but within SPZ1 so risk of water remediation strategy should include a Protect and enhance air, soil and water pollution. Removal of the football stadium will Construction 3 - - - Ongoing Local Low Med Negligible Negative Yes rigorously designed CEMP to reduce and resources improve local air quality through lessening of & Operation manage risk of mobilising contaminants, traffic congestion. Site has good access to bus particularly during demolition and construction. and cycleroutes, though nearest train station is over 1km away.

The development should include suitable Protect areas that are at risk from flooding and Minor - part of site within an area at low risk Construction 4 - - - Ongoing Local Negligible Med Negligible Negative No measures to minimise risk and impact of reduce flood risk (below 6%) of flooding from sewer sources. & Operation flooding. SuDS may not be suitable given SPZ1.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

None - site does not feature any known heritage assets (e.g. listed building, Identify, protect, maintain and enhance 7 conservation area, scheduled monument, Neutral No heritage assets and their setting registered park or garden) though buried assets SEA Objectives SEA may be present.

Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored;

Moving football stadium to new location will 9 Reduce crime and fear of crime reduce crowding in the town centre and + ++ Ongoing Operation Local Med High Moderate Positive No potential anti-social behaviour.

Site accessibility is good regarding accessible healthcare, education and open space, though Consideration should be given to nearby Encourage healthier lifestyles and reduce some distance from dedicated children's play. 10 Neutral Yes provision of children's play area as part of the adverse health impacts of new developments The proposal has no health, sports, recreation, development. education, leisure, community or cultural elements but has good links to cycle routes.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres.

UE-0130 Luton LP DAM_6_131213 220 33 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 220: Luton Town Football Club, Kenilworth Road Luton. - 100% housing 2 and 3-bed units; 50dph; 75 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Provide and encourage the use of sustainable Site accessibility is good regarding education, Sustainable transport measures should be 13 integrated transport systems, improve access employment, health facilities & bus transport + + Ongoing Operation Local Med Med Minor Positive Yes maximised (e.g. onsite cycle facilities, and mobility and cycle routes but limited access to railway. strengthened links to public transport).

Loss of the football ground will result in a loss of employment opportunity and community Construction Promote employment, learning, skills and Opportunities to provide work-based training 14 involvement schemes in the area. Construction + - - Ongoing and Local Med High Negligible Mixed Yes innovation during construction should be explored; phase will provide some local and accessible operation employment opportunities

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 220 34 / 62 DETAILED ASSESSMENT MATRIX Housing Site 221: Midland House, 41 King Street - 100% housing 1-bed flats; Planning permission; 27 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide new trees or planting Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes within the scope of the development should be infrastructure any open space or other GI. explored. The site has good accessibility to public Following site investigation, design of transport and cycleroutes which will encourage remediation strategy should include a CEMP to their use, but access to train station is reduce and manage risk of mobilising Protect and enhance air, soil and water moderately poor. Site is PDL, not land currently Construction 3 - - - Ongoing Local Med Med Minor Negative Yes contaminants. Sustainable transport measures resources used for agriculture or close to major air & Operation should be maximised (e.g. onsite cycle parking pollution sources (e.g. AQMA, M1, airport), not facilities, strengthened links to public adjacent to R Lea or tributaries, but within transport). SPZ1.

The development should include suitable Protect areas that are at risk from flooding and Not within flood zones but in an area at Construction 4 - - - Ongoing Local Minor Med Negligible Negative No measures to minimise risk and impact of reduce flood risk medium risk (6-15%) of sewer flooding. & Operation flooding. SuDS may not be suitable given SPZ1.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Site is not in agricultural use and is an efficient Waste materials produced during demolition Increase resource efficiency and reduce use of PDL. Site will need to comply with LP37, and groundworks should be re-used on site 6 + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste though unlikely to lead to significant resource wherever possible, or re-processed off site for consumption. future use in aggregates.

Development proposals should assess scale of potential risk and deploy suitable building Site is within Town Centre conservation area, protection measures where necessary. As and adjacent to 39 Kings Street a Grade II listed required by LP30, it should be possible to building, which may be subject to reduce negative effects via a high quality dust/vibration impacts during construction. design which responds to and enhances the Identify, protect, maintain and enhance 7 Policy LP30 protects the fabric and setting of -- Initial Construction Local Med Med Minor setting of historical features, and uses an heritage assets and their setting known assets, and aims to maximise their appropriate selection of materials. Heritage

SEA Objectives SEA contribution to regeneration, but impacts to Statements should be prepared and, where town centre possible through loss/damage of evidence points to potential presence of buried assets particularly in early stages. remains, mitigation will be required (e.g. investigative trenching, watching brief, recovery & interpretation of remains).

Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored;

Development will result in a slight increase in 9 Reduce crime and fear of crime activity in the area though this is unlikely to Neutral No have a significant effect on this objective

The site is close to healthcare, education and employment areas, which will encourage Improved accessibility to sporting facilities and Encourage healthier lifestyles and reduce walking to these locations. Site has moderate children's play areas (which could be 10 + + Ongoing Operation Local Med Med Minor Positive Yes adverse health impacts of new developments accessibility to sporting facilities and play areas. incorporated into design) should be Good links to cycleroutes will also help considered. encourage healthier lifestyles.

UE-0130 Luton LP DAM_6_131213 221 35 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 221: Midland House, 41 King Street - 100% housing 1-bed flats; Planning permission; 27 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres.

The site has good links to both buses and Sustainable transport measures should be Provide and encourage the use of sustainable cycleroutes, but moderate accessibility to maximised (e.g. onsite cycle facilities such as 13 integrated transport systems, improve access trains. The site is within a short distance of + + Ongoing Operation Local Med Med Minor Positive Yes bicycle parking and strengthened links to rail and mobility education, healthcare and town centre which network). should encourage use of buses or cycles..

Promote employment, learning, skills and Construction phase will provide local and 14 + Initial Construction Local Med Med Minor Positive No innovation accessible employment opportunities;.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 221 36 / 62 DETAILED ASSESSMENT MATRIX Housing Site 337: Land west of Newlands Road. - 100% housing 2 and 3-bed units; Refers to development at Roebuck Close as an exemplar. Newlands Road site is approx. half the area of Roebuck Close site ; 54 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Ecological surveys and assessment will be required to establish which (if any) protected species may be using the site and to design a Site is not PDL. Semi-natural habitats present suitable mitigation strategy. Habitats of on site and impacts to protected/notable Construction Maintain and enhance biodiversity, habitat and greatest interest should be retained where 1 species (e.g. bats, reptiles) are possible. -- - - Ongoing and Regional Med High Moderate Negative Yes landscape possible. Development should seek to Adjacent to green belt and 12m from the Operation enhance/protect local wildlife sites for instance Stockwood Park CWS. by implementation of native planting scheme, improvement of footpath network or provision of interpretation boards.

Site is not PDL. Semi- natural habitats are Construction Enhance ecological connectivity in wider area Conserve, restore and enhance green 2 present on site and development will result in -- - - Ongoing and Local High High Moderate Negative Yes by providing habitat for species associated with infrastructure loss of green infrastructure Operation nearby open space within development.

Following site investigation, design of Site is not PDL and adjacent to major air remediation strategy should include a CEMP to pollution area (M1). Not adjacent to R Lea, but Construction Protect and enhance air, soil and water reduce and manage risk of mobilising 3 within SPZ2. Limited access to cycle and railway ------Ongoing and Local High High Moderate Negative Yes resources contaminants. Sustainable transport measures networks and remote location likely to Operation should be maximised (e.g. onsite cycle facilities, encourage car use. Site is currently ALC 3 strengthened links to public transport).

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ2. reduce flood risk ground or sewer sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Construction Increase resource efficiency and reduce Development will result in the loss of 6 - - - Ongoing and Local Med High Minor No resource use and waste agricultural land (ALC3). Operation None - site does not feature any known heritage assets (e.g. listed building, Identify, protect, maintain and enhance 7 conservation area, scheduled monument, Neutral No heritage assets and their setting registered park or garden) though buried assets may be present.

SEA Objectives SEA Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored;

Current site use is agricultural in location 9 Reduce crime and fear of crime outside town centre. Unlikely that development Neutral No will have a significant effect. Development location and distance to employment centres is likely to encourage car Opportunities to provide play space, pockets Encourage healthier lifestyles and reduce use. However development has good access to 10 - - Ongoing Operation Local Med High Minor Negative Yes parks or improved access to cycle routes should adverse health impacts of new developments education, healthcare, sports facilities and be explored. open space. Site is adjacent to major pollution source.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is outside urban area and has moderately Improvement of sustainable transport links to 12 Support vitality and viability of centres poor accessibility to employment areas and - - Ongoing Operation Local Med Med Minor Negative Yes existing neighbourhood and district centres centres

UE-0130 Luton LP DAM_6_131213 337 37 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 337: Land west of Newlands Road. - 100% housing 2 and 3-bed units; Refers to development at Roebuck Close as an exemplar. Newlands Road site is approx. half the area of Roebuck Close site ; 54 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site accessibility is good regarding education and health facilities but currently poor in Provide and encourage the use of sustainable Improvement of sustainable transport links to relation to employment (policy LP5 will help to 13 integrated transport systems, improve access - - Ongoing Operation Local Med Med Minor Negative Yes existing neighbourhood and district centres address this). Limited access to cycle routes and mobility and employment areas. and railway and proximity of M1 is likely to encourage reliance on car transport

Construction phase will provide some local and Promote employment, learning, skills and accessible employment opportunities. No 14 + Initial Construction Local Med High Minor Positive No innovation provision within development for employment within site.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 337 38 / 62 DETAILED ASSESSMENT MATRIX Housing Site 339: Land at Stockingstone Road. - Leisure and residential 2 and 3-bed units; 50dph on half of site allowing other half for leisure/ other uses; 50 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Site is within the urban area, not close to any coverage of trees, hedges & other natural landscape or conservation designations. features wherever possible. Ecological surveys Maintain and enhance biodiversity, habitat and 1 Partially PDL with semi-natural habitats present - - - Ongoing Permanent Local Low Med Negligible Negative Yes and assessment will be required to establish landscape on site and impacts to protected/notable which (if any) protected species may be using species (e.g. bats, reptiles) are possible. the site and to design a suitable mitigation strategy. .

Site layout should seek to minimise visual Development is 315m from AGLV, and may impact of new development. And maintain Conserve, restore and enhance green 2 result in the loss of some semi-natural habitat - - - Ongoing Permanent Local Negligible Med Negligible Negative areas of green infrastructure within infrastructure surrounding current leisure facilities. development. A survey should be carried out to assess visual impact on landscape

Following site investigation, design of Site is partially PDL, not close to major air remediation strategy should include a CEMP to pollution sources (e.g. AQMA, M1, airport), not Protect and enhance air, soil and water Construction reduce and manage risk of mobilising 3 adjacent to R Lea, but within SPZ3. Good bus - - - Ongoing Local Med Med Minor Negative Yes resources & Operation contaminants. Sustainable transport measures accessibility but poor access to railway or should be maximised (e.g. onsite cycle facilities, cycleroutes. strengthened links to public transport).

The development should include suitable Protect areas that are at risk from flooding and Minor - within an area at low risk (below 6%) of Construction 4 - - - Ongoing Local Negligible Med Negligible Negative No measures to minimise risk and impact of reduce flood risk flooding from sewer sources. & Operation flooding. SuDS may not be suitable given SPZ3.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site partly PDL, will need to comply with LP37, Increase resource efficiency and reduce and groundworks should be re-used on site 6 and unlikely to lead to significant resource - + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for consumption. future use in aggregates.

None - site does not feature any known heritage assets (e.g. listed building, Identify, protect, maintain and enhance 7 conservation area, scheduled monument, Neutral No heritage assets and their setting registered park or garden) though buried assets

may be present. SEA Objectives SEA Construction phase will provide some local and Reduce poverty and inequality and promote accessible employment opportunities. Initial and Construction Opportunities to provide work-based training 8 + + + Local Med High Minor Positive Yes social inclusion Renovation of leisure facilities will lead to ongoing & Operation during construction should be explored; increased local employment opportunities

Development is likely to increase activity and 9 Reduce crime and fear of crime extent of overlooked space in comparison to + + Ongoing Operation Local Med Med Minor Positive No current use, thereby reducing fear of crime.

Development will include renovation of Improving access to cycleroutes will encourage existing leisure and sporting facilities. However Encourage healthier lifestyles and reduce use of sustainable transport and provide links 10 current access to cycleroutes are poor and + + Ongoing Operation Local High Med Moderate Positive Yes adverse health impacts of new developments to leisure facilities. Consider inclusion of play there is poor accessibility to children's play area within development design. areas.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres.

UE-0130 Luton LP DAM_6_131213 339 39 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 339: Land at Stockingstone Road. - Leisure and residential 2 and 3-bed units; 50dph on half of site allowing other half for leisure/ other uses; 50 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? The site has good links to bus service though Provide and encourage the use of sustainable accessibility to train and cycle routes is poor. Improvement of access to cycle routes and bus 13 integrated transport systems, improve access Access to education and healthcare is good, - - Ongoing Operation Local Low Med Negligible Minor Yes routes to main employment areas. and mobility however distance to closest employment centre is 1507m. Development is some distance from main employment centres, though access to Promote employment, learning, skills and Greenwood Court ELR site is good. Construction 14 + + + Ongoing Local Med Med Minor Positive No innovation Construction phase will lead to local & Operation employment opportunities as will operation of leisure facilities.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 339 40 / 62 DETAILED ASSESSMENT MATRIX Housing Site 342: The Laurels, Ely Way - 100% housing 2 and 3-bed units; Pre-application discussion with outline plan, 2013; 20 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide new trees or planting Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes within the scope of the development should be infrastructure any open space or other GI. explored.

The site has good accessibility to buses but Following site investigation, design of only moderate to rail and poor to cycleroutes remediation strategy should include a CEMP to which is likely to encourage car use. Site is PDL, reduce and manage risk of mobilising Protect and enhance air, soil and water 3 not land currently used for agriculture or close - - - Ongoing Operation Local Med Med Minor Negative Yes contaminants. Sustainable transport measures resources to major air pollution sources (e.g. AQMA, M1, should be maximised (e.g. onsite cycle parking airport), not adjacent to R Lea or tributaries, but facilities, strengthened links to public within SPZ2. transport).

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ2. reduce flood risk ground or sewer sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Site is not in agricultural use and is an efficient Waste materials produced during demolition Increase resource efficiency and reduce use of PDL. Site will need to comply with LP37, and groundworks should be re-used on site 6 + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste though unlikely to lead to significant resource wherever possible, or re-processed off site for consumption. future use in aggregates.

As required by LP30, it should be possible to Christ Church a Grade II listed building lies reduce negative effects via a high quality 49m NE, as a result minor impacts through dust design which responds to and enhances the and vibration are possible. Impacts also setting of historical features, and uses an Identify, protect, maintain and enhance possible through loss/damage of buried assets appropriate selection of materials. Heritage 7 - Initial Construction Local Low Med Negligible heritage assets and their setting particularly in early stages of construction. Statements should be prepared and, where Policy LP30 protects the fabric and setting of evidence points to potential presence of

SEA Objectives SEA known assets, and aims to maximise their remains, mitigation will be required (e.g. contribution to regeneration. investigative trenching, watching brief, recovery & interpretation of remains).

Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored.

Development may result in a slight increase in activity and overlooked space in the area 9 Reduce crime and fear of crime Neutral No though this is unlikely to have a significant effect on this objective

The site is close to healthcare, education and Improved accessibility to sporting facilities and employment areas, which will encourage Encourage healthier lifestyles and reduce children's play areas (which could be 10 walking to these locations. However, site has - - Ongoing Operation Local Med Med Minor Negative Yes adverse health impacts of new developments incorporated into design) should be moderate accessibility to sporting facilities and considered. play areas and poor links to cycleroutes.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres.

UE-0130 Luton LP DAM_6_131213 342 41 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 342: The Laurels, Ely Way - 100% housing 2 and 3-bed units; Pre-application discussion with outline plan, 2013; 20 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? The site has good links to buses and moderate accessibility to trains but links to Provide and encourage the use of sustainable cycleroutes are poor. The site is within a short Improved links with cycleroutes would 13 integrated transport systems, improve access + + Ongoing Operation Local Low Med Negligible Positive Yes distance of education, healthcare and town encourage their use. and mobility centre which should encourage use of sustainable transport. Promote employment, learning, skills and Construction phase will provide local and 14 + Initial Construction Local Med Med Minor Positive No innovation accessible employment opportunities;.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 342 42 / 62 DETAILED ASSESSMENT MATRIX Housing Site 343: Westlea Old Peoples Home, 121 High Street. 100% residential 2 and 3-bed units; 2013 planning application; 57 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Site layout should seek to retain & increase coverage of trees, hedges & other natural Site is within the urban area, not close to any features wherever possible. Ecological surveys landscape or conservation designations. and assessment will be required to establish Maintain and enhance biodiversity, habitat and 1 Development of the site may result in the loss - - - Ongoing Operation Local Low Low Negligible Negative Yes which (if any) protected species may be using landscape of trees which could provide habitat for the site and to design a suitable mitigation protected species (birds and bats) strategy. Opportunities to provide habitat linkages with other green space in the area could be explored.

Site is within the urban area, although adjacent Opportunities to provide greenspace, within Conserve, restore and enhance green to Addington Way Sports Field, no impacts to the development should be explored, 2 Neutral Yes infrastructure green infrastructure other than those described particularly with regards offsetting the loss of for Objective 1 are predicted. any trees or vegetation.

Site is PDL but is within 80m of M1 which is a Following site investigation, design of major source of air pollution. The site is not remediation strategy should include a CEMP to Protect and enhance air, soil and water adjacent to R Lea, but within SPZ2. Good bus reduce and manage risk of mobilising 3 - - - Ongoing Operation Local Med Med Minor Negative Yes resources accessibility but limited access to railway or contaminants. Sustainable transport measures cycleroutes is likely to increase reliance on car should be maximised (e.g. onsite cycle facilities, travel. strengthened links to public transport).

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ2. reduce flood risk ground or sewer sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

None - site does not feature any known heritage assets (e.g. listed building, Identify, protect, maintain and enhance 7 conservation area, scheduled monument, Neutral No heritage assets and their setting registered park or garden) though buried assets

may be present. SEA Objectives SEA Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored;

Development will result in a slight increase in 9 Reduce crime and fear of crime activity in the area though this is unlikely to Neutral No have a significant effect on this objective The development is close to healthcare and sports facilities which will discourage car use. Addington Way play area is 217m away though Encourage healthier lifestyles and reduce 10 within but is not accessible by road and + + Ongoing Operation Local Med Med Minor Positive No adverse health impacts of new developments Addington Way sports field is adjacent to the development which will encourage use of existing sporting facilities.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres.

UE-0130 Luton LP DAM_6_131213 343 43 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 343: Westlea Old Peoples Home, 121 High Street. 100% residential 2 and 3-bed units; 2013 planning application; 57 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? The development is close to healthcare, education and centres, including main Provide and encourage the use of sustainable employment area which will encourage walking Improvement to cycleroute access should be 13 integrated transport systems, improve access or use of sustainable transport methods. Bus + + Ongoing Operation Local Med Med Minor Positive Yes considered. and mobility links are good but cycleroute links and accessibility to railway are moderate and poor respectively Development is close to main employment Promote employment, learning, skills and Construction 14 area. Construction phase will lead to local + + + Ongoing Local Med Med Minor Positive No innovation & Operation employment opportunities.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 343 44 / 62 DETAILED ASSESSMENT MATRIX Housing Site 351: 27A Upper George Street. 100% residential 1-bed flats; planning permission; 26 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide new trees or planting Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes within the scope of the development should be infrastructure any open space or other GI. explored

Site is PDL, not close to major air pollution If proposal involves demolition/ sources (e.g. AQMA, M1, airport), not adjacent redevelopment, remediation strategy should Protect and enhance air, soil and water Construction 3 to R Lea, but within SPZ1. Good bus and - - - Ongoing Local Med Med Minor Negative Yes include a rigorously designed CEMP to reduce resources & Operation cycleroute accessibility is likely to encourage and manage risk of mobilising contaminants, use of sustainable transport methods particularly during demolition and construction.

The development should include suitable Protect areas that are at risk from flooding and Minor - within an area at low risk (below 6%) of Construction 4 - - - Ongoing Local Negligible Med Negligible Negative No measures to minimise risk and impact of reduce flood risk flooding from sewer sources. & Operation flooding. SuDS may not be suitable given SPZ1.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

As required by LP30, it should be possible to reduce negative effects via a high quality Site is within Town Centre conservation area, design which responds to and enhances the and close to Christ Church a Grade II listed setting of historical features, and uses an building. Policy LP30 protects the fabric and Identify, protect, maintain and enhance appropriate selection of materials. Heritage 7 setting of known assets, and aims to maximise - Initial Construction Local Low Med Negligible heritage assets and their setting Statements should be prepared and, where their contribution to regeneration, but impacts evidence points to potential presence of possible through loss/damage of buried assets remains, mitigation will be required (e.g. particularly in early stages

SEA Objectives SEA investigative trenching, watching brief, recovery & interpretation of remains).

Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored;

Development is likely to increase activity and extent of active, overlooked space in 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No comparison to current use, thereby reducing fear of crime. The site is close to healthcare facilities and schools as well as having a central location close to employment areas EM1 and CA1. It Encourage healthier lifestyles and reduce also has good access to cycleroute, therefore 10 + + Ongoing Operation Local Med Med Minor Mixed No adverse health impacts of new developments likely to discourage car use. However, development has poor access to open space and play area though access to sports facilities is good.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

The development is within the town centre and 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No will contribute to its vitality and viability.

UE-0130 Luton LP DAM_6_131213 351 45 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 351: 27A Upper George Street. 100% residential 1-bed flats; planning permission; 26 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? The development is in a central location with Provide and encourage the use of sustainable good bus and cycle links which are likely to 13 integrated transport systems, improve access + + Ongoing Operation Local Med Med Minor Positive No encourage the use of sustainable transport over and mobility car use.

The development is within the town centre and Promote employment, learning, skills and Construction 14 close to employment areas. Construction phase + + + Ongoing Local Med Med Minor Positive No innovation & Operation will also provide locally accessible employment.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 351 46 / 62 DETAILED ASSESSMENT MATRIX Housing Site 352: 40-58 Collingdon Street - 1 and 2-bed flats with offices; Planning permission; 88 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide new trees or small Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes semi-natural open spaces within the scope of infrastructure any open space or other GI. the development should be explored.

The site has good accessibility to buses, rail and cycleroutes which is likely to discourage car Following site investigation, design of Protect and enhance air, soil and water use. Site is PDL, not land currently used for remediation strategy should include a CEMP to 3 - - - Ongoing Operation Local Med Med Minor Negative Yes resources agriculture or close to major air pollution reduce and manage risk of mobilising sources (e.g. AQMA, M1, airport), not adjacent contaminants within SPZ. to R Lea or tributaries, but within SPZ1.

The development should include suitable Protect areas that are at risk from flooding and Construction 4 Part of the site is within FZ2. - - - Ongoing Local Med Med Minor Negative No measures to minimise risk and impact of reduce flood risk & Operation flooding. SuDS may not be suitable given SPZ1.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Site is not in agricultural use and is an efficient Waste materials produced during demolition Increase resource efficiency and reduce use of PDL. Site will need to comply with LP37, and groundworks should be re-used on site 6 + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste though unlikely to lead to significant resource wherever possible, or re-processed off site for consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

SEA Objectives SEA Construction phase will provide local and Opportunities to provide work-based training Reduce poverty and inequality and promote accessible employment opportunities; Construction during construction should be explored; 8 ++ ++ ++ Ongoing Local High Med Moderate Positive Yes social inclusion operation phase will provide job opportunities & Operation provision for business incubator and/or through employment uses. live/work units may be suitable. Development may result in a slight increase in activity and overlooked space in the area 9 Reduce crime and fear of crime Neutral No though this is unlikely to have a significant effect on this objective The site is close to healthcare, education and employment areas, which will encourage Consideration could be given to the provision Encourage healthier lifestyles and reduce walking to these locations. Site also has good 10 + + Ongoing Operation Local Med Med Minor Positive Yes of children's play area as part of the adverse health impacts of new developments accessibility to sporting facilities and development. cycleroutes which will encourage use, but poor access to play.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres.

UE-0130 Luton LP DAM_6_131213 352 47 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 352: 40-58 Collingdon Street - 1 and 2-bed flats with offices; Planning permission; 88 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Site has good public transport links and access Provide and encourage the use of sustainable to cycleroute network. The site is within a short 13 integrated transport systems, improve access distance of education, healthcare and town + + Ongoing Operation Local Med Med Minor Positive No and mobility centre which should encourage use of sustainable transport.

Construction phase will provide local and Opportunities to provide work-based training Promote employment, learning, skills and accessible employment opportunities; Initial and Construction 14 + + + Local Med Med Minor Mixed Yes during construction should be explored; innovation operation phase will provide job opportunities Ongoing & Operation provision for live/work units may be suitable. through employment post construction.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 352 48 / 62 DETAILED ASSESSMENT MATRIX Housing Site 353: Car Park adj 95 Maple Road East - 100% housing 2 and 3-bed units; 75dph (2013 urban capacity work); 49 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site is within the urban area, not close to any Site layout should seek to retain & increase Construction Maintain and enhance biodiversity, habitat and landscape or conservation designations. Site is coverage of trees, hedges & other natural 1 - - - Ongoing and Local Low Low Negligible Negative Yes landscape 264m south of AGLV so impacts to visual features wherever possible. An LVIA should be Operation landscape possible. carried out to assess impacts (if any) to AGLV.

Opportunities to provide new trees or planting Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes within the scope of the development should be infrastructure any open space or other GI. explored.

Site is PDL, not close to major air pollution Following site investigation, design of sources (e.g. AQMA, M1, airport), not adjacent Protect and enhance air, soil and water remediation strategy should include a CEMP to 3 to R Lea, but within SPZ2. Good accessibility to + + Ongoing Operation Local Med Med Minor Mixed Yes resources reduce and manage risk of mobilising public transport and cycleroutes is likely to contaminants within SPZ. decrease reliance on car travel.

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ2. reduce flood risk ground or sewer sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Site is not in agricultural use and is an efficient Waste materials produced during demolition Increase resource efficiency and reduce use of PDL. Site will need to comply with LP37, and groundworks should be re-used on site 6 + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste though unlikely to lead to significant resource wherever possible, or re-processed off site for consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though

buried assets may be present. SEA Objectives SEA

Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored.

Development is in a central, urban location. Likely to increase activity and extent of active, 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No overlooked space in comparison to current use, thereby reducing fear of crime.

Site has good access to open space and Encourage healthier lifestyles and reduce children's play areas but only moderate to 10 + + Ongoing Operation Local Med Med Minor Positive No adverse health impacts of new developments sporting facilities. The site has good access to cycleroutes which will encourage bicycle use.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres.

Site has good access to public transport and Provide and encourage the use of sustainable Providing cycle facilities within the cycleroutes. Proximity of education, healthcare 13 integrated transport systems, improve access + + Ongoing Operation Local Med Med Minor Positive Yes development such as parking and storage will and employment areas should further and mobility encourage bicycle use. encourage sustainable transport methods.

Promote employment, learning, skills and Construction phase will provide local and 14 + Initial Construction Local Med Med Minor Positive No innovation accessible employment opportunities;.

UE-0130 Luton LP DAM_6_131213 353 49 / 62 DETAILED ASSESSMENT MATRIX Housing Site 353: Car Park adj 95 Maple Road East - 100% housing 2 and 3-bed units; 75dph (2013 urban capacity work); 49 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 353 50 / 62 DETAILED ASSESSMENT MATRIX Housing Site 359: Bramingham Centre, Weltmore Road. 100% housing 2 and 3-bed units; 50dph; 70 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Ecological surveys and assessment will be required to establish which (if any) protected species may be using the site and to design a suitable mitigation strategy. Habitats of Semi-natural habitats present on site and greatest interest should be retained where impacts to protected/notable species (e.g. bats, possible. Construction should be carried out Maintain and enhance biodiversity, habitat and reptiles) are possible. Site is adjacent to River Initial and Construction, Local and 1 ------Medium Medium Moderate Negative Yes under a CEMP to avoid potential impacts to the landscape Lea CWS and adjacent to Limbury Riverside ongoing operation Regional river and adjacent habitats. The development Park. Also within River Lea DWS possible should seek to enhance/protect local wildlife impacts through pollution and disturbance. sites for instance by implementation of native planting scheme, improvement/maintenance of footpath network or provision of interpretation boards.

Enhance ecological connectivity in wider area for species moving through development from adjacent areas of natural habitats and local Semi- natural habitats are present on site and wildlife sites by providing wildlife corridors Conserve, restore and enhance green development will result in loss of green Initial and Construction, which connect outside habitat to retained 2 - - - Local Medium Medium Minor Negative Yes infrastructure infrastructure in the form of existing playing ongoing operation green space within the development. fields. Opportunities to provide greenspace, pocket parks, new trees, green walls/roofs should be explored, particularly given comparatively large size of site.

Following site investigation, design of Site is not close to major air pollution sources remediation strategy should include a CEMP to Protect and enhance air, soil and water (e.g. AQMA, M1, airport), but is adjacent to R Initial and Construction, 3 - - - Local Medium Medium Minor Negative Yes reduce and manage risk of mobilising resources Lea, and within SPZ2. Potential impacts to ongoing operation contaminants during demolition of existing son water resources. site structures and construction phase.

It is recommended that development design Site is within FZ2 and adjacent to FZ3 therefore Protect areas that are at risk from flooding and Initial and Construction, incorporates suitable flood protection 4 flooding impacts are predicted. Also in an area - - - Local Medium High Minor Negative Yes reduce flood risk ongoing operation measures. SuDS may not be appropriate due to at medium risk of sewer flooding. location within SPZ2.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

As required by LP30, it should be possible to

SEA Objectives SEA reduce negative effects via a high quality Wauluds Bank SAM lies within 100m of design which responds to and enhances the development. Policy LP30 protects the fabric setting of historical features, and uses an Identify, protect, maintain and enhance and setting of known assets, and aims to appropriate selection of materials. Heritage 7 - Initial Construction Local Low Med Negligible heritage assets and their setting maximise their contribution to regeneration, Statements should be prepared and, where but impacts possible through loss/damage of evidence points to potential presence of buried assets particularly in early stages remains, mitigation will be required (e.g. investigative trenching, watching brief, recovery & interpretation of remains).

Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored;

Development is likely to increase activity and extent of active, overlooked space in 9 Reduce crime and fear of crime + + Ongoing Operation Local Med Med Minor Positive No comparison to current use, thereby reducing fear of crime.

UE-0130 Luton LP DAM_6_131213 359 51 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 359: Bramingham Centre, Weltmore Road. 100% housing 2 and 3-bed units; 50dph; 70 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? The development has good links to cycle and bus networks and open space. Good Encourage healthier lifestyles and reduce 10 accessibility to education and healthcare but + + Ongoing Operation Local Med Med Minor Positive No adverse health impacts of new developments distance to employment centres may encourage car use.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Close to Marsh Rd DC, a large development 12 Support vitality and viability of centres such as this is likely to contribute to vitality of + + Ongoing Operation Local Med Med Minor Positive No centres

The site has good bus and cycle links. Cycle Provide and encourage the use of sustainable links along River Lea which will encourage their 13 integrated transport systems, improve access use. Healthcare and education facilities in close + + Ongoing Operation Local Med Med Minor Positive No and mobility proximity. However distance to main employment centres may encourage car use

Construction phase will provide some local and Promote employment, learning, skills and accessible employment opportunities. No 14 + Initial Construction Local Med High Minor Positive No innovation provision within development for employment within site.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 359 52 / 62 DETAILED ASSESSMENT MATRIX Housing Site 361: 2 - 32 Beechwood Road - 100% housing 2 and 3-bed units; 50dph on half of site allowing other half for employment/ other uses; 15 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide new trees or planting Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes within the scope of the development should be infrastructure any open space or other GI. explored.

Site is PDL, not close to major air pollution Following site investigation, design of sources (e.g. AQMA, M1, airport), not adjacent remediation strategy should include a CEMP to Protect and enhance air, soil and water to R Lea, but within SPZ2. Good bus Construction reduce and manage risk of mobilising 3 - - - Ongoing Local Med Med Minor Negative Yes resources accessibility but limited access to railway or & Operation contaminants. Sustainable transport measures cycleroutes is likely to increase reliance on car should be maximised (e.g. onsite cycle facilities, travel. strengthened links to public transport).

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ2. reduce flood risk ground or sewer sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

Construction phase will provide some local and Opportunities to provide work-based training SEA Objectives SEA Reduce poverty and inequality and promote accessible employment opportunities; Construction 8 + + + Ongoing Local Med Med Minor Positive Yes during construction should be explored; social inclusion operation phase will provide job opportunities & Operation provision for live/work units may be suitable. through employment and retail uses.

Development is likely to increase activity and 9 Reduce crime and fear of crime extent of overlooked space in comparison to + + Ongoing Operation Local Med Med Minor Positive No current use, thereby reducing fear of crime.

Site accessibility is good regarding healthcare, Opportunities to provide improved access to but not regarding sports provision or cycle Encourage healthier lifestyles and reduce cycle routes should be explored. Consideration 10 routes. The proposal has no health, sports, - - Ongoing Operation Local Med Med Minor Negative Yes adverse health impacts of new developments should be given to nearby provision of sporting recreation, education, leisure, community or facilities cultural elements.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and it will provide a 12 Support vitality and viability of centres + + Ongoing Operation Local Low Med Negligible Positive No contribution to the vitality of centres.

Site accessibility is moderate to good Provide and encourage the use of sustainable regarding education, employment, health Sustainable transport measures should be 13 integrated transport systems, improve access facilities & bus transport, but limited access to + + Ongoing Operation Local Low Med Negligible Positive Yes maximised (e.g. onsite cycle facilities, and mobility railway or cycleroutes and distance to nearest strengthened links to public transport). crèche likely to encourage car use.

UE-0130 Luton LP DAM_6_131213 361 53 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 361: 2 - 32 Beechwood Road - 100% housing 2 and 3-bed units; 50dph on half of site allowing other half for employment/ other uses; 15 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Construction phase will provide local and Promote employment, learning, skills and accessible employment opportunities; Construction 14 + + + Ongoing Local Med Med Minor Positive No innovation operation phase will provide job opportunities & Operation through employment and retail uses.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 361 54 / 62 DETAILED ASSESSMENT MATRIX Housing Site 364: Land at 10 - 24 Caleb Close - Mixed retail, employment and housing (2- and 3-bed units); 75dph (2013 urban capacity work); 24 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide new trees or planting Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes within the scope of the development should be infrastructure any open space or other GI. explored

Site is PDL, not close to major air pollution Following site investigation, design of sources (e.g. AQMA, M1, airport), not adjacent remediation strategy should include a CEMP to Protect and enhance air, soil and water to R Lea, but within SPZ2. Good bus Construction reduce and manage risk of mobilising 3 - - - Ongoing Local Med Med Minor Negative Yes resources accessibility but limited access to railway or & Operation contaminants. Sustainable transport measures cycleroutes is likely to increase reliance on car should be maximised (e.g. onsite cycle facilities, travel. strengthened links to public transport).

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ2. reduce flood risk ground or sewer sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

Construction phase will provide some local and Opportunities to provide work-based training Reduce poverty and inequality and promote accessible employment opportunities; Construction SEA Objectives SEA 8 + + + Ongoing Local Med Med Minor Positive Yes during construction should be explored; social inclusion operation phase will provide job opportunities & Operation provision for live/work units may be suitable. through employment and retail uses.

Development is likely to increase activity and 9 Reduce crime and fear of crime extent of overlooked space in comparison to + + Ongoing Operation Local Med Med Minor Positive No current use, thereby reducing fear of crime.

Site accessibility is good regarding healthcare, Opportunities to provide improved access to but not regarding sports provision, play Encourage healthier lifestyles and reduce cycle routes should be explored. Consideration 10 facilities or cycle routes. The proposal has no - - Ongoing Operation Local Med Med Minor Negative Yes adverse health impacts of new developments should be given to nearby provision of sporting health, sports, recreation, education, leisure, facilities community or cultural elements.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area though some 12 Support vitality and viability of centres distance from centres. It will provide a minor + + Ongoing Operation Local Low Med Negligible Positive No contribute to the vitality of centres.

UE-0130 Luton LP DAM_6_131213 364 55 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 364: Land at 10 - 24 Caleb Close - Mixed retail, employment and housing (2- and 3-bed units); 75dph (2013 urban capacity work); 24 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Site accessibility is moderate to good Provide and encourage the use of sustainable regarding education, employment, health Sustainable transport measures should be 13 integrated transport systems, improve access facilities & bus transport, but limited access to + + Ongoing Operation Local Low Med Negligible Positive Yes maximised (e.g. onsite cycle facilities, and mobility railway or cycleroutes. Distance to nearby strengthened links to public transport). crèche likely to encourage car use.

Construction phase will provide local and Promote employment, learning, skills and accessible employment opportunities; Construction 14 + + + Ongoing Local Med Med Minor Positive No innovation operation phase will provide job opportunities & Operation through employment and retail uses.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 364 56 / 62 DETAILED ASSESSMENT MATRIX Housing Site 365: 146 - 158 Park Street - Student accommodations; Planning Permission; 29 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide new trees or planting Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes within the scope of the development should be infrastructure any open space or other GI. explored.

Following site investigation, design of Site is PDL, not close to major air pollution remediation strategy should include a CEMP to sources (e.g. AQMA, M1, airport), not adjacent Protect and enhance air, soil and water Construction reduce and manage risk of mobilising 3 to R Lea, but within SPZ1. Site is not on - - - Ongoing Local Med Med Minor Negative Yes resources & Operation contaminants. Sustainable transport measures agricultural land. Good bus and cycle should be maximised (e.g. onsite cycle facilities, accessibility but moderate access to railway strengthened links to public transport).

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ1. reduce flood risk ground or sewer sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Site is not in agricultural use and is an efficient Waste materials produced during demolition Increase resource efficiency and reduce use of PDL. Site will need to comply with LP37, and groundworks should be re-used on site 6 + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste though unlikely to lead to significant resource wherever possible, or re-processed off site for consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

SEA Objectives SEA Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored.

Development is likely to increase activity and 9 Reduce crime and fear of crime extent of overlooked space in comparison to + + Ongoing Operation Local Med Med Minor Positive No current use, thereby reducing fear of crime.

Site is close to healthcare facilities , sporting facilities and open space. Accessibility to children's play areas is moderate though Encourage healthier lifestyles and reduce Consideration of cycle storage / parking would 10 unlikely to have significant import due to + + Ongoing Operation Local Med High Minor Positive Yes adverse health impacts of new developments encourage use of existing cycle routes. proposals for use as student accommodation. Bus and cycle links are good with rail accessibility moderate.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and it will provide a 12 Support vitality and viability of centres + + Ongoing Operation Local Low Med Negligible Positive No contribution to the vitality of centres.

Bus and cycle links are good with rail Provide and encourage the use of sustainable accessibility moderate. Proximity of the 13 integrated transport systems, improve access development to university increases likelihood + + Ongoing Operation Local Med High Minor Positive No and mobility that sustainable transport methods will be used.

UE-0130 Luton LP DAM_6_131213 365 57 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 365: 146 - 158 Park Street - Student accommodations; Planning Permission; 29 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Promote employment, learning, skills and Construction phase will provide local and 14 + Initial Construction Local Med Med Minor Positive No innovation accessible employment opportunities;.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 365 58 / 62 DETAILED ASSESSMENT MATRIX Housing Site 402: The Orchards Centre, Straners Way - 100% housing 2 and 3-bed units; 75dph; 67 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide new trees or planting Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes within the scope of the development should be infrastructure any open space or other GI. explored.

The development is close to major air pollution Following site investigation, design of source (M1). Site has good links to buses, remediation strategy should include a CEMP to Protect and enhance air, soil and water moderate links to cycleroutes but poor access reduce and manage risk of mobilising 3 - - Ongoing Operation Local Med High Minor Negative Yes resources to railway services. The site is on PDL which is contaminants. Sustainable transport measures not ALC but is within SPZ2, it is not open space should be maximised (e.g. onsite cycle facilities, or close to the River Lea or its tributaries. strengthened links to public transport).

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ2. reduce flood risk ground or sewer sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Site is not in agricultural use and is an efficient Waste materials produced during demolition Increase resource efficiency and reduce use of PDL. Site will need to comply with LP37, and groundworks should be re-used on site 6 + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste though unlikely to lead to significant resource wherever possible, or re-processed off site for consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though

buried assets may be present. SEA Objectives SEA Reduce poverty and inequality and promote Construction phase will provide some local and Opportunities to provide work-based training 8 + Initial Construction Local Med High Minor Positive Yes social inclusion accessible employment opportunities during construction should be explored.

Development is likely to increase activity and 9 Reduce crime and fear of crime extent of overlooked space in comparison to + + Ongoing Operation Local Med Med Minor Positive No current use, thereby reducing fear of crime.

Site is close to healthcare facilities , sporting Opportunities to provide improved access to facilities and open space. Accessibility to Encourage healthier lifestyles and reduce cycle routes should be explored. Consideration 10 children's play areas is moderate. Bus links are + + Ongoing Operation Local Med High Minor Positive Yes adverse health impacts of new developments of cycle storage / parking would encourage good with cycleroute accessibility moderate. use of existing cycle routes. Links to railway network are poor.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

The site is some distance away from existing 12 Support vitality and viability of centres centres and as such is unlikely to have a Neutral No significant impact on vitality or viability

Links to bus transport are good, however Provide and encourage the use of sustainable accessibility to cycleroutes and railway is Sustainable transport measures should be 13 integrated transport systems, improve access moderate to poor. Distance from centres may + + Ongoing Operation Local Low Med Negligible Positive Yes maximised (e.g. onsite cycle facilities, and mobility encourage car use, however education, strengthened links to public transport). healthcare and employment areas are close by.

UE-0130 Luton LP DAM_6_131213 402 59 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 402: The Orchards Centre, Straners Way - 100% housing 2 and 3-bed units; 75dph; 67 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required? Promote employment, learning, skills and Construction phase will provide local and 14 + Initial Construction Local Med Med Minor Positive No innovation accessible employment opportunities;.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 402 60 / 62 DETAILED ASSESSMENT MATRIX Housing Site 412: Land at 38a Wingate Road. - Mixed retail, employment and housing. 2 and 3-bed units; 50dph on half of site allowing other half for employment/ other uses; 15 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Site layout should seek to retain & increase Maintain and enhance biodiversity, habitat and Site is within the urban area, not close to any 1 Neutral Yes coverage of trees, hedges & other natural landscape landscape or conservation designations. features wherever possible.

Opportunities to provide new trees or planting Conserve, restore and enhance green Site is within the urban area, not adjacent to 2 Neutral Yes within the scope of the development should be infrastructure any open space or other GI. explored

Site is PDL, not close to major air pollution Following site investigation, design of sources (e.g. AQMA, M1, airport), not adjacent remediation strategy should include a CEMP to Protect and enhance air, soil and water to R Lea, but within SPZ2. Good bus Construction reduce and manage risk of mobilising 3 - - - Ongoing Local Med Med Minor Negative Yes resources accessibility but limited access to railway or & Operation contaminants. Sustainable transport measures cycleroutes is likely to increase reliance on car should be maximised (e.g. onsite cycle facilities, travel. strengthened links to public transport).

Protect areas that are at risk from flooding and None - site not subject to flood risk from fluvial, 4 Neutral No SuDS may not be suitable given SPZ2. reduce flood risk ground or sewer sources.

Proposals will need to comply with LP37 on Design should consider use of renewable 5 Reduce carbon emissions carbon reduction & sustainable energy; unlikely Neutral Yes energy (e.g. solar thermal/PV, micro wind, to significantly increase carbon emissions. ground source heat, CHP etc.).

Waste materials produced during demolition Site is an efficient use of PDL, will need to Increase resource efficiency and reduce and groundworks should be re-used on site 6 comply with LP37, and unlikely to lead to + + Ongoing Operation Local Med High Minor Positive Yes resource use and waste wherever possible, or re-processed off site for significant resource consumption. future use in aggregates.

None - site is previously developed and does not feature any known heritage assets (e.g. Identify, protect, maintain and enhance 7 listed building, conservation area, scheduled Neutral No heritage assets and their setting monument, registered park or garden) though buried assets may be present.

Construction phase will provide some local and SEA Objectives SEA Opportunities to provide work-based training Reduce poverty and inequality and promote accessible employment opportunities; Construction 8 + + + Ongoing Local Med Med Minor Positive Yes during construction should be explored; social inclusion operation phase will provide job opportunities & Operation provision for live/work units may be suitable. through employment and retail uses.

Development is likely to increase activity and 9 Reduce crime and fear of crime extent of overlooked space in comparison to + + Ongoing Operation Local Med Med Minor Positive No current use, thereby reducing fear of crime.

Site accessibility is good regarding healthcare, but poor regarding sports provision, play Consideration should be given to nearby Encourage healthier lifestyles and reduce 10 facilities or cycle routes. The proposal has no - - Ongoing Operation Local Med Med Minor Negative Yes provision of sporting facilities and improving adverse health impacts of new developments health, sports, recreation, education, leisure, access to cycle routes. community or cultural elements.

Site will provide dwellings in accordance with Provide decent, affordable and safe homes for LP16,35&37 regarding affordability, design & 11 ++ ++ Ongoing Operation Local High Med Moderate Positive No all sustainability; site likely to yield 20% affordable units or financial contribution.

Site is within the urban area and will contribute 12 Support vitality and viability of centres + + Ongoing Operation Local Med Med Minor Positive No to the vitality of centres. Site accessibility is moderate to good Provide and encourage the use of sustainable Sustainable transport measures should be regarding education, employment, health 13 integrated transport systems, improve access + + Ongoing Operation Local Low Med Negligible Positive Yes maximised (e.g. onsite cycle facilities, facilities & bus transport, but limited access to and mobility strengthened links to public transport). railway or cycleroutes.

UE-0130 Luton LP DAM_6_131213 412 61 / 62 SEA Objectives SEA

DETAILED ASSESSMENT MATRIX Housing Site 412: Land at 38a Wingate Road. - Mixed retail, employment and housing. 2 and 3-bed units; 50dph on half of site allowing other half for employment/ other uses; 15 units Mitigation Duration Temporary Geographic Level of Scale of Positive or or other No. SEA Objective Description of predicted effect Frequency or Magnitude Supporting comments / Proposed mitigation Short Medium Long significance certainty significance negative action permanent term term term required?

Construction phase will provide local and Promote employment, learning, skills and accessible employment opportunities; Construction 14 + + + Ongoing Local Med Med Minor Positive No innovation operation phase will provide job opportunities & Operation through employment and retail uses.

Key Major negative effect -- Negative Severe Optimal Positive Negative effect - Magnitude of Major Major The 'Duration' column is noted as: Positive effect + significance is Moderate Moderate Major positive effect ++ illustrated as: Minor Minor

Neutral environmental effect Negligible Negligible SEA Objectives SEA

UE-0130 Luton LP DAM_6_131213 412 62 / 62

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