Committee Ref:

EX/08/21

Notice of Meeting

Committee : Executive

Date : Monday, 16 August 2021

Time : 18:00

Place : Council Chamber Town Hall,

Councillors : Simmons (Chair) K. Malik A. Hussain Roche J. Hussain T. Saleem A. Khan Shaw Malcolm Timoney

Quorum : 3 Members

Contact Officer: Matthew Hussey (01582 546032) Email [email protected] Livestream Meeting Link

INFORMATION FOR THE PUBLIC

PURPOSE: The Executive is the Council’s primary decision-making body dealing with a range of functions across the Council’s activities and services.

This meeting is open to the public and you are welcome to attend.

For further information, or to see the papers, please contact us at the Town Hall:

IN PERSON, 9 am to 5 pm, Monday to Friday, or

 CALL the Contact Officer (shown above).

An induction loop facility is available for meetings held in Committee Room 3.

Arrangements can be made for access to meetings for disabled people.

If you would like us to arrange this for you, please call the Contact Officer (shown above).

NOTE:

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Members of the public are entitled to take photographs, film, audio-record and report on all public meetings in accordance with the Openness of Local Government Bodies Regulations 2014. People may not however act in anyway considered to be disruptive and may be asked to leave. Notice of these rights will be given verbally at the meeting, as appropriate.

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AGENDA

Agenda Subject Page Item No.

1. Apologies for Absence

2. Published record of the meeting

1. 19 July 2021 7 - 14

Section 106, Local Government Finance Act 1992

Those item(s) on the Agenda affected by Section 106 of the Local Government Finance Act 1992 will be identified at the meeting. Any Members so affected is reminded that (s)he should disclose the fact and refrain from voting on those item(s).

Disclosures of Interests

Members are reminded that they must disclose both the existence and nature of any disclosable pecuniary interest and any personal interest that they have in any matter to be considered at the meeting unless the interest is a sensitive interest in which event they need not disclose the nature of the interest.

A member with a disclosable pecuniary interest must not further participate in any discussion of, vote on, or take any executive steps in relation to the item of business.

A member with a personal interest, which a member of the public with knowledge of the relevant facts would reasonably regard as so significant that it is likely to prejudice the member’s judgment of the public interest, must similarly not participate in any discussion of, vote on, or take any executive steps in relation to the item of business.

Disclosable pecuniary interests and Personal Interests are defined in the Council’s Code of Conduct for Members and Co-opted members.

3. Business not covered by current forward plan: General Exception

The Executive Leader to report on any business which it is proposed should be considered by the Executive following compliance with Regulation 10 of the Local Authorities (Executive Arrangements) (Meetings and Access to Information) () Regulations 2012.

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1. Waste Management Contract Direct 15 - 32 Award

(Report of the Service Director, Sustainable Development)

2. Acquisition of Plait Court (See Item: 13)

(Report of the Service Director, Housing)

4. Business not covered by current forward plan: Special Urgency

The Executive Leader to report on any business which it is proposed should be considered following compliance with Regulation 11 of the Local Authorities (Executive Arrangements) (Meetings and Access to Information) (England) Regulations 2012.

5. References from committees and other bodies

6. Recommendations from Scrutiny Reviews

7. Petitions

Business items

Executive Leader

8. Revised governance arrangements in respect of 33 - 42 London Limited

(Report of the Chief Executive)

Inclusive Growth (Finance and Revenues & Benefits)

9. Revenue and Capital Budget Monitoring – Quarter 43 - 90 1 2021-22

(Report of the director, Finance, Revenues & Benefits)

Inclusive Economy (Sustainable Development & Highways)

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10. A New Heritage Strategy for Luton 91 - 284

(Report of the Policy Strategy and Partnerships Manager)

11. Regulation 4 of the Local Authorities (Executive Arrangements (Meetings & Access to Information)(England) Regulations 2012

To consider whether to pass a resolution under Regulation 4 of the Local Authorities (Executive Arrangements) (Meetings and Access to Information) (England) Regulations 2012 to exclude the public from the meeting during consideration of the item(s) listed below as it is likely, that if members of the public were present during the transaction of the item(s), exempt information within the meaning of the Paragraph(s) of Part 1 of Schedule 12A to the Local Government Act 1972 indicated next to the item, would be disclosed to them.

12. Published Record of the Meeting

1. 19 July 2021

• Paragraph (3) - Information relating to the financial or business affairs of any particular person (including the authority holding that information). Population Wellbeing (Housing, Waste & Climate Change)

13. Acquisition of Plait Court

• Paragraph (3) - Information relating to the financial or business affairs of any particular person (including the authority holding that information). • Paragraph (6) - Information which reveals that the authority proposes – (a) to give under any enactment a notice under or by virtue of which requirements are imposed on a person; or (b) to make an order or direction under any enactment. 14. Appropriation of Land at Farley Hill

• Paragraph (3) - Information relating to the financial or business affairs of any particular person (including the authority holding that information). Note: Rescheduled Items

• LLAL Final SFM Agreement - Deferred to 13 September 2021 • Lease of Wigmore Valley Park to LLAL - Deferred to 13 September 2021

Note: Five days’ notice is hereby given of items to be considered in private as required by Regulations (4) and (5) of the Local Authorities (Executive Arrangements) Meetings and Access to Information) (England) Regulations 2012.

Details of any representations received by the Executive about why any of the above exempt decisions should be considered in public: none at the time of publication of the agenda. If representations are received they will be published separately, together with the statement given in response.

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Item No: 2.1 Executive 19 July 2021

Present: Councillor Simmons (Chair), Councillors: A. Hussain, J.I. Hussain, Khan, Malcolm, Roche, Shaw and Timoney

Apologies: Councillors K. Malik and T. Saleem

In Attendance: Councillor Franks

Decision Sheet Exemptions from the call-in process: (1) If the Council would be likely to suffer legal prejudice (2) If the Council would be likely to suffer financial prejudice (3) Where the calling-in of the decision would result in the decision not being capable of implementation at all (4) Where the decision is to in incur or forego expenditure of £5,000 or less except where the decision has been taken otherwise that in accordance with the Council's Policy Framework or any policies, practices, or procedures adopted by the Executive (5) Where the decision results from a reference or report or recommendation from the Overview and Scrutiny Board or from a Task and Finish Group. (6) Where the decision will be the subject of a recommendation to the Full Council Page 7 of 284

Agenda Subject Dec. Decision and reason for decision Other options considered item(s) ward No. affected 2.1 Published decision sheet EX/79/21 That the published decisions of the All of the Executive meeting meeting of the Executive held on 28th June held on 28th June 2021 be agreed as a correct record of the meeting and the Chair be authorised to sign them.

5.1 Reference from Scrutiny EX/80/21 That the Executive notes the a) To agree the recommendation All Finance Review Group- recommendation from the Scrutiny Finance of Scrutiny FRG Capital Strategy Review Group as follows: Framework b) Not to agree the (i) That the Scrutiny Finance Review recommendation and consider Group welcomes the introduction of an alternative as the the Capital Strategy and looks forward responsible decision making to seeing how it improves Luton body Borough Council’s capital procedures in regard to the Capital Strategy.

Reason: To consider the recommendation of Scrutiny Finance Review Group

5.2 Reference from the EX/81/21 That the Executive notes a) To agree the recommendations All Overview and Scrutiny recommendations from the Overview and of the OSB Board – Anti-Littering Scrutiny Board as follows: Strategy b) Not to agree the The Overview and Scrutiny Board recommendations and consider supports: an alternative as the responsible decision making (i) The introduction of the anti-littering body strategy;

(ii) The proposal to increase the current fixed penalty for littering to £150 Page 8 of 284 discounted to £75 if paid within 10 days;

That the recommendations below be agreed and included in item 10 below:

(iii) Find some budget to seriously ramp up the education, publicity and enforcement of the Strategy;

(iv) Investigate whether the proprietors of fast food takeaways can be made to contribute to this budget.

Reason: To consider the recommendations from the Overview and Scrutiny Board meeting held on 22 June 2021

8. Capital Strategy EX/82/21 That the Capital Strategy Framework and a) To agree the recommendation All Framework governance model be approved. in the report.

Reason: To implement a new capital b) Not to agree the strategy and governance model which recommendation and request addresses the recommendations set out further information by CIPFA

9. Food Safety, Food EX/83/21 That the Food Safety, Food Standards & All Standards & Feed Law Feed Law Service Plan 2021-22 be Service Plan 2021/22 approved.

Reason: Statutory 10. Anti-Littering Strategy EX/84/21 (i) That the introduction of an ant-littering a) To approve the All strategy be agreed. recommendations.

Page 9 of 284 (ii) That the increasing of the current fixed b) Not to approve the penalty for littering to £150 discounted recommendations and request to £75 if paid early be agreed. further information

The Executive agreed the following recommendations from the Overview and Scrutiny Board reference item 5.2 above:

(iii) To find some budget to seriously ramp up the education, publicity and enforcement of the Strategy;

(iv) To investigate whether the proprietors of fast food takeaways can be made to contribute to this budget.

Reason: To eradicate littering in Luton as set out in the anti-littering strategy

11. Open-Lea EX/85/21 That the capital spend of funding in the a) Repair of the culvert was South Green Book, item 100, project PR14, Silver deemed less value for money at Street Culvert Repairs which required a £1.2m and does not attract business case approval when the Capital ERDF funding nor offer any Programme was approved at Full Council meaningful betterment of the be approved. town centre environment

Reason: To approve the funding b) Do nothing, however, the culvert provisionally outlined in the capital would remain at risk of collapse. programme to deliver a new pocket park Determined not to be appropriate

Page 10 of 284 12. Regulation 4 of the Local EX/86/21 A resolution was passed under Regulation Authorities (Executive 4(2) of the Local Authorities (Executive Arrangements)(Meetings Arrangements) (Meetings and Access to and Access to Information) (England) Regulations 2012 to information)(England) exclude the public from the meeting during Regulations 2012 consideration of the item(s) listed below as it is likely, that if members of the public were present during the transaction of the item(s), exempt information within the meaning of Paragraph(s) of Part 1 of Schedule 12A to the Local Government Act 1972 indicated the item would be disclosed to them. 13.1 Published Private decision EX/87/21 That the private published decisions of the sheet of the Executive meeting of the Executive held on 28th June meeting held on 28th June 2021 be agreed as a correct record of the 2021 meeting and the Chair be authorised to sign them.

[Note: the above item was considered in private by virtue of Paragraph 3 of Part 1 of Schedule 12A to the Local Government Act 1972, Part VA)

14. Acquisition of a new HR & EX/88/21 That the recommendations in the report of All Payroll System the Interim Service Director, Customer and Organisational Development be approved and noted.

[Note: the above item was considered in private by virtue of Paragraph 3 of Part 1 of Schedule 12A to the Local Government Act 1972, Part VA)

Page 11 of 284 15. Completion of Acquisition EX/89/21 That the recommendation in the report of .All of Leasehold Interest in the Service Director, Property & Preservation House Infrastructure be approved.

[Note: the above item was considered in private by virtue of Paragraph 3 of Part 1 of Schedule 12A to the Local Government Act 1972, Part VA)

Meeting ended: 6.55 pm Date of Publication: 21st July 2021

Page 12 of 284 Exempt Information Summary of those matters which by virtue of Part 1 of Schedule 12A of the Local Government Act 1972 may be discussed in private

Paragraph No.

1. Information relating to any individual.

2. Information which is likely to reveal the identity of an individual.

3. Information relating to the financial or business affairs of any particular person (including the authority holding that information).

4. Information relating to any consultations or negotiations, or contemplated consultations or negotiations, in connection with any labour related matter arising between the authority or a Minister of the Crown and employees of, or office holders under, the authority.

5. Information in respect of which a claim to legal professional privilege could be maintained in legal proceedings.

6. Information which reveals that the authority proposes:

(a) to give under any enactment a notice under or by virtue of which requirements are imposed on a person; or (b) to make an order or direction under any enactment.

7. Information relating to any action taken or to be taken in connection with the prevention, investigation or prosecution of crime. Page 13 of 284

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Item No: 3.1 Report For: Executive Date of Meeting: 16 August 2021 Report Of: Service Director – Sustainable Development Report Author: Shaun Askins Subject: Waste Management Contract Direct Award Lead Executive Member(s): Cllr Shaw Wards Affected: All Consultations: Councillors  Scrutiny  Stakeholders ☐ Others ☐

Recommendations 1. Executive is recommended to agree a direct award to the current waste disposal contract with FCC Environment for a period of up to two years, with the contract end date moving from 31 March 2022 until 31 March 2024.

Background 2. as a unitary authority has a legal duty, under the Environment Act 1990, to both collect household waste as the waste collection authority (WCA) and arrange for disposal acting as the waste disposal authority (WDA).

3. The council has worked in close partnership with the current contractor, FCC Environment, since 2004. During this period, partnership working has delivered increases in performance and significant savings.

4. The contract is based on a fixed Unitary Rate per tonne, for every tonne of waste handled and covers the cost of operating the facilities in Luton, staffing and haulage but not landfill tax or Energy from waste (EfW) charges.

5. Waste managed under the contract includes; all household residual, co-mingled dry recycling, green waste, all Tidy Tip waste streams, hazardous waste, clinical waste and street cleaning waste as well trade waste.

6. Residual waste disposal charges other than landfill are in addition to the unitary charge, as is Landfill tax for the materials we cannot send to EfW

7. FCC Environment employ contract specific staff and operate facilities leased to them by the council to be used in delivery of the contract;

 1 x WTS/MRF – Located at Kingsway  2 x Tidy Tips – Located at Eaton Green Road and Progress Way. In line with the EPA, these offer residents a disposal route for small volumes of additional household waste which cannot be disposed of conveniently via the kerbside services  Currently 50+ people are employed across the contract operations in Luton; including a dedicated contract manager, HWRC manager, FTE MRF operators,

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FTW HWRC operatives, as well as shovel drivers, weighbridge operators and haulage driver/s. 8. Current uncertainty exists around proposed legislation changes and the impact this will have on WDA and WCA functions, namely the Environment Bill and associated consultations; Deposit Return Scheme (DRS), End Produce Responsibility (EPR) and Collection Consistency.

The Current Position 9. Luton currently has a long standing waste disposal contact, with FCC Environment, which has been in place since 2004. This was originally based on the Public Private Partnership (PPP) model and was let for 12 years, with options to extend at the councils request. This was renegotiated to deliver long term savings from 2015, with an extension period of 6 years, up to March 2022.

10. Given the additional workload caused by the pandemic as well as changes being made at senior management level, work on the procurement of a new contract stalled. This also allowed the budget earmarked to progress this work (£145K) to be taken as a saving as part of the emergency budget savings in 20/21. In normal circumstances the procurement would have progressed without the need to request a further extension. However, as a consequence of the delay there is now a short lead in period to 2022, resulting in the need to go outside the normal procurement process and give a direct award outside of the Public Contract Regulations to allow time for a thorough procurement exercise.

11. Apart from the timescales, there are benefits in continuing with the current supplier which will allow time for the following activities to be carried out;

12. A full and thorough waste options audit be completed, outlining environmental outcomes including carbon and climate change impacts and for this to be used as basis for the scope of the forthcoming procurement and subsequent new contract.

13. The periodic review of Luton’s adopted waste strategy to be completed so that it aligns with the 2040 vision and Net Zero aims.

14. Full and final outcomes of the Environment consultations and subsequent Environment Bill be realised, including proposed enactment dates. The Environment Bill had been delayed but is expected to be enacted over the summer of 2021

15. Ensure future disposal options align with mandatory elements of the Environment Bill, such as the separate collection of food waste. The proposed direct award period will ensure the authority is best placed to react to all policy and legislation changes in relation to contract specification and scope

16. Additionally, the proposed direct award of the disposal contract will allow for the full economic market impact of the Covid pandemic be realised, therefore ensuring market conditions are evaluated in terms of the ‘new normal’ and that this forms the baseline of any future waste disposal contract

Goals and Objectives

17. The proposed direct award of the waste disposal contract will ensure that the authority can achieve the following objectives;

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 Stability of the current service as the authority develop new longer term waste disposal options.

 Allows sufficient time for a transition from the current contract to a new mid/long term waste disposal contract, by following a clear procurement timetable to ensure that the procurement is completed and awarded in time for smooth transition at the end of the direct award period.

 The procurement will incorporate; options analysis, soft market testing, and specification development, all with stakeholder involvement and in line with corporate governance requirements. Project team will involve finance, legal, procurement and service members with regular project meeting with Service and Corporate Directors.

 Enables the international waste market to stabilise following the Covid pandemic, allowing the authority to make comprehensive long term financial decisions with regard to the future contract scope.

 Complete the scheduled works to the fire suppression system at the Kingsway waste transfer station, due to commence in spring 2022. These works are required to bring the facility up to a standard that complies with regulatory and insurance requirements. The proposed extension will allow these works be carried out in partnership with FCC Environment, providing a VfM solution

Proposal 18. It is proposed that a waste disposal contract with FCC Environment be directly awarded to for a period of up to two years, with the contract end date moving from 31 March 2022 until 31 March 2024.

19. The proposed direct award will see no material changes to terms of the existing contract in line with procurement and legal guidance.

20. The proposed direct award will be awarded to FCC Environment at the risk to the authority of a challenge and is outside of the Public Contract Regulations 2015.

21. If this proposal is approved and agreed with FCC Environment, work would commence on drawing up a timeline and proposal for a future, long term procurement of a waste disposal contract. This will align with not only the adopted waste Strategy but also Luton’s 2040 vision and Nett Zero Carbon targets.

22. Any future contract will include mechanisms for handling future legislative changes for example:;

i. Deposit Return Scheme; “All in” national scheme for drinks containers including; glass, plastic, aluminium and steel cans with a refundable deposit (@ 20p) for each returned unit.

ii. Consistency of collections; Collections of 6 materials; paper & card, plastic bottles, plastic pots, tubs and trays, cans and glass bottles/containers plus mandatory separate household food waste collections. This is likely to be classified as a new burden.

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iii. Extended Producer Responsibility; based on full net recovery funded by producers for all packaging. Funding to cover all parts of the packaging supply chain including collection and re-processing.

Key Risks 23. There is a risk in giving a direct award which could result in a challenge by a competitor company. This could take one of two main routes; a complaint to the cabinet office who would initially contact the council’s procurement manager for an explanation of the reasons for the direct award, or an injunction lodged with the courts, which although anyone could lodge, would necessitate the council to take action to defend. In either case the council would need to provide evidence to defend the action it has taken. The challenge would need to have a reasonable and sound basis i.e. that they could have bid for and delivered the service, in this case provision of the waste management & disposal service set out in the background section of this report.

24. To mitigate the risk, the authority will advertise a Voluntary Ex Ante Transparency notice to mitigate our approach to the market to defend a potential procurement challenge for declaration of ineffectiveness under the Public Contract Regulations. Note the award of a contract, will typically be reported in the Find a Tender Service portal. Suppliers will have 30 days to challenge this decision and members need to note that this could result in retendering the requirement if a robust challenge is received. Further to this we are able to demonstrate that a comprehensive project plan for a compliant procurement exercise and governance process is being put in place. Therefore we will, within the next two years, develop and procure a new contract for the services required to start by 31st March 2024.

Consultations 25. N/A

Alternative options considered and rejected (please specify) 26. A number of options have been considered ;

a) Go out to procurement immediately – The uncertainty regarding the impending legislation and the scope of the contract could see increased costs due to additional criteria being required at a later stage of the project. This would not allow the development of options to review the current infrastructure/ facilities to ascertain whether they are required in the medium to long term. Furthermore this would also necessitate the council taking on the risk associated with legislative change with regard to the Environment Bill and anticipated changes to waste service requirements including food waste, recycling e.g. Proposed Deposit Return Scheme for recyclable bottles & cans.

b) Remain as is - If the proposed direct award was not enacted the authority would be left without a disposal contract in place post 2022, and therefore be in breach of our statutory duty as a waste disposal authority under the EPA 1990. The absence of a formal legal agreement with FCC will make it difficult for both parties to remedy any performance issues and could give rise to further costs as a result. Additionally this will expose the authority to a high risk of challenge and potential contractor variations/claims.

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Appendices Attached Appendix A - Integrated Impact Assessment

List of Background Papers - Local Government Act 1972, Section 100D There are no background papers to the report.

Implications - an appropriate officer must clear all statements

For CLMT only Legal and Finance are required Required Item Details Clearance Dated Agreed By Legal The proposal for the Direct award must follow Raj Popat, 1st July 2021 the VEAT Notice process and the contract may Principal only be varied through this process without a Solicitor further call for competition, if the variation to the contract does not amount to a material change affecting the conditions of the existing contract.

In order to mitigate the risk of a challenge the Council must issue a valid VEAT Notice in the Find a Tender Service portal. This provides notification to potential challengers of the variation, and the legal grounds relied upon for making the variation.

VEAT notices are a commonly used means of ascertaining – and mitigating – the risk of a procurement challenge. Properly drafted they can provide an absolute defence to a claim for a declaration of ineffectiveness under the Public Contract Regulations.

Finance The proposed direct award has no direct Darren 1st July 2021 financial implications. It will enable a Lambert, comprehensive and thorough procurement to Finance be carried out for a new mid to long term Business disposal contract to include any legislative Partner changes that the Government may introduce, as referred to in the report. Retendering the contract may have offered the opportunity for cost savings, but whilst there is so much uncertainty surrounding Government policy it is likely that retendering would have left gaps in the contract that could result in significant variations with potentially significant cost implications.

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Item Details Clearance Dated Agreed By Equalities / Any direct award to the waste disposal contract Maureen 29 July 2021 Cohesion / would be a universal service provided and used Drummond, Inclusion by all residents of the town. Equality (Social and Justice) Diversity Adviser

Environment The proposed direct award tfor the current Keith Dove, 1st July 2021 requirement will enable the authority to fully Strategic realise the impact the pending Environment Bill. Policy The direct award will enable the authority time Advisor to develop a mid/long term waste disposal contract which focuses on key principles of the waste hierarchy and Luton low carbon agenda and commitments Health The proposed extension will enable Luton to Matt Corder 01.07.2021 continue to manage its waste in a manner which will not affect public health and enable ongoing campaigns in relation to food waste to continue. Optional Item Details Clearance Dated Agreed By Community Safety Staffing

Other

Page 20 of 284 Appendix A - Integrated Impact Assessment Form (IIA)

The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement

‘Enabling Luton to be proud, vibrant, ambitious and innovative’.

Why do I need to do an IIA? The aim of this impact assessment process is to:  Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council.  Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens.  Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion.  Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified.

When do I need to do an IIA?

 An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.

 The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA.  If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA.  An IIA must at all times identify those who will be affected by the decision, policy or strategy.  At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens.  Your first early draft is to be sent to the Social Justice Unit for comments and guidance  Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit. If you need further guidance please contact the Social Justice Unit (SJU). Please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.

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Page 21 of 284 Appendix A - Integrated Impact Assessment Form (IIA)

Proposal Title: Waste disposal contract extension Lead Officer Name: Shaun Askins Date of IIA: 30 June 21

Date updated after consultation: n/a Early draft Seen by: (Please send an early draft of your IIA to the SJU to ensure all impacts are being considered at the appropriate time)

Finalised IIA Signed and seen by SJU : Name: Maureen Drummond, Equality and Diversity Adviser Date 1 July 2021

Names of all other contributors and Shaun Askins, Steve Lawson, Sue Frost, stakeholders involved in the preparing of FCC operate Kingsway WTS/MRF as well this proposal who have been consulted with as two HWRCs. In total around 50 people and agreed this assessment: are employed by FCC on the Luton (Please note the IIA must not be carried out by one person) contract, as such they will be included as a key stakeholder If there is any potential impact on staffing please include the name/s of the trade union representative/s involved in the preparation of this assessment or any supporting evidence of request to participate:

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Page 22 of 284 Appendix A - Integrated Impact Assessment Form (IIA)

Proposal Outline

Information supporting the proposal (who, what, where, how, why). Breakdown of present users by ethnicity, age, sex, disability, religion/belief, sexual orientation (if recorded). Show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered. It is proposed that the current waste disposal contract with FCC Environment be extended for a period of up to two years, thereby extending the contract end date from 31 March 2022 until 31 March 2024.

This proposed extension to the contract will allow time for the following activities to be carried out;

 A full and thorough waste options audit be completed, outlining environmental outcomes including carbon and climate change impacts

 The periodic review of Luton’s adopted waste strategy be completed

 Fully and final outcomes of the Environment consultations and subsequent Environment Bill be realised, included proposed enactment dates. The Environment Bill had been delayed but is expected to be enacted over the summer

 Ensure future disposal options align with mandatory elements of the Environment Bill, such as the separate collection of food waste. The proposed extension period will ensure the authority is best placed to react to all policy and legislation changes in relation to contract specification and scope

 Additionally, the proposed extension of the disposal contract will allow for the full economic market impact of the Covid pandemic be realised, therefore ensuring market conditions are evaluated in terms of the ‘new normal’ and that this forms the baseline of any future waste disposal contract

It is key to note that the waste disposal contract is universally applied to all users and stakeholders regardless of; demographics, age, ethnicity, sex, disability, religion and/or sexual orientation.

Additionally, FCC Environment employs around 50 people on the Luton contract, most of which live local, thereby this proposed extension seeks to maintain these roles for local people.

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Page 23 of 284 Appendix A - Integrated Impact Assessment Form (IIA)

Impact Table The purpose of this table is to consider the potential impact of your proposal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.

Once you have completed this process you should have a clearer picture of any potential significant impacts1, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.

Citizens/Community Staff (for HR related issues) Protected Groups Positive Negative Neutral Positive Negative Neutral Race X X Sex X X Disability X X Sexual Orientation X X Age X X Religion/Belief X X Gender Reassignment X X Pregnancy/Maternity X X Marriage/Civil Partnership X X (HR issues only) Care Responsibilities2 X X (HR issues only) Social & Health3 Impact on community cohesion X Impact on tackling poverty X Impact on health and wellbeing X Environment Impact on the quality of the natural X and built environment Impact on the low carbon agenda X Impact on the waste hierarchy X Economic/Business Impact on Luton’s economy and/or X businesses Impact on jobs X Impact on skills X

1 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large. 2 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 3 Full definitions can be found in section 3

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Please answer the following questions:

1. Research and Consultation

1.1. Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate. Click here for local demographics and information N/A

1.2. Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate). Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.

Click here for the LBC Consultation Portal N/A

1.3. Have you carried out any specific consultation with citizens likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document. For advice and support from Consultation Team click here N/A

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Appendix A - Integrated Impact Assessment Form (IIA)

2. Impacts Identified

2.1. Where you have identified a positive impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. Guidance Notes: By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic? The proposed extension will enable the authority time to develop a mid/long term waste disposal contract which focuses on key principles of the waste hierarchy and Luton low carbon agenda and commitments

2.2. Where you have identified a negative impact please explain the nature of this impact and why you feel the proposal may be negative. Outline what the consequences will be against each group identified. You will need to identify whether mitigation is available, what it is and how it could be implemented. Specific actions to be detailed in action plan below. Guidance Notes: By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic? None identified

2.3. Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. Guidance Notes: By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic The waste disposal contract is universally applied to all users and stakeholders regardless of; demographics, age, ethnicity, sex, disability, religion and/or sexual orientation.

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Appendix A - Integrated Impact Assessment Form (IIA)

3. Social & Health Impacts

3.1. If you have identified an impact on community cohesion4’, tackling poverty5 or health and wellbeing6, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children. Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.

For advice & support from the Social Justice Unit click here

For advice and support from the Public Health team click here N/A

4 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 5 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 6 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services? 7 Page 27 of 284

Appendix A - Integrated Impact Assessment Form (IIA)

4. Environment Impacts

4.1. If you have identified any impacts related to the built and natural environment7, low carbon8 and waste minimisation please describe here what this may be and who or where you believe could be affected Guidance Notes: Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:

Waste Hierarchy

For advice and support from the Strategy & Sustainability Team click here The proposed extension to the current contract will enable the authority to fully realise the impact the pending Environment Bill. Therefore ensuring key principles of this legislation form the basis of the mid/long term waste disposal contract. The additional time which the proposed extension offers, enables the authority to develop a new contract which priorities waste diversion, recycling and prevention.

7 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution? 8 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport. 8 Page 28 of 284

Appendix A - Integrated Impact Assessment Form (IIA)

5. Economic Impacts

5.1. If you have identified any impacts related to Luton’s economy and businesses 9, creating jobs10 or improving skill levels 11, please describe here what this may be and who or where you believe could be affected Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below. Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below.

For advice and support on Economic Development click here FCC Environment currently employ around 50 people on the Luton contract, many of whom live locally. FCC offer in-house training to employees thereby upskilling the local workers.

9 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 10 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well-being and the reduction of poverty in the social box. 11 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships? 9 Page 29 of 284

Appendix A - Integrated Impact Assessment Form (IIA)

Impact Enhancement and Mitigation Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:

Responsible Date Completed Action Deadline Intended Outcome Officer / Ongoing

A review of the action plan will be prompted 6 months after the date of completion of this IIA.

Key Contacts Name Position Shaun Askins Service manager – Strategy & Sustainability

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Appendix A - Integrated Impact Assessment Form (IIA)

Next Steps  All Executive Reports, where relevant, must have an IIA attached  All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment)  All reports are to be forwarded to the Social Justice Unit, Legal Department, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline  On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager

Completed and signed IIA’s will be published on the internet once the democratic process is complete

Useful Documents Corporate Plan http://intranet/SupportServices/Document%20library/LBC-corporate-plan.pdf Equality Charter https://www.luton.gov.uk/Community_and_living/Lists/LutonDocuments/PDF/Social%20Justi ce/Equality%20Charter.pdf Social Justice Framework Joint Strategic Needs Assessment (JSNA)

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Item No: 8 Report For: Executive Date of Meeting: 16 August 2021 Report Of: Chief Executive Report Author: Robin Porter Subject: Revised governance arrangements in respect of London Luton Airport Limited Lead Executive Member(s): Councillor Simmons Wards Affected: None Consultations: Councillors  Scrutiny ☐ Stakeholders ☐ Others ☐

Recommendations 1. The Executive is recommended to:

(i) note the revised governance arrangements for London Luton Airport Limited (LLAL) as set out in the schedule attached as Appendix A to this report and to request the Board of Directors of LLAL to implement them;

(ii) appoint Graham Olver and Mark Turner as directors of the company with immediate effect and to delegate to the Chief Executive, in consultation with the Leader of the Council, authority to appoint other executive and independent non-executive directors as set out in this report;

(iii) appoint Mark Turner as Company Secretary in place of Luton Borough Council (a corporate body);

(iv) instruct officers to prepare a report to Executive on shareholder governance of Council companies, taking external advice as necessary to assist the Council on developing and implementing new governance arrangements for all its subsidiary companies.

Background 2. At its meeting held on 9th February 2021, the Executive approved a “framework for stabilisation” for LLAL, aimed at ensuring that the company could remain a going concern despite the devastating impact on passenger numbers (and hence revenue) of restrictions on travel arising out of the Covid-19 pandemic.

3. As part of that framework, it was proposed that the Board of Directors of LLAL should be strengthened by the addition of three independent non-executive directors with experience in the aviation industry. Whilst that may be appropriate given that the nature of the company’s operations has changed significantly over the last few years to taking a more entrepreneurial role in shaping the future of the airport, it may on its own not be sufficient to enable the company to take full advantage of the opportunities presented by the end of the current Concession Term, currently expected in 2031.

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4. In considering proposals for governance in respect of LLAL, it should be recalled that the company was established by the Council not from choice but from obligation arising from s. 13 of the Airports Act 1986. The company, and its Directors, are subject to a wide range of duties as set out in the Companies Act 2006 and, it is important, therefore, that the company is understood and seen to be a separate legal entity, with its own rights and obligations, rather than as a department of the Council. The relationship between the Council as shareholder and the company is different to that between the Council and one of its own departments. As a result, clarity in that relationship, in the governance that supports it and in communication and liaison between the parties is of paramount importance in protecting the interests of all including the taxpayers of Luton.

5. For the purposes of the Airports Act 1986, the Council is the “controlling authority” in respect of London Luton Airport, which itself is termed a “public airport company”, both of these arising from the Council’s shareholding (s. 16, Airports Act 1986). The company’s Articles of Association give the Council as shareholder powers over the activities of the company. It is for these reasons that the approval of the Executive, in exercising the authority of the shareholder, is sought for the proposals set out in this report.

6. The Board of Directors of LLAL considered the proposals, which included the establishment of a two-tier Board structure, at its meeting held on 25th March 2021 and was broadly supportive of the direction of travel. Some concerns were expressed about the need for absolute clarity in the allocation of responsibilities between the proposed Supervisory and Managements Boards and that the Supervisory Board should not simply become a “talking shop”. The Board asked that these concerns, and any raised by the Council as shareholder, be addressed and a further report be made at the meeting of the Board scheduled for 25th May 2021.

7. The Council commissioned Bevan Brittan to advise on the arrangements of the Council with LLAL. They have produced a report with recommendations and those recommendations will be reviewed and further reports brought back to Executive in order to deal with the governance aspect from the Council side. Following consultation with the shareholder, and the taking of legal advice from Bevan Brittan, it was proposed that, instead of establishing a two-tier structure, the company should retain a unitary Board (referred to as the Full Board for clarity) and establish a Management Committee comprising executive and independent non-executive directors. This was accepted by the Board of Directors of LLAL at its meeting held on 20th July 2021 and the following comments reflect this revised proposal. It should be noted that further change to LLAL governance, including to the schedule of reserved matters, may be required following the review of the shareholder arrangements by the Council.

8. In respect of the concerns raised by the Board, it is clear that, under corporate law and the provision of the company’s Articles of Association that the Management Committee will exercise all the powers of the directors in relation to the direction and management of the company except in respect of those matters that are specifically reserved to the Full Board. This is what currently happens in practice through officers and the introduction of the Management Committee as the identifiable body that exercises those powers will increase transparency in decision-making and give the Full Board, through its access to Management Committee papers, an even greater oversight of day-to-day operational issues than the Board currently has.

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9. A comparison of the schedule of reserved matters for the current Board and the proposed Full Board shows that there is very little change in responsibilities except to increase the financial limits on delegation to bring them more in line with what would be expected in a company of this nature undertaking the activities that it does. This, together with the work programme set out in a report also considered by the Board at the same meeting, indicates that there is likely to be no reduction in the volume and importance of the work undertaken by the Full Board. Indeed, should the Full Board choose, it could find itself with more work as it will have the opportunity to consider issues that it considers important in greater depth than is currently possible.

10. Overall, it should also be recalled that the activities of the Management Committee will be limited by the company’s Annual Business Plan which, in accordance with the schedule of reserved matters, will be approved by the Full Board for submission to a General Meeting of the company for consideration by the Executive in its role as shareholder. The Full Board will be involved in the development of the Annual Business Plan and that plan will need to be consistent with the strategic direction of the company as determined by the Full Board.

The Current Position 11. The Board of Directors of LLAL is currently made up wholly of Members of the Council, nine in total of which six are from the majority group, two from the larger of the minority groups (these seats are currently vacant) and one from the smaller minority group. In addition, there are two advisory members who are not directors but bring an external perspective to bear on matters.

12. It is uncommon for limited companies to have a Board wholly made up of non- executive directors, by which is meant those directors that have no responsibility for the operational management of the company. It is notable in this respect that the Board of the Council’s other leading wholly-owned company, Foxhall Homes Limited, is a mix of executive and non-executive directors.

13. Moreover, it is customary in limited companies for the non-executive directors to be, to as great a degree as is practically possible, independent in order that they may give objective advice to the Board free of any potential conflict of interest. As all of the directors of LLAL are Members of the Council they cannot, within the sense given to that term by the UK Corporate Governance Code, be considered independent.

14. On the other hand, if LLAL is to achieve its aim of being seen as the UK’s leading community airport, it is essential that it retains the core values and outlook that being a publicly-owned airport company brings to the way in which LLAL conducts its business. To that extent, the involvement of Members of the Council in the governance of the company is an essential component.

Goals and Objectives 15. The object of this governance review is to equip the company with the skills and structure needed at the present time to ensure a successful recovery and to meet the requirements of the stabilisation framework.

Proposal 16. The detailed proposals for change are set out in the schedule attached at Appendix A. In developing these proposals due regard has been given to the guidance set out in

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the Code of Practice on the Governance of Council Interests in Companies prepared by Lawyers in Local Government and to the lessons learned as set out in the Grant Thornton report “Nottingham City Council – Report in the public interest on the Council’s governance arrangements for Robin Hood Energy Ltd.”

17. It is proposed to retain and expand the existing unitary Board structure and to establish a Management Committee of that Board dealing with the day-to-day tactical operational decisions with the Full Board setting strategy, approving the company’s policy framework and annual Business Plan and having a number of matters reserved to it. These reserved matters are set out at Annex A to Appendix A.

18. It must be recognised that, in law, all directors, whether sitting on the Full Board or Management Committee, are accountable for all decisions made by the company. Effective communication between Board and Committee is essential.

19. The creation of the Management Committee is intended to enable key operational decisions to be made more quickly. It is also designed to undertake a co-ordinating role across all areas of LLAL business. It will consist of executive directors – those senior officers of the Council dedicated to supporting LLAL – and the independent non-executive directors. The introduction of constructive challenge and industry insight in the form of the independent non-executive directors will help to increase the robustness and resilience of the company’s business decisions, whilst providing those who manage the company with valuable knowledge and the benefit of their experience.

20. The Full Board will focus on setting the strategy of the business and holding the Management Committee to account for the delivery of the Annual Business Plan that the Full Board has approved. The continued involvement of Council Members at strategic and policy level will ensure that the company retains its public sector ethos and substantially reduces the risk of conflicts of interest that could arise in relation to operational matters. It is legitimate, given the objectives of the company in terms of maximising social impact, to consider the broader interests that are of concern to Members when developing the company’s corporate strategy.

21. Transitional arrangements will be in place until such time as the full complement of officers referred to at point 10 of Appendix A and the non-Executive Directors have been appointed. During this time, the Board will continue to function in its usual fashion but with the addition of the Corporate Director, Airport and Service Director, LLAL as directors.

22. It is also proposed, as part of the process of clearly demarcating the functions of the Council as shareholder and of the company, that the Council should relinquish its nominal responsibility as Company Secretary to enable that function to be carried out by the executive director with responsibility for governance.

23. It is important to stress that none of these proposals diminishes in any way either the influence that the Council can exercise over the strategic direction of the company or the control it retains as sole shareholder. The first comes through the continued involvement of Members of the Council on the Full Board; the second, through the shareholder’s rights in the Articles of Association and the Companies Act 2006.

24. Article 4, in particular, sets out the provisions that enable the shareholder to restrict the powers of directors and to limit the business activities of the company to only

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those that have been approved by the shareholder at a general meeting of the company. Furthermore, Article 5 states that the shareholder may, by special resolution at a general meeting, direct the directors to take, or refrain from taking, specified action. As the Council is sole shareholder it will always be able to determine the outcome of a general meeting of the company, and it is, virtue of section 303 of the Companies Act, able to require the directors to call a general meeting. Whilst these powers should be used sparingly, they are available to the shareholder if necessary.

Key Risks 25. Where functions are delegated to a committee of the Board there is a risk in directors on the Full Board, for example, being held liable for decisions made by the Management Committee. It is proposed to mitigate this risk in a number of ways: by ensuring that all directors are, before the event, equally aware of matters being considered by either Board or Committee, by providing for frequent meetings between the Chairs of the Board and Committee and by giving members of the Full Board the opportunity to “call-in” decisions of the Management Committee.

Consultations 26. The proposals have been considered and broadly supported by the LLAL Board and have been informally consulted on with the Council as shareholder.

Alternative options considered and rejected (please specify) 27. A first option is to maintain the current governance arrangements with no change whatsoever. This was rejected as it would not meet the requirements of the “framework for stabilisation”.

28. A second option is to maintain the Board of LLAL as it is currently constituted with the addition of independent non-executive directors. This was rejected on the basis that it would not resolve the risk of, and potential for, conflicts of interest in operational matters between the role of the members of the Board as directors and as councillors or to give the appropriate degree of distance. It would also not resolve the issue of the senior officers supporting the company being de facto directors.

Appendices Attached 29. Appendix A – Schedule of proposed changes to governance arrangements.

30. Annex A to Appendix A – Schedule of Matters Reserved to the Full Board

List of Background Papers - Local Government Act 1972, Section 100D 31. Public interest report - Nottingham City Council

32. The Governance of Council Interests in Companies – Code of Practice (available from Mark Turner, Service Director, LLAL & Monitoring Officer)

Implications - an appropriate officer must clear all statements

For CLMT only Legal and Finance are required Required

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Item Details Clearance Dated Agreed By Legal The legal implications are covered in the body Raj Popat, 2nd August of the report. Principal 2021 Solicitor Finance There are no direct financial implications for the Dev Gopal, 3 August Council. It is expected that the independent Service 2021 non-executive directors required by the Director “framework for stabilisation” will be paid for (Finance, their services. This will be a cost to LLAL. Revenues & Benefits) Equalities / As this report refers to matters affecting LLAL, Maureen 8 June 2021 Cohesion / which is not subject to the Public Sector Drummond, Inclusion Equality Duty, the Council’s Legal Service has Equality and (Social advised that an IIA is not required. It will be Diversity Justice) noted, in any case, that the report refers to Adviser administrative matters. Environment There are no environment implications to this Shaun 7th June report. Askins – 2021 Service Manager – Strategy & Sustainability Health There are no health implications to this report. Sally 9.6.21 Cartwright – Interim Director of Public Health

Optional Item Details Clearance Dated Agreed By Community Safety Staffing

Other

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Schedule of proposed changes to governance arrangements

LLAL Governance

LLAL will adopt a unitary Board structure comprising the Full Board giving strategic direction and a Management Committee dealing with tactical and operational matters.

The Full Board

1. Will consist of up to nine members of the Council (six from the majority Group, two from the larger minority group and one from the smaller, varied from time to time according to the political balance of the Council). 2. The full Board will also include the three executive directors and independent non-executive directors making up the Management Committee. 3. The Full Board will decide whether or not it wishes to appoint advisory members. 4. All directors will be appointed by the Council (acting by the Executive) as shareholder in accordance with the Articles of Association of the company. 5. The Chair of the Full Board shall not be a member of the Council’s Executive. 6. The Full Board will be responsible for exercising powers in relation to the matters reserved to it as defined at Annex A). 7. The Full Board shall provide the Annual Business Plan to the Executive of the Council, acting as shareholder, to enable it to decide how it shall instruct the Chief Executive, as the shareholder’s representative to vote upon it at a General Meeting called for the purpose of adopting the Annual Business Plan. 8. Shall meet at least quarterly (and more frequently if required). 9. The shareholder’s representative (being the Chief Executive of the Council) may attend as an observer but shall only participate if invited to do so by the Chair. 10. Where, outside the scope of the Annual Business Plan, matters of interest within the remit of the Council’s section 151 officer are to be discussed, (s)he shall be invited to attend the meeting as an observer but shall only participate if invited to do so by the Chair. 11. It should be noted that following the review by the Council of its own arrangements in respect of discharging its rights and obligations as shareholder, further granting of observer status may be considered. 12. The Full Board may, and is recommended to, establish Committees to maintain detailed supervision of key elements of the company’s business. It is suggested that these, in the first instance in addition to the Management Committee, should be an Audit Committee and a Sustainability and Social Responsibility Committee. No member of the Management Committee shall serve on the Audit Committee.

The Management Committee

13. Will consist of three executive directors being the Chief Executive Officer of LLAL, Service Director (LLAL) and Finance Director (LLAL) plus up to three independent non-executive directors. 14. All directors will be appointed by the Council, either through their role with the Council or by selection in the case of the non-executive directors. 15. It is expected that the independent non-executive directors will be paid for their services. 16. The Management Committee will meet monthly. 17. The Management Committee shall exercise all the powers of the company under the Articles except in relation to matters that are specifically reserved to the Full Board.

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18. The Chair of the Management Committee shall be the Chief Executive Officer. The Vice-Chair of the Management Committee shall be the Service Director. 19. The shareholder’s representative (being the Chief Executive of the Council) may attend as an observer but shall only participate if invited to do so by the Chair. 20. The shareholder’s representative shall receive regular briefings at one-to-one meetings with the Chief Executive Officer of LLAL.

Liaison between the Board and the Committee

21. The Chairs of the Board and Committee shall meet at least fortnightly (if not more regularly). 22. Management Committee agenda and papers shall be sent to the members of the Full Board including those who are not members of the Management Committee. 23. Decisions of the Management Committee (in the form of an abbreviated Decisions sheet) shall be circulated to all members of the Full Board within three working days of the meeting. 24. The “call-in” process will apply. Unless the decision is exempt, any member of the Full Board (other than those who are members of the Management Committee) may, within five working days of the decision being published and with the consent of the Chair of the Full Board, ask for a decision to be “called-in” giving reasons for doing so, which shall then be considered at either the next scheduled meeting or a specially convened meeting of the Full Board, depending on the urgency with which the matter must be dealt. The Full Board may confirm the decision of the Management Committee or ask the Management Committee to review it. The Company Secretary will prepare detailed guidelines on the “call-in” process. 25. The Management Committee shall submit a quarterly report, including financial and performance information, to each ordinary meeting of the Full Board.

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Appendix A – Annex A Schedule of Matters Reserved to the Full Board

1. Strategy and Management

a. Responsibility for the overall leadership of the company and setting the company’s values and standards. b. Approval of the company’s strategic aims and objectives. c. Recommendation of the annual Business Plan to a general meeting of the company d. Approval of the annual operating income and expenditure budget and capital investment programme and any material* changes to them. e. Oversight of the company’s operations. f. Review of performance in the light of the company’s strategic aims, objectives, business plans and budgets and ensuring any necessary corrective action is taken. g. Extension of the company’s activities into new business or geographic areas. h. Any decision to cease to operate all or any material part of the company’s business.

2. Structure and Capital

a. Changes relating to the company’s capital structure including reduction of capital, shares issues and share buy backs. b. Major changes to the company’s corporate structure, including, but not limited to, the acquisition or disposal of shares. c. Changes to the company’s management and control structure.

3. Financial Reporting and Controls

a. Approval of the annual report and accounts. b. Approval of the dividend policy. c. Approval of any significant changes in accounting policies or practices. d. Approval of treasury policies. e. Approval of unbudgeted capital or operating expenditure.

4. Internal Controls

a. Ensuring the maintenance of a sound system of internal control and risk management. b. Reviewing the effectiveness of the company’s risk and control processes to support its strategy and objectives.

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5. Contracts

a. Approval of major capital projects. b. Letting of any contracts, valued in excess of £5m required in order to deliver any aspect of the company’s Business Plan. c. Procurement and letting of any contracts, of whatever value, in relation to matters not included in the company’s Business Plan. d. Major investments. e. Approval of the acquisition or disposal of fixed assets (including intangible assets) valued in excess of £500,000.

6. Board Membership and other appointments

a. Recommending changes to the structure, size and composition of the Full Board for consideration by the shareholder. b. Selection of the Chair of the Full Board. c. Appointment of members of Full Board committees except that of the Management Committee which is determined by function. d. Appointment or removal of the company secretary. e. Appointment or removal of the external auditor to be put to shareholders for approval in general meeting (and reappointment should the elective resolution for automatic reappointment lapse). f. Appointments to boards of subsidiaries (on an interim basis or for the purposes of incorporation).

7. Delegation of authority

a. Approval of Schemes of Delegation recommended by the Management Committee. b. Establishing Full Board Committees and approving their terms of reference, and approving material changes thereto. c. Receiving reports from Full Board Committees on their activities.

8. Corporate governance matters

a. Undertaking a formal and rigorous annual review of its own performance, that of its committees and individual directors, and the division of responsibilities. b. Considering the balance of interests between shareholders, stakeholders and the community. c. Review of the company’s overall corporate governance arrangements. d. Authorising conflicts of interest where permitted to do so. e. Approval of policies. f. Overview and monitoring of the company’s Corporate Social Responsibility programme.

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Item No: 9 Report For: Executive Date of Meeting: 16 August 2021 Report Of: Dev Gopal, Director of Finance, Revenues & Benefits Report Author: Tim Lee, Principal Accountant Subject: Revenue and Capital Budget Monitoring – Quarter 1 2021/22 Lead Executive Member(s): Councillor Malcolm Wards Affected: Click here to enter text. Consultations: Councillors ☐ Scrutiny ☐ Stakeholders ☐ Others ☐

Recommendations 1. Executive is recommended to:

i) note the net forecast revenue budget overspend of £1.802m reported at the first Quarter’s monitoring for the current year, after applying savings contingencies and some one-off gains.

ii) note the current shortfall on delivery of the savings programme and the need for actions to further improve this and enable the release the savings contingencies for future budget planning.

iii) note the current financial impacts of coronavirus and the potential longer term cost risks. iv) note the current forecasts for the Housing Revenue, Public Health and Schools budgets.

v) note the earlier provision of debenture loans from within the current capital programme, which increases capital spend for the current year.

vi) approve a cost neutral amendment to the budget, for posts approved by Administration & Regulation Committee resulting from the increased take-up of green waste collection.

Background 2. The General Fund Budget position continues to be extremely challenging with a significant shortfall in the delivery of the current savings programme, continued cost pressures on core demand-led services and the ongoing cost impacts from coronavirus.

3. Grant funding for the costs of coronavirus is currently only confirmed for Q1 of 2021/22, with £6.7m of general funding already included in the Budget, This is supplemented by partial compensation of the fees and charges shortfalls identified during the year, also just confirmed for Q1 currently.

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The Current Position 4. The Quarter 1 monitoring of General Fund services forecasts a net over spend of £1.802m. This the net impact after use of available grant funding for coronavirus costs, the use of delivery contingencies to mitigate the current shortfalls reported in the savings programme and some gains in the corporate resource accounts relating to borrowing costs. The underlying position is analysed below showing the gross service pressures and current compensating variations:

General Fund Services at Q1 Core Services Coronavirus (incl. unmet Impacts met Coronavirus from Grant costs & income)

Gross Service Pressures incl. Cumulative Saving Shortfalls £13.374m £5.455m Use of Savings Delivery Contingencies (para. 4e) -£5.512m Savings Contingency Released & Re-used (para. 4e) -£3.468m Net Service Pressures After Use of Contingency £4.394m Use of £6.7m Coronavirus General Grant (para. 6a) (£6.7m) -£1.749m -£4.947m Grant for Coronavirus SFC Income Losses (para. 6b) -£0.074m -£0.508m NJC Employee Pay Award Offer (para. 4f) £1.241m Reduction in Borrowing Costs (para. 4f) -£2.010m Net General Fund Overspend at Q1 £1.802m £0.000m

Original General Contingency Approved for 2021/22 -£2.251m

5. Sufficient general contingency cover is available within this year’s approved budget to cover the current net overspend of £1.802m.

6. The largest elements within £13.374m gross service pressures are:

 Current Savings Programme Shortfalls £8.418m  Temporary Accommodation for Homelessness (excl. savings shortfall) £0.710m  Children’s Care Placements (excl. savings shortfall) £1.049m  Waste Disposal £0.450m  Revenues Recovery Fees £0.822m

 Preservation House for CPAR (options are being explored) £1.140m

7. All costs and income losses currently reported for the impacts of coronavirus are fully covered by the combined income available from the £6.696m general grant and the partial reimbursement grant available from the Scales, Fees & Charges compensation scheme.

8. Appendix A shows the Q1 consolidated Budget Summary for the General Fund, Public Health, HRA and Schools accounts.

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9. Appendices B to E of this report provide a more detailed statement of each department’s forecast position, including the main variations reported to-date across each service directorate.

10. Main GF Budget Variations at Period 3 – Core Budget (non-coronavirus):

General Fund Departments Current Core Service Budget Variations at £’000 Q1 £’000 Airport -22 0 Chief Executive’s 10,494 994 Children Families & Education 58,937 -379 Inclusive Economy 43,461 4,139 Population Wellbeing 58,339 -359 Total General Fund Services 171,209 4,394

11. Chief Executives Department – £0.994m net overspend (Appendix B), primarily relating to:

 shortfalls in the revenues team enforcement fee income of £0.882m (gross) relating to collection of outstanding income for ASC and other services, part compensated by £0.250m of delivery contingency. Plus £0.132m of increased costs of on purchased recovery measures that should generate future income benefits from the collection fund.

 An overspend of £0.100m on finance employee costs due to the current increased workload and the use of agency staff in advance of filling key posts in the division.

 £0.031m net reduction in income across legal services, sponsorship and from community centres after partial compensation from the sales fees & charges grant.

12. Children, Families Education a -£0.379m net underspend (Appendix C).

 Education services: 0.191m net overspend, primarily relating to a reduction in trading income (OCA pending) and unachievable staff turnover targets.

 Statutory Social Work, Early Help & Prevention – a net overspend of £0.912m: i) Children’s care continues to be the largest cost pressure with an overspend of £1.676m reported at Q1, primarily on fostering costs £0.818m and 16+ leaving care costs £0.913m. 715(fte) children were supported in June, a reduction of 28 compared to the position at March ’21 (-25 LAC, -18 SGO, residence & adoption and +15 care for children aged 18+ incl. unaccompanied asylum children), but the combined cost pressures of overall care remain higher than budgeted. The overspend in the directorate is being partly mitigated by the use of additional grant funding provided for the Luton Family Partnership Service.

 Quality Improvement & Practice Innovation – a net underspend of 0.073m relating to minor variations across the directorate.

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 Central Budgets for the Department - £0.948m of the department’s savings delivery contingency is currently being used to mitigate the forecast savings shortfalls at Q1. A further £0.495m is also being released as the savings have been delivered. This fully offsets the current reported pressures for the department, resulting in a net forecast underspend at Q1

13. Inclusive Economy - £4.139m net overspend (Appendix D).  Customer & Organisational Development £0.642m overspend, relating to unachieved prior year savings on IT costs and for trading income in strategic change, plus unachievable income following the change of the agency staff contract. There are also increased IT costs for telephony & conferencing and on the iTrent HR system.

 Inclusive Growth - £0.077m overspend relating an unachievable income target in procurement, due to revised purchasing arrangements

 Property & Infrastructure £4.202m overspend, including: £1.65m for the unachieved saving to rationalise the leisure, community & culture estate, £1.140m of annual costs following the purchase of preservation house for the first stage of the Century Park Access Road (CPAR), £0.915m for unachieved savings on highways maintenance, £0.211m unachieved saving on concessionary fares, £0.150m of increased cost on traffic signals and road markings, £0.158m of unachievable fee income from CPAR; partly offset by £0.384m of reduced cost on street lighting energy costs.

 Neighbourhood Services £0.724m overspend:, including £0.170m for repairs to the cremator furnace and skip hire for the removal of excess soil, £0.116m for rates costs on car parks, plus a £250k projected shortfall in income at the crematorium.

 Sustainable Development £0.712m overspend: £0.374m of reduced income from transport and PTU trading, building regulations and waste charges. A £0.450m overspend on waste disposal costs due to higher waste volumes and increased amounts sent to landfill. Partly mitigated by a £0.122m underspend in the Local Plan budget.

 Savings Delivery Contingencies, £2.203m of the contingency is being used at this forecast to mitigate the current savings shortfalls across the department and £0.055m is released, reducing the net overspend for the department to £4.139m at Q1.

 The introduction of charging for green waste collection has been very successful and the income target has been overachieved £0.425m. However, the level of take up by households means that more collection staff have had to be employed to meet demand (7fte staff for 2 crews: £0.320m incl. support costs) with the cost covered by the ring-fenced income. In addition, as expected when the original proposal was made, there has been an increase in fly tipping of green waste and to counter this problem, part of the income received has been utilised to create a fly tipping response crew (3fte staff £0.080m).

 Preservation House: The leasehold acquisition of the property was approved by the Executive in August 2019, to secure the site for the proposed construction

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of Century Park Access Road (CPAR) Phase 1. The business case for CPAR is still in development. However, the Council was legally committed to acquire the site and it has been purchased for £3.2m. A cost of £1.140m is included in the Q1 monitoring for the initial capital financing charges, annual rental charge, business rates and security on the property. A tenant is being sought for the building on a short term basis, to partly offset the costs being incurred. The acquisition of the freehold and financing options is being looked in to, linked to developments with the CPAR project.

14. Population Wellbeing a -£0.359m net underspend (Appendix E).

 Housing £2.201m overspend on homelessness costs including repair & maintenance costs on temporary accommodation properties and a shortfall in rent income collected compared to the budget, including the £0.973m savings target currently set for the service. An invest to save proposal is in development to work on reducing the overspend.

 Adult Social Care £1.196m net overspend including: £0.988m of increased purchased care cost due to NHS hospital discharge funding ceasing from October 2021 and £0.911m for in-house provider services mainly due to unachievable savings on day-care transport. This is being partly offset by a £0.525m underspend on staffing due to vacancies.

 Population Health £0.035m net overspend relating to: £0.120m unachieved saving on the ELFT mental health contract and a £0.073m reduction in traded income with schools. Largely offset by an underspend on staffing mainly for the business intelligence growth posts that are not yet filled.

 Savings Delivery Contingencies: £2.616m is currently being used to mitigate the current savings shortfalls reported for the department and £1.194m is also being released as the savings have been delivered, more than offsetting the overspends reported across the department.

15. Total Budget Savings Programme and Use of Contingencies (Appendix F)

The budget savings programme over the past 3 years totals £38.605m, including the increases needed at the 2020/21 Emergency Budget. The amount of savings delivered over the last three years to date is £30.2m which represents 78% of total savings target. This has been an extremely challenging target to deliver, alongside the measures needed to support the community and business during the pandemic.

The gross savings targets are supported by short-term contingencies to phase the delivery of each year’s programme over a 2 year period. Further support has also been available last year and this year from the grant funding provided by the Government to meet the impacts of coronavirus; helping to meet the delays in delivery of the savings resulting from the lockdowns and wider restrictions.

The timely and full delivery of each year’s savings programme remains crucial to the longer term sustainability of the Council’s budget position. 2 of the years are still within the original timeframes, but some 2019/20 savings are still to be delivered during 2021/22. Further progress has been made on these (£7.5m was outstanding at the start of 2020/21), but £3.999m of this is not yet secured and continues to pressure this year’s forecast outturn position.

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Analysis of the gross and net position on the savings programme for 2019/20 to 2021/22 is provided in the table below.

2019/20 2020/21 2021/22 Total Total Savings Programme £15.817m £16.899m £5.889m £38.605m Delivered to Date £11.818m £15.328m £3.041m £30.151m Gross Forecast Shortfalls Q1 £3.999m £1.571m £2.848m £8.418m Use of Delivery Contingency -£1.971m -£1.265m -£2.276m -£5.512m Net Impact on Q1 Forecast £2.028m £0.306 £0.572m £2.906m

16. Appendix E provides further details on £13.428m of specific projects being monitored this year, due to estimated risks on timing or delivery at the start of the year. A significant number of these are currently forecasting some shortfall, resulting in a gross pressure of £8.418m at the Q1 forecast. This reduces to a £2.906m final net cost this year after the use of available delivery contingency cover, but it must be noted that this cover is only short-term and needs to be phased out of the budget for future years.

17. A further £3.468m of contingency cover has been released at this forecast as the savings have now been delivered. This is being used to offset the wider cost pressures reported across services, reducing the net overspend position across the General Fund.

18. Corporate Level Budget Variations – a net underspend of -£0.769m is reported in the corporate resource accounts at Q1, this includes:

 A £2.010m forecast reduction in borrowing costs for 2020/21. This results from the cumulative effect from using short-term borrowing at historically low interest rates, reduced cumulative borrowing up to Q1 and lower interest rates on the PWLB borrowing drawn-down since March 2021.

 A forecast increase of £1.241m in employee costs across the Council resulting from the draft NJC Pay Offer for 2021/22. The budget for 2021/22 included a minimal increase for the pay award, due to the expected public sector pay restraints announced by the Government toward the end of 2020. Following negotiations, the pay offer received in May is for a 1.5% increase across all NJC pay grades. This higher than budgeted, resulting in a further £1.241m of pay cost for general fund services. The pay offer has not yet been accepted and the forecast cost therefore remains provisional pending the final settlement.

Other Funds – Period 2 Forecast

19. Public Health – The budget for the current year is £15.380m, fully funded by the ring- fenced Public Health Grant. A net underspend of £0.354m is reported on core public health activity at Q1, due to lower spend on some activity based health contracts. Some additional specific grants have also been received this year to further support this year’s health programme. Further information is provided at Appendix E.

20. Housing Revenue Account – The HRA budget for the current year is set with a surplus and contribution to balances of £1.651m, in line with the current business plan, including the requirement to support the 2020/21 HRA capital programme from revenue resources.

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A net underspend of £0.537m is reported at Q1, increasing the potential contribution to balances to £2.251m, pending the final requirement to support capital spend in 2021/22.

21. The forecast underspend mainly results from a £0.600m underspend on the repairs programme resulting from disruptions cause by coronavirus, staffing vacancies and material shortages from suppliers. This is partly offset by a small increase in wider staffing costs and a marginal increase in the provision for bad debts. Further information is provided at Appendix E.

22. Schools Budget – The budget for the current year totals £162.984m, fully funded by the Dedicated Schools Grant. A net underspend of £0.582m is forecast in the central schools budget at Q1, relating to:

 A £0.499m underspend on the high needs block relating to reduced top-up funding (less placements) and lower levels of alternative learning provision.

 £0.083m underspend on the central provisions block due to staff vacancies and release of an unallocated contingency budget.

Further information is provided at Appendix C.

General Coronavirus Funding and Costs & Income Losses at Period 2

23. £6.696m of general grant support has been provided to meet the continuing costs of coronavirus and this is built in to the original budget approved for 2021/22. The support covers the Governments estimate of funding needed for Q1 of the current year, but use of the grant will be ongoing to meet costs beyond Q1.

There is no certainty at present if any further general grant support will be provided beyond Q1. The grant is fully used within the Q1 forecast to meet:  £1.964m of coronavirus of costs, related to service bids to enhance support to the community during the pandemic  £3.604m of uncompensated losses on sales fees and charges income and commercial income  £1.128m to partially meet the delayed implementation of planned savings

24. The Sales Fees & Charges income compensation grant is also only confirmed for income losses incurred over Quarter 1 of the current year. At present £0.582m of grant is expected from this against net forecast income losses totalling £3.087m at Q1. This gap is currently being met from the capacity within the £6.696m of general grant funding.

25. It must however be noted that the Q1 forecast is just an early projection of this year’s cost pressures and income losses and remains vulnerable to ongoing developments with the virus locally and nationally and to the full economic and social impacts of the virus materialising over the longer term.

Ring-fenced Grant Funding for Coronavirus

26. Significant ring-fenced grant funding has been provided by the Government to continue with the virus counter measures and specific support needed by the local community for the current year. This includes new funding for 2021/22 and unused funding brought

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forward from 2020/21, as required by the grant conditions. To date, the funding available this year includes:

New B/F  Contain Outbreak Management Fund £1.728m £5.676m  Infection Prevention Control & Rapid Test – Adult Care £1.675m  Covid Winter Grant & Covid Local Support Grant £1.117m  Test & Trace Support Payment, LA Practical Support £0.486m £0.420m  Welcome Back Fund £0.187m  Additional Home to School/College Transport £0.163m  Administration & Delivery Grants £0.478m  Clinically Extremely Vulnerable £0.881m £5.834m £6.977m

27. The vaccination programme is continuing to be rolled out across the community. At 30th June 2021:  56.7% of the 16+ population have now received the first vaccination and 38.6% have also received the second vaccination  157,000 individuals have been tested representing 73.7% of the local population, of which 14% have tested positive.  569 deaths have been reported since the start of the pandemic

28. The grant funding will continue to be used to support the full range of measures needed to control and reduce infections, enhance wider public safety and support those most vulnerable to and most impacted by the virus.

Capital Budget Monitoring at Quarter 1

29. The Base Budget for the 2021/22 Capital Programme was approved at £131.038 million: £106.403 million for the General Fund and £24.635 million for the Housing Revenue Account. The Revised Capital Programme for 2021/22 reflects the slippage brought forward from the final outturn position in 2020/21: £186.223 million, £158.065 million for General Fund and £28.158 million for the HRA.

30. The Q1 update forecasts spend at £204.621 million: £178.007 million for General Fund and £26.614 million for the HRA, a cumulative increase in spend of £18.398 million. The table below summarises the change by Department compared with the Base Budget.

Revised Variance 2021/22 Revised Budget to Original Annual 2021/22 Programme Summary by incl. Revised Base Forecast Department Slippage/ Budget at Budget at Q1 Advances Q1 £m £m £m £m Inclusive Economy 36.934 45.390 42.721 -2.669 Children, Families & Education 11.363 13.992 16.629 2.637 Population & Wellbeing 2.745 15.654 15.654 0.000 Total General Fund Service Projects 51.042 75.036 75.004 -0.032 Corporate Projects 55.361 83.029 103.003 19.974 Total General Fund Programme 106.403 158.065 178.007 19.942 Housing Revenue Account 24.635 28.158 26.614 -1.544 Total LBC Capital Programme 131.038 186.223 204.621 18.398

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31. The main reasons for the £18.398 million net change in forecast expenditure are:

 £19.974m of earlier drawdown on Debenture Loans for LLAL (advanced form future years)

 £1.917 million of additional highways maintenance expenditure, fully funded by LTP grant

 £1.435 million of additional expenditure on school maintenance fully funded from the Schools’ Conditional Grant funding allocation.

 -£2.455m of net spend re-profiled to 2022/23 budget allocation across several projects

 -£2.500 million of reduced cost for the Vale Cemetery Extension in line with current forecast spend for the project

Q1 Capital Spend and Budgets

32. As at 30th June 2021, actual capital expenditure incurred or committed (excluding corporate projects) is £11.785 million, around 46% of the profiled spend forecast provided by budget holders at Q1. Spend on the corporate projects at Q1 is around 35%. It is recognised that there is a timing delay in terms of invoices being paid, but the profile of projects needs to be improved to aid overall assessment of the full financial implications, including the revenue implications of the forecast capital spend. Capital budget holders will continue to be challenged on their forecasts throughout the year.

Spent/ % of Profiled Var. to Annual Commi Q1 Forecast Budget Forecast Spend and Forecast at Quarter 1 by tted at Budget for Q1 at Q1 at Q1 Department Q1 Spent £m £m £m £m Inclusive Economy 11.348 4.325 -6.447 38.1% 42.721 Children, Families & Education 3.498 1.315 -2.183 37.6% 16.629 Population & Wellbeing 3.914 1.036 -2.878 26.4% 15.654

Total General Fund Service Projects 18.760 6.676 -12.084 35.5% 75.004 Corporate Projects 20.757 7.186 -13.571 34.6% 105.766 Total General Fund Programme 39.517 13.862 -25.655 35.1% 180.770 Housing Revenue Account 7.040 5.109 -1.931 72.6% 26.614 Total LBC Capital Programme 46.557 18.971 -27.586 40.7% 207.384

33. The capital programme has been updated at Q1 following the receipt of the latest LLAL Medium Term Financial Plan and the Foxhall Homes Business Plan.

34. LLAL’s current investment plan in the DART, DCO, Bartlett Square and CPAR forecasts spend of £89.475 million for 2021/22.

Capital Financing Summary

35. The table below summarises the capital financing for 2021/22 following the expenditure forecasts reported at Q1.

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Updated Summary of Resources for Financing Capital Programme Expenditure 2020/21 Budget Q1 £m General Fund Financing Grants & Contributions 26.893 Revenue Reserves/Budget 0.000 Capital Receipts RCCO in Place of Dividend/Corporate Contribution 5.053 Corporate Projects Borrowing 105.766 GF Borrowing Requirement 43.058 Total General Fund Programme 180.770 HRA Financing 1-4-1 Capital Receipts Other Capital Receipts 10.876 Earmarked Revenue Reserve Major Repairs Reserve 15.738 HRA Borrowing Requirement Total Housing Revenue Account 26.614 Total LBC Capital Programme 207.384

Goals and Objectives

36. To advise the latest financial performance to Budget for 2021/22.

Proposal 37. To note the Quarter 1 forecast position for 2021/22 and to further develop departmental action plans to return the budget to a balanced position.

In particular, to focus on the savings that are not currently delivering against the original timescales and reduce the current shortfall, to assist the current net forecast overspend for 2021/22 and the overall prospects for the forthcoming 2022/23 Budget.

Key Risks 38. Main Revenue Budget Risks:

 Delivering the full savings programme included in the 2021/22 budget.

 Managing in-year cost pressures, including those reported in volatile and demand led statutory service budgets, to deliver a balanced outturn position and demonstrate value for money on service delivery.

 Managing the continued developments and impacts from the coronavirus. In particular the longer term impacts expected on reduced income levels after the compensation arrangements cease.

 The continued development of procurement & commissioning activity to support the plans to deliver the savings required for future Budgets.

Consultations 39. None.

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Alternative options considered and rejected (please specify)

40. The executive can accept, reject of amend the report.

Appendices Attached 41. Appendix A – Revenue Budget Summary, Q1 Forecast Appendix B – Chief Executive’s Department Q1 Forecast Appendix C – Children, Families & Education Department Q1 Forecast Appendix D – Inclusive Economy Department Q1 Forecast Appendix E – Population Wellbeing Department Q1 Forecast Appendix F – Budget Savings Monitoring at Q1 Appendix G – Volatile Budget Monitoring at Q1

List of Background Papers

42. There are no background papers to the report.

Implications - an appropriate officer must clear all statements

Required

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Item Details Clearance Dated Agreed By

Legal The Council is required by section 151 of the Michael 3rd August Local Government Act 1972 to make Pearson, 2021 arrangements for the proper administration of its Solicitor financial affairs. The Council’s Service Director for Finance, Revenues & Benefits is required to establish financial procedures to ensure the Council’s proper financial administration. These include procedures for budgetary control. It is consistent with these arrangements for Executive to receive information about the revenue and capital budgets as set out in this report.

Section 3 of the Local Government Act 1999 requires the Council as a best value authority to “make arrangements to secure continuous improvement in the way in which its functions are exercised, having regard to a combination of economy, efficiency and effectiveness”. Monitoring of performance information is an important way in which that obligation can be fulfilled.

Finance The financial challenge faced by the Council Dev Gopal, 3rd August continues to be difficult, with a large programme Service 2021 of budget savings to be achieved and continued Director pressures on core demand led services including Finance, children’s care, homelessness, waste disposal Revenues & and strain on income sources. Progress is being Benefits made in most areas, but needs to be improved further in some areas toward eliminating the current forecast overspend and achieve a sustainable balanced outturn position.

The current impacts from coronavirus are included in this report and the longer term position on the Council’s income levels, costs and on the recovery of LLAL are continuing to be closely tracked, to inform future monitoring.

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Item Details Clearance Dated Agreed By

Equalities / There are no direct equalities implications to this Maureen 4 August Cohesion / report. Drummond, 2021 Inclusion Equality and (Social Diversity Justice) Adviser

Environment There are no direct environmental implications to Shaun 3rd August this report. Askins– 2021 Service Manager Strategy & Sustainability

This report does not have any direct health Health implications. Chimeme 4th August Egbutah, 2021 It is however recognised that exceptional actions Public Health continue to be necessary to ensure that measure Service are in place to reduce transmission of Manager coronavirus and this has financial implications. (Healthcare)

Optional

Item Details Clearance Dated Agreed By

Community Safety

Staffing

Other

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Page 56 of 284 Appendix A 2021/22 REVENUE BUDGET MONITORING - QUARTER 1 (based on spend at June '21) Director of Finance, Revenues & Benefits Executive Member: Councillor Malcolm + + Current Forecast Variations to Budget Core % Budget Outturn Core Coronavirus before £'000 £'000 £'000 £'000 internal (+) = cost or overspend / (-) = income or underspend recharges

GENERAL FUND BUDGET SUMMARY General Fund Departments Airport -22 -22 0 0 n/a Chief Executive 10,494 12,758 994 1,270 4.1% Children, Families & Education 58,937 58,888 -379 330 -0.6% Inclusive Economy 43,461 50,739 4,139 1,978 4.6% Population Wellbeing 58,339 59,857 -359 1,877 -0.4% General Coronavirus Support Budget 6,696 0 -1,750 -4,947 SFC Income Loss Compensation Grant 0 -583 -75 -508 Service Costs Sub Total 177,906 181,637 2,571 0 1.4% Other Accounts General Coronavirus Support Grant 21/22 -6,696 -6,697 0 0 0.0% General Budget Contingencies 5,610 5,610 0 0.0% Draft Pay Award (NJC staff) 1,241 1,241 Staff Severance Costs 700 700 0 0.0% Env. Agency Levy & General Grants etc. -9,934 -9,933 0 0.0% Sub Total -10,320 -9,079 1,241 0 Dividend, Interest & Capital Airport Dividend 0 0 Interest on Investments -31,947 -31,947 0 0.0% Capital Financing -10,761 -10,761 0 0.0% Borrowing & Treasury Management 13,415 11,405 -2,010 -15.0% Sub Total -29,292 -31,302 -2,010 0 Net Budget prior to Reserves 138,295 141,256 1,802 0 1.3% Budgets b/f from 20/21 Draft Budgets c/f to 22/23 Contribs. to/from(-) Other Specific Reserves -1,801 -1,801 Net General Fund Total 136,494 139,456 1,802 0 Contribution From (-) or To GF Reserves (+) at Q1 -1,802

PUBLIC HEALTH BUDGET SUMMARY Public Health Services 15,830 15,476 -354 0 -2.2% Public Health Grant -15,830 -15,830 0 0 Net Public Health Total 0 -354 -354 0 Contribution From (-) or To GF Reserves (+) at Q1 354

HOUSING REVENUE ACCOUNT BUDGET SUMMARY HRA Expenditure 38,725 38,188 -537 0 n/a HRA Income -40,376 -40,376 0 0 Revenue Contrib. to support Capital Prog. 0 0 0 0 n/a Net Housing Revenue Account Total -1,651 -2,188 -537 0 Contribution From (-) or To GF Reserves (+) at Q1 537

SCHOOLS BUDGET SUMMARY DSG Central Expenditure 30,543 30,543 0 0 0.0% Individual Schools Budget 132,441 132,441 -582 0 Dedicated Schools Grant Page-162,984 57 of 284-162,984 0 0 Appendix A Schools Net Total 0 0 -582 0 Contribution From (-) or To GF Reserves (+) at Q1 582

Page 58 of 284 Appendix B

Budget Monitoring Report for Chief Executive’s Department – Quarter 1 2021/22

Service Directorate Budget Forecast Variations £'000 % Change £'000 Core Services Covid

Chief Executive Expenditure 5,595 -255 0 -4.6% Income -332 0 0 0.0%

Citizen Engagement & Legal Expenditure 8,231 -17 -75 -0.2% Services Income -5,704 47 555 -0.8%

Finance, Revenues & Expenditure 75,270 762 304 1.0% Benefits Income -72,566 456 485 -0.6%

Total Department 10,495 994 1,270 9.5% Variations met from Covid SFC Compensation Grant -56 Variations met from £6.7m General Covid Grant -12 -1,108 Net Variations not met from Covid Grants 982 106

2021/22 Budget Context & Period 3 Forecast

Core Service Budgets: the 2021/22 budget for the department includes the Housing Benefits Subsidy account which is highly volatile and difficult to predict, particularly during the current economic climate. The budget also includes the Community Centres, which have been severely impacted by Covid-19 in terms of income losses.

The current forecast indicates an overspend of £2.26m for the department, of which £1.3m relates to Covid-19 pressures including loss of income at Community Centres, from Court Summons and Enforcement activity, and additional staff requirements in Finance, Revenues and Benefits. These were also areas impacted by Covid-19 in 2020-21. Further schools have also converted to academies and this will affect the ability of the LMS team to fully recover their costs, although part of the income shortfall will be offset by holding a post vacant.

Budget Savings: the programme for the department this year totals £2,201k, across 12 projects. This includes:  Remaining Targets from 2019/20 £170k  Year 2 Delivery from 2020/21 £380k  New Savings in 2021/22 £1.651m

The current progress against this year’s combined target forecasts that services are on target with the exception of C&C/19/002 Increased Enforcement Income target of £170k, which has been affected by the pandemic, and CE/21/001 Regular financial review of Adult Social Care packages £500k. However, all of the following savings proposals require further work to ensure that they can be fully delivered  CE/21/006 Review of 3rd and 4th tier structures (£150k)  CE/21/005 Legal admin/CE Business support (£30k)  C&C/20/011 Reduction in bank charges from recommissioning (£100k)  C&C/19/002 Increased enforcement income (£170k)  CE/21/001 Regular financial review of Adult Social Care packages (£500k)  C&C/21/001 New Council Tax Reduction scheme for 21/22 (£500k)

Coronavirus Activity & Costs:  Expenditure & Cost Impacts

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o The Accounts Payable team have needed to employ additional temporary staff to address the increase in workload, including audit and compliance requirements. The estimated cost is £31.5k and an Approval Form is in place. o £20k additional costs in due to a Recovery Tool for Revenues & Benefits, for which an Approval Form is in place. o Revenues & Benefits – additional staffing costs of £229k have been reported at Q1. These costs will be covered by New Burdens Grant – hence no net impact at this stage.  Income Losses & Partial Compensation o Community Centres – gross income losses reported of £338k (£279k net after associated cost savings). It is expected that compensation of circa £56k will be claimed against this but this is not included in the above figures. At this stage, it has been assumed that income will start to be received from July and will increase gradually as the year progresses. However, current Government guidance is that they will only provide compensation against income losses related to the first quarter of the year. o Court summons estimated loss of income of £536k due to courts being closed. However, it may be possible to recoup part of this loss if the courts manage to address the backlog when they reopen. No compensation is claimable against this loss. o Estimated loss of enforcement income of £178k as enforcement activity has had to be suspended due to the pandemic. No compensation is claimable against this loss  Specific Grant Funding o Additional New Burden grant of £229k has been received, and income and matching expenditure has been included in the monitoring figures for additional costs, including staffing, in revenues and benefits to administer increased workload resulting from Covid-19.

Service Directorates at Quarter 1

Chief Executive

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 659 0 0 N/A Other Running Expenses 4,936 0 0 N/A External Income -20 0 0 N/A Internal Income -312 0 0 N/A Total 5,263 0 0 Us of Savings Contingency -255 0 Net Position after use of savings contingency -255 0

There are no current forecast variations reported for the directorate. The delivery of savings within the directorate is currently on target, although the comments on savings above indicate that further work will be required in some areas to confirm this position.

Of the delivery contingency held to assist with the phased deliver of current savings targets for the department, the current monitoring forecasts that £255k of this is needed at this stage. However, it is not proposed to release any of the contingency at this stage due to the uncertainty about delivery of some of the savings.

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Citizen Engagement & Legal Services

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 4,770 -69 -64 -1.45% Other Running Expenses 3,461 53 -10 1.52% External Income -1,833 60 373 -3.25% Internal Income -3,871 -12 182 0.31% Total 2,527 31 481 Use of savings contingency 0 0 Net Position after use of savings contingency 31 481

The current forecast variations reported for the directorate include  £372k net loss of sales, fees and charges income in Community Centres due to Covid. This is the current projection for the income loss for the whole year, and will be refined as the year progresses  £11k loss of income in legal services due to the Magistrates Court being closed due to Covid. No compensation can be claimed against this loss.  £29k income loss from sponsorship and advertising due to Covid. No compensation is claimable against this loss.

The delivery of savings within the directorate is currently on target, although the comments on savings above indicate that further work will be required in some areas to confirm this position.

Finance, Revenues & Benefits

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 6,968 288 210 4.14% Other Running Expenses 68,302 474 94 0.69% External Income -62,531 242 485 -0.39% Internal Income -10,035 213 0 -2.13% Total 2,704 1,218 789 Use of savings contingency -255 Net Position after use of savings contingency 963 789

The main forecast variations reported for the directorate under Core Services include  A £440k estimated shortfall in internal income related to recovery of Adult Social Care Debt. There is a £500k budget saving target which is referred to earlier in the report; of this, £250k is currently estimated to be achieved with a delivery plan being developed to identify how the full saving and income target can be achieved. At this stage, the £250k contingency provided in the budget against the saving is being utilised to offset the current shortfall.  £280k forecast overspend on Agency Staff in Corporate Accountancy as temporary contractors fill in ahead of appointing to key posts. Of this, £100k will be recovered through recharges with a further £80k covered by an underspend on salaries.  The cost of the Shared Anti Fraud Service is estimated at £238k, and is included in the Other Running Expenses variance of £474k in the above table. However, these costs will be fully recharged to other Council services and therefore additional income of £238k is included in the Internal Income line above.  Unachieved internal income targets of £382k within the Aged Debt Team and the Billing and Recovery Team. These are historic targets based on being able to recover aged debt owed to the Council. Debt has proven difficult to recover but the service are exploring all options to recover as much debt as possible

Page 61 of 284 Appendix B

 Additional costs of £132k on tracing, insolvency and rates listing projects, all of which will generate income benefits for the Collection Fund, but may also help recover some aged debts. This cost will be fully offset by a contribution from the Collection Fund

The main forecast variations reported for the directorate under Covid-19 include  Court summons estimated loss of income of £536k. The courts have been closed and there is a backlog of hearings to be cleared. However, it may be possible to recoup part of this loss if the courts manage to address the backlog when they reopen. No compensation is claimable against this loss  Estimated loss from Enforcement Income of £178k. Enforcement activity has had to be suspended due to the pandemic. No compensation is claimable against this loss  £75k of additional costs, including additional staffing costs in Accounts Payable and Accountancy team due to an increase in workload, including audit and compliance requirements as a result of Covid, which will all be covered from the £6.7m of emergency funding  £229k of additional costs in Revenues & Benefits due to additional pressures created by Covid which will be covered by New Burdens Grant – hence no net impact at this stage.

The delivery of savings within the directorate is currently on target, with the exception of the achievement of the additional £170k of enforcement income due to the pandemic. The comments on savings above indicate that further work will be required in some areas to confirm this position. In particular, meetings are being held with Adult Social Care Colleagues to agree a delivery plan regarding the £500k income target on CE/21/001.

Corporate Director’s Statement

The net variations of Core Services amounts to £994K. The main reason for this shortfall is as result of a significant drop in the collection of debts which is largely explained by the impact of the pandemic and the closure of the courts which meant recovery processes had to be put on hold during that period.

This shows that not all the losses in fees and charges are fully compensated by central government. Council tax and Business Rates Enforcement Income has reduced as an impact of Covid-19, due to Covid-19 enforcement activity being largely curtailed or ceased altogether. Every effort is being made to start the full recovery process which has been also hampered by an issue with CIVICA ICON. This has been escalated to CIVICA. Some of the costs can be potentially funded from the COVID grant or through the Collection Fund – this will be explored.

Budget Monitoring Report for Airport Department – Quarter 1 2021/22

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 845 0 0 0.00% Other Running Expenses 25 0 0 0.00% External Income -893 0 0 0.00% Internal Income 0 0 0 0.00% Total -23 0 0

2021/22 Budget Context & Period 3 Forecast

The Airport department includes a number of employees who are employed by the Council but who are fully paid for by London Luton Airport Limited.

All costs charged to the department will be fully recharged to LLAL, and no variances have been reported at Q1. No Covid related expenditure has been reported at Q1.

Page 62 of 284 Appendix C

Budget Monitoring Report for Children Families and Education – Quarter 1 2021/22

Service Directorate Budget Forecast Variations (£000's) (£000's) Core Services Covid-19 % Change Expenditure 10,168 107 10 1.1% Education Income (6,615) 84 98 -1.3% Operations, Stat. Social Work, Expenditure 47,096 1,639 0 3.5% Early Help & Prevention Income (8,861) (727) 27 8.2% Quality, Improvement & Practice Expenditure 3,986 (215) 0 -5.4% Innovation Income (969) 143 30 -14.8% Expenditure 18,832 (1,376) 164 -7.3% Department Central Costs Income (4,698) (34) 0 0.7% Total Department (General Fund) 58,938 (379) 330 -0.6% Variations met from Covid SFC Compensation Grant (22) Variations met from £6.7m General Covid Grant (308) Net variations not met from Covid Grants (0) 2021/22 Budget Context & Period 3 Forecast

Core Service Budgets (GF): The 2021/22 budget for the department includes non-schools education services, spend on Looked After Children and Family Support Services. There has been significant growth over a number of years due to the level of need and complexity of care required by families and children in the town and in response to the need to improve the quality of services. Recruitment of quality social care staff has also added to budget pressures. However through significant investment to ensure teams are properly resourced and the creation of a social work academy to help “grow our own” quality workforce, the plan to reduce dependency on expensive agency staff will abate and in turn help with better case management which will in turn reduce the cost of care packages.

The current forecast indicates a net under spend of £379k (gross overspend is £2m before use of savings delivery contingency and government grant) for the department. There continues to be underlying cost pressures with social care packages which is being offset by savings delivery contingencies available in the base budget this year.

An overview of the Children Placement Model shows that the FTE number of Support Nights provided for children is 4% less compared to position at the end of 2020/21, while the average cost per week has increased by 1%. This is resulting in a net impact of 3% reduced overall spend on Children placements projected for 2021/22 at Q1.

Budget Savings: The programme for the department this year totals £3,100k (cumulative). Within this there is a shortfall of £30k against 2021-22 projects and no shortfall against 2020/21 projects. The main shortfall of £1,865k is from the 2019/20 projects across the Luton Families Programme, in respect of placement costs and staffing. The full available contingency of £2,423k will be used to offset these shortfalls and support the department with its wider budget pressures.

Coronavirus Activity & Costs: Expenditure & Cost Impacts is as below:

 £20k additional costs to support schools in particular the continuation of a Covid 19 helpline  £146k net income losses primarily due to reduced trading income  £164k for pending Covid bids still to be appraised and approved. It is anticipated that additional Children’s placement cost resulting from the pandemic will be met from this funding.

Page 63 of 284 Appendix C

Service Directorates at Period 3

Education (Non DSG)

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 5,313 149 20 2.8% Other Running Expenses 4,854 (42) (10) -0.9% Internal Income (2,773) 0.0% External Income (3,842) 84 98 -2.2% Total Service (Gross) 3,552 191 108 5.4% Use of Contingency (15) Total Service (Net) 3,552 176 108 5.0%

The current forecast variations reported for the directorate include:  £149k in relation to unachievable staff turnover savings and additional senior management staffing costs.  £84K under recovery of income primarily due to lack of buy back on traded services and lower levels of grant income expected.  £88k of net income losses is predicted which will be fully offset by the Covid-19 sales, fees and income compensation and general Covid-19 grant.  A further detailed analysis is required to understand the full impact on all trading income achievement post pandemic and its implications to the department and Council budgets in total.

An OCA is currently underway to reduce the staffing establishment to remove posts that have become unviable due to lack of buy back from schools.

£15k of savings contingency is being used to offset the reduced Elective Home Education funding expected. It should be noted that this position needs to be reviewed given the significant demand in the numbers of EHE as a result of the pandemic which had not been predicted at the time of the saving proposal.

Service Director Operations, Statutory Social Work, Early Help & Prevention Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 19,101 (122) -0.6% Other Running Expenses 27,995 1,761 6.3% Internal Income (350) 0 0.0% External Income (8,511) (727) 27 8.5% Total Service (Gross) 38,234 912 27 2.4% Use of Contingency (933) Total Service (Net) 38,234 (21) 27 -0.1%

The current forecast variations reported for the directorate include:  Over spend £1,676k relating to care placements in particular agency foster care placements (£516k), in-house fostering (£302k) and 16+ leaving care (£913k). A retendering exercise for both agency foster care and 16+ supported accommodation has taken place to improve value and outcomes along with the revision of in-house foster care allowance payments implemented from January 2021.  Grant shortfall of £136k in respect of over 18 unaccompanied asylum seeker spend not covered by government grant  Under spend of £122k in staffing spend due to vacancies  Use of £1m troubled families grant to support Luton Family Partnership Service is helping to reduce the overall divisional overspend

Page 64 of 284 Appendix C

 £27k of net income losses for the contact centre is predicted which will be fully offset by the Covid-19 sales, fees and income compensation and general Covid-19 grant.

The delivery of savings within the directorate is currently forecasting a shortfall in the following 2019/20 projects:  £590k Luton Fostering Work stream, however the Q1 Placement model is clearly showing that Internal Foster Carers are increasing while Agency Fostering is reducing.  £1,044k Edge of Care. However cost avoidance of £337k is projected due to the prevention of additional children coming into the care. There could also be a further £132k cost reduction if some planned re- unification takes place on time.  £232k Luton families Workforce programme

Available delivery contingency of £932.70k is being utilised to partly offset these overspends.

Service Director Quality, Improvement & Practice Innovation

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 2,268 (184) 0 -8.1% Other Running Expenses 1,718 (32) 0 -1.9% External Income (969) 143 30 -14.8% Total Service 3,017 (73) 30 -2.4%

The current forecast variations reported for the directorate is made up of underspends on employees primarily within the Youth Offending Service (YOS) but this is being offset by reduced contributions from third parties towards the Youth Offending pooled budget. There is currently no draw down needed in the YOS partnership reserves brought forward from the previous years. An OCA is pending, to ensure the staffing establishment reflects the current activity and funding contributions. There are also minor underspends within supplies and services budgets offsetting income shortfalls in the Integrated Family Partnership Service (IFPS). £30k of net income losses in Nursery rental income is predicted which will be offset by the Covid-19 sales, fees and income compensation and general Covid-19 grant.

Central Budgets for the Department

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 1,671 (27) 0 -1.6% Other Running Expenses 17,161 75 164 0.4% External Income (391) 0 0 0.0% Internal Income (4,307) (34) 0 0.8% Total Service (Gross) 14,134 13 164 0.1% Use of Dept. Contingency (1,423) Total Service (Net) 14,134 (1,410) 164 0.1%

£2,443k of total delivery contingency is held here to assist with the phased deliver of current savings targets for the Luton Families programme. The current monitoring forecasts that £948k of this is needed to cover the current projected shortfall with these savings, although this contingency is held centrally under Corporate Director, for clarity use of these contingencies are also shown against each service directorate summary tables above. It is also to note that further £475k of Contingency to be used to offset further overspends projected across the department. There is also £121k of Covid-19 contingency budget awaiting bids to be appraised and approved.

Page 65 of 284 Appendix C

Dedicated Schools Grant (DSG)

Service Directorate Budget £'000 % Change Forecast Variations £'000 Expenditure 163,589 -582 -0.36% Education Income -162,984 0 Total Department 605 -582

The Schools and Central Education services are directly funded by the ring-fenced Dedicated Schools Grant (DSG). Schools related DSG is driven by a national funding formula and is allocated directly to the schools by the Local authority. Any in-year surpluses or deficits are retained by the schools and reported at the financial year-end accordingly. The Central element of the DSG includes the High Needs Block (HNB), Early Years Block (EYB) and Central Provisions Block (CPB) and any variations are reported on monthly/quarterly basis alongside consultation with the Schools Forum.

At P3, the central DSG is projecting a net underspend of £583k which means there is no call to drawdown on central DSG reserves brought forward from the previous financial years. The main variations at P3 are detailed below:

 HNB is projecting a net underspend of £499k, which includes: o Net underspend of £341k in Top up funding due to less placements expected o Underspend of £100k in commissioning of Alternative Provisions due to of lower activity levels o Release of £127k un-allocated budget £127k held since the start of the year o Overspend of £40k in Hospital Tuition o Overspend of £55k in the start-up cost of new special schools  EYB is not projecting any variances at P3  CPB is projecting a net underspend of £83k, which includes: o £28k in Schools Admissions team due to of vacancies o Release of £55k un-allocated budget held since the start of the year

Corporate Director’s Statement

The local and national context for Children’s Services remains exceptionally challenging .We remain determined to deliver the required improvements in our service offer for our children and young children –this has required system wide investment .There are significant areas of unpredictability and high costs associated with children’s placements that leave our placements budget in deficit position along with our workforce budget. It should be noted that significant work has been undertaken through key work streams including workforce, fostering and commissioning and good progress has been made, but in the context of increased demand and complexity there remains challenges and underlying risks. Without the savings contingency monies CFE would continue with a forecast deficit position of £2m. It should be noted this is a continued improved reduction from previous years. However, we have made significant strides in Children’s Social Care in improved budget oversight and control- combining improved outcomes for our children and value of the Luton £. We are actively tracking our budget recovery plans and this includes meeting regularly with the portfolio holder for finance. There are further opportunities where we can improve value and outcomes through invest to save approaches i.e. Family Drug and Alcohol Court (FDAC) and creating sustainability of our Edge of Care Service which is currently only funded for one year; work is underway to look at how we can model existing grants to ensure sustainability for a further 12 month period. There are opportunities for further value through our commissioning work programme, however we need to be cognisant of our capacity to fulfil the ambition and work programme in this area which is being tracked through the CFE DMT.

Page 66 of 284 Appendix D

Inclusive Economy Department Quarter 1 Revenue Monitoring Report

Service Directorate Budget Forecast Variations £'000 £'000 Core Services Covid % Change

Corporate Director of Expenditure 5,307 -2,258 260 -42.6% Inclusive Economy Income -468 40 0 -8.5%

Customer & Organisational Expenditure 17,885 276 32 1.5% Development Income -18,899 366 0 -1.9%

Expenditure 10,727 0 44 0.0% Inclusive Growth Income -4,204 77 0 -1.8%

Expenditure 36,899 3,994 0 10.8% Property & Infrastructure Income -27,345 208 3 -0.8%

Expenditure 23,731 341 32 1.4% Neighbourhood Services Income -15,883 383 1,607 -2.4%

Expenditure 28,076 1,117 0 4.0% Sustainable Development Income -12,364 -405 0 3.3%

Total Department 43,461 4,139 1,978 9.5% Variations met from Covid SFC Compensation Grant -75 -355 Variations met from £6.7m General Covid Grant -483 -1,526 Net Variations not met from Covid Grants 3,582 98

2021/22 Budget Context & Quarter 1 Forecast

Core Service Budgets: the 2021/22 budget for the department includes a number of historic pressures and some new pressures created by the Covid pandemic including:-  Property repair and maintenance costs  Parking income, which has been severely impacted by Covid  Concessionary fares, where it has been difficult to achieve expected savings due to Covid and the need to support local bus operators  Highways maintenance costs, which have been subject to significant budget reductions over the last ten years, including in 20/21.

The current forecast indicates an overspend of £6.12m for the department against approved budget, primarily relating to  Property & Construction £4.2m overspend including o underachieved property related savings £1.65m o Additional costs of £1.1m related to the corporate purchase of Preservation House o unachieved concessionary fares saving £0.2m o underachieved savings of £0.9m regarding Highways o unavoidable spend on traffic signals and marks £0.2m o unachieved fee income from Century Park Access Road £0.2m o Increase in spend of £0.1m on Highway Winter Maintenance Page 67 of 284 1

Appendix D

o Increased building cleaning charges of £0.1m at Arndale House o Partly offset by £0.4m saving in Highways Lighting due mainly to reduced energy costs due to the rollout of LED lighting  Customer & Organisation Development overspend of £0.6m against approved budget including unachieved IT savings (£0.2m)  Neighbourhood Services overspend of £2.3m relating mainly to loss of parking income due to Covid (£1.3m), estimated loss of licensing income due to Covid (£0.3m), and additional unavoidable costs at the Vale cemetery and crematorium (£0.2m)  Sustainable Development overspend of £0.7k relating mainly to an estimated increase in waste disposal costs of £0.5m and the net loss of fleet transport trading income (£0.2m)  Use of £2.203m of contingency to offset unachieved savings, and the release of £55k of contingency that is not required

Budget Savings: the programme for the department this year totals £9.028m across 34 projects. This includes:  Remaining Targets from 2019/20 £752.0k  Year 2 Delivery from 2020/21 £7,082.1k  New Savings in 2021/22 £1,194.3k

The current progress against this year’s combined target forecasts a shortfall of £3.36m, which reduces to £1.16m after applying the £2.203m of contingencies. The current shortfall relates mainly to  Rationalisation of the Community, Leisure and Cultural estate £1.65m, against which contingency of £1.353m will be applied.  Highways related savings £915k, against which contingency of £245k will be applied.  Concessionary fares £211k, which will be covered by use of contingency  Parking income £329k of which £98k will be covered by contingency  IT related savings £198k, which will be covered by contingency

Coronavirus Activity & Costs:  Expenditure & Cost Impacts o An additional £358k of Covid related emergency expenditure is expected and will be funded from the Council’s £6.7m General Covid Grant for 21/22  Income Losses & Partial Compensation o Sales, fees and charges income across the department is estimated to be underachieved by about £1.6m before estimated compensation of £430k (not included in the above figures). The majority of this loss relates to parking.  Specific Grant Funding o Winter Grant Scheme funding of £255k is available in 21/22 o Covid Local Support Grants of £861k have been allocated for April – September o Unspent 20/21 CEV Grant funding of £881k has been carried forward to defray in 21/22 & 22/23 o £710k of Test & Trace Support Scheme grant has been carried forward from 20/21 to enable further self isolation payments to be made to individuals (£405k Main Payments, £196k Discretionary Payments)

The estimated £1.6m of income losses will be partly compensated by £430k through the Government compensation scheme; however this scheme only provides partial compensation for losses incurred in the first 3 months of the year. Of the remaining £1.2m, some of the parking losses (£98k) can be covered from contingency, whilst the balance will be covered from the Council’s 21/22 General Covid Grant, subject to sufficient funds being available.

Page 68 of 284 2

Appendix D

Service Directorates at Quarter 1

Customer & Organisational Development

Cost/Income Category Budget £000 Forecast Variations £000 % Change Core Services Covid-19 Employee Costs 6,712 -79 32 -1.17% Other Running Expenses 11,172 355 0 3.17% External Income -584 194 0 -33.29% Internal Income -18,314 172 0 -0.94% Total -1,014 642 32 Use of Savings Contingency -198 0 Net Position after use of savings contingency 444 32

The current forecast variations reported for the directorate total £674k (£476k after use of savings contingency) and include  unachieved IT savings £198k which will be fully covered by contingency. Work is ongoing to identify further ongoing, sustainable savings. This will be updated at Q2  non-achievement of historic income targets within the Strategic Change team (£72k) and related to the old agency staff contract (£63k). Both of these income targets are over 5 years old; the former was intended to be achieved through the Strategic Change team selling their services, but this has not happened; the latter will not be achieved because the contract has now ended and has been replaced by the contingent labour Joint Venture.  additional ICT cost pressures of £76k relating to additional corporate costs to provide conferencing and telephony related costs and additional costs associated with iTrent of £50k  additional spend of £32k due to Covid on temporary staff within the Customer Service Centre to address additional applications to the Council Tax Reduction Scheme

The delivery of savings within the directorate is currently forecast to fall short by £198k as mentioned above. Work is continuing to identify ongoing, permanent IT related savings and the position will be updated at Q2.

Inclusive Growth

Cost/Income Category Budget £000 Forecast Variations £000 % Change Core Services Covid-19 Employee Costs 4,229 0 0 0.00% Other Running Expenses 6,497 0 44 0.00% External Income -2,872 0 0 0.00% Internal Income -1,331 77 0 -5.79% Total 6,523 77 44 Use of Savings Contingency 0 0 Net Position after use of savings contingency 77 44

The current forecast variations reported for the directorate total £121k and include a £77k internal income shortfall related to a historic target for discounts received, which will not be achieved because of the changes to how procurement is now conducted. The £44k Covid related spend relates to additional support for employment and skills activity in response to the impact of Covid, and will be funded from the £6.7m emergency Covid funds.

The delivery of savings within the directorate is currently on target.

Page 69 of 284 3

Appendix D

Property and Infrastructure

The current forecast variations reported for the directorate show an overspend of £4.205m (£2.376m after use of savings contingency) and include  Underachieved property related savings £1.65m relating to rationalisation of the community, leisure and cultural estate. This will be reduced by utilising a contingency of £1.353m that has been provided against this saving. Delivery of this saving will require significant reductions to the Council’s property estate or a significant reduction in maintenance costs.  Additional unbudgeted costs of £1.14m associated with the corporate purchase of Preservation House to facilitate the first stage of Century Park Access Road. The Council will need to pay annual rental costs of £513k, plus other operational costs including rates and security estimated at £147k, and the annual revenue cost to finance the leasehold acquisition is estimated at £480k.  Underachieved savings of £915k regarding Highways maintenance. Highways maintenance budgets have been reduced significantly over the years, and although increased capital funding has been provided, the service have reported that these revenue savings are not achievable. The impact will be reduced by utilising a contingency of £245k that has been provided against these savings.  Unachieved concessionary fares saving £211k. Through the pandemic, bus operators have continued to provide services and the Council has been required to pay operators in line with previous years. This has made it impossible for the service to achieve the required level of savings, although a contingency will be utilised to offset the failed saving  non-achievement of busway access fee income of £20k. The introduction of access charges to bus operators for use of the busway is unlikely to happen this year at least. This shortfall will be covered by contingency.  Unavoidable spend of traffic signals and marks £150k. This spend has been required to ensure that appropriate enforcement can be undertaken to maximise parking income.  Estimated additional spend on winter maintenance of £95k. This is a contractual commitment and may increase if the winter weather is harsher than normal  Forecast savings of £384k on street lighting due to reduced energy costs energy costs associated with the rollout of LED lighting  Unachieved income on Century Park Access Road (CPAR) of £158k. CPAR is not progressing this year and therefore income included in the budget for fee income will not be achieved.

The delivery of savings within the directorate is currently forecast to fall short by £2.796m as explained in the first four bullet points above. Of the £2.796m, contingency of £1.829m will be applied leaving a net shortfall of £967k, of which £297k relates to property and £670k relates to highways. The only way that these savings can be achieved is if maintenance of properties and the highways infrastructure is curtailed which will potentially increase risks in terms of health and safety and insurance claims. Subject to sufficient funding being available, the shortfall of £967k may be covered from the £6.7m of emergency Covid funding.

Neighbourhood Services

Cost/Income Category Budget £000 Forecast Variations £000 % Change Core Services Covid-19 Employee Costs 11,584 -45 24 -0.39% Other Running Expenses 12,146 372 8 3.06% External Income -10,133 296 1,607 -2.93% Internal Income -5,750 101 0 -1.76% Total 7,847 724 1,639 Use of Savings Contingency -201 0 Net Position after use of savings contingency 523 1,639

Page 70 of 284 4

Appendix D

The current forecast variations reported for the directorate show a total overspend of £2.363m (£2.162m after use of savings contingency) consisting of £724k against core services and £1.639m due to Covid pressures. The core services variances relate mainly to  additional unavoidable costs at the Vale cemetery and crematorium £170k. This relates to £110k of additional cremator furnace repairs which are essential to ensure that income can be protected, and £60k

for additional skip hire costs to remove excess soil as part of a health and safety review.  additional rates for car parks of £116k. This includes £57k of rates relating to 20/21 which were not paid and could not be accrued for in 20/21 as they are internal costs.  Under achieved income against target at the crematorium of £250k. Historically, the target has not been achieved and was only achieved in 2020/21 due to Covid. It is expected that the number of cremations and burials will reduce this year partly due to new facilities opening nearby (e.g. Hitchin)

The Covid related variances relate mainly to  Parking income losses - the reported shortfall is £1.34m but government compensation of £292k could be claimed to reduce the impact. Of the balance, contingency of £98k can be utilised, leaving a net shortfall of £950k which could be charged in part or full against the £6.7m of emergency Covid funding.  licensing income losses – the reported shortfall is £263k income against which compensation of about £61k could be claimed, leaving a net shortfall of £202k which could be charged in part or full against the £6.7m of emergency Covid funding.  Additional spend of £22k to facilitate reopening of pavilions and to provide additional cleansing materials for street cleansing and refuse staff to facilitate a safe working environment.

The delivery of savings within the directorate is currently forecast to fall short by the £414k, primarily due to loss of parking income. Contingencies of £146k are proposed to be used to reduce the impact of the unachieved savings, with the balance to be covered from the £6.7m emergency Covid funds if any is uncommitted.

Sustainable Development

Cost/Income Category Budget £000 Forecast Variations £000 % Change Core Services Covid-19 Employee Costs 5,693 -103 0 -1.81% Other Running Expenses 22,383 1,468 0 6.56% External Income -2,808 -531 0 18.91% Internal Income -9,556 -122 0 1.27% Total 15,712 712 0 Use of Savings Contingency -30 0 Net Position after use of savings contingency 682 0

The current forecast variations reported for the directorate show an estimated overspend of £712k (£682k after use of savings contingency) which includes:  an estimated overspend of £450k on waste disposal costs. Current indications are that waste volumes will remain high due to more people spending more time at home with more waste being sent to landfill – over 60% on contract waste in May was sent to landfill. The position will be closely monitored during the year.  an estimated net loss of fleet transport trading income £155k. The gross loss of income is reported as £398k, offset by reduced costs of £243k. This is due to a number of contracts ending which the service are trying to replace although this is difficult in the current environment.  A reported shortfall in Building Regulation income of £79k and additional costs of £32k. The service will continue to seek work to reduce the impact.

Page 71 of 284 5

Appendix D

 unachieved waste income of £80k related to a savings proposal to introduce charges for the disposal of rubble and hardcore at tidy tips that was not implemented, due to a policy decision  a net underspend in Strategic Planning of £122k relating mainly to the £180k budget for the Local Plan not being spent in year. A request will be made to carry this forward to 2022/23.  the loss of a PTU contract with Central Beds £62k. The PTU contract with Central Beds will cease in July and will not be renewed.

The delivery of savings within the directorate is currently forecast to fall short by £30k due to non-achievement of additional PTU commercial income £30k. The service will need to replace the income lost due to the ending of the Central Beds contract before they can generate additional income. The shortfall will be covered by utilisation of contingencies.

Central Budgets for the Department

Cost/Income Category Budget £000 Forecast Variations £000 % Change Core Services Covid-19 Employee Costs 2,063 0 0 0.00% Other Running Expenses 3,245 0 260 0.00% External Income -112 40 0 -35.71% Internal Income -356 0 0 0.00% Total 4,840 40 260 Use of savings contingency -2,258 0 Net Position after use of savings contingency -2,218 260

Delivery contingency is held to assist with the phased delivery of current savings targets and the current monitoring forecasts that £2.203m of this is needed to cover the current projected shortfall whilst £55k is surplus to requirement and can be released.

The ongoing financial impacts from coronavirus across the department are currently being met by £430k of partial compensation for income losses incurred and £358k towards additional Covid related costs from the £6.7m of emergency Covid funding. It is also probable that the uncompensated income losses due to Covid, and savings that have not been delivered due to Covid, will be partly or wholly funded from the £6.7m.

In relation to specific Covid grants, specific Winter Grant Scheme funding of £255k is expected to be fully spent in year, as is the Test & Trace Support Scheme funding of £406k carried forward from 20/21, against which payments of £198k have been made so far this year.

Corporate Director’s Statement

The Inclusive Economy departmental budget position at quarter one remains challenging. There are a number of areas that have experienced significant impacts because of covid. These include the waste service (due to increased home working and on-line shopping) and parking (where the income has fallen substantially). The parking income losses are likely to continue as town centre businesses, including the Council, change their methods of working and it will be some time before we can assess accurately what the longer term impact is likely to be. With waste disposal, we will work with our contractor to agree how the demands can be better managed.

In addition, some of our services such as environmental health, procurement and economic development have continued to work on covid related business during this period. This has had an impact on substantive services but has significantly supported the wider economy on opening up safely.

There are a number of savings areas where we haven’t made progress including property and highways. We will be working closely with elected members in the coming months on further options for our community estate. It

Page 72 of 284 6

Appendix D should be noted that we have significantly reduced our office estate in recent years, including moving out of Apex House and Futures during Q1. In respect to highways, the SD for Property and Infrastructure is actively working with Volker Highways to review potential savings options.

We are making steady progress with our ICT savings and will continue to monitor closely. The saving for concessionary fares will also need to be re-evaluated in the light of the covid recovery.

Members are keen for further investment in core services (street cleaning, refuse, parks and potholes) and these have been significantly reduced over the last few years. Service directors will be bringing forward proposals for members to consider during Q2.

Page 73 of 284 7

Page 74 of 284 Appendix E

Budget Monitoring Report for Population Wellbeing Department – Period 3 2021/22

Service Directorate Budget Forecast Variations (£000's) £000's Core Services Covid-19 % Change Expenditure 15,830 (354) -2.2% Public Health Income (15,830) 0.0% Total Public Health 0 (354) 0 0.0%

Expenditure 38,725 (537) -1.4% Housing Revenue Account (HRA) Income (40,376) 0.0% Total Housing Revenue Account (HRA) (1,651) (537) 0 32.5%

Expenditure 47,205 (2,181) 569 -4.6% Housing General Fund Income (43,879) 4,382 -10.0% Expenditure 76,723 2,383 (459) 3.1% Adult Social Care Income (29,693) (1,187) 1,175 4.0% Expenditure 7,570 64 428 0.8% Population Health Income (2,601) (29) 1.1% Expenditure 345 1 0.3% Public Health (Commissioning) Income (333) 0.0% Expenditure 4,456 (3,790) 164 -85.1% Central Budgets Income (88) 0.0% Total Department 59,705 (357) 1,877 -0.6% Variations met from Covid SFC Compensation Grant (75) Variations met from £6.7m General Covid Grant (1,802) Net variations not met from Covid Grants 0 2021/22 Budget Context & Period 3 Forecast

Core Service Budgets: the 2021/22 budget for the department includes Private Sector Housing, Adult Social care and Wellbeing commissioned services.

The current forecast indicates a net underspend of £357k (gross overspend £3,420k) which is 0.6% for the department, primarily relating to an over spend in homelessness and an over spend in adult social care which are being offset by the use of savings contingencies.

Budget Savings: the programme for the department totals £8m over 2020/21 and 2021/22. The remaining savings still to be delivered:  Remaining Targets from 2019/20 £250k  Year 2 Delivery from 2020/21 £150k  New Savings in 2021/22 £980k

£250k target from 2019/20 related to savings project of “Collection of outstanding ASC Contributions” which still remains outstanding. The 2020/21 and 2021/22 combined target forecasts a shortfall of £950k in respect of transport savings across Adult Social Care and £180 in respect of the Mental Health Contract with ELFT.

Coronavirus Activity & Costs:

There are a number of service areas which continue to be impacted by the Covid pandemic including:

 £200k contingency set aside for Mutual Aid payments to ASC Care providers

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 £324k across Adults Social Care and Commissioning for additional staff to cover increase demand in Care Management activity and also additional staff required to help increased engagement with external care providers, facilitating additional payments to them in respect of COVID funds (e.g. Infection Control), and increased activity (hospital discharge)  £230k additional temporary housing costs for homeless people  There is a further £425k pending approval to support service delivery.  £586k to cover net loss of income (gross £1,175k) in Adult Social Care mainly due to day centre closures due to COVID  The service also continues to passport the Infection Control Grant to help support care providers with additional costs during lockdown

Hospital discharge cost reimbursement by NHS England is expected to cease at he the end of September which will significantly impact purchased care spend and result in the service overspending to budgets. Further discussions will be required with the BLMK CCG about the shared approach to hospital discharge.

Service Directorates at Period 3

Public Health Grant

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 1,068 0.0% Other Running Expenses 314 0.0% PH Services 14,448 (354) -2.5% Internal Income 0 0.0% External Income (15,830) 0.0% Total Service 0 (354) 0 0.0%

There is currently an underspend of £354k projected in the Public Health grant in relation to lower spend on various activity based PH contracts. There are also additional grants available as below which are projected to be spent during the year:

 £372k additional Criminal Justice Grant  £46k additional grant for inpatient detox  £404k Rough Sleepers Grant.

Housing Revenue Account

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 5,308 23 0.4% Other Running Expenses 33,417 (560) -1.7% External Income (40,376) 0.0% Total Service (1,651) (537) 0 32.5%

The main forecast variations reported for the HRA include:  £23k overspend in staffing costs.  Repairs underspend of circa £600k as the pandemic had impacted on the first quarter work by BTS. Issues with recruitment in the Client services team has led to delays in the new build programme, estate works and some parts of the planned programmes. There have also been delays in works due to the current

Page 76 of 284 Appendix E

material shortages. Suppliers are trying to fulfil inventory orders, but are struggling with some materials such as wood and cement.  Provision for bad debts has been increased by £40k as collection rates are declining marginally in 2021.

The HRA expects to generate a surplus to fund its capital programme in line with the business plan.

Housing General Fund

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 13,628 (39) -0.3% Other Running Expenses 33,577 (2,142) 569 -6.4% Internal Income (24,233) 2,000 -8.3% External Income (19,646) 2,382 -12.1% Total Service (Gross) 3,326 2,201 569 66.2% Use of Contingency (1,486) Total Service (Net) 3,326 715 569 21.5%

The current forecast variations reported for the Housing Service include:  £2,418k underspend in Building Technical Services due to continued impact of Covid on staffing and suppliers. As BTS is a trading service, cost reductions are offset by a like decrease in recharge income.  £2,270k overspend in Homelessness with the main reasons being: o no budget provision for repairs costs on properties of circa £706k, o accommodation cost savings of £1,413k as the number of tenancies reduces, and o income under recovery by £3,399 as budget is based on 2018/19 levels.

It should be noted that Homelessness accommodation costs have reduced by £4,193k from £15,868k in 2018/19 to £11,675k in 2020/21. Rent and housing benefit receipts have reduced by £4,086k from £11,995k to £7,909k over the same period. Homelessness Prevention Grant have moved marginally from £3,055k to £3,344k during the same time. There is a need to review the build of the Homelessness budget as both cost and income bases have changed. An Invest to Save proposal is under evaluation to turn around service performance. Centrally held housing contingency of £1.486m is also being allocated to deal with the overspend.

Adult Social Care

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 16,359 (525) 96 -3.2% Other Running Expenses 60,364 2,908 (555) 4.8% Internal Income (100) 0.0% External Income (29,593) (1,187) 1,175 4.0% Total Service (Gross) 47,030 1,196 716 2.5% Use of Contingency (950) Total Service (Net) 47,030 246 716 0.5%

The current forecast variations reported for the directorate include:  £525k net underspend on staffing across the division due to vacancies in learning disability day services due to reduced activity due to Covid  £988k overspend in purchased care primarily relating to hospital discharge care packages which will cease being funded by NHS England from October 2021 onwards  £911k overspend across in-house provider services primarily due to unachievable savings targets in day care transport services

Page 77 of 284 Appendix E

 £1,034k increased spend in purchased care across mental health pooled budgets is being offset by increased contributions from health towards these high cost placements

The delivery of savings within the directorate is currently forecast to shortfall due to day care transport. The saving was achieved in 2020-21 due to day centre closures during the pandemic, however as lockdown is being lifted, day care transport spend will increase again. Passenger transport service is under review which will include a re-tender for externally contracted provision. £950k of centrally held contingency is also being allocated to ASC to offset these savings pressure.

It is too early to determine the impact of Covid on the demand for adult social care in particular whether people will take up day care/social activities to the extent they did prior to the pandemic. This is also impacting non-residential income, where there is a net loss of £0.5m expected (shortfalls offset by underspend in purchased care and COVID sales and income grants). There is also expected to be a significant increase in home care spend in the latter part of the year as the discharge to assess scheme which is currently funded by NHS England will cease and the burden of hospital discharge costs will fall back on the council.

Population Health

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Core Services Employee Costs 2,765 (275) 228 -9.9% Other Running Expenses 4,805 339 200 7.1% Internal Income (1,662) 0.0% External Income (939) (29) 3.1% Total Service (Gross) 4,969 35 428 0.7% Use of Contingency (180) Total Service (Net) 4,969 (145) 428 -2.9%

The current forecast variations reported for the directorate include

 £275k underspend in staffing the majority of which relates to Business Intelligence posts. These were funded from 2021-22 growth in respect of the Children’s Improvement plan but remain unfilled. Work to recruit to these posts is currently underway. There is also a shortfall of £73k unachievable income due to reduced buy back from schools in respect of data protection services  £120k net overspend in supplies and services the majority of which relates to an unachieved savings in the East London Foundation Trust (ELFT) contract. £136k additional income will fund Digitalisation and Mental Health transformation work.

The delivery of savings within the directorate is currently forecast to shortfall due to difficulty identifying efficiency savings with the East London Foundation Trust (ELFT) who provide mental health care management staff for adult care. ELFT have been tasked with identifying the potential to deliver the saving through improved assessment and commissioning of placements and so reduce spend within mental health purchased care instead. However, COVID has also created additional demands for mental health support. Centrally held £180k ELFT savings contingency is being allocated to offset the pressure.

There are significant additional costs being incurred due to COVID primarily on additional staff to help engage and facilitate Covid grant payments to external providers plus a contingency for mutual aid payments that may be required when specific grant schemes cease.

Page 78 of 284 Appendix E

Public Health (Commissioning)

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 300 1 0.3% Other Running Expenses 45 0.0% Internal Income (78) 0.0% External Income (255) 0.0% Total Service 12 1 0 8.3%

There are minor variations on employees and supplies and services being reported by the directorate currently.

Central Budgets for the Department

Cost/Income Category Budget £'000 Forecast Variations £'000 % Change Core Services Covid-19 Employee Costs 604 0.0% Other Running Expenses 3,852 164 0.0% Internal Income (34) 0.0% External Income (54) 0.0% Total Service (Gross) 4,368 0 164 0.0% Use of Dept. Contingency (3,790) Total Service (Net) 4,368 (3,790) 164 -86.8%

£3,790k of delivery contingency is held here to assist with the phased deliver of current savings targets for department and the current monitoring forecasts that £2,616k of this is needed to cover the current projected shortfall and released. Although this contingency is held centrally under Corporate Director, for clarity use of these contingencies are shown against each service directorate summary tables above. The remainder is being used to offset the remaining overspend in Housing and Adult Social Care.

The ongoing financial impacts from coronavirus in the department is projected to be £1,877k which is being funded by Sales, Fees and Charges income compensation and also by using generic council wide C-19 grant £6.7m.

Corporate Director’s Statement

The 21/22 financial year will continue to be a challenging year with a significant impact from COVID on the delivery of services and additional demands for services such as mental health. Additional commissioned activity funded through the Contain Outbreak Management Fund has been put in place for this financial year but this funding is only available in 21/22.

During COVID there has been a different approach to Hospital Discharge with additional funding into the health system. As this is withdrawn this will increase pressure on local authority budgets. Patients discharged earlier from hospital are likely to have greater care needs. This is likely to become significant as the health system tries to catch up on elective surgery that has been delayed due to COVID. Work is progressing to reach agreement with the CCG on a new model.

There is an increasing fragility in the home care and care home market which the Council will need to keep under constant review.

The Housing Service has a continued focus on reducing the number of households in temporary accommodation. The new Service Director has reviewed activity and recommended further investment to support reducing numbers as an invest to save. This remains a key priority for the service.

Page 79 of 284

Page 80 of 284 Appendix F

BUDGET SAVINGS MONITORING 2021/22 - Delivery of 2019/20 to 2021/22 Savings Q1 Savings Proposal Reference Gross Savings Q1 Variations 2021/22 Comments on Savings Proposal Progress Review

Description Var. Var. Var. use of net impact Progress Lead Officer 2019/20 2020/21 2021/22 2019/20 2020/21 2021/22 contingen Recovery Measures Planned to Improve the Current Forecast Indicator cy £'000 £'000 £'000 £'000 £'000 £'000 £'000 £'000 Chief Executive's Department Nigel Robinson C&C/19/002 - Increased enforcement C/Tax and Business Rates Enforcement Income has reduced as an impact of income Covid-19. Courts have recently reopened and are starting to address our backlog of cases. As a result, the income target is not expected to be met this -170.0 170.0 170.0 year due to the impact of Covid, but it is anticipated that the target will be Amber achievable in 2022/23 subject to the operation of the Courts returning to near normal.

Adam Divney CE/20/005 - Structural & functional review - -155.0 -154.0 0.0 Savings are on target to be delivered to support Luton 2040 and community GREEN empowerment Dev Gopal C&C/20/011 - Reduction in bank charges options to reduce charges are being assessed, but the saving is on target to be -100.0 0.0 from recommissioning met GREEN

Dev Gopal CE/21/001 Regular financial review of Adult SLA agreed with ASC service and staff are being recruited.Pilot Project under Social Care packages -500.0 250.0 -250.0 0.0 way and progress is being made toward target. Amber

Dev Gopal C&C/21/001 New Council Tax Reduction C/Tax reduction should reduce C/Tax Hardship payments made from Collection fund. However, cases tend to increase during the year particularly whilst Covid Scheme proposal for 21/22 -500.0 0.0 has an impact. The position will be reviewed at Q2 when 6 months of activity is GREEN available

Robin Porter CE/21/006 Review of 3rd and 4th tier -150.0 0.0 On Target structures GREEN

Other minor savings 5.0 -5.0

Chief Executive's Net Position -170.0 -255.0 -1,304.0 170.0 0.0 255.0 -255.0 170.0

Children, Families & Education Allison C&L/19/016 - Luton Families Programme- The revised improved internal fostering recruitment and retention programme Parkinson Fostering Workstream has been implemented since 1st January 2021 and there is invest to safe budget available to support this. The overall position of this work stream is showing positive movement where spend on IFA is down as compared to previous financial year and spend on Internal fostering is increased. If the revised model which was based on number of children turning 18 and some additional -590.0 590.0 -295.0 295.0 reduction in IFAs and further recruitment of Internal foster carers continues throughout 2021/22 and 2022/23, this could result in further cost avoidance. AMBER However the complexity of some cases means in-house provision is not always the most suitable placement and also it could be counterproductive to transfer existing agency placements to in-house if they are stable and meet child’s needs.The full delivery contingency needs to be used at Q1 to mitigate the current shortfall, pending further review during the year.

Page 81 of 284 Appendix F

BUDGET SAVINGS MONITORING 2021/22 - Delivery of 2019/20 to 2021/22 Savings Q1 Savings Proposal Reference Gross Savings Q1 Variations 2021/22 Comments on Savings Proposal Progress Review

Description Var. Var. Var. use of net impact Progress Lead Officer 2019/20 2020/21 2021/22 2019/20 2020/21 2021/22 contingen Recovery Measures Planned to Improve the Current Forecast Indicator cy £'000 £'000 £'000 £'000 £'000 £'000 £'000 £'000

Damian Elcock C&L/19/017 - Luton Families Programme- The programme went live in March 2021 and work has commenced with Edge of Care families. The revised target of this work stream is based on achieving the saving over two years: 2021/22 - 2022/23. Detailed financial tracking work is ongoing with the service, business intelligence and the finance team, to ensure full cost avoidance is being recorded and reported in a timely manner. This will encompass all the cases where coming in to care has avoided, based on the -1,043.9 1,043.9 -522.0 521.9 average cost of the placement type that would have been needed. However there is some risk on continuation of this programme when invest to save AMBER budget runs out at the end of 2021/22, as the EOC team is currently being resourced by this funding. Further ITS or growth options will need to be considered at the 2022/23 budget setting process. The full deliver contingency needs to beused at Q1 to cover the forecast shortfall, pending further review during the year.

Allison C&L/19/018 - Luton Families Programme- Children's social care staffing spend was within budget in 2020/21 due to the Parkinson Work Force Workstream combined effect of converting agency staff to permanent positions, the additional staffing budget approved at the emergency budget and the utilisation of various DFE funding streams. The establishment of the Social Worker Academy has -231.5 231.5 -115.7 115.8 been agreed and this will also help to reduce the reliance on using expensive AMBER agency staffing. If all these initiatives including conversion to permanent roles continue, this will result in further cost reduction. The full delivery contingency needs to be used at Q1, pending to further review during the year.

other minor savings -15.3 Children, Families & Education Net Position -1,865.4 0.0 0.0 1,865.4 0.0 0.0 -948.0 932.7

Inclusive Economy Sarah Hall P&I/17/001 - Parking enforcement Income has continued to be significantly affectedby Covid-19. The shortfall additional income reported for the year is forecast at £679.8k against an original budget of £2.211m. The shortfall in income up to Period 3 is £237.7k and Government compensation grant of £166.4k.is expected to partly meet this. The Government -115.0 115.0 115.0 compensation scheme currently only provides for loss of income up to June. The RED remaining shortfall of £513.4k may be recovered from the £6.7m general Covid Grant received for 2021/22.

Aidan Wilkie CE/18/007 - Rationalise number of One-off savings have been identified in year. However, further work will be business applications -175.0 0.0 required in 2021-22 to ensure that ongoing, recurrent savings can be achieved. AMBER Recovery Plan has 4 Strategies: 1) 1 family 1 View project. 2) New IT strategy. 3) Business case re Capita One/ Liquid Logic 4) IT Contract Register.

Sarah Hall Parking charges were increased to deliver the savings, but income has been significantly affected by Covid-19, as Car Parks are not being used to full capacity as more people are working from home. Ths shortfall is being reported P&I/19/017 + E&R/20/010 -Additional -62.0 -152.0 0.0 in the service budget as a coronavirus pressure: £659.6k reduction against an parking income, (incl. inflation and original budget of £1.844m. The shortfall in income up to Period 3 is £203.3k and RED increased recovery) Government compensation grant of £142.3k is expected to partly meet this. The Government compensation schem ecurrently only provides for loss of income up to June. The balance of £517.3k may be recovered from general Covid Grant Page 82 of 284 Appendix F

BUDGET SAVINGS MONITORING 2021/22 - Delivery of 2019/20 to 2021/22 Savings Q1 Savings Proposal Reference Gross Savings Q1 Variations 2021/22 Comments on Savings Proposal Progress Review P&I/19/017 + E&R/20/010 -Additional Description Var. Var. Var. use of net impact Progress Lead Officer parking income, (incl. inflation and 2019/20 2020/21 2021/22 2019/20 2020/21 2021/22 contingen Recovery Measures Planned to Improve the Current Forecast RED Indicator increased recovery) cy £'000 £'000 £'000 £'000 £'000 £'000 £'000 £'000 CS23 Aidan Wilkie CE/19/003 - Centralise Management of IT IT has driven down the cost per device by £300. Savings on centralisation of systems hardware will be achievable by driving a behaviour change. The majority of -200.0 100.0 -100.0 0.0 savings identified in year are one-off and work is continuing to deliver the saving AMBER target in 2021-22 through ongoing, recurrent savings.

Shaun Askins C&L/19/004 - Luton Families Programme- -240.0 0.0 Green Transport Workstream

Roger Kirk P&I/20C/005 - Concessionary Fares - reduce spend in line with reducing journey Talks with Bus Service providers have resulted in a reduction on the numbers -580.0 211.0 -211.0 0.0 reimbursement of fares but have not been able to achieve the full £580k saving RED as the Council have had to continue paying operators at pre-Covid levels.

Roger Kirk E&R/20/008 - Highways service options Partially covered by salary underspends in the current year, but the remainder is -400.0 232.8 -200.0 32.8 review reduce costs and increase income not currently met RED toward self-financing Roger Kirk P&I/19/009 & P&I/20C/012 - Highways Additional capital funding had been received to enable this one-off revenue maintenance - reduce spend on saving in 20/21. Budget was not added back in 21/22, resulting in overspend, as -200.0 -393.0 200.0 393.0 593.0 maintenance expenditure returns to prior levels to cover required Highways repairs and RED maintenance

Roger Kirk E&R/20/006 - Rationalisation of the Requires ultimate Member approval. Proposals for the Community Estate have Community, Leisure & Cultural Estate. -824.5 -824.5 824.5 824.5 -1,353.0 296.0 not been supported. Proposals for the Leisure Estate are being developed. The RED saving is not expected to be fully delivered this year

Aidan Wilkie C&C/20/010 & IE/21/001 - Review of wider This is linked to items CE/18/007 and CE/19/003. At this stage it appears -100.0 -200.0 25.0 73.0 -98.0 0.0 ICT contracts (Application Portfolio unlikely that this saving will be fully achieved in year. RED Management), including Phase 2

Aiden Wilkie C&C/20/001 New recruitment service for The contingent labout Joint Venture is behind where it was anticipated to be at contingent labour this stage, partly due to the Council successfully reducing its reliance on agency -272.8 0.0 0.0 staff. The budgeted surplus is unlikely to be achieved this year, but any AMBER underachievement will be rolled forward to be offset by profits in future years.

Roger Kirk C&C/20/013 Transfer of shopping parades from the HRA to General Fund, with GF -250.0 -250.0 0.0 On target GREEN properties moving to the HRA (subject to

Roger Kirk IE/21/005 - Highways staffing restructure This is linked to E&R/20/008 and is not being achieved. Reducing staff would leave the service unable to deliver statutory responsibilities. Options will be -90.0 90.0 -45.0 45.0 considered to see whether the additional costs can be covered be alternative RED funding

Roger Kirk P&I/21/001 - Office Estate Rationalisation -152.0 0.0 On target GREEN

other minor savings 38.5 60.4 -98.9 Inclusive Economy Net Position -992.0 -2,699.5 -1,789.3 453.5 1,120.9 1,613.3 -2,105.9 1,081.8

Population Wellbeing

Page 83 of 284 Appendix F

BUDGET SAVINGS MONITORING 2021/22 - Delivery of 2019/20 to 2021/22 Savings Q1 Savings Proposal Reference Gross Savings Q1 Variations 2021/22 Comments on Savings Proposal Progress Review

Description Var. Var. Var. use of net impact Progress Lead Officer 2019/20 2020/21 2021/22 2019/20 2020/21 2021/22 contingen Recovery Measures Planned to Improve the Current Forecast Indicator cy £'000 £'000 £'000 £'000 £'000 £'000 £'000 £'000 Maud O'Leary ASC/19/008 - Collection of outstanding The employee resources for ASC recovery are now in place and are working ASC contributions closely with the service to improve the collection of outstanding charges. A -250.0 250.0 0.0 250.0 number of unrecoverable debts were written off and age debt provision was RED increased by £82k in 2020/21. No contingencies available.

Maud O'Leary PH&WB/20/008 - Review of ASC in-house This project is subject to the review of the Council wide Transport offer (in-house transport following strength based reviews and externally commissioned) . The saving was achieved in 2020/21 due to day (Side by Side Programme) and review of -100.0 -650.0 100.0 650.0 -750.0 0.0 centres being closed, but activity levels are expected to increase this year. The model of care across provider services full delivery contingency is currently required until the transport review is RED concluded.

Maud O'Leary PH&WB/20/009 - Review clients travel This project is subject to the review of the Council wide Transport offer (in-house following strength based assessments and externally commissioned) . The saving was achieved in 2020/21 due to day (Side by Side programme) and -50.0 -150.0 50.0 150.0 -200.0 0.0 centres being closed, but activity levels are expected to increase this year. The commissioning activity efficiencies full delivery contingency is currently required until the transport review is RED concluded.

Sally Cartwright PH&WB/20/017 - Review of Mental Health Full contingencies will be required in 2021/22 as ELFT review of efficiencies is Social Work provider exploring potential for still on-going. RED efficiency savings -180.0 180.0 -180.0 0.0 Colin Moone C&C/19/001 - Temporary Accommodation - Temporary Accomodation costs are forecast to be under budget by £1.4m reduction in overspend through positive -2,000.0 586.9 -586.9 0.0 against a £12.3m budget. TA tenancies are estimated to reduce from 1,214 to action to reduce number of households in 1,151 by year end. temporary accommodation AMBER Housing Service is making changes so that application, prevention, relief and acceptance procedures work to reduce numbers in temporary accommodation.

Colin Moone C&C/19/015 + C&C/20/012 - Temporary Accommodation: increase rent collection Collection rate for current tenancies at June 2021 is 85.6% compared to target of rate and recover outstanding sums -673.0 -300.0 673.0 300.0 -486.5 486.5 95.0%. Total debt at June is £9.4m of which £8.4m relates to former tenant accounts. Debt has increased by £0.3m compared to end of March 2021. RED A working party has been formed to tackle housing debt. Staff vacancies has had some impact on collections and resourcing is being addressed. Processing is focussed on collectable debt.

Public Health & Welbeing Net Position -2,923.0 -450.0 -980.0 1,509.9 450.0 980.0 -2,203.400 736.5 Key to Status of Variations On target to be achieved in full - no issues GREEN Issues arising - plans in place to bring it back on target AMBER -5,950.4 -3,404.5 -4,073.3 3,998.8 1,570.9 2,848.3 -5,512.3 2,921.0 High risk re: timing and/or deliverability RED

Page 84 of 284 APPENDIX G

VOLATILE AND DEMAND LED BUDGETs - Q1 MONITORING 2021-22 Q1 Review

Approved P03 Progress Item Ref. Description Comments on Monitoring Results Budget Variations Indicator Recovery Plan Details, if not on Target Lead Officer £'000 £'000 Supporting Performance Information, Client Data etc. (cumulative) (+ increased cost or reduced income / - reduced cost or increased income)

The collection rate at the end of the first quarter is 27.1%. The collection rate continues to be severally impacted by Covid-19 restrictions, court and recovery limitations. Latest figures show £29.3m out of £108.3m has been collected (£27.5m out of £101.4m had been collected for the Reflects Impact of Covid 19 on local economy. Council Tax Income -80,854 AMBER VB01 same time last year) Collection closely monitored Nigel Base now Change Collection Rate 21/22 30.1% 27.1% -3.1% Robinson Business rates collection has been severely affected by Covid-19. Latest figures show £41.1m VB02 out of £46m has been collected (£68.7m out of £70.8m collected at the same stage last year) Reflects Impact of Covid 19 on local economy. Business Rates Income -54,410 AMBER Collection closely monitored Nigel Base now change Robinson Collection Rate 21/22 29.5% 21.9% -7.5% VB03 COVID-19 is impacting on the speed of claimants moving from HB to UC as they are impacted by the economic downturn. Rents have Increased inline with LHA due. Costs and income will Housing Benefit continue to be monitored in detail up to year-end, to track any movement from the current Ongoing work by Recovery team to recover HB 670 AMBER Payments (Net Cost) forecast. Overpayments, aim to meet target Nigel Robinson Property Repairs and maintenance is currently reported as an overspend of £240K. However, this cost is offset by reductions in premises costs of £350k due to buildings being closed as a result of Covid-19, otherwise the overspend would have been higher. The property estate as a whole is being reviewed with the aim of reducing the number of properties. The Council has incurred costs Ongoing dialogue with Members and partner Property Repairs and 707 96 of £939k to make buildings Covid compliant, but these costs will be covered by funding received AMBER organisations to rationalise the property estate with maintenance VB04 from Central government. the aim of reducing costs

Roger Kirk

VB05 With the increased time people have been spending at home we have seen a substantial increase in the levels of waste collected from the kerbside. Coupled with the contractual increased unitary rate, cost of landfill and EFW, the cost of disposal has increased compared to 2020/21 equivalent. Waste Disposal Mar Apr May Reflect the impact of Covid-19 and resulting Contract, including 9,143 450 Monthly tonnes of total waste-Contract 7,362 7,548 6,892 RED lockdowns, significantly increasing quantities of waste. landfill costs. Waste figures are being continually monitored Shaun Cumulative tonnes of total waste 7,362 14,910 21,802 Askins Monthly tonnes to landfill -Contract 1,721 1,590 4,340 Cumulative tonnes to landfill 1,721 3,311 7,651 % cumulative waste to landfill 23.4% 22.2% 35.1% The base budget has increased by £300k to reflect increased demographic growth in this area. Covid has had an impact as providers continue to be paid under mutual aid agreements and some A review is underway and all viable options will be children have continued to attend school, so the number of externally provisioned trips has considered, including encouraging independence, to VB06 SEN Transport 3,338 increased to ensure social distancing rules are adhered to. However a change in providers has ensure suitable provision is maintained and to improve the sustainability of budget resources. There is also a resulted in fewer externally provisioned routes and a significant increase in support from the in- Green house service. The additional costs have been covered by a dedictated government grant to cover proposal to have a centralised team to deal with all COVID related expenditure. client transport requests and an options appraisal is currently being drafted to determine whether this will Shaun help deliver a balanced budget in this area. Askins

Page 85 of 284 APPENDIX G

VOLATILE AND DEMAND LED BUDGETs - Q1 MONITORING 2021-22 Q1 Review

Approved P03 Progress Item Ref. Description Comments on Monitoring Results Budget Variations Indicator Recovery Plan Details, if not on Target Lead Officer £'000 £'000 Supporting Performance Information, Client Data etc. (cumulative) (+ increased cost or reduced income / - reduced cost or increased income)

The number of children supported in residential care remains fairly static. Although there have been some reductions due to Children transitioning to leaving care or Adult Care as they turn 18. VB07 Work is ongoing to to ensure children's residential placements offer value for money. This is a Childrens Residential very volatile area and the number of children and placement costs can fluctuate considerably Placements (Tri-partite, depending on the type of care needed. Non Tri-partite & Secure 4,947 55 RED March now change Remand) '21 Allison Average number of placements (FTE) 31 27 -4 Parkinson Average weekly cost per placement £3,501 £3,539 £38 Although there is still a significant overspend in this area, projected spend is expected to be less than 2020-21 as the number of children placed has signficantly reduced. The average weekly cost of placements has increased following a tendering exercise alongside the other two LA's, however it is expected this will benefit the service longer term with a more VB08 consistent pricing framework, more commissioning options and the council will not having to enter Foster Care - Agency The Luton Families Programme has been developed into spot purchase arrangements with non approved providers as happened in years. The service (SPARC, IFA Preferred 6,771 517 to deliver change and improvement across Children continues to ensure children are placed in the most appropriate care setting for the welfare of child & Non Preferred) services in Luton . The programme incorporates and this may be an agency foster placement AMBER previous work from the former Glidepath programme March now change and the PeopleToo recommendations. The planned '21 work in the programme includes measures to assist Allison Average number of placements (FTE) 147 136 -11 areas which are under significant budgetary pressure. Parkinson Average weekly cost per placement £955 £1,023 £67 This a 5 year plan that will deliver a balanced budget There is an ongoing recruitment campaign to attract more in-house foster carers however the across Children’s Services by 2022-23. complexity of some cases means in-house provision is not always the most suitable placement. There was a recent review of foster care payment rates and changes to this is expected to attract more carers to the service and there have been recent success in increasing the number of children placed with in-house carers rather than more expensive agency fostering. The number of VB09 2,639 303 contract carers has reduced due to retirements and this has resulted in the lower average unit cost of placements, but this does have some risk of placing children in an emergency and could result Foster Care - In-house in further use of agency foster placements. The rates and bandings for in-house carers that took AMBER effect from January has increased costs which is why the budget is predicting to overspend. There is contingency held to fund this but whilst the directorate i sprojecting to underspend there has not been any formal request to release these funds. March now change '21 Allison Average number of placements (FTE) 121 129 8 Parkinson Average weekly cost per placement £412 £395 -£17 Legal Services spend is directly linked to court proceedings and the number of children being VB10 placed in care. The budget has been increased in recent years to reflect the increased activity and spend is predicted to remain within budget based on current activity. Children's Legal Costs 1,421 -33 GREEN Denise Base now change Goodwin number/estimate of cases 143 137 -6 average cost per case £10,780 £10,131 -£649 Activity has not returned to pre-pandemic levels with the primary causes being social distancing, vacancies and inventory shortages. Impact on gross expenditure is circa £2m, however, as costs BTS to provide a schedule to address delays in VB11 BTS trading services 23,488 -2,000 are wholly offset by recharges the net impact is nil. AMBER repairs, maintenance and enhancement of TA and Apr May Jun HRA properties. Tim Keogh KPI - under redesign VB12 Direct cost of accommodating homeless tenants have reduced in successive years from the peak in 2018/19 in line with lower tenancies. The service plan is to reduce tenancies to circa 900 of Service is changing procedures to manage tenancy Homelessness - which nightly lets will be capped at 30. flows. Work continues to reduce nightly let Prevention & Temporary 12,323 -1,413 RED Page 86 of 284 accommodation. TAPS 2 acquisition of thirty 3 or 4 Accommodation bedroom properties will alleviate pressure. APPENDIX G

VOLATILE AND DEMAND LED BUDGETs - Q1 MONITORING 2021-22 Q1 Review

Approved P03 Progress Item Ref. Description Comments on Monitoring Results Budget Variations Indicator Recovery Plan Details, if not on Target Lead Officer £'000 £'000 Supporting Performance Information, Client Data etc. (cumulative)

Homelessness - (+ increased cost or reduced income / - reduced cost or increased income) Service is changing procedures to manage tenancy flows. Work continues to reduce nightly let Prevention & Temporary 12,323 -1,413 RED Nazakat Apr May Jun accommodation. TAPS 2 acquisition of thirty 3 or 4 Ali Accommodation No of Temp Accommodation properties 1,214 1,215 1,200 bedroom properties will alleviate pressure. No of TA voids 40 36 52 No of households in nightly let accommodation 93 95 99 VB13 Current tenant debt is managed within the service whereas former tenants debt is covered by Revenue & Benefit service. Collection rates have fluctuated in calendar 2021. Collection teams have been tasked with pursuing debt Homelessness - Income Nazakat -10,977 3,400 Target June Value RED more vigorously. Housing vacancies are to be Collection Ali Current Tenant Arrears 95.0% 85.6% £0.95m supported by temporary hires. Former Tenant Arrears £8.0m £0.065m £8.40m VB14 Prompt repairs and void turnaround reduces waiting times for tenancies and income loss. Responsive Repairs Target turnaround times need to be closely monitored Ray (including Void 4,629 -360 Target June YTD Amber and process issues resolved. (Note that KPI set is Frampton Management) Routine repairs completed on time 98% tba tba under development). Average no of days to complete repairs 11 tba tba VB15 The number of people placed permanently in residential and nursing placements significantly Older Person's Private & dropped in 2020-21 due to high Covid mortatlity rates however numbers have remained relatively Voluntary Residential stable since the initial few months of the pandemic.. 7,694 -23 RED Vamsi and Nursing Care Base now change Pelluri packages number of permanent clients in care homes 309 314 5 average weekly net cost per £471 £469 -£2 client VB16 There is a underspend in Learning Disability placements due to lower than expected cost of transition placements and not all placements have transpired. There has also been a reduction in Purchased Care Budgets (items VB15 - VB22) need placements since 2019-20 due to higher mortality rates. The increase in unit cost is a combination to be viewed as a whole, due to ongoing changes in Learning Disability the level and type of care required to best support of inflationary increases and a very high cost placement previously funded 100% by health now Private & Voluntary changes in individual client needs. 12,996 -424 jointly funded. GREEN Residential and Nursing Base now change Vamsi Care packages Pelluri number of permanent clients in care homes/ 173 174 1 averageSupported weekly Living net cost per £1,348 £1,389 £42 client The average cost has increased due to the national living wage and inflation. Agreement to fund Physical Disability placements with health in the same way as pooled budget arrangements has still not been agreed VB17 Private & Voluntary and the Council continues to bear a signification proportion of these costs compared to Health. 1,401 474 RED Vamsi Residential and Nursing Base now change Pelluri Care packages Number of permanent clients in care homes 62 60 -2 Average net weekly cost per client £582 £599 £18

The number of people with Mental Health needs requiring continued support has remained fairly static since the start of the year. This follows significant interventions from LBC care management, however there are still placement disputes and the numbers could rise as a consequence. The massive increase in numbers supported from previous years required budget Mental Health Private & reallocations as part of budget setting so the overspend in this area does not appear as significant Voluntary Sector as previous years. Contributions from Health have also significantly increased as LBC care 5,145 131 RED Residential & Nursing management have ensured panel decisions are followed up and pursued where joint funding is disputed. The increased average cost is due to high cost placements and inflationary increases. VB18 Care Packages Vamsi Base now change number of clients in care homes 154 153 Pelluri -1 average weekly net cost per £605 £661 £56 client

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VOLATILE AND DEMAND LED BUDGETs - Q1 MONITORING 2021-22 Q1 Review

Approved P03 Progress Item Ref. Description Comments on Monitoring Results Budget Variations Indicator Recovery Plan Details, if not on Target Lead Officer £'000 £'000 Supporting Performance Information, Client Data etc. (cumulative) (+ increased cost or reduced income / - reduced cost or increased income) VB20 Although the number of clients requiring home care reduced due to COVID 19 lockdowns as family members who have been furloughed or are able to work from home have been able to provide care previously provided by the council which has also resulted in reduced spend during 2020-21 however numbers are now starting to increase. The Council's spend on hospital Private & Voluntary discharges continues to be reimbursed by Health to ensure there is bed capacity in respect of Sector Home Care 9,611 1,191 Covid-19 but this funding comes to an end in September 2021 and home care is projected to GREEN Packages overspend as a result. Vamsi Base now change number of clients receiving 931 968 37 Pelluri home care average weekly cost per client £209 £214 £5

VB21 The Direct Payment (DP) review project has resulted in a reduction of nearly 100 DP clients in a year - 800 were supported at March 2019, compared to 701 currently. This has been done in conjunction with the Side by Side project which has now embedded a different way of initially assessing care needs across care management. A budget saving of £300k was allocated to direct payments as part of the emergency budgetrelating to the introduction of prepaid cards. Although there are ongoing referrals for care funded by DP, the current projection is now under budget following the reviews undertaken for the prepaid card project, which is a significant Direct Payment achievement compared to previous years. Due to the nature of the Side by Side project, the cohort 8,482 -204 GREEN Packages of people supported by Adult Care with a DP are those with higher care needs. This coupled with increased costs in relation to national living wage is resulting in a higher unit cost. The recovery of money from holding accounts significantly reduced the outturn position in previous years and it is anticipated this will level out as the introduction of prepaid cards will limit the allocation of funds that are unutilised and need to be reclaimed. Vamsi Base now change Pelluri number of clients receiving a direct 725 644 -81 averagepayment weekly cost per client £218 £251 £33

VB22 There has been a significant reduction in income due to Covid-19 and lockdown as people are not attending day care or are in receipt of non chargeable home care. The projection has been based on current activity levels, however this should increase if lockdown is lifted, but there is uncertainty The reduction in income is partially offset by around the level of uptake in particular on day care as vulnerable clients may continue to shield corresponding reductions in cost. The remaning themselves. The current income loss has been offset by significant lower spend across day care shortfall will be met by COVID income loss grant and Non Residential Income -3,593 671 services. Many day care providers have furloughed staff reducing the level of mutual aid GREEN COVID emergency grant. payments made by the Council. It is expected the income loss will be covered by the sales, fees and income losses grant and the remainder the emergency Covid grant. Vamsi Base now change Pelluri number of clients charged for non residential 608 602 -6 averagecare weekly charge per -£72 -£93 -£21 client Activity has not returned to pre-pandemic levels with the primary causes being social distancing BTS to provide a schedule to address delays in and vacancies. Forecast impact is circa £2m, however, as costs are wholly offset by recharges the repairs and maintenance of TA and HRA properties. BTS trading services 23,488 -2,000 net impact is nil. This masks operational issues so gross figures are report here. AMBER VB23 There is also impact on GF and HRA capital projects Apr May Jun where staffing resources are no available. Tim Keogh No of vacancies VB24 Direct cost of accommodating homeless tenants have reduced in successive years from the peak in 2018/19 in line with lower tenancies. The service plan is to reduce tenancies to circa 900 of Service is changing procedures to manage tenancy Homelessness - which nightly lets will be capped at 30. flows. Work continues to reduce nightly let Temporary 12,323 -1,413 RED Nazakat Apr May Jun accommodation. TAPS 2 acquisition of thirty 3 or 4 Accommodation Ali No of Temp Accommodation properties 1,214 1,215 1,200 bedroom properties will alleviate pressure..

Page 88 of 284 APPENDIX G

VOLATILE AND DEMAND LED BUDGETs - Q1 MONITORING 2021-22 Q1 Review

Approved P03 Progress Item Ref. Description Comments on Monitoring Results Budget Variations Indicator Recovery Plan Details, if not on Target Homelessness - Service is changing procedures to manage tenancy Lead Officer £'000 £'000 Supporting Performance Information, Client Data etc. (cumulative) flows. Work continues to reduce nightly let Temporary 12,323 -1,413 RED accommodation. TAPS 2 acquisition of thirty 3 or 4 Accommodation (+ increased cost or reduced income / - reduced cost or increased income) bedroom properties will alleviate pressure.. No of voids 40 36 52 No of households in nightly let accommodation 93 95 99 VB25 Current tenant debt is managed within the service whereas former tenants debt is covered by Revenue & Benefit service. Collection rates have fluctuated in calendar 2021. Collection teams have been tasked with pursuing debt Homelessness - Income -10,977 3,400 Apr May Jun RED more vigorously. Housing vacancies are to be Nazakat Collection Ali Current Tenant Arrears supported by temporary hires. Former Tenant Arrears VB26 Prompt void turnaround reduces waiting times for tenancies and income loss. Responsive Repairs Target turnaround times need to be closely monitored Ray (specifically Void 4,629 -360 Apr May Jun Amber and process issues resolved. Frampton Management) Number of voids Income loss through void properties (%) 2,457 Key to Status of Budgets

Budget on target - no Budget not on target and is GREEN AMBER Issues arising - recovery / mitigations in place RED issues and ongoing pressure

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Item No: 10 Report For: Executive Date of Meeting: 16 August 2021 Report Of: Luton 2040, Chief Executive’s Report by: Lilly Smith, Heritage Enabler Contact Officer: Lilly Smith Subject: A New Heritage Strategy for Luton Lead Executive Member(s): Councillor Roche Wards Affected: All Consultations: Councillors  Scrutiny  Stakeholders  Others 

Recommendations 1. The Executive is recommended to:

(i) Approve the heritage strategy, strategic priorities and recommendation bullet points within each heritage section.

(ii) Approve the strategic approach of creating five non-designated heritage zones across the town to frame the Heritage Implementation Plan (incl: Built Heritage Action Plan and Place-making Heritage Interpretation plan).

(iii) Approve the new proposed governance model for delivering the new Heritage Strategy.

(iv) Approve a pilot design code charrette for the former ABC building.

(v) Approve the use of the dynamic local list appraisal framework.

Background 2. The council were successful with a bid to National Heritage Lottery Fund to:

 appoint a Heritage Enabler

 produce a new 10-year heritage strategy for Luton

 work with the community and partners to increase participation from all sectors of the community in heritage

 support the Heritage Forum to deliver a new governance model

3. As part of the New Heritage Strategy, the Heritage Enabler has been developing a strategic approach and shaping a heritage implementation plan for Luton (five years and beyond).

(i) The emergent key major projects have been discussed with the National Lottery Heritage Fund. They have recommended and support an application for a five-

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year bid to programme manage feasibility and support community projects to help each other.

The Current Position 4. Following public consultation (online survey and workshops) and stakeholder focus groups, The final heritage strategy is attached as appendix 1. A shortened version is also attached as appendix 2. The local list dynamic appraisal framework is attached as appendix 3 ( will form an appendix to the strategy document)

(i) Strategic priorities have emerged from consultation with major funders and to support Luton 2040 and all key delivery partner outcomes.

(ii) The approach of focusing on zones (as emergent ‘non-designated heritage zones), involving community decision making in embedding heritage interpretation and developing design codes, is predicated UK Government ‘Planning For The Future’ proposal to position place-making, predicated on heritage, at the heart of post-COVID regeneration; dovetails with the new Town Centre Masterplan activity zoning; is inspired by The Hat District as an existing local model; and develops on from designated heritage conservation areas without the burden of statutory obligation.

Goals and Objectives 5. The ten-year strategy document signifies a collaborative partnership ambition to ‘curate the town’. To recover, regenerate, re-connect and re-imagine. It is intended to provide a framework for an ambitious Place-making Heritage Implementation Plan as mentioned above.

Proposal 6. Adopt this strategic approach, support major projects emerging, and agree with the recommendations within each heritage section of the strategy (turning them into committed action points in the heritage implementation plan), agreeing on heritage at risk as an action priority, and considering delivery partnership infrastructure.

(i) emergent major projects:

 Natural Heritage: (capital project) o The River Lea o de-culverting o as Linear Park o Wardown Lake

 Built Heritage: (toward capital projects)

o Feasibility study toward the potential of opening High Town underground War Tunnel as visitor attraction (2039 - Centenary of WW2)

o Extending the Hat District to encompass existing hat makers in High Town (supported by existing hats & headwear ‘significance’ collection)

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 Industrial Heritage (toward capital project) o Siting Luton as a centre of engineering excellence (motor and aviation); positioning Vauxhall Heritage Collection as an international visitor experience in Luton (supported by Mossman road transport significance collection)

 Cultural Heritage (non-capital project)

 Heritage Interpretation Implementation Plan: development of a five- year place-making/place-activation plan

 Intangible heritage (non-capital project) o Digital archive management: developing best practice partnership and community infrastructure for centralisation, conservation and preservation of definitive dynamic Luton digital archive and oral history collection (scoping past and future)

(ii) Considering delivery partnership infrastructure

Following the adoption of the heritage strategy by all key delivery partners, the heritage implementation plan development and delivery will be guided by a steering group of key strategic partners. This would follow a similar model to that set up for the Arts and Culture Strategy Group. In terms of the future delivery of the heritage implementation plan: there are strong strategic and community delivery partners in natural, industrial and cultural heritage areas. But re: built heritage, the council is in a unique position because of its statutory planning responsibilities.

i. The need to develop a more formal relationship with Luton Heritage Forum (in line with their governance development funded by NLHF Heritage Fund) re: the built environment will be crucial for the heritage implementation plan delivery

ii. We discussed with the St. Albans planning department their relationship with the award-winning community engagement design code charrette group LOOK!StAlbans who have an MoU with the council to host design code workshops, facilitated by a third party (e.g. The Princes Foundation) paid for by ‘sympathetic’ developers (in lieu of or as well as conservation heritage consultancy reports) and look to piloting this re: the former ABC site. We have a sympathetic developer but would need an MoU between LBC and the Heritage Forum to proceed with a charrette in the Autumn.

Key Risks 7. Not to have stakeholders sign off/ un-adopted strategy jeopardises and/or delays significant heritage grant funding/ inward investment.

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Consultations 8. Stage 1: extensive public consultation (online survey and workshops); stage 2: stakeholder focus groups; stage 3: individual engagement with key delivery partners and members.

Alternative options considered and rejected (please specify) 9. To reject the recommendation

10. To request further information

Appendices Attached Appendix 1 – The draft Heritage Strategy Appendix 2 – shortened version of the draft strategy Appendix 3 - Integrated Impact Assessment

List of Background Papers - Local Government Act 1972, Section 100D  Local List Appraisal Framework

Implications - an appropriate officer must clear all statements

For CLMT only Legal and Finance are required Required Item Details Clearance Dated Agreed By Legal Under the Planning (Listed Buildings and Paul 23 July Conservation Areas) Act 1990 the Council McArthur 2021 has a duty to formulate and publish proposals for the preservation and enhancement of conservation areas. In addition, para 185 of the National Planning Policy Framework advises that plans should set out a positive strategy for the conservation and enjoyment of the historic environment, which should take into account the desirability of sustaining and enhancing the significance of heritage assets and also the wider social, cultural, economic and environmental benefits that the conservation of the historic environment can bring. Consideration of any legal implications of actions proposed in the strategy will be needed in due course.

Finance The development of the strategy has been Darren 26th July funded through The National Lottery Heritage Lambert, 2021 Fund. A further bid is to be put into fund the Finance implementation plan programme and enable Business the Heritage Enabler post to be extended. Partner

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Item Details Clearance Dated Agreed By There is a small budget within the LIF / Luton 2040 reserve to also deliver against this work.

Delivery of any capital projects arising from the Strategy where the Council is the lead organisation or is required to make a financial contribution will need to be included in the Council’s approved Capital Programme. Similarly, any bids for external funding to deliver projects will need to identify any financial impliations for the Council, including ongoing revenue costs. Equalities / No specific issues. The strategy includes and Maureen 28 July Cohesion / involves all communities and demographics Drummond, 2021 Inclusion and has involved extensive consultation. Equality and (Social Diversity Justice) Adviser Environment No specific issues. There will be a positive Shaun 27th July impact on the environment, emphasising Askins – 2021 heritage, including embedding diaspora, Service conservation, preservation, and sustainability Manager with a particular focus on natural heritage. Strategy & Sustainability Health No specific issues. There are many positive Matt Corder 26.07.2021 impacts on health and well-being as well as Public Health civic pride. Service Manager Optional Item Details Clearance Dated Agreed By Community Safety Staffing

Other

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Page 96 of 284 Appendix 1 Curating Luton A new Heritage Strategy 2021-2031

This new, co-created Heritage Strategy for Luton signifies a collective ambition to curate the town.

Vision: ‘Luton's sense of place is anchored through its heritage; where wellbeing, civic pride and our identity as a proud industrious working-class town can be celebrated and sustained’

Page 97 of 284 Curating Luton A new Heritage Strategy 2021-2031

Contents

How we co-produced our heritage strategy

Foreword

Executive summary 1. Strategic priorities  place-making  embedding diaspora and diversity into heritage interpretation narratives  embracing digital innovation  conservation, preservation and valuation  improving prospects for young people  ‘Future-proofing - beyond sustainability

2. Strategy framework – mapping our assets 2.1 The tangible: our physical environment 2.1.1 Luton's natural heritage 2.1.2 Luton's built heritage 2.2 Where the tangible and intangible connect: 2.2.1 Luton's industrial heritage Brewing and pubs Luton’s hat industry Luton as a site of engineering innovation and excellence 2.2.2 Luton's cultural and community heritage – the heart of the matter

2.3 The intangible: making our invisible, visible 2.3.1 heritage craft skills 2.3.2 a digital archive for Luton

3. Emergent non-designated heritage zones

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3.1 St. Mary’s Heritage Zone: a significant social history quarter 3.2 Hat Industry Heritage Zone: High Town and Plaiter’s Lea – strengthening and growing our Hat District 3.3 Engineering Heritage Zone: Luton as a site of engineering innovation and excellence (Luton Airport and Vauxhall Motors) 3.4 River Lea Linear Park Heritage Zone 3.5 British-Asian Heritage Zone

4. Responsibility for delivery - a joined-up partnership approach 4.1 How you can contribute 4.2 Partnership infrastructure 4.3 Next steps

Page 99 of 284 Curating Luton A new Heritage Strategy 2021-2031

Foreword

I am delighted to present Luton’s Heritage Strategy for 2021-2031. This is an important document that, alongside our Arts and Culture Strategy, will be central to our shared ambition to transform lives through arts, culture and heritage as we seek to deliver on our town-wide vision for Luton 2040.

This strategy has been prepared against the backdrop of the Covid pandemic, and I am incredibly grateful to everybody who has committed their time and energy to co- produce this strategy, including the hundreds of residents and partners that took part in our consultation.

This is an extremely timely strategy as we emerge from the pandemic. I am certain that heritage will be integral to both our economic recovery and our aims to improve the wellbeing of our population as we build a healthier, fairer and more sustainable town where everyone can thrive.

The case for supporting our town’s heritage is clear, with benefits to our local economy, our wellbeing and our environment. Heritage activity adds an estimated £1bn to the local economy each year, and for every £1 invested by the public sector, around £1.60 is generated in return. We also know that retrofitting historic buildings can result infewer carbon emissions than some new buildings.

Besides these benefits, we also know that supporting heritage helps to create a sense of place, strengthening our collective identity and pride in our community.

This strategy sets a clear direction for how we will work collectively with partners and residents to put heritage at the heart of our recovery and our ambitions for Luton 2040.

Heritage will be at the heart of our place-shaping efforts as we reimagine our town centre and transform our communities, our neighbourhoods and our greenspaces. The strategy will also help us to preserve and protect our most valued heritage assets, reflecting and embedding the diversity of all parts of our community. It will also enable us to promote skills and opportunities that transform lives, especially for our young people.

This is a highly ambitious strategy that will require collaboration, innovation and input from all parts of our community, including residents and organisations across all sectors, and I look forward to working closely with everyone in Luton to deliver on this strategy.

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Cllr Robert Roche Portfolio Holder for Sustainable Development

Page 101 of 284 Curating Luton A new Heritage Strategy 2021-2031

How we co-produced our Heritage Strategy

Stage 1: public consultation survey - first ran February 2021 to March 2021; re-opened for use during public consultation workshops

Stage 2: public consultation workshops – 12 community workshops between March and May 2021 Stage 3: four stakeholder focus groups – May and June 2021

Stage 4: draft documents and input from key strategicdelivery partners and elected council members

We have engaged with more than 300 individuals and more than 30 stakeholder group representatives to co-produce this strategy.

Our formal online consultation ran from February to March 2021, with 152 responses. Of these responses, 66% came from people who had never engaged in heritage activity before.

This engagement has helped to widen participation in heritage further:

 almost half of all newly engaged people wanted to be involved in long term strategy development and monitoring  68 new people asked tojoin meetings of the Luton Heritage Forum  30 individuals wanted to be involved in work to review Luton’s local list  10 community representatives were invited to take part in testing our local list appraisal framework

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Public Consultation Survey April 2021 Number of responses by individual or organisation type

140 123 120 100 80 60 40 12 20 7 2 5 3 0 Individuals Business Faith Community Education Charity or VCS Not selected Establishment Group

We asked : “What is heritage: what does the word mean to you?”

Public Consultation Survey April 2021 % of survey respondents by ethnicity (144 people responded to the ethnicity question)

80.0% 69.6% 70.0% 60.0% 50.0% 40.0% 30.0% 20.0% 8.8% 10.0% 2.9% 0.0% African-Caribbean Asian White

At the end of April 2021 - we were not satisfied that engagement with the online survey was representative of Luton demographics. Our intention is to widen engagement with heritage, so we increased:  Consultation with African and Caribbean communities by organising 3 different focus groups (including ACCDF and Heritage Alliance); and se veral 1:1 meetings involving representatives from ACCDF; UK Centre for Carnival Arts; and Heritage Alliance.

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 Engaged young people from RevoLuton to facilitate public consultation workshops; and awarded seed funding to fund projects involving young heritage ambassadors.  Re-opened the online survey following specific stakeholder meetings, for example with young people and Luton Irish Forum; and  Increased engagement with individuals and communities of Asian descent through direct invitation to Luton Heritage Forum public feedback sessions.

We are also developing strategies and frameworks for engagement of wider audience participations in heritage decision making and consequent heritage strategy implementation planning; and have developed two specific heritage strategic priorities to support this.

Further details can be found in the consultation report.

Executive summary

This new, co-created Heritage Strategy for Luton signifies a collective ambition to curate the town. It is, in effect, a commitment: to a future 10 years of 'joined-up' partnership working to deliver a town-wide vision of making Luton a healthy, fair and sustainable town, where everyone can thrive, and no-one has to live in poverty. This strategy is a commitment to transforming lives through embedding heritage at the heart of post-Covid regeneration planning.

We want to thank more than 300 individuals who took part in our heritage consultation survey and the 30 stakeholder group representatives (including those from business, education, arts, culture and heritage communities) who took part in our strategy co-creation focus group workshops.

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This document builds upon the previous draft ‘Foundations for a Luton Built Heritage Strategy’ (2019) to embrace all categories of our town's tangible and intangible heritage (natural, built, industrial, cultural and community) and deliver, as promised, a new heritage strategy driving wider participation in heritage in Luton. Its' co- creation, using public consultation and stakeholder engagement as a point of departure, would not have been possible without The National Lottery Heritage Fund's support for a heritage enabler post.

Results from the public consultation survey can be found on the Let's Talk Heritage Consultation. In a series of workshops designed to open discussion and discover ‘What IS the heritage of Luton’, we investigated what the term 'heritage' means to us as individuals and how we collectively define and identify our tangible and intangible heritage assets: in other words, what we choose to value. Finally, we asked a series of questions to help map our heritage assets, develop a shared vision, a co-created heritage strategy, and shape the consequent implementation plan.

Through research, we have discovered best practice approaches. Through public consultation, we have collated and shared a deeper understanding of our collective heritage, what it means, where we come from and who we are. Through open discourse, we have discovered hidden heritage assets (and the need to reveal them).

We recognised our award-winning parks, nationally accredited museums, designated conservation areas, listed buildings, monuments and prehistoric earthworks. Beyond our physical landscape, Luton is a proud working-class town, continually re-created through generations of settling economic migrants and re-settled diaspora’s. We are proud of our multi-cultural population. We acknowledged the need to address the re- interpretation of our historical narratives and our commitment to embed diversity in all areas of heritage interpretation. We re-confirmed that resilience, tolerance, and compassion emerge as characteristics of what makes us 'Lutonian' through further discussion.

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This has been an unprecedentedly difficult year to embark on community engagement, but it has given us a wonderful opportunity to 'deep-dive', to research and reflect upon the wider meanings of 'heritage'; to discuss what we choose to collect and preserve for future generations, and consider how we cherish and value our collective heritage.

This strategy hopes to address the different frameworks and valuation methodologies we can apply to help us protect local heritage assets. We are commited to develop an inter-sectional local list that will include public art, natural heritage and architectural features, as well as whole buildings, acknowledging heritage assets which are valued by our local communities.

This strategy underpins and explains how we can implement post-Covid recovery by leveraging both our own shared research and monitoring data and the government’s current incentivising of investment in repair, maintenance and public appreciation for heritage. Investing in the historic environment generates economic returns for local places.

There are economic, sustainability, and public health and wellbeing arguments for committed investment in heritage:

“The heritage sector is an important source of economic prosperity and growth with a total Gross value Added (GVA) of £31billion equivalent to 1.9 per cent of national GVA.” (Historic England).

“England’s heritage sector generates a larger GVA than the security industry, defence industry, aerospace industry and the arts and culture industry combined… £7.1 billion in GVA was generated by heritage-related construction activities in England in 2018.” (Centre for Economic and Business Reseaerch (Cebr).

“25% of businesses surveyed agreed that the heritage setting was an important factor in their decision to locate” (case: The role of culture, sport and heritage in

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place shaping - Trends Business Research Ltd, NEF Consulting Ltd and Middlesex University, October 2016)

“60% of creative industries based in historic buildings are start-ups“ (National Lottery Heritage Fund).

“Heritage-based tourism is worth £20.2bn to the UK economy per annum. Overseas visitors to UK cultural, historic and natural heritage attractions spend more than double per visit (an average of £560) compared with their domestic overnight counterparts (an average of £210 per trip) (our research, 2016).” (Economic Insight into the impact of the Coronavirus (COVID-19) across the Heritage Sector in the UK 2020 ) https://www.heritagefund.org.uk/sites/default/files/media/attachments/Economic%20I mpact%20of%20Coronovirus%20March%202020_0.pdf

"When a typical historic building is refurbished and retro-fitted, it will not only create jobs but also emit less carbon by 2050 than a new building" (https://historicengland.org.uk/research/heritage-counts/).

"Investment in environmental adaptations can consistently deliver high returns, with benefits between two and ten times the cost…" (Foreign and Commonwealth Office, 2020).

“Participation in culture, sport, or heritage has positively influenced education choices, health and wellbeing, social cohesion, and economic participation” (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attach ment_data/file/416279/A_review_of_the_Social_Impacts_of_Culture_and_Sport.pdf).

“The NHS saves a yearly total of £11.91 for every person partaking in cultural or sporting activity, from a reduction in GP visits and use of psychotherapy services (Department for Digital, Culture, Media and Sport (DCMS)). Based on this figure,

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there is the potential to save the NHS £2.5m each year locally through participation in arts and culture (based on Luton’s population of 213,052).

Different types of 'heritage at risk' are acknowledged within this strategy framework and the need for preservation and protection are highlighted within every category. Natural assets tend to be protected nationally through a legal and policy context set by Natural England, reporting to Defra, while national protection for the more ‘historic’ built assets are protected through Historic England, reporting to DCMS (Department of Culture, Media and Sports). Identifying our local 'heritage at risk' will be a dynamic process that will help shape our future implementation action plans. As we ‘recover’ our heritage, the risk register will change over 10 years: reflecting our achievements and our priorities.

Like many towns, Luton has felt the impact of Covid. Consecutive lockdown measures have accelerated the decline of our historic high streets (two of which are nationally designated conservations areas). The impacts on retail and hospitality have especially affected the income of young adults, many of whom begin their careers in these sectors. Education has been interrupted, and a move towards homeworking has disrupted the chances of young people to enter into worthwhile training and apprenticeships. This strategy addresses meaningful ways we can use heritage to improve prospects for our young people. For example, investigating how transferable employment skills might be gained through developing a modular heritage apprenticeship, and using the ‘High Street Heritage Action Zone’ model as best practice for our town centre regeneration.

The need for joint arts, culture and heritage ‘place-making and place-activation planning (to compliment the Town Centre Masterplan and emergent planning design codes) is necessary to embed our heritage narratives of diaspora and diversity across the town.

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The experience of Covid related deaths has impacted all areas of our super-diverse population. For example, our airport (itself a site of heritage) has been in most part closed for a year, preventing people overseas from travelling to honour deceased loved ones, which has been particularly painful for Luton's highly transient population.

Our heritage consultation has identified how residents from all communities and backgrounds have experienced losing loved ones and the loss of cultural and intangible heritages associated with funeral rites and bereavement customs. We heard this from our Afro-Caribbean, Irish, South-Asian and Roma communities and various religious groups, particularly our Islamic population. So to mark this significant period in recent history, a new heritage memorial: a town centre monument, embracing digital innovation, is being created https://ourriver.uk/ .This will offer our communities a space to reflect upon local lives impacted by Covid; a space for remembrance, and a space for inspiring our hopes for the future. It is the intention that this new Heritage Strategy for Luton may offer the same.

1. Strategic priorities Allegiance through values shared by all key delivery partners (set out below) and delivering a robust heritage strategy, driven by wider participation, will help us secure a strong economic and social recovery following the impacts of Covid. Through community and stakeholder consultation, what has emerged is the need to entrench the strategic priorities (detailed below) within all areas of our heritage decision- making and implementation.

These strategic priorities align with those within the Luton 2040 vision, The Inclusive Economy Strategy, The Population Wellbeing Strategy, The Culture Trust, Luton's Business Plan, The Wildlife Trust (Bedfordshire, Cambridgeshire and Northamptonshire), Chiltern Conservation Trust, the University of Bedfordshire and the corporate values of London Luton Airport. They support project objectives of the

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University of Bedfordshire’s Heritage Impact Accelerator and Heritage Enterprise Hub, Luton Heritage Forum’s constitution, and the National Lottery Heritage Fund's priority outcomes:  place-making  embedding diaspora and diversity into heritage interpretation narratives  embracing digital innovation  conservation, preservation and valuation  improving prospects for young people  ‘future proofing’ - beyond sustainability

"I've not been to many places that have such an established sense of self" (Rae Leaver – Lutonian – from public consultation heritage workshop March 2021)

Strategic priority: place-making The aim of ‘place-making’ is to connect local people with public space and improve the perception of the public realm. This heritage strategy investigates the relationships between nature, historical buildings, public art, and culture more fully, and how through two of its’ strategic priorities, ‘place-making’ and ‘embedding narratives of diaspora and diversity’, we can embed heritage interpretation in our townscape.

There are two grounded reasons for investing in place-activation: civic pride and wellbeing. Using heritage interpretation as an anchor for place-activation will help make Luton a better place to live, work and visit. Economic regeneration will mean our economy can be boosted through tourism and inward investment. The Nobel Prize-winning economist, Robert Merton Solow stated that "over the long term, places with strong, distinctive identities are more likely to prosper than places without them”. This strategy endeavours to unwrap Luton and identify its tangible and intangible characteristics.

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“People spend more in their local economy after investment in the historic environment” (English Heritage - Imapct of Historic Envionment Regeneration Final Report 1 October 2010, Amion Consultancy and Locum Consultancy). Investing in the historic environment can successfully increase footfall: evaluation evidence from the Derby Partnership Scheme in Conservation Areas (PSiCA) shows that while average footfall on high streets around the nation dropped by 26% between 2008 and 2013, the Derby PSiCA areas reversed a spiral of decline through heritage-led regeneration and saw footfall growth between 12% to 15% in the same period (Historic England Heritage and the Economy 2019 Heritage Counts) . If this strategy truly signifies a collective ambition to curate the town, then it also signifies a partnership commitment to our ethos and approach to place-making; to embed our town's heritage as a place of making, at the beginning of our post-Covid recovery journey. Place-making invites people to collectively reimagine, reinvent and re- connect with their public spaces.

Place-making promotes wellbeing through better urban design by identifying the characteristics of and supporting, the ongoing evolution of each urban area. Place- making is both an ethos, and a practical approach to improve place management. It focusses on collaboration, communication and connections and mutual responsibilities. This heritage strategy seeks to address issues of re-connectivity: between Lutonian’s and Luton and between Lutonian’s and their individual heritage. In line with new planning guidelines, this strategy is a commitment to placing our heritage at the heart of our place-making.

Aligned with our Arts and Culture Strategy and ambitious Town Centre Masterplan, place-making will be supported by our Public Art Plan and updated Local Plan and policies. This strategy is a partnership commitment to place management: we will continue developing local government heritage conservation management plans for our nationally designated conservation areas and involve our community in developing design codes in those areas.

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Place management and place-activation are both the process and outcome of place- making. Without people, without interactivity, we have no sense of ‘place’. "We need communities to take responsibility for their towns ….experiences in towns based on heritage activities and events are not wishy-washy; they actually work. If you go to Stockton-On-Tees, which has 97 events a year, it creates footfall and, as a consequence, you get commerce around it, so it does work." (Bill Grimsey, previous CEO of companies such as Wickes, Iceland, and Focus Do It All; the Grimsey Review November 2020).

Our heritage implementation plan will include a joint arts and culture place-activation plan to support further aspirational community-led visions like the Hat District Future Scope and the Creative Bury Park Manifesto. Those that protect and engage us with our natural environment, like the Luton Lea Catchment Partnership and those that help redress our hidden cultural histories, like The Luton Windrush Partnership Programme (LWPP).

We will also invite artists, individuals, and community groups to initiate innovative heritage-led place activation projects by developing a heritage fund. In this way, place-activation becomes integral to our management processes and Heritage Implementation Plan. Using heritage as a key driver in ‘place-making’ will facilitate greater involvement. In addition, heritage-led ‘meaningful’ place-activation will help us to improve our town centre offer, increase wellbeing, develop an inclusive economy and reposition Luton as a destination town. Embedding heritage will anchor Luton’s ‘sense of self’, transforming it into ‘sense of place’. Target outcomes:

 We will work in partnership to develop and deliver ‘Place-making’: our heritage implementation plan, including the use of community charrette style workshops to develop design codes within our heritage conservation areas. (a ‘charrette’ workshop enables civic decision making).

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 We will develop a Heritage Fund to support artists, individuals and community groups to initiate innovative heritage-led place activation projects (LBC LEAD).

Strategic priority: embedding diaspora and diversity into heritage interpretation narratives Through public consultation, we discovered a defining characteristic of Luton, summed up by the word ‘diaspora’: Luton is a place of re-settlement.

From the first migrations of agricultural workers and Scottish straw plaiters into its hat industry in the eighteenth century, the fabric of Luton is woven through generational stories of continuous politically displaced and economic immigrations. Luton has become a destination home for global settlers from every continent of the earth and is one of only four towns in the UK with a ‘super-diverse’ ethnic mix. The heritage of Luton is a story of ever-changing diasporic waves. For example, “Luton’s Irish population grew most rapidly between 1951 and 1961, reaching a peak of 5.8 per cent of Luton’s population by 1971 before beginning to fall again after 1981” (Walter 1986, from The Long Term Sustainability of Luton Irish Forum, McElhatton 2010*).This is just one illustration of our transient waves, the ‘rise’ and ‘fall’ in our changing demographics, which are largely the result of the town’s offer of economic prosperity. The story of Vauxhall as a magnet offering financial security reached its peak in the 1970s, and this intrinsic relationship is investigated further in the Industrial heritage section of this strategy document below.

The Windrush Generation also helped shape Luton with people arriving from Caribbean countries between 1948 and 1971. For example, waves of Irish and Afro- Caribbean nurses helped develop our Luton and NHS University Hospital. This is further investigated in the Cultural Heritage section of this strategy. Between 2001 and 2011, the Afro-Caribbean population in Luton grew from 11,700 to 19,800, and our Asian populations continue to grow, as Luton’s Bury Park has emerged as a British-Asian success story.

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Through public consultation, we also discovered barriers to engagement in heritage based around ethnicity; and learned about the huge responsibility that lies with us all to curate Luton’s rich diasporic history. Heritage is the physical embodiment of our story, and Luton has an overflowing abundance of stories. We have recognised the direct correlation between our museums’ collections policies and engagement. Re- addressing, our history and heritage narratives, is currently a nationwide discourse ignited by international movements like Black Lives Matter. The Culture Trust, Luton has taken the lead in addressing current issues around representation through working with a curatorial specialist, and how we include demographic representation is discussed further through our ‘conservation, preservation and valuation strategic priority below.

The nature of diaspora, our intangible heritages, is also one of broken lineage, and this will be addressed further in the intangible heritages section of this strategy. Luton’s 2021 demographic census results are not yet available. Still, they will shape the delivery of how we embed diaspora and diversity narratives into all areas of our heritage implementation plan as a strategic priority.

Target outcomes:

 we will work in partnership to widen participation and breaking down barriers to heritage involvement

 we will work in partnership to embed diaspora and diversity narratives into all parts of our heritage implementation plan

 we will make best use of the 2021 demographic census results for Luton to further shape these narratives (LBC LEAD).

Strategic priority: embracing digital innovation

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Essential to supporting both future-proofing and place-making, embracing digital culture is an absolute must. Regarding its role in place-making: we have a fantastic opportunity to embed innovative digital technologies within infrastructure and physical regeneration. We can learn from several best practice models that use Augmented Reality (AR) to embed heritage as a key driver in ‘place-making’, inward investment, destination tourism and community engagement.

For example, taking inspiration from consortiums developed to deliver Historic England’s High Street Heritage Action Zones, using creative partners and community groups, ‘Sounds UK’ (sound generator artists) have created immersive heritage story worlds. Closer to home, we can build on pilot community-level as well as, student-led as well as research projects by the University of Bedfordshire. Beyond the Arts and Culture Projects team’s heritage activity, a further illustration is activity led by the Research Institute for Media Art and Performance (RIMAP), based within the Faculty of Creative Arts, Technologies and Science, including in-situ cross-media storytelling initiatives; and harness Luton’s home-grown augmented reality and artificial intelligence skills-base. Additionally, The University of Bedfordshire’s Arts and Culture Projects team, based also within the Faculty of CATS, has been an active partner to HSAZ consortiums in other areas of Bedfordshire and this regional activity and learnings can be harnessed for the transactional benefit of Luton.

Our heritage implementation plan will also develop the use of GPS (Global Positioning System) technology in the dynamic process of updating, recording and reviewing our designated and non-designated built heritage assets; and support the use of shared digital technologies by partner organisations, for example, Luton Heritage Forum, in work around both heritage trails and our local list.

Emergent from stakeholder engagement is the need for a coordinated collective Digital Archive Management approach to preserving Luton’s oral history and digital collections. This is one of two projects emerging in the Intangible Heritage section of this strategy.

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Consultation with stakeholders and delivery partners has identified the need for coordinated real-time dynamic natural heritage biodiversity data collection. Some decisions around managing our natural environment have been based on 10-year- old survey data. Aligned with our ‘Future-proofing: beyond sustainability’ priority, this strategy supports local research programmes to develop engineering solutions and commits to embracing digital innovation in all areas.

Target outcomes:  We will work in partnership to harness our digital and artificial intelligence skills base locally, building on pilot projects, to embed heritage as a key-driver in place- making.

 We will work in partnership to develop the use of GPS technology to record and review our heritage assets and develop our local list.

 We will work in partnership to establish a coordinated dynamic approach to data collection

 We will work in partnership to use best practice digital archive management.

Strategic priority: conservation, preservation and valuation As in "our collective ambition to curate the town", the ar of curation is the act of selecting, organising and looking after our collective heritage. This section of the strategy addresses how we arrive at decisions about heritage, what we value, what we choose to preserve, the policies, mechanisms and capacities of how we preserve it, and the valuation methodologies we use to support and resource preservation mechanism and capacity. Conservation is generally associated with protecting

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natural resources, while preservation is associated with the protection of buildings, objects, and landscapes.

To ensure true co-creation:  We asked: ‘How do you define 'heritage'?’This was to ensure that we embed a collective voice in our understanding.  We asked, ‘Which category of heritage is most important to you?’ We strive to include all areas of heritage in this strategy, and the answers to this question can help us prioritise implementation timelines, shape milestones and resource capacities.  We asked, ‘What is your favourite building and why?’ This is so that we can include what is valued in our local list review and so that we can deep-dive into the stories of individuals and communities who have used the buildings.  We asked, ‘Who is your favourite Lutonian and why?’ This is so we can remember and appreciate people within our coordinated heritage trails or, for example, through a local Blue Plaque Scheme.  We asked ‘What is your favourite heritage feature?’ and ‘What do you think is Luton's best-kept heritage secret?’ This helped us to reveal the hidden, overlooked or privately owned collections.  We asked, ‘What is a Lutonian?’ The answers can help us shape heritage interpretation narratives; and  We asked what you think is most synonymous with Luton. This data helps us understand the town's distinctive identity and ensure we make decisions about collections and curation based on the town's sense of self.

Protective frameworks exist for our tangible heritage: our built and our natural environment. For example, we have clear selection guidelines for what types of monitored biodiversity together constitute a County Wildlife Site demarcation. We have clear terms of reference for the professional steering groups who decide upon those guidelines. We have clear frameworks for establishing nationally designated conservation areas and nationally listed buildings in our built heritage.

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Through consultation, we discovered that groups of, often hidden, architectural features can create a local characteristic (for example ‘the Victorian features of High Town), and that continuity and historical use-value. In other words, the stories of people and communities connected to the buildings are what makes a building meaningful in terms of our local heritage. We learned that we need to use adjusted appraisal frameworks, scoping mechanisms, selection criteria and valuation methodologies to create a list of local built heritage assets and non-designated heritage zones that are meaningful for our communities. These emergent non- designated heritage zones are addressed in Section 3.

Through public consultation, we learned that place and street naming is an important mechanism for acknowledging our history and, in this way, representing therefore protecting and preserving our heritage narratives, forming a thread in our heritage implementation plan.

Our museum collections are tangible objects, and like our townscapes, need to be curated to represent our histories. We currently have local collections of natural history, archaeology, costume and textiles, fine art, local history archives and records, social history, community, industrial and military, and two ‘significant’ collections: ‘Hats and Headwear’ and ‘Horse Drawn Vehicles and Road Transport’. These collections are to some extent protected by being held in accredited museums.

We heard of several artefacts and collections of memorabilia held in community or private ownership through our public consultation workshops, vulnerable to being lost to the town. A centralised digital archive management project beginning with a town-wide audit can protect digital, photographic and oral archives for future generations. Some valuable heritage assets in private collections, including larger paintings and artefacts of national significance as well as local importance, such as the Vauxhall Car Collection, which until recently was housed in the former Vauxhall

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Heritage Centre, were also identified as being vulnerable. Private collections of tangible heritage and memorabilia identified as in danger of being lost include those around the socio-economic importance of Vauxhall Motors, our Windrush Generation and Bangladesh communities. The Culture Trust, Luton is working with a curatorial specialist, who provide advice and support to ensure that our collections policies, plans and practice are developed in response to current issues around representation.

The most difficult to audit and protect are our intangible heritage assets: our community oral histories, our digital archives, our faith, customs, traditions, and our heritage craft skills. Through this year of research and consultation, we have identified a diverse range of digital heritage projects across town: from Hatters Heritage (150 years of the social Town Football Club) to Kadam Dance (Asian dance and music); and hidden community archives (such as those with our Bangladesh Communities).

We will develop a steering group to lead on the review of conservation, collections policies and protection frameworks to ensure that they support the delivery of major projects within our developing Heritage Implementation Plan. We will support community-led activities that help to collect and collate socio-economic and cultural evidence to support the development of our ‘significant collections’ towards national designation.

Stewardship of our heritage assets, tangible and intangible, is enabled through partnership funding, which in turn is facilitated through our audit and valuation frameworks.

The government, via Natural England, has established a Natural Capital Approach to valuing natural heritage, and through DCMS, is developing a framework for valuing heritage using social cost-benefit analysis principles published in HM Treasury’s Green Book: an asset-based approach, beginning with built heritage.

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Using a range of tangible assets that are appropriate to be measured by economic values, alongside other information, both quantitative and qualitative, can create a robust evidence base not just for our built heritage but also across our cultural heritage and industrial heritage planning. The aim of accurate articulation of the value of associated services, social offers, and benefits provided by heritage assets is to support decision making. DCMS has issued research calls towards developing a database of values for a range of heritage assets and a set of heritage capital accounts.

There have been various frameworks for calculating the economic value of heritage assets, for example:  The Economic Value of Heritage: A Benefit Transfer Study (nesta.org.uk)  Measuring Economic Value in Cultural Institutions (ukri.org); Guidance Note - How to estimate the public benefit of your Museum using the Economic Values Database_0.pdf (artscouncil.org.uk  Valuing Heritage Assets, Final Report of a Reserach Project. Examining the case for the Valuation of Heritage Assets. Prepared by Kingston University on behalf of RICS and HM Treasury March 2009  https://www.ipsasb.org/publications/financial-reporting-heritage-public-sector- 0

This strategy recommends the adoption and consistent use of the most recent DCMS framework: Valuing culture and heritage capital: a framework towards informing decision making (January 2021).

This strategy supports a partnership approach to investigating collaborative opportunities for asset audit (data monitoring) and research to contribute to this field; and to use the Heritage Capital framework to help us value our heritage, attract inward investment and deliver our developing Heritage Implementation Plan. This, in turn, supports our strategic priority of ‘Future-proofing –‘beyond sustainability’.

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Target outcomes:

 We will diversify our collection at Wardown House Museum and Gallery, the study centre and young people’s programme in order to widen community audience and engagement in Museum events exhibitions and programmes. (CULTURE TRUST LEAD)

 We will work in partnership to co-produce and update dynamic local lists and heritage at risk registers and will identify heritage management and heritage implementation plans to prioritise protection and care for assets identified.

 We will develop a steering group to lead on the review of conservation, collections policies, protection frameworks and valuation methodologies as part of our implementation plan.

 We will support Museum Makers and other volunteer and community-led activities that widen engagement and awareness in heritage assets.

 We will develop community and stakeholder groups, to help collect and collate socio-economic and cultural evidence to support major heritage projects and protect our heritage assets (LBC LEAD).

 We will prioritise a partnership approach to the audit and valuation of heritage assets, using the Heritage Capital framework.

Strategic priority: improving prospects for young people Children and young people across the country have been disproportionately impacted by the pandemic, in terms of missed education and, more broadly, their social, emotional, and mental health.

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Luton has one of the youngest demographics in the country: a fifth of our population are under 16Young people are by nature creative, energetic and dynamic. Impacts of Brexit and consecutive Covid lockdown measures have detrimentally affected prospects of young people in the UK more than any other age group.

An accelerated decline of our historic high streets and impacts on retail and hospitality have especially affected the income of young adults, many of whom begin their careers in these sectors; education has been interrupted, and a move towards homeworking has disrupted the chances of young people to enter into meaningful training and apprenticeships.

In Luton, two of our designated conservation areas include historic high streets (George Street and High Town). Although neither are Historic England funded ‘high street heritage action zones’, we can use this best practice model as a framework to model economic, social and cultural recovery and help breathe new life into them for future generations.

The ability to engage young people in the consultation process and co-creation of this strategy has been hampered as schools have had to focus on Covid lockdown and testing rather than extra-curricular activity, and youth organisations have had to focus on consequent mental health issues, such as isolation and anxiety.

We have had some engagement with young consultation facilitators holding inter- generational workshops and through individual youth heritage ambassadors; and have heard through consultation that “for many young people in Luton, heritage is pain”. This theme is investigated further in our intangible heritage section. To ensure that we engage young people in heritage strategy development, and for several positive reasons, this strategy will be revisited and reviewed within 2 years, and mechanisms for the inclusion of decision making by young people are included in our developing heritage implementation plan.

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Luton’s town motto ‘Scientiae et labori detur’ (by science as an industry) signifies our heritage as an innovative and industrious town. This strategy seeks to address how meaningful heritage engagement might improve prospects for our young people. Considering:  Luton as a site of engineering excellence in motor and aviation industries, supporting historical equality in STEM (Science Technology Engineering and Mathematics)  the global reputation of our eco-system of hat makers, devastatingly impacted by Covid, as creative designers and international trend-setters  current innovative and engineering opportunities in cultural and creative augmented realities industries  educational opportunities in sustainable science and biodiversity monitoring

We asked: ‘What might a heritage apprenticeship look like in Luton?’ and ‘How might our heritage action zones and conservation areas be developed to support skills training from school through to post-graduate level?’

The DCMS ‘Culture & Heritage Capital Programme’ relies on heritage science, as a growing area, to help us value our tangible heritage assets. A heritage conservation apprenticeship of modular design might combine work experience with our local heritage conservation construction specialists, academic study of heritage science, and Historic England Conservation Accreditation. A natural heritage apprenticeship could address local needs for power tools and plant machinery qualifications, with biodiversity monitoring engineering studies.

A hat-making (and block-making) apprenticeship, for example, again of modular design, could offer education and skills training across all science, technology and engineering disciplines, as well as business entrepreneurship and might, for example, be delivered in partnership with the Queen Elizabeth Scholarship Trust (QEST). With national support from the UK film and television sector; and preventing

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international loss of hat-making skills and knowledge (as identified by the Heritage Craft Association’s ‘red list of endangered crafts’) modular heritage apprenticeships like this offer valuable and transferable contemporary industrial and real-life creative industries opportunities for our young people. Where better to consider working in partnership with educators and hat makers than through the development and growth of our Hat District? Target outcomes:

 we will involve children and young people in the review of the heritage strategy; and in the development of the heritage implementation plan through appropriate networks and mechanisms

 we will develop formal apprenticeship opportunities and accredited qualifications for children and young people that help to create opportunities and address Luton’s heritage needs

 we will partner with educational organisations in Luton and beyond to develop Ofsted accredited local heritage education resource packs

Strategic priority: ‘future-proofing’ – beyond sustainability Future-proofing means many things in terms of our heritage: from offering meaningful intergenerational engagement (ensuring heritage skills, historical knowledge and collective memory are not irreplaceably lost) to financial sustainability. Future-proofing lies in understanding. For example, how changes in national planning frameworks and the government’s navigation towards zoning and design codes will affect how we protect our conservation areas' integrity, authenticity, and characteristics and how we can map collective memories across non-designated heritage zones. It means revisiting our collections policies and community initiatives to ensure they support our major emergent projects to become key heritage drivers. It means developing infrastructure, governance, resources and community capacities to deliver in partnership.

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It means supporting a net gain approach to creating ‘heritage capital’ in all areas: natural, built, industrial, cultural and intangible. It means embedding future-proofing in partnership delivery and action planning, beyond sustainability, in all areas of our heritage implementation plan. Target outcomes:

 we will embed measures to future-proof our heritage through all aspects of our heritage implementation plan

 we will promote intergenerational engagement, including skills, knowledge and collective memory in heritage activity

 we will develop greater infrastructure, governance, resources and heritage capital within our communities

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1. Strategy framework – mapping our assets It began over 3,000 years ago with a natural spring emerging from ancient chalk downland. The spring created a marsh: and waters trickled and played. The chalk stream etched out a nourishing valley: and people came. The river supported animals and agriculture: a market town was born, and people came. From golden crops of hops and wheat: a brewing industry was born, and people came. Straw plait and lace went to market: a millinery and hat industry emerged, and people came: dexterous people. Transport and train lines connected the town into the tendrils of London, and national markets developed. The dexterous people upskilled: Luton developed as a centre of engineering excellence: aviation and motor innovation. At the invitation of the Luton Corporation, Vauxhall Motors re-located; an airport emerged: and people came, from all over the country, from all over the world. From these waves of diaspora, a diverse demographic developed. This is Luton.

This section addresses the whole range of our heritages: natural, built, industrial, cultural and intangible. We identify our heritage assets, protective frameworks, heritage at risk, recommendations, and action plan in each area.

2.1 The tangible: our physical environment 2.1.1 Luton's natural heritage National and local context Most green measures… (e.g. meadow and riverside land management, tree planting and improving the condition of green spaces generally) …have a high benefit:cost ratios, with multiple co-benefits for health and the natural environment as well as the economy. In line with the UK government's 2018 '25-year Environment Plan'* which sets out to achieve, amongst other targets, ' thriving plants and wildlife' and 'enhanced beauty, heritage and engagement with the natural environment', investing in 'Landscapes and nature' is one (of two) priority areas, identified by the Natural Lottery Heritage Fund** as priority areas in their strategic funding framework 2019- 24.

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This strategy sets out to support government intention to protect threatened species, provide richer wildlife habitats and open up the mental and physical health benefits of the natural world to people from the widest possible range of ages and backgrounds, "taking into account the often-hidden additional benefits in every aspect of the environment for national wellbeing, health and economic prosperity” * The 25-year Environment Plan * has six key policy areas. This new heritage strategy for Luton supports two: 'Recovering nature and enhancing the beauty of landscapes' and 'Connecting people with the environment to improve health and wellbeing' *. This strategy also supports the government's commitment to leading in environmental science and intends "to set gold standards in protecting and growing natural capital”*. Key partners are currently working together to deliver on the UK’s ‘biodiversity 30/30 net gain’ targets. * HM Government - A Green Future: Our 25 Year Plan to Improve the Environment ** Heritage Fund - Strategic Funding Framework 2019-2024

Current decisions around the management of County and District Wildlife Sites and our registered Sites of Special Scientific Interest (SSSI) have relied on monitoring data over 10 years old. This strategy recognises the resource and capacity needs: for co-ordinated real-time dynamic natural heritage biodiversity data collection; for environmental and social scientists, to collate and analyse the wealth of biodiversity data already collected (e.g. that available from Natural England), and to enable and train community volunteers to continue activities in this field.

Our natural heritage assets, significance and protection Our 2021 online heritage consultation survey asked: ‘What is your favourite heritage feature in Luton?’ Pride in our parks and natural environment came out top. We asked: ‘What is Luton's best-kept heritage secret?’ And again (along with strong evidence in built and industrial heritage areas – see below), an abundance of parks, gardens, bluebell woods, and other natural heritages were mentioned. In particular, the need to un-culvert the River Lea. Despite its' urbanisation and stretch to fill

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borough boundaries, Luton is rich in green spaces, parks and parkland. Six parks in Luton (Brantwood, , Memorial, Peoples, Stockwood and Wardown) successfully retain their internationally recognised 'Green Flag' status (October 2020), awarded by the environmental charity 'Keep Britain Tidy', for setting Ministry of Housing Communities and Local Government (MHCLG) benchmark standards including community involvement and environmental, biodiversity, landscape and heritage management. We are extremely proud of our green spaces in Luton and set out to protect them in various ways.

Nationally designated natural Heritage assets , Bury, , and The (Ian Finlay) Improvement Garden (in ) are nationally registered on the Historic England statutory Heritage 'Register of Parks and Gardens of Special Historic Interest in England' as historic parkland. Registration is a 'material consideration' in the planning process, meaning that planning authorities must consider the impact of any proposed development on the landscapes' special character.

Luton Hoo Luton Hoo Estate is outside of the local authority boundaries; the northern estate gates sit within. The Saxon word Hoo means spur of a hill, and the estate was passed from de Hoo, Rotherhamand Napier Families. One of four historic Luton country homes, the estate dates back to at least 1601 when Robert Napier, Third Earl of Bute, bought the estate. “…the then Prime Minister to George the Third and the famous landscape designer, Capability Brown, was engaged to redesign the surrounding parkland and gardens (which now extend to 1,065 acres). In 1903 the estate was bought by Sir Julius Wernher, a leading diamond dealer who commissioned Charles Mewes and Arthur Davis, the architects of the Ritz Hotel in London, to redesign the interior in a lavish Edwardian ‘Belle Époque’ style. During World War Two, the estate and mansion house was commissioned by Eastern Command, playing an important role in testing the Churchill tanks (manufactured by Vauxhall, Luton). The

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estate was also used as the base for Eastern Command and as a training farm for land girls. On 26 June 1948, Sir Harold Wernher and his wife Lady Zia, Countess Anastasia Mikhailovna de Torby, hosted a memorable visit by Sir Winston Churchill where 110,000 local people gathered to hear him address the crowd and thank them for their support during the Second World War. It is also a site of art, sporting and film making history: Sir Julius’s art collection, including several Faberge eggs were exhibited in the house in 1951. Well- known race horses including Brown Jack, who won 25 races in his 10-year racing career and Charlottetown, who won The Derby in 1966, were bred in the stables. The location has been used for filming productions including Four Weddings and a Funeral, Enigma, Eyes Wide Shut, Inspector Morse, Nicholas Nickleby, Vanity Fair and Bleak House.” (Detail from, Luton Hoo Elite Hotels website).The estate was purchased in 1999 by Elite Hotels, and following £60m refurbishment, was opened as an elite five star hotelwith an 18-hole golf course and spa in 2007.

Putteridge Bury “A magnificent neo-Elizabethan manor house built in 1911 in the style of Chequers, with a beautiful reflecting pool and massive yew hedges, set within 30 acres of landscaped gardens. One of three historic Luton parklands, its’ history can be traced back to Edward the Confessor (having links to the Domesday Book). The mansion was built by architects Sir Ernest George and Alfred Yeats; the grounds redesigned by Edwin L Lutyens (soon to be recognised as the foremost architect of the era) and planted by Gertrude Jekyll (one of the first lady Victorian gardeners). Queen Mary and King George the Fifth often visited with their son, the Prince of Wales, and on 1 December 1926, the King planted an oak tree in the lawn to the south of the house. It housed a prisoner of war camp in and after World War Two, and some German prisoners of war decided to make Luton their home after that (the theme of Diaspora runs strongly throughout the town’s history). In 1965 Putteridge Bury was acquired by Luton Council and, in 1966, opened as a College of Education. Following government cutbacks, the teacher training college merged with Luton

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Technical College to become, in 1978, the Luton College of Higher Education. In 1983 Luton College of Higher Education became the Univerisity of Luton. Since 1985 the function rooms were gradually renovated to their original splendour and conference centre standards, and the unused gymnasium converted into a learning resources centre. Now licenced to perform civil marriage ceremonies, the historic house and heritage gardens are enjoyed by visitors.” In 1993 the University of Luton merged with the Bedford campus of De Montfort Univeristy in August 2006 and remains the property of the University of Bedfordshire. (Detail from University of Bedfordshire – Putteridge Bury campus website).

Wardown Park Wardown Park is a Historic England nationally listed park: Historic England - Wardown Park.During the mid-nineteenth century (Tithe map, 1844), the parcel of agricultural land known as Shott lay with several adjacent similar small parcels bounded by the Old and New Bedford Road’s in open country to the north of Luton. In 1847, Robert How built a white stucco farmhouse on one of the plots towards the north of the area, and in 1868 Frank Chapman Scargill (1836 to 1919), a successful local solicitor, purchased it and began to buy up the adjacent parcels of land to the north and south, living in the farmhouse and planning his new mansion to be built on the site of, or close to, the existing house. In 1875 he commissioned C T Sorby to design and build a new house, completed by 1877, at the cost of £10,000, other estate buildings and lodges. The gardens and pleasure grounds were laid out first around this building with further features, including a park added during the 1880s and early 1890s. In 1897 the estate was leased to B J H Forder, who changed the name to Wardown House after his former home in Buriton, Hampshire; and then in 1900 to Mr Halley Stewart, founder of the London Brick Company. In 1904, Luton Corporation bought it for £17,000, and laid out the Pleasure Gardens, which opened in 1905. From 1904 to 1907, a network of paths was laid, a small boating lake with an island and boathouse was enlarged, new bowling green’s laid out, and a bandstand erected. The cricket ground was enlarged replacing the kitchen gardens. The house was partly used for staff accommodation, and during the First World War

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as a convalescent hospital, until 1931, when it became Luton Museum. The council installed a suspension bridge, which was renovated and re-opened in 2015, after being closed for three years, and the park remains in municipal ownership and open to the public.

Hamilton Finlay Improvement Garden Luton Council bought Stockwood Park, the site of Finlay’s Improvement Garden, in 1945. In 1985, the council commissioned Ian Hamilton Finlay to design a contemporary interpretation of the green landscape garden of the eighteenth century through modern sculpture. It was seen as an extraordinarily ambitious and far- sighted commission from an urban local authority in the mid-1980s. Finlay created the master plan, 'Six Proposals for the Improvement of Stockwood Park' (1986), which included lithographs by Gary Hincks, which are now at Tate Britain. He worked with Master Gardener for Luton Council Robert Burgoyne, who planned the planting scheme with Sue Finlay and completed the design. The Improvement Garden, a green glade area of about five acres, was opened in April 1991 and is considered to be the most important example in England of the work of Ian Hamilton Finlay. Finlay is widely considered the most adventurous and controversial sculptor-cum- landscape designer of the post-war era in Britain. The work was funded by the Henry Moore Foundation and was the first public park to be completed by Finlay in Britain. The inspiration for the sculptures and gardens range from Greek mythology and Roman architecture to the grand landscape gardens of the eighteenth century and reference the lost mansion and garden of Stockwood Park itself. It comprises six sculptures set apart from each other by carefully conceived vistas and views across the green glade:  Tree Plaque – carved by Nicholas Sloan  Flock of Stones – carved by Nicholas Sloan  Buried Capital – carved by John Sellman  The Herm of Aphrodite (the goddess of love) – carved by Nicholas Sloan  Double Tree-column Base – carved by Keith Bailey  The Errata Of Ovid - carved by Caroline Webb

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In August 2020, Historic England classified The Improvement Garden by Ian Hamilton Finlay as a site of Special Historic Interest in England. It is noted as heritage at risk on Luton’s Heritage risk register. Stockwood Park itself, a former country estate covering 100 acres on the southwest edge of Luton, is not a nationally registered historic parkland. Still, it is rich in historical significance: It was developed by the Crawley family in 1708. A Palladian mansion with stables and a walled kitchen garden were built in 1740. The Crawley Family wealth is connected to the history of slave trade labour. In 1771, Samuel Crawley (1790 to 1852), a London merchant and owner of Stockwood, Luton, provided a mortgage for two coffee plantations at Richmond and Digue on the island of Grenada. A list of his 74 slaves survives. Included in the transaction were ‘the future issue, progeny and increase of the females of the said slaves and also nine horned cattle (Ref.C1521, https://bedsarchives.bedford.gov.uk/Newsletters/BedfordshireandtheSlaveTrade.asp x). In 1823 Samuel Crawley advocated the emancipation of the West Indian slaves without infringing proprietors’ rights (his paternal inheritance may have included a coffee plantation in Grenada). In 1825 Samuel Crawley presented a Honiton anti- slavery petition. He stood for Bedford as a reformer, stressing the importance of ‘economy and retrenchment’ as ‘the great end of the reform bill’, (https://bedsarchives.bedford.gov.uk/Newsletters/BedfordshireandtheSlaveTrade.as px), but being evasive on the slave question. In around 1870, the walled gardens were extended to accommodate the construction of the now Grade Two listed greenhouses. The Crawley family left Stockwood House in 1939 when, during World War Two, it became the Alexandra Hospital for children with hip disorders. Luton Council purchased the park in 1945 and the walled gardens were used as flower nursery, and the house was demolished in 1964. It has significant landscape and historical features (all of which now appear on the local list):  a tree-lined avenue from Farley Hill to the centre of the park where Stockwood House once stood  a Grade Two listed stable block, which is incorporated into the Discovery Centre  the historic walled garden and other garden areas associated with the house

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 the ha-ha to the south of the house  the lodge house at the Farley Hill entrance  Lawn Path, the ancient right of way running through the park  the original parkland trees and copses which gave structure and visual unity to the landscape and provide valuable habitats for wildlife  historic trees, boundary wall and some lodge gate entrances around the periphery of the park  a type 24 World War Two hexagonal pillar box

Within the park, Stockwood Discovery Centre, built in 2008, displays rural crafts including the rare medieval masterpiece the Wenlok Jug; period gardens reflecting the changing styles of gardening in this country, a contemplative Sensory Garden, a colourful World Garden and a Medicinal Garden, the town's last tram and the of carriages - the largest collection of its kind on display in the UK. The Grade Two listed walled kitchen gardens and nineteenth century glasshouses are also sited and maintained as part of the Stockwood Park Discovery Centre.

Natural wildlife sites Natural wildlife sites have a national hierarchy of significance: sites of 'non-statutory' heritage sites i.e. those that are not protected in other ways are appraised and classified as County Wildlife Sites (CWS) and District Wildlife Sites (DWS), which by default become 'non-designated heritage assets' and should be protected as such. In Luton, we have several County Wildlife Sites and District Wildlife Sites. Statement of Significance citation at the Biological Records and Monitoring Office in Bedford are non-public (affording one layer of protection for the integrity of rare biodiversity on- site). Cowslip Meadow in Luton, covers an area of 6.36 hectares (ha). It was nationally recognised as a Site of Special Scientific Interest (SSSI) on 13 October 2020 because of its species-rich lowland meadow biodiversity and population of the

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nationally rare plant great pignut Bunium Bulbocastanum, and therefore becomes by definition a CWS and also by definition site of natural heritage asset.

Meadowland sites within Luton have been identified as 'heritage at risk': Specific conservation management is needed to protect biodiversity, and therefore site's SSSI status.Unlike SSSI or CWS, District Wildlife Sites are not currently individually protected in law, but the system of classification and recording and monitoring is a legal requirement. They have similar terms of reference as CWS but with definitions based on frameworks for CWS. In addition to biodiversity, these have broader criteria such as their landscape value as 'green assets', i.e. their 'use' values as amenity spaces, historical parks or areas with non-designated archaeology. This criterion is comparable to the way 'group' and landscape' values define built heritage. It is recommended that the local list appraisal framework, attached, is expanded to include alongside the current built local assets those 'green' and 'archaeological' assets that are important and valued by local people but cannot currently be recorded or protected through national frameworks. Some DWS in Luton are already afforded some protection because the council has adopted the selection criteria and classification system framework and local planning policy with the Local Plan 2011 - 2031 (November-2017). In addition, there are town-wide landscape designations. This strategy recommends reviewing and including all new DWS and CWS sites to be cited within the new local plan and creating policy to increase future protection in line with that proposed in the government's ‘25 year Environment Plan’ in which there are no plans to upgrade CWS to Area Of Natural Beauty (AONB) status, but suggestions that protection may be increased through future changes in national planning laws).

The creation of national Nature Recovery Networks is a major commitment in the government’s 25-year plan (policy paper November 2020) and forthcoming nature strategy; Department for Environment, Food and Rural Affairs (DEFRA) and Natural England bring together partners, legislation, and funding to help create them. Locally

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the Chiltern Conservation Board is developing Luton’s surrounding chalk downlands as a potential Nature Recovery Network.

Natural England are also looking into the possibilities of extending and designating as AONB additional land around the Chilterns. https://www.chilternsaonb.org/chilterns-aonb-boundary-review.html. This strategy supports the extension of the AONB, even though the possibility of extending into Luton Borough itself is quite limited (though not impossible, e.g. at Common/Bradger Hill).This is because, although most of the designated AONB lies outside of the borough boundary, the nearest urban population, the ‘audience’ that benefits most from this landscape comes from Luton. The Chiltern Conservation Board’s Heritage Funded project ‘Chalk-scapes’ and The Wildife Trust, Beds, Cambs and Northants Project ‘Wilder Futures’ both involve local communities. ‘Chalkscapes’ features a suite of complimentary projects connecting a greater range of people and communities with the special landscapes and nature around them. Previous AONB engagements with Luton have included ‘Beacons of the Past: Hillforts in the Chilterns Landscape’, examining Walaud’s bank in Ward, and the Nissan Hut at Marsh House; and,working out from the John Dony Field Centre in , The Wildlife Trust’s ‘Wilder Futures Project’ (2020-2023) also funded by The National Lottery Heritage Fund, is a programme of activity engaging local people in protecting and restoring wildlife and wild places across the Bradgers Hill Scheduled Ancient Monument and Nature Reserve.

Research Publications from Natural England evidence how people from Black, Asian and Minority Ethnic (BAME) communities can feel ‘disengaged from the natural environment’. While these demographics make up around 10% of the national population, ethnic minorities represent only about 1 per cent of visitors to National Parks.

This strategy partners (including Chiltern Conservation Board and Bedfordshire, Cambridgeshire and Northamptonshire Wildlife Trust, and Luton Council) seek to

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address all of Luton’s super-diverse population engagement and investigate ways of removing access barriers such as economic circumstances, language barriers, lack of transport and limited access to information. In the past, a lack of cultural understanding and awareness among organisations working in the natural environment has led to marginalisation of ethnic minorities from the outdoor landscape. Through developing a Heritage Implementation plan in partnership, we will apply innovative engagement approaches to re-dress this.

Nationally designated ancient monument sites:

Nationally listed on the Historic England national registry are the Saxon agricultural strip lynchets on Stopsley Common, Barnfield Ward; the Iron Age Dyke, Dray’s Ditches, Bramingham Ward; and the Neolithic Enclosure Waulud’s Bank at Marsh Farm, Leagrave Ward. In addition, there are other non-designated archaeological sites within the town, such as the medieval agricultural earthworks in People’s Park.Previous Heritage Open Days (HODs) held at Luton’s Dray’s Ditches have received active engagements in the past, helping to improve the town’s positioning in the Royal Society of Arts (RSA) Heritage Index. The two sets of three linear ditches, forming part of an Iron Age territorial boundary security dyke run at right angles to the Way (crossing from Bramingham to Warden Hill). This document identifies them potentially as heritage at risk through infrastructure development (widening of the A6) and because parts run through the land in private ownership. At Waulud’s Bank, Chiltern Conservation Board archaeologist Wendy Morrison has been working with Marsh Farm Outreach, where the ‘Beacons of the Past’ Hillfort Project team have been researching and documenting evidence of the Marsh House and Leagrave Marsh area from this Neolithic siting, through centuries of agricultural history and nineteenth century use as ‘The Blockers Seaside’ to the farm’s role in World War One and World War Two, and into twentieth century urbanisation. Both the historic farmhouse Marsh House and the World War Two Nissan hut are sited inside Waulud’s Bank Ancient Monument and are non-designated local heritage

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assets. Adjacent to Waulud’s Bank,Leagrave Marsh brings us full circle to the River Lea (and its’ emergence from the surrounding Chiltern’s chalk streams). The river is Luton’s major natural heritage asset; and, as evidenced by the public consultation results above, a source of pride for Lutonian’s. Chalk streams are a globally unique natural heritage: there are only 210 recorded in the world, and 160 of them are in the south-east of England. The main skeleton that makes up the River Lea is a DWS protected both because of its biodiversity and as a landscape feature, its’ adoption as a DWS, and its’ protection debuted in the 2017 Local Plan. The council has also adopted the Greensands Trust's previous work to maintain public access to stretches along its corridor. This strategy supports local desire to reveal and ‘un- culvert’ the river; and this, along with the need to embed interpretation of its’ socio- economic and natural (biodiversity) heritage, forms the major emergent natural heritage project for the town.

On a micro level natural heritage collections held by the museum (complied by Elise Naish, Head of Heritage and Collections, The Culture Trust, Luton) include: The Bedfordshire county herbarium, containing over 11,000 specimens, brought together by Dr JG Dony, comprising major donations from Abbot, Saunders, Crouch, Adams, JG Dony and C Dony. Major invertebrate collections, totalling over 30,000 specimens, of macro-lepidoptera (the Munns, Taylor, Palmer and Tebbs) Coleoptera (the MacKenzie-Jarvis and Milne-Redhead collections) and Mollusca (the Verdcourt collection), together with collections of most other orders, in particular Diptera (flies), Hymenoptera (ants, bees and wasps), Odonata (dragonflies and damselflies), Hemiptera (true bugs) and Orthoptera (grasshoppers and crickets).

Natural heritage - strategy areas of focus o major project emerging: . The River Lea. This strategy recognises the de-culverting of the River Lea and Wardown Lake management as two of the first major capital natural heritage projects. o Heritage at risk

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. this strategy recognises biodiversity in the River Lea as heritage at risk through low water levels and residual urban pollution . ancient monument and archaeological features Drays Ditches, at risk by impeding road infrastructure, and because of parts sited in private ownership . Lowland meadowland, which needs specialist management in order to maintain the biodiversity of habitat and species . see also ‘Intangible Heritage’ Section - heritage craft skills of hedge-laying skills, and the growing of hazel to supply materials

Recommendations (forming framework for the Heritage Implementation Action Plan) o that heritage interpretation of the River Lea (embracing its’ chalk-stream origin, biodiversity and socio-economic history and embedding all six strategic priorities) is considered and embedded at every stage of capital planning for de-culverting and developing a River Lea Linear Park. o that the dynamic draft local list framework, attached, is developed to include alongside the current built local assets, ‘green assets’ and ‘archaeological assets’ that are important and valued by local people, but cannot currently be recorded or protected through other/ or national frameworks, for example: Medieval earthworks in People’s Park, and our ‘pocket parks’ protected o that a local ‘heritage-at-risk register’ is maintained (across all categories of heritage). o that the developing Heritage Implementation Plan includes action plan to prioritise identified natural heritage at risk: Drays ditches; Lowland meadowland; hedge laying heritage craft skills training (and growing of coppiced hazel); and biodiversity within The River Lea.

o the Stockwood Discovery Centre gardens has recently being designated by Historic England for its heritage importance and so a specific

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conservation management plan for Ian Hamilton Finlay public art, the Garden and heritage structures, needs to be developed.

o that development of a Stockwood Parkland Master plan considers the historic parkland and its former use and a future plan for public engagement, includes orientation, park landscape design, sympathetic new developments, historic interpretation and the potential expansion of Stock wood Discovery Centre to widen its Museum offer, public facilities and enable future sustainability.

o that all partners commit to collectively addressing identified needs for coordinated biodiversity data collection, for environmental and social scientists, for community and volunteer training

o Call for research: engineering research to develop real-time dynamic natural heritage biodiversity analysis

2.1.2 Luton’s built heritage National and local context Like many towns, Luton has felt the impact of Covid. Consecutive lockdown measures have accelerated the decline of historic high streets. This heritage strategy is being co-created against a backdrop of UK government post-Brexit and post-Covid initiatives. For built heritage, this is a complex, conflicting landscape: on the one hand, government initiatives, such as High Street Heritage Action Zones (delivered through English Heritage) and 2021 government spending reviews, such as the Levelling Up and Welcome Back funds, show a commitment to support historic high streets, town centres, and cultural and heritage assets. New planning bills will see increased permitted development rights without intervention from Local Government Planning Control, putting our non-designated heritage assets at risk.

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This illustrates the urgency for developing a built heritage implementation plan; the urgent need to identify and value our built heritage assets; and preserve, enhance, promote, and utilise them for the town's prosperity. We will establish robust scoping and appraisal methodology for local listing and partnership infrastructure for developing vision, management plans, and design statements for all our conservation areas through our built heritage action plan.

Local achievements to date Luton has five designated conservation areas and 116 nationally listed buildings, four scheduled ancient monuments, and four sites nationally listed as historic parks and garden parks (as detailed in the natural heritage section above). Since the council’s draft ‘Foundation for Luton Built heritage Strategy’, produced in 2019 and laying out steps we will take to implement our built heritage action plan, we have:  had three new inclusions on the Historic England national registry  engaged with a wider range of local people to identify what is valued locally and why  adopted a robust scoping methodology and appraisal framework to establish, review and expand our local list  supported the development of Luton Heritage Forum and its’ role in reviewing and developing a detailed directory, including photographic records, of local heritage assets  broadened the local list to include architectural and archaeological features and public art  reviewed the historic environment section within the Luton Local Plan  developed a ‘heritage at risk’ register  developed partnership infrastructure to support vision, and co-create management plans and design guides for our built heritage conservation areas

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We have also prioritised place-making: positioning heritage interpretation at the heart of a new Town Centre Masterplan and supported The Culture Trust Luton’s best practice in developing the Plaiter’s Lea Hat District Conservation Area and University of Bedfordshire’s role in widening access and participation into higher education and supporting place-making initiatives.

This section outlines our joint strategic approach to built heritage: developing a framework to facilitate how we choose what to conserve; how we value, preserve and protect our historic environment; and how we identify local heritage at risk. It sets out to address how we will bridge gaps between community action, public perception and statutory obligations, and our capacity to deliver, recommending actions, we will use to build a heritage implementation plan. It also considers how we will achieve our vision by enabling greater involvement in decision-making, collecting and sharing knowledge, to protect and celebrate our heritage through meaningful place-making activities.

Our built heritage assets, significance and protection Our 2021 online heritage consultation survey asked: ‘What is your favourite building, and why?’ There was a whole range of answers, including several addresses that were or had once been called ‘home’. Twelve of people’s favourites were nationally listed, including  Hart Lane and Bailey Water Towers  St Mary’s Hospital (former workhouse)  two pubs (The Painters Arms, High Town and The Moat House (a late fourteenth century manor with moat)  two buildings statemented for their interiors (the former Odeon cinema, now a church  Hart House - the former director’s offices of Vauxhall Motors)  two grand park estates (Putteridge Bury and Luton Hoo)  plus various Georgian buildings in George Street West, including the registrar office

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Top of the poll, with 16% of the total vote, was Grade Two listed Wardown House Museum, 15% cited our Grade One listed parish church St Mary’s as their favourite, and 10% our Grade Two listed the town hall, equal favourites with 6% of the vote each were: The Hat District buildings, and the former ABC Cinema (sited within George Street Conservation Area but not listed). Only two ‘favourites’ were on the pre-existing draft local list: 27 George Street and 28 King Street. Two were twentieth century: St George’s Library and The Mall; and two contemporary (twenty-first century): Inspire Luton Sports Village and the University of Bedfordshire’s new £46 million seven story Library building. This informs us that buildings of all ages are valued not just for their age or architecture but also for their use value.

Thirteen of the public’s ‘favourite’ buildings are neither currently within designated conservation areas, or mentioned on the original draft local list. Many are significant because of their continued historic use value, these include:  Denbigh High School  UK Centre for Carnival Arts  Marsh House  the former Masonic Lodge (currently Pizza Express) in Church street, admired (like Hart House) for its’ interior  116 Bury Park Road (currently an Islamic Centre, formerly Synagogue, cinema, and aviation factory)  London Luton Airport (itself a site of heritage)  the football ground (). Two ‘favourite buildings’ were lamentations because they no longer exist: 33 Arts Centre and the Starlight Club; and one has yet to be built: ‘the new football stadium at Power Court’. This informs us that we need to have a clear strategic approach about the purpose of local list; a clear scoping methodology to identifying our built heritage assets; the need to develop a dynamic process to review our local list and designated heritage conservation areas.

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Case study - Bute Mills In 2013, Youthscape, a Luton based charity working to support young people, initiated a community-led campaign approach to purchasing and refurbishing the Grade Two listed Bute Mills building, which sits within the Plaiter’s Lea Hat District Conservation Area. Global design, architecture, engineering and planning firm HOK was commissioned to work with the Youthscape team enabling local young people to conceive a new vision for the 110-year industrial building transforming one of Luton’s key historical assets into a practical and inspiring space for young people. Grant funding from National Lottery Heritage Fund supported a heritage research project at Youthscape. One outcome was a cohort of ‘youth ambassadors’ leading historical guided tours of the building. This community-led approach remains an exemplar model for heritage building conservation and a meaningful framework for engaging young people in our built heritage townscape.

Case study - Bailey Hill Water Tower Bailey Hill Water Tower is one of two water towers built, in bold ‘Arts and Crafts’ architectural design, to supply water to Luton following a drought in 1898. The Grade Two listed Bailey Hill Water Tower overlooks Luton Hoo Memorial Park and is an exemplar model of commercial property development. Following quality refurbishment and conversion, the disused building was converted into a single high- end private dwelling: becoming the first residential property in Luton to be marketed for sale over £1million and remains an exemplar model for commercial redevelopment of local heritage assets.

Case study - St Mary’s Church St Mary’s Church (an Anglican Church of St Albans Diocese) was the site of the first religious community in Luton. It has been a centre for local worship in the area for over 1,000 years. The building erected, endowed and offered, around 930AD by King Athelstan as an act of thanksgiving for victory over the Danes is over 850 years old. It is Luton’s only Grade One listed building with architectural detail evidence rich, deep and meaningful heritage significance, only because it has been consistently

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maintained and refurbished for centuries. Extended beyond its’ original basic layout, it has remained cruciform (with north-south aisles). Including chapel extensions, it now measures 53 metres (174 ft.) long and 17 metres (56 ft.) wide, with a height of 27 metres (89 ft.). The current church, built by Robert First Earl of Gloucester in 1121, was consecrated in 1137. An increase in population during the Twelfth century lead to aisles being added around the start of the thirteenth century. In the fourteenth century, the transepts were extended with twin arches opening into the new chapels on their eastside; and the tower, vaulted sacristy (an upper room on the North Chancel), and a new font (with unique, richly carved octagonal canopy) erected. In the fifteenth century, Someries Chapel was restored, extended, re- configured and renamed Wenlock Chapel after Lord John Wenlock (whose father John is one of three people interred there). The Hoo Chapel, the Rotheram family monuments, and the Barnard Chantry chapel were later developed; and in the nineteenth and twentieth centuries, extensive restoration works began: the distinctive flint and stone chequer, materials taken from our unique Chilterns AONB landscape,was extended to cover most of the exterior, the tower restored (1906); Wenlock Chapel restored (1914); offices, halls and vestries built, also in the chequered style (1960s); and the Magnificat Window in the south transept installed (1979). The church clock was first installed in 1901 and overhauled in 1909. In 1949 a new clock was installed, which seized and stopped in 1979: unheard for 28 years until the neighbouring University of Luton (now University of Bedfordshire – itself a site of heritage) funded and facilitated its’ restoration ready for the new millennium. The clock was officially re-opened and rang for the first time on Armistice Day 11 November 1999.

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How we protect our built heritage through various local and national planning, policy and legislative frameworks

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This document takes a strategic approach to focussing on areas of heritage and ways we can develop multiple layers of protection through utilising national and local planning and heritage frameworks. As the local planning authority, Luton Council has an obligation to ensure that legislation and guidance are followed to protect the heritage of the town from any negative impacts of development, but also has to make planning decisions in adherence with national planning policy law. Two main national policy and legislation pieces forming statutory guidance for this purpose are the National Planning Policy Framework and The Planning (Listed Buildings and Conservation Areas) Act, last updated June 2019.

The National Planning Policy Framework (NPPF) is national level planning policy for England. Carrying a ‘presumption in favour of sustainable development’, incorporating economic, social, and environmental implications: it sets out core land- use planning principles; taking account of the character of areas; encouraging re-use of existing buildings; and conserving heritage assets “in a manner appropriate to their significance so that they can be enjoyed for their contribution to the quality of life of this and future generations”. Areas taken into account include: enhancing/sustaining heritage assets’ significance (including through viable alternative uses “consistent with their conservation”; consideration of ‘social, cultural, economic, and environmental’ benefits in asset conservation and management; how new development can contribute positively to local character/distinctiveness; and how the contribution of the historic environment to the character of a places ‘townscape’ can be realised.

“We want a society that as re-established powerful links between identity and place, between our unmatchable architectural heritage and the future, between community and purpose…. to cherish the past, adorn the present and build for the future.” (Charles Russell Speech in Planning for the future white paper, https://www.gov.uk/government/consultations/planning-for-the-future/planning-for- the-future)

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Following the ‘Building Better, Building Beautiful Commission’, ‘Planning For the Future’ consultation (August 2020 updated February 2021) and informed by the ‘Building Better, Building Beautiful Commission’, the UK Government proposes radical reform developing a new planning system with an emphasis on ‘place- making’, insisting upon a “higher regard on quality, design and local vernacular” and “supporting…regeneration without losing… human scale, inheritance or sense of place”. There is an expectation that: developments create ‘net gain’; that locally produced, site and area-specific, visual and map-based design codes will be created through “world-class” civic engagement and pro-active plan-making, “prepared locally…and based upon genuine community involvement” and resulting in design codes that form legally binding planning decisions.Luton already has some design codes for new re-generational developments, for example, High Town East (sitting outside the designated High Town Conservation Area). This strategy focuses only on protecting our existing heritage assets and preserving the characteristics of our historic townscapes. While the government seeks to strengthen enforcement powers so that “communities can have confidence that rules will be upheld”* and establishes a new body to ensure that each authority has a chief officer for design and place- making, this strategy document proposes immediate recommendations to support community involvement, capacity, engagement and delivery of design codes within our designated conservation areas.

* https://www.gov.uk/government/consultations/planning-for-the-future/planning-for- the-future

Nationally listed buildings – designated heritage assets

The Planning (Listed Buildings and Conservation Areas) Act 1990 also national level legislation, provides protection for nationally listed buildings and buildings within heritage conservation areas (designated heritage assets). National listings are ultimately decided by the Secretary of State, based on principles of selection

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requiring national significance. The Act sets out special controls around the demolition, alteration or extension of any buildings or objects of historic or architectural interest, requiring agreement from Historic England. As the local planning authority, Luton Council has a legal obligation to ensure these controls are used to consider, preserve and enhance heritage assets. Nationally listed buildings benefit from enhanced protection through the processes of Listed Building Consent (LBC) and planning permission. Local planning authorities have the power under section three of the 1990 Act to serve a Building Preservation Notice (BPN) on the owner and occupier of a building that is not listed but which they consider to be:

a) of special architectural or historic interest b) in danger of demolition or of alteration in such a way as to affect its character as a building of such interest. They must at the same time submit an application to the Secretary of State through Historic England for the building to be added to the statutory list, and evidence its national significances a general rule, age and rarity are significant factors in national listing decisions: “all buildings built before 1700 are of national significance”*; those built before 1850 need to “retain a significant proportion of their original fabric”*; if built between 1850 and 1945 “because of the greatly increased number of buildings erected and the much larger numbers that have survived, the progressively greater selection is necessary”*; for buildings built after 1945 “careful selection is required”; and buildings under 30 years old are not normally listed “unless they can demonstrate outstanding quality to stand the test of time”*. These listing decisions are based on architectural and historic significance, taking into account group value, extant fixtures and fittings, and their sited value in enhancing designated conservation areas. See Principles of selection for listed buildings (DCMS). *https://www.legislation.gov.uk/ukpga/1990/9/pdfs/ukpga_19900009_en.pdf

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This informs us that heritage assets within conservation areas and symbiotically conservation areas based upon high numbers of heritage assets have more protection.

If a local authority serves a building preservation notice, it remains in force for six months, affording a ‘stay of execution’ for historic buildings under threat of imminent demolition. However, suppose the Secretary of State decides not to list the building (i.e. the building is not of national significance). In that case, owners or developers could seek financial compensation from the local authority for costs incurred during this period.

This informs us that it is crucial for a heritage asset audit and listing processes before such a crisis occurs, in collaboration with property owners, and not left open to the risk of sudden demolition.

Locally listed buildings – non designated heritage assets

Crucial to understanding how we will map our heritage assets, how we will value our non-designated built heritage, quantify and value our historic buildings as a focus for place-making, and position heritage as a key driver in place activation and regeneration is our local list appraisal framework. In October 2019 and again in February 2021, the government announced updated guidance for preparing, improving, extending and updating existing local lists for all types of heritage assets including buildings, monuments, sites, places, areas or landscapes “which have been identified as having a degree of significance meriting consideration in planning decisions, because of their local heritage interest.” (https://historicengland.org.uk/images-books/publications/local-heritage-listing- advice-note-7/heag301-local-herita ge-listing/).

Government expectation is that guidance will be in line with Historic England’s guidance, but weighted to local importance:

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 for scoping methodology to be clearly defined  that identification of assets for inclusion on the local list must involve the local community  the local list information should be recorded and made publicly available in digital form (available from the local authorities website) and added to the local Historic Environment Record  organisational infrastructure is in place for dynamic updating of the list and Historic Environment Register “as new non-designated heritage assets which are not on a ‘list’ per se are identified, e.g. through the decision-making process on planning applications.”*;  “that local authorities should communicate clearly on how the local list will be used to inform their decision-making and planning”*. https://www.gov.uk/government/publications/local-heritage-list-campaign-call-for- expressions-of-interest/local-heritage-list-campaign-guidance

Our developing built heritage implementation plan will address these issues.

'Valuing culture and heritage capital: a framework towards decision making'. This DCMS framework, published in January 2021, identifies how effective management interventions can increase the value of heritage assets by taking into account the goods and services they generate and the public benefits that, in turn, creates. The framework recommends applying heritage science to assess the condition of assets; and calls for case studies of best practice research (combining economic valuation methodology with heritage science) to work out the impact of preservation intervention in the conservation of our heritage towards a formal approach towards a Green Book methodology for valuing culture and heritage assets.

Our public consultation data provides strong evidence that the heritage significance of local historic buildings is based upon a different set of values to that of nationally listed buildings. Using a criteria framework for national listing has, in some areas,

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undermined the value of a local list. Addressing one concern raised in a public consultation workshop that “the local list doesn’t mean anything - if they were good enough they would be on a national list” we have taken a best practice approach: of first adopting a robust appraisal framework and scoping methodology (that can be used, for guidance, throughout the decision making process) in order to identify assets for inclusion, as the first stage in our being able to create a valuable local list. Taking this strategic approach mitigates potential arbitrary issues caused through unconscious bias and intermittent preparation of significance statements. We have created a consistent local list framework, based upon Historic England guidance (considering architectural and historical importance) but weighted towards what Lutonian’s have asked for: local list criteria weighted towards ‘group value’, ‘townscape’ and ‘local community value’ rather than national, significance; and we recognise the work of Luton Heritage Forum in building a new website to photographic, record and make public this information and archive the built heritage of Luton (based on engagements of ‘Collective Memory’ – see intangible heritage section below).

This strategy supports

 a local list that strengthens the position of our conservation areas; and includes architectural and historical features (e.g. street furniture and ghost signs) in addition to whole buildings  clear scoping and appraisal criteria framework that can be issued as guidance  development of a dynamic local list review methodology  the appointment of a Conservation Officer and development of infrastructure to support professional and trained community volunteer capacity in dynamic conservation area appraisal process

Designated conservation areas

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Conservation areas benefit from general control over the demolition of unlisted buildings. It is therefore important to recognise if an area would better benefit from regeneration. The law defines conservation areas as 'areas of special architectural or historic interest, the character or appearance of which it is desirable to preserve or enhance'; and the objective of planning policy is to conserve those characteristics, including landscape and public spaces, that define an area's special interest. Protection extends beyond buildings to include streets, trees, paths and views, and significance can be valued by local as well as national importance. The designation is the formal process that councils undertake to establish a conservation area. Designations can be challenged without following due process (conservation area appraisals and photographic survey of all buildings).Following adoption, the council is required to review conservation area assets and boundaries and formulate and prepare management plans (including communication and engagement). Luton has five designated conservation areas (see below), two of which have been identified by Historic England as ‘heritage at risk’: High Town and Plaiter’s Lea Hat District. The council has already developed and adopted a heritage management plan for the Plaiter’s Lea Hat District and intends the same for all other conservation areas.This informs us of the need for infrastructure and capacity to audit, review, and prepare management plans and design statements for our conservation areas.Based upon the evidence, the council can add to the types of alterations that need planning permission by making Article Four directions within conservation areas: these can be used to protect particular features in an area from being lost.

When we asked people to list their favourite buildings (in our 2021 public consultation), the significance of local ‘group’ value (as used for national listing) became apparent. For example, our ‘modern’ Central Library, St George’s Square was mentioned; and, sited inside our Town Centre Conservation Area: ‘the historic skyline of Manchester Street’. In particular, numbers 11 and 13 Manchester Street (former Liberal Club) were noted. These buildings and numbers 29-39 Manchester Street do feature on our local list. Other buildings and architectural features mentioned included ‘the Victorian terraces’ of High Town (sited outside the

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designated conservation area), and ‘Victorian features’ of High Town Road.This informs us that these smallest of architectural and decorative features, not just whole buildings, which collectively contribute to the characteristics of conservation areas preserving its’ identity, is the ensemble that local people value. It is these heritage assets that will be protected and enhanced through community development of design codes.

Designated and non-designated heritage assets (example, locally listed buildings) that sit within conservation areas are protected in various ways through  alerting and involving the community  information communication for property owners  the development of management plans and design statements  law as conservation areas are required to have this recorded as a Local Land Charge and is a criminal offence to carry out demolition in a conservation area without planning permission, and licenses are required to prune and cut down trees

Luton has five designated conservation areas In addition to 101 listed buildings and historic features, Luton has five registered conservation areas. This strategy seeks to address how to connect them, both physically and through heritage narrative.

Two of the conservation areas include historic high streets: George Street and High Town Road. These two streets are intrinsically linked through the heritage of Luton’s historic hat industry. These themes are looked at in more detail in the industrial heritage section below. A third challenge is the need to embed heritage interpretation narratives within the physical regeneration of St Mary’s Quarter: a new area developing from the Town Centre Masterplan mentioned above.

Rothesay Road designated conservation area

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This area includes most of Napier Road and Ashburnham Road as well as the area around Brantwood Park, including Grove Road, Brantwood Road and the eastern end of Road. A residential area containing no statutory listed buildings, although the area does contain several significant landmarks and heritage features. The most significant Rothesay Road Cemetery, the first graveyard in Luton for non- conformists as well as Anglicans, was opened in 1854, affords a magnificent view over Luton and includes the listed gravestone of Captain Charles Beecroft. Much of the Rothesay conservation area's built heritage is residential property, with many of the homes along various roads making a positive contribution to the architectural character and appearance of the conservation area. In particular, many of the homes on Napier Road as well as the even-numbered houses on Grove Road, are considered to be of architectural interest. Opposite Brantwood Park, but lying just outside the conservation area on Dallow Road, is another non-listed historic building with historic architectural and value significance. A former school converted into The Guru Nanak Gurdwara Luton, providing Sikh religious teaching and practice for all members, and since 2020 the site of a new Sikh Temple.

Luton South designated conservation area This is largely aresidential conservation area containing predominantly nineteenth and twentieth century terraced and semi-detached housing, within South and Farley Wards. It is largely linear and characterised by the London Road ‘spine’ containing the largest detached residential dwellings: rich in historic quality and distinctive architectural detailing. The area contains one listed building: the West Hill Road, Bailey Hill Water Tower (one of a pair donated to the town by Luton Hoo); one listed war memorial, Memorial Road; and several non-listed heritage assets: Bowls Pavilion Memorial Park, Luton Hoo Memorial Park, electric Substation, Luton Hoo Memorial Park and several mature trees.

Luton Town Centre Conservation Area This is an area shaped by The Mall to the north and Stuart Street and Chapel Viaduct to the south, which was nationally designated in 1998. It encompasses

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Upper George Street, George Street and George Street West: for this reason, and to prevent confusion with the new Town Centre Masterplan boundary; this strategy recommends changing the name of this designated conservation area. Within this area is . Luton Town Hall Luton’s first town hall was constructed in 1847, on the current site, by the Luton Town Hall Company and used by the County Court and for public meetings and entertainment. A clock was installed in1856 to commemorate peace following the end of the Crimean War, with a single bell that struck on the hour. In 1875 the Luton Town Hall Company was dissolved, and the building was sold to the Board of Health, who encouraged the town’s citizens to petition for municipal borough status. The Charter of Incorporation was granted on 26 February 1876, and the town hall and became the home for the new authorities until July 1919 when Lutonian’s famously burnt the building to the ground: when only the privileged were invited to Luton’s Peace Day Parade celebrations honouring the end of the war, veterans and their families came together to demand recognition and inclusion. Denied entrance to a lavish banquet held in their honour (unless they could afford a 15 shilling price tag – equivalent to a week’s wages if you were fortunate enough to be employed). Veteran’s groups marched to the town hall to demand an audience with the Mayor. Dissatisfied with the response, they rioted in the street, setting the town hall alight and stealing pianos from a nearby music store. According to local reports, the crowd sang ‘Keep the Home Fires Burning’ as local women danced on top of the pianos. Very little survived the fire: the building was gutted, and civic documents were destroyed. The Mace was salvaged but badly damaged and subsequently renovated, as was the town's pride. A new building, faced in Portland Stone, was completed in 1936 using fireproof materials in its internal construction. The existing town hall was registered with Historic England as a Grade Two listed building in 1988 because of its’ interior and exterior neo-classical and architectural features. Particularly noteworthy is its elaborately decorated staircase with bronze balustrading and thistle and rose motifs leading to the principle first floor rooms, including the Mayor’s Parlour and committee rooms. In terms of heritage assets,

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both the Council Chamber and Committee Room Two are aesthetically designed in connection with the War Memorial. The copper-clad mansard roof was added around 1960, and the 144 ft. clock tower, incorporating the town's Coat of Arms and distinctive clock bell, has undergone structural repairs and lighting works completion coinciding with the launch of this strategy document (September 2021). The town hall and war memorial together remain a symbol of the town’s resilience, hope and civic pride. Luton’s Pilot Year of Culture The town hall became a focal point for heritage lead place activation in 2017. The pilot year of culture was inspired by the 1919 Luton Peace Day riots and launched with a staged heckling at the town hall. The People’s Launch brought together 10 people with experience of unemployment who, through text, spoken word and movement, interrupted the formal speeches and surprised the VIP guests with real life stories of living in Luton. The launch was the opening production for a series of six events which animated Luton and celebrated our heritage. Creative place activation continues to be a significant part of Luton’s place-making initiatives.

This designated conservation area also contains 24 Grade Two listed buildings mainly located on Castle Street, George Street, King Street and George Street West. The two most significant in stature are Christchurch House (former church) and the town hall. Castle Street contains four nineteenth century Grade Two listed buildings, including two public houses, The Red Lion Hotel and The Castle (formerly the White Hart). George Street West contains 10 Grade Two listed buildings: the highest concentration of listed buildings within the town centre. With mainly Georgian and early Victorian offices and townhouses, these include numbers 1, 3, 6 (Luton Register Office), 7-9, 9A, 8-10, 11, 13-17 and 19 George Street West.

Art Deco influence

The prominent town hall, rebuilt in 1936, and Luton War Memorial erected in 1922 (Grade Two listed), heralded a period of new Art Deco influenced builds interspersed with Victoriana throughout the historic high street. From our 2021 public survey, several art deco styled buildings and features were noted as people’s favourites:

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these included potential but currently non-designated heritage assets, including the plaster stucco feature (68 George Street), the retail row 55-61 George Street (adjacent to the former ABC Cinema site), and the former ABC Cinema site itself. Together with creating an important townscape and ‘mise en scene’ for heritage interpretation within the town, interestingly, none of these buildings, though attracting immense public interest, were previously included in the local draft list. Over 150 people booked to participate in an online public meeting, hosted by Luton Heritage Forum, about the future of the former ABC Cinema site. This informs us that several non-designated heritage assets are highly valued by local people and evidence the need for a robust and focussed approach to developing local listings to support heritage narratives within our conservation areas.

Case study - The former ABC cinema site

The 1,892 seat Savoy Cinema opened in 1938, one of three ABC cinemas in Luton at the time. It was designed by in-house architect William R Glen designed by Associated British Cinemas (ABC). In 1971 it was refurbished into a three-screen cinema: the tripling destroyed much of the original interior. Renamed Cannon in 1986, it finally closed in 2000. Empty for 20 years, it has suffered dilapidation and decay and is neither nationally nor locally listed; however: its’ heritage significance to the townscape and Lutonian’s should not be under-estimated. William R Glen was renowned for his interior architectural design rather than exteriors. Still, it is the preservation of ‘Modernist’ ‘Art Deco’ exterior ‘façade’ and collective memory of the site as a historic cinema that causes public outcry. Despite having little historic fabric left in the building (and therefore not suitable for national listing), this site is a prime example of how non-designated heritage assets are valued locally. Historic England does not support ‘facadism’ of listed buildings, a practice of protecting only the exterior wall while erecting a new building behind or around it. However as this building is not listed, its’ exterior is a key feature within our historic high street and it issited within a nationally designated heritage conservation area, the National Lottery Heritage Fund has supported community engagement towards decision

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making. With a sympathetic developer and high public demand, we might look to award-winning community lead design charettes (like LOOK! StAlbans, https://lookstalbans.org/) as a best practice model for collaborative solutions to produce design codes within our designated heritage conservation areas.

High Town Conservation Area High Town lies across the railway line from Luton town centre. A distinctive ‘Victorian’ suburb with four national listings sited within the historic high street conservation area: High Town Methodist Church, gates, wall and railings, church hall and The Painters Arms Public House; and one adjacent: Church of St Matthew, Wenlock Street. The first house (believed to be built c.1815), High Town Ward, and the unique terraced housing within it, stretches across People’s Park and Popes Meadow, towards Wardown Park, recalling two hundred years of brewing and hat history narratives. Once the home of 10 historic public house Inns, there are now only seven of these buildings remaining (five within the existing historic high street designated conservation area), and only three remaining as licensed public houses: The Painter’s Arms, The Well and The Bricklayers Arms (dating back to 1834) of contemporary historic note as the birthplace of Luton 2020 (LTFC) Developments Ltd. Before 1815, the only development to the north or east of the River Lea was cottages known as Coney (Rabbit) Hall, on the site of the English Rose public house, famously linked to the 1919 Peace Day riots. This connection to political rebellion connects to High Town pubs as punk and anarchist music venues in the 1970s and 1980s. During World War Two, a network of bomb shelters and underground tunnels were constructed in Luton. The best example of this civil engineering remains deep under the streets of High Town. An internet ‘buzz’ around these underground tunnels evidences immense interest and demand for re-opening one as a visitor attraction. In preparation for national centenary celebrations remembering the outbreak of World War Two, this strategy recommends the development of a feasibility study to research Luton’s Wartime history and the possibility of the High Town underground tunnel becoming a national visitor attraction.

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Following the introduction of the railway line, 1858, High Town was connected to the town centre for 140 years solely by a footbridge. This protected the area from significant modernisation, making it today rich in significant historic and architectural features. Twentieth century engineering units continue their industrial legacy: one is home to Europe’s only block makers Boon and Lane, holding the only urban furnace license in the UK. High Town remains the home of several hat makers, including Tom Llewelyn (hat-maker to the Queen and VivienneWestwood) and Philip Wright, continuing 300 years of hat design and manufacture in the purpose-built (1889) Walter Wright Hat Factory. Covid lockdowns of the hospitality event economy have threatened Luton’s historic hat-making industry, with the demise of three more local hat manufacturers: a globally important heritage industry eco-system not only in decline but at risk of extinction. The issue of physical and historical re-connectivity of High Town and Plaiter’s Lea Hat District conservation areas through  the shared heritage of hat-making  the national cultural and creative significance of Lutonian hat design; the “bold and unashamedly utopian” vision (Hat District Future-scape 2020) for developing The Hat District as a creative cultural hub and destination;  the existing (international) visitors attracted by the last remaining Lutonian hat makers  Historic England’s research and designation of both Plaiter’s Lea and the wider High Town Ward as nationally significant ‘heritage at risk’, all inform the strategic challenge in section 3.2 of this document; will be addressed by re-connecting of the whole of High Town with Plaiter’s Lea via the station gateway. This wider non-designated Hat Industry heritage zone will become an economically robust aspirationally strengthen the relationship between these areas and create in line with successfully proven economically sustainable best practice models like the Birmingham Jewellery District, to creative cultural quarter.

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Both High Town and hat-making are recognised nationally as ‘heritage at risk’: the area is recorded on the Historic England risk register, and the artisan skills of block- making and hat-making, joining millinery, in the Heritage Craft Association’s ‘Red Book’ (updated May 2021).

Plaiter’s Lea Hat District Plaiter’s Lea Hat District Conservation Area is home to seven nationally listed buildings, connecting with High Town via Luton central railway station and St George Street, via The Mall, and leading into the new St Mary’s Quarter/Power Court development site is the heart of the current Hat District. Largely due to an inspirational Future-Scape vision (Hat District Future-scape 2020), led by a small group of cultural entrepreneurs, The Plaiter’s Lea Hat District is our most established designated heritage conservation area. It heralds re-development through the re- settlement of creative industries. The origins of Plaiters’ Lea lie in the establishment of Barbers Lane which is considered to be the earliest route into the town centre, a medieval conduit joining the market town, through interwoven patterns of open field systems on the higher land to the north (an earthwork in People’s Park can be seen in archaeological testament). Its’ industrial heritage, intrinsically linked to the town’s hat industry, is evidenced through street layout (once a densely packed hive of small factories, showrooms and warehouses, jostling for space beside terraced cottages, shops and pubs historical architecture); and architectural styles (Victorian polychromy (the art of painting in several colours), Queen Anne Revival and Neo-Jacobean. From the 1880s onwards, the adoption of the pier and panel design, reflecting advanced cast- iron construction, created an industrial aesthetic that contrasts with neighbouring buildings of conventional construction such as the public houses) and its retail ghost signs. Together, the nationally listed buildings, and contemporary public art, form a townscape of factory showroom blocks (from the 1880s and onwards), individually restored with monies from the National Lottery Heritage Fund and supported by a

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council Conservation Area Management Plan, form the framework to realising the areas inspirational vision more fully discussed in section 3.2 below.

Case study - Hat Works creative workspace “Hat Works (47 Guildford Street, Luton) was a former hat factory now adapted into creative work, show and share space, last occupied in 2006 as a factory. The Culture Trust charity purchased the derelict building in 2017 and transformed it into a creative workspace for young entrepreneurs as part of a growing cultural cluster of creative workspaces, arts venues, and galleries called the Hat District. Hat Works is Grade Two listed and is the oldest former Hat factory in Luton. This three-storey property, with a distinct façade of Luton grey bricks, stucco dressings and a Welsh slate roof, is located in the Plaiters Lea Conservation Area was built circa 1840. It was originally a domestic dwelling, meaning it was adapted from home to factory to creative workspace. Newly complete, Hat Works is emerging to be the creative industry engine room of the growing ecology…. Adaptive, re-use, economic, environmental and social impact - future-proofing …The Culture Trust worked closely with Historic England, Luton Council conservation officers and EBS Ltd. The Trust and design teams recycled and reused materials found in the building and re-fit for use. Where replacement materials were required, they were sourced, reclaimed or matched with the original local equivalents. Funding from South East Midlands Local Enterprise Partnership (SEMLEP) and National Lottery Heritage Fund supported this work to a very high standard. The Culture Trust redevelopment of this former hat factory has taken four years to complete with the design team Fleet Architects with ‘You&Me’ and Luton based Neville Special Projects Construction Ltd ( part of the Neville’s Group – local family a company with connections to Luton since 1875) . The creativity of this adaptation lies in how the finished building promotes a modern and heritage narrative. An example of this is how the contemporary stairwell slices diagonally through three floors and reveals historic features, stories of former use and scarred walls scaling three floors. This has created a remarkable and playful transition for users passing upwards through the building to the workshops, studios and

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workspaces and describes how the building has been used for 150 years and its use today. A new glazed lantern was introduced on the top floor to prevent water ingress from a failed valley gutter whilst cleverly flooding natural light into this otherwise landlocked space and down the staircase beyond. A further example of new glazing is in the Member Lounge, which references the first glazed covering of the yard some 100 years prior. Equally, the diamond hatched stable block floor replicates the original flooring, and the roof light now casts long beams of natural light at angles across the walls and floor and creates an uplifting and inspiring space.This thoughtful adaptive reuse project has a business model that ensures income will protect the qualities of the building to a high standard for years to come. The Culture Trust, Luton charity is pioneering the growth of a not-for-profit area revitalisation through the Hat District. The Culture Trust, Luton owns the Hat Works freehold and so will be able to safeguard a cultural and creative use in the heart of Luton town centre long into the future irrespective of land/property prices increase. Economically, Hat Works provides 2,400 sq. ft. of new creative and digital workspace for entrepreneurs, innovators and micro-businesses in an inspiring heritage environment. It provides use for up to 75 members per day and promotes micro-business start-ups. Hat Works provides learning and skills opportunities and networks that will engage over 1,000 people a year. In Luton’s Purple Flag assessment, The Hat District was noted for making an important contribution to the town’s night-time economy. (Taken from notes by Guy Smith, The Culture Trust, Luton)

Built heritage - strategy areas of focus o Major projects emerging:  A new Hat Industry Heritage Zone will be created to combine Plaiter’s Lea Conservation area, High Town Conservation Area and the wider High Town hat industry heritage as identified by English Heritage: to include strategic support for hat maker owned historic hat factories in High Town (to make

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them post Covid safe and publicly accessible destinations). Sited within this wider Hat Industry Heritage Zone:  there is potential for a future capital project to develop access to the town’s most structurally sound underground war tunnel as a visitor attraction, evidenced through substantial national internet interest  the Plaiter’s Lea Hat District will be supported and developed by continuing heritage care and conservation projects that address historic hat industry buildings most in need and which can be adapted into a new use that aligns with the Hat District Creative District not-for profit ecology and completion of the Hat District ‘Hat Studios’ project.  Built heritage at risk:  conservation areas: High Town and the Plaiter’s Lea Hat District are both recognised nationally by English Heritage as areas of ‘heritage at risk’(https://historicengland.org.uk/advice/heritage-at-risk/search-register/list- entry/2231; https://historicengland.org.uk/advice/heritage-at-risk/search- register/list-entry/2233). Full audit to identify all buildings at risk within these areas recommended.  heritage buildings identified through consultation (including but not limited too):  historic pubs; and Victorian villas, significant through ‘group value’, like many local heritage assets in private ownership, remain ‘at risk’ of demolition (other built heritage groups on the local list include ‘art deco style white residential houses’ and ‘ workers terraced cottages with Bedfordshire Blue Brick’, these group characteristics are not ‘at-risk’)  the façade of the former ABC Cinema remains at risk.  the National Centre for UK Carnival Arts, significant because of its’ high score on the local list appraisal framework, national significance, its’ local social and cultural heritage value, and its position within the emergent St Mary’s Quarter is identified as ‘heritage at risk’

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 hat Industry related heritage craft, design, technology and engineering skills associated with hat manufacturing (block-making & hat-making) became nationally recognised (in May 2021) along with millinery as skills at risk of extinction and were added to the national Heritage Craft Association ‘red list’.

Recommendations (forming framework for the Heritage Implementation Action Plan)  that a full audit to identify all buildings at risk within the Hat Industry Heritage zone be undertaken;  that the draft local list framework is expanded to include micro-architectural, street furniture design ‘features’, and ghost signs  that local list framework is expanded to adopt blanket group value properties with simple design code recommendations, e.g. . “all commercial and residential flat-roofed art deco buildings, to be automatically locally listed, and to remain white with flat roofs”; all green- tiled art deco residential buildings to be automatically locally listed, and to remain white with green-tiled roofs” . “all workers cottages dated between 1850 and 1945 and constructed using local Luton Grey/ Bedfordshire Blue bricks to be automatically added to the local list, and if sited within conservation areas to have bricks/ brickwork protected”  that an ‘at-risk register’ is maintained (across all categories of heritage); and implementation plan developed to conserve heritage at risk  that all strategic partners adopt the SROI valuation methodology based upon January 2021 DCMS published 'Valuing culture and heritage capital: a framework towards inspiring decision making'  that the ‘Town Centre Conservation Area’ be renamed ‘St George’s Conservation Area’ to avoid confusion with the Town Centre Masterplan boundary, and to acknowledge that other designated conservation areas exist within the town centre; and because this conservation area roughly embraces the area from

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George Street south of The Mall, north-west following Upper George Street to Stuart Street, and south following George Street West to the viaduct  that all partners commit to collectively addressing identified needs for example the need for a conservation officer and supporting the organisational infrastructure of community group development and volunteer training to coordinate local list activity and support a conservation area audit data.  calls for research: built heritage valuation case studies using DCMS (Gov UK DCMS) framework.

2.2 Where the tangible and intangible connect 2.2.1 Luton’s industrial heritage National historical context Luton’s built environment has simultaneously shaped and been shaped by its’ history as a proud industrial and industrious town. Major historic industries have included brewing, hat making, and aviation and motor engineering.

Scientiae et labori detur These Latin words are the town’s motto, roughly translating as ‘by science and industry’ and signified through symbols on the borough Coat of Arms, officially granted in 1876: The bee as the industry's emblem wheat sheaf representing agriculture and the straw hive plaiting.

Made in Luton - Our Industrial heritage assets, significance and protection

Brewing and pubs The earliest public house in Luton is likely to have been the George Hotel (George Street), known to have been in the town as early as 1509; and many were directly connected to local brewers. Like all nineteenth century industrial towns, Luton had its’ share: There are 10 recorded in the town, the oldest being the Luton Brewery

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Company (1767- acquired by JW Green in 1898); and by far the largest was the Flowers Brewery (previously Phoenix Brewery). Throughout the nineteenth and twentieth century JW Green expanded nationwide before being bought out by Whitbread, who acquired the Flowers Brewery in 1961, closed, and subsequently demolished it (1972), when they moved to modern plant in Oakley Road (itself closed in 1984). JW Green, owned or leased over 96 licensed premises in the town between 1936 and1952, producing ‘The Lutonian’ ales.In the late twentieth and early twenty-first century, Fedora and Firkin and the Rockhopper Brewing Company Ltd have been registered as local micro-breweries.

Due to consecutive Covid lockdowns, it has not been possible to fully engage pub landlords and pub communities in this consultation period. The involvement of this community, spanning business and social sectors, will be involved in the strategy review.Ten of Luton’s Grade Two listed buildings are, or once were, public houses; and many more unlisted historic buildings, surviving only through their public use, are at risk of demolition. By 1870 the town had 226 inns, with more than 70 around the centre of the town. In terms of auditing our built heritage assets connected with the town’s brewing history: all those surviving within our conservation areas will be assessed, with particular reference to their ‘group’ and ‘townscape’ values, using our local list criteria.

Luton’s hat industry

Straw plaiting and hat making had already become an important part of Luton’s economy by the late 1600s. Apparently bringing our first economic migration of Scottish straw plaiters. During the 1700s, when fine straw hats became very fashionable, the Napoleonic Wars (1789 to 1815) interrupted the supply of imported plait and hats as ports became blockaded: consequently, home production boomed. Although the war ended in 1815, very high duties imposed on imported goods still favoured the home industry. Straw plaiting flourished in surrounding villages, and more and more hat factories were set up in towns. Luton’s plait market was the largest in the area because the industry grew exponentially between 1820 and 1840.

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There was plenty of land for sale in the town; building development was not controlled, and people did not need much money to set up in the hat business. Most factories were small artisan workshops in or behind houses, work mainly done by women and children. The purpose-built Luton Plait Halls opened in 1869 at the same time as regular imports of plait from China and high-quality plaits, produced in Italy and Switzerland, increased. This abundance of cheap plait and materials coincided almost exactly with the development of hat sewing machines. Edmund Wiseman of Luton, patented his highly successful concealed stitch sewing machine in 1878. Following fashion trends, Luton began to process felt hoods, purchased from the north-west and from Atherstone, into hats. Both the first railway station in Luton, Luton Bute Street (1858 extension from Welwyn), and Luton Midland Road (1868, extension from St Pancras) facilitated growth in Luton’s Hat Industry. One hundred years after the first hat industry boom, by the 1930s, felt hat production played a major role in the town’s trade and resilience to economic depression; and during most of the twentieth century hat making continued to be an important part of Luton’s economy.

In our 2020 public consultation survey, we asked people what they thought most represents ‘the Luton brand’. The highest response (24.34%) said hat-making.

Following the closure of Olney Headwear, famous makers of the Luton Boater, in December 2020, there were only 14 local companies associated with our historic hat industry: a delicate eco-system at risk. All are highly dependent on socio-cultural events such as weddings, Royal Ascot and design and produce for UK theatre, film and TV and fashion industries.

“Luton is the hat centre of the world” (Philip Treacy OBE, January 2021)

The Covid impact on Luton’s hat eco-system has been devastating, reducing the turnover of our seven heritage hat companies by 50% and causing others to close. For hundreds of years, businesses involved in this delicate eco-system have

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remained primary private custodians of historic industrial heritage collections, including tooling, machinery, prototypes, and block and hat examples. While larger hat factory buildings have been restored and repurposed, it is behind smaller closed doors that our living heritage is at risk of loss. Despite attempts to support our artisan heritage craft sector, the UNESCO accredited Heritage Craft Association have, in accordance with Intangible Cultural Heritage (ICH) safeguarding, have this year added block making, hat making and millinery to the UK Red list of endangered crafts.

Our strategic approach to collection and preservation of our hat industry heritage includes:  developing the ‘Hats and Headwear’ significance collection at Wardown House Museum (supporting research and evidence towards national designation status)  connecting the whole of High Town with the Plaiter’s Lea Hat District via the station gateway to create a wider Hat Industry Heritage Zone, as a focus for heritage interpretation and place activation  embracing our remaining hat makers in their efforts to develop upon their pre- Covid visitor numbers (300 per year)

Luton as a site of engineering innovation and excellence (motor and aviation) The airport as a site of heritage “not only has Luton a fine Aerodrome but due to its location, a sound investment in the future” (Sir Kingsley Wood in his 1938 opening speech). The following contains excerpts from notes written by Peter Simpkins, from the London Luton Airport 75 year anniversary book, and notes for The Culture Trust, Luton. The council as pioneering early adopters

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“In the 1930s, it was difficult to understand in which direction commercial aviation was going, and at a time when local government money was tight, it would be a brave council to invest in an airfield, but that’s just what Luton Corporation did.” Following advice from the aviation consultancy company of Chamier, Gilbert and Lodge, and after contemplating four sites, the council chose Stopsley. In May 1936, the Air Ministry approved the site and allowed the council to borrow money to purchase Eaton Green Farm from Ben and William Hartop for the sum of £100 an acre, a total price of £32,950. An additional £31,840 was paid for additional land and facilities. In 1937 Edgar Percival moved his aircraft design and manufacturing company from Gravesend and leased adjoining land on a 99-year lease. The official opening ceremony was in July 1938, involved releasing 100 homing pigeons, exhibiting 100 aircraft and an air display, organised by William Courtney (accomplished aviator and aviation writer for Fleet Street and the New York Times and close friend to Amy Johnson). In 1939 one of the earliest charter flights from Luton Flying Club carried six hat industry salesmen, taking 80 straw and felt samples, to Manchester to publicise the innovations of Luton’s hat and new emergent aviation industries. Greeted by hat buyers and press in Manchester and council members and hat manufacturers on their return, the trip successfully achieved London and Manchester press coverage and increased sales. War time engineering excellence Commercial enterprises were soon to be turned to military effort on the outbreak of World War Two later that year (1939 to 1945). Percival Aircraft were one of several companies involved in manufacturing the Mosquito, possibly the first multi-role combat aircraft made of balsa and plywood. They went on to manufacture a large number of Oxford training aircraft and the Percival Proctor radio trainer and communications aircraft. In August 1938, the Air Ministry took out a 12-year lease at the airfield for the Royal Air Force Volunteer Reserve (RAFVR) or No. 29 Elementary and Reserve Flight Training School (EFTS). “They ran an advert in the Luton News for ‘Pilots airmen and boys’, and in the first three weeks, 4,000 had applied for admission. After the war, the additional squadrons disappeared but No 10 (F) remained and still exists today, with their headquarters being in Proctor Way at the

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Airport.” In 1940 D Napier and son moved to the Old Bellman Hanger at Luton Airport to develop two experimental aircraft. Throughout the Second World War, the main role for Napier’s was the development and manufacture of the outstanding 2,200 horse power 24 cylinder, Sabre engine (for the Hawker Typhoon) and the momentum air filter (of by Cecil Cowdrey and Mr Bonar) and oil and coolant systems developed to handle its increasing engine power. On 1 February 1941, the Air Training Corps (ATC) was officially formed as an integral part of the RAF. “With 200 candidates, nearly 700 semi-trained men passed through these squadrons into the services. After the war, the additional squadrons disappeared, but No 10 (F) remained and still exists today, with their headquarters being in Proctor Way at the Airport.Other wartime activities include No. 5 ferry pool of the ATA, which was based at Luton for a short while, between November 1942 and April 1943.” Continuing innovation After the war aviation business development pace and activity at Luton Flying Club was slower due to the civil aviation acts of 1946 and 1949 limiting passenger transportation numbers. In 1952 a new “architecturally beautiful” control tower was built “…it was practical and functional in its design, giving the controllers a comprehensive and commanding view of the entire airport and its approaches. With an overall height of 52 ft. six inches, the floor of the control room was 42 ft above ground level. The ground floor was used as a pilots reporting room, and moving up to the first floor is where the meteorological office was housed.” In 1959 the council once again showed progressive, pioneering spirit by sending out a tender for a new all-weather concrete runway and the provision of night lighting. The civil engineering company of G Percy Trentham Ltd won the runway contract (“at £271,914- 14s -2d, which being the lowest, was accepted by the council.”) and C Maurice of Bishops Stortford the lighting contract. The official opening was celebrated on 8 July 1960. This new concrete runway and customs facilities kick- started the airport’s lucrative ‘Package tour’ era, seeing a rapid year on year increase in profitability due to increasing passenger numbers. Also in 1960, Autair approached the council considering airline operations in Luton but only if larger and improved passenger accommodation could be provided. So

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once again, the council took the initiative, and Luton Corporation proved its dedication to offering a new alternative to Heathrow and Gatwick. A new passenger lounge was opened in 1961 and extended in 1962 to take a through-foot of 200 people per hour. “Located at the base of the control tower, the new construction was made from cedar wood sections…. It was designed to hold 150 passengers in comfort while they waited for their aircraft. From their seats, they had a panoramic view or the airport through almost full length windows. “In 1962, KLM, the national carrier of the Netherlands, stated that it would be using Luton as its first overflow airport.

By 1963 BEA, Air Lingus, and Swiss Air were all using Luton as a main diversionary airport. In 1964 the runway was extended to 6,632ft, and additional taxiways were built and over time. This attracted other airlines and new businesses such as Monarch Airlines, who launched their ambition to promote passenger service for the demand and needs of the average family rather than marketing solely for the wealthier client, with a charter flight from Luton Airport in 1968. Passenger numbers doubled year on year until the early 1970s when “…the Roskill Commission suggested that ‘Maplin’ be the third London Airport, thwarting any expansion plans that Luton had, resulting in the infamous tents being used as an extension to the terminal….” In the mid-1970s, the oil crisis saw the end of cheap fuel: hitting the airports operational profits until the European Open Sky’s Agreement spurned the development of ‘no frills’ airlines heralded its recovery and position. In 1983 a new terminal was opened by Prince Charles, and the airport was once again used to market local industry, this time as part of a Vauxhall Motor dealer sales incentive, when British Airways Concorde visited the airport carrying 10 lucky Luton Vauxhall workers, who had won a round Britain champagne flight. In 1995 a new control tower, opened by Neil Kinnock, (in his role as the European Commissioner for Transport) illustrated architectural innovation and engineering excellence: at the time, it was the tallest in the UK “157 feet (48 metres), it was also the highest above sea level at 673 ft. (205 metres). It is 13 storeys high, and there

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are 225 steps to the top. From the control room, on a clear day, you can see some London landmarks including Canary Wharf.” In 1990 the airport was re-named London Luton Airport to reflect its proximity to the capital. 3.4million people travelled via the airport in 1997. By 1998 that figure rose to 4.4million: making London Luton Airport the fastest growing in the country. In 1999 another new terminal was opened by The Queen and Prince Philip and Luton Airport Parkway railway station opened, facilitating travel time to London in less than 30 minutes. In 2004/5, new departure and arrival lounges were developed, and the airport management announced support for government plans to expand the airport and build a new runway and terminal. But in 2007, following local campaigns, it was announced to scrap plans for a second runway and terminal for financial reasons and instead follow Department for Transport advice to extend the taxi and runways. In 2006 the last training operator ceased training at the airport. In 2008 Silverjet ceased its long haul flights to Dubai due to global economic crisis; in 2016 L Compagnie ceased long haul flights to Newark. After nearly 50 years at Luton, Monarch airlines entered administration in 2017. It was the biggest airline collapse in the UK at that point, followed two years later by the collapse of Thomas Cook. Despite this, London Luton Airport remained resilient: with new European airlines such as Wizz Air based at the airport; and in 2018, a three-year redevelopment plan was launched and work on the Luton DART (an automated mass passenger transport system) began between Luton Airport Parkway and the airport (eliminating the need for shuttle buses), scheduled to open in 2022. A people’s airport In 1983 in his speech opening the then new terminal, Prince Charles noted how unique it is that the airport is owned in effect by the town, saying how he hoped that “the people of Luton realise that they are all shareholders in the airport”.The airport is still owned by London Luton Airport Ltd (LLAL), a company wholly owned by Luton Council. It is the UK's fifth-largest airport. In April 2019 17 million pasengers had flown through the airport in the previous 12 months. Prior to the Covid pandemic estimated passenger numbers for 2021/22 were 18 million passengers, an increase of five per cent on 2017, with numbers forecast for 17.687m in the following year.

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LLAL indirectly employs over 8,600 staff and is a key economic driver for the town. easyJet, Wizzair, Ryanair, Thomson, EL AL, Blue Air, TAROM, Sun Express, Iberia (Air Nostrum), Fly KISS, VLM, Vueling, Transavia and Adria Airways all currently operate from the airport. The route network currently serves 135 destinations, including Europe, the Middle East, the Canary Islands, North Africa and Scandinavia. The airport is operated and being developed by a consortium of which the majority shareholder is AENA, the world's largest airport operator, and AMP, a major international investor. Following completion of the £160m investment, airport capacity has now been transformed to service 18million passengers per annum.Because of its unique heritage as a council-owned airport, Luton has benefited economically, both directly and indirectly. In addition to employment, vital to the town’s economy, it has historically directly provided support for the people of Luton. In 2019 after paying all operating costs, London Luton Airport Ltd provided £29million to the council and £9.9million, via its community fund, to local charities and community group’s costs. In 2020 the council received a dividend of £19.1m, and a further £9.9millionfor local charity and community groups. Because of the impact of Covid lock down we is not foreseeing further dividends in the near future. Reflecting the devastating impact of Covid on the airport, Luton received a capitalisation directive from the government and in 2021 the council retained its most valuable asset.

The role of London Luton Airport as an existing heritage asset should not be underestimated. Through both public consultation and stakeholder focus groups it has been noted how, throughout the twentieth century and in recent decades, the airport has been both a gateway of hope for and a large employer of economic migrants. Just as Ellis Island is a poetic symbol of the American dream, London Luton Airport symbolises this diasporic characteristic of Luton: in this way, it remains both a site of industrial heritage and a site of cultural heritage.

“The airport as a site of heritage is not just about continuing engineering innovation and excellence; it’s a symbol of hope…it’s like Luton’s very own Ellis Island”

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(Jakub – Lutonian - from heritage focus group workshop May 2021).

The significance of Vauxhall Motors The impact and importance of Vauxhall Motors to Luton and the National Social and Economic Context is evidenced in this significant statement by Dr Len Holden: “The importance of the motor vehicle industry to the British economy …in the twentieth century cannot be overemphasised. By the 1960s, the car and commercial vehicle industry in terms of employment, production profitability and export sales were challenging the old staple industries which had created the industrial revolution. Vauxhall Motors….part of that process had become, by the 1930s, one of the ‘Big Six’ motor vehicle manufacturers in Britain, along with Morris, Ford, Austin, Standard and Rootes, and by the 1960s was one of the three remaining large scale British vehicle manufacturers. The company’s impact on Luton cannot be underestimated. An oft-quoted local saying was that ‘when Vauxhall sneezes, Luton catches a cold.’ This was understood to mean that if Vauxhall entered a downturn, its effects could clearly be felt in Luton. Local businesses that relied on Vauxhall and its employees for business and trade could suffer the consequences. Before the First World War, Luton relied heavily on the hat trade. Luton Council had long been concerned about the reliance on one trade and had sought in the early twentieth century to attract industries to the town to diversify employment opportunities. In 1905 Vauxhall was invited to transfer its business from London to Luton. The Griffin, itself a symbol of Luton, originates from the coat of arms of Sir Falkes de Breaute, who King John awarded the Manor of Luton in the thirteenth century….…The town council’s ‘New Industries Committee’ had successfully attracted the town a number of engineering…firms with cheap land and low commercial rates. Initially, many of these companies thrived, but when Vauxhall, then an ailing company, was taken over by General Motors in 1925, it underwent huge growth. In 1905 it had 200 employees and by 1934 had 6,000 doubling to over 12,000 by 1950 and accounting for nearly 20% of all employment in Luton. By 1963 that figure had risen to 30,000, and by 1971 had risen to a peak of 37,256. This was larger than some towns, and

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the main company site had its own shops, cafes and canteens and even its own bank. The corporate growth of Vauxhall was interrupted by the war when production of cars ceased, and Bedford Trucks for the armed forces became a priority. Vauxhall produced over 250,000 trucks for the war effort. Vauxhall also produced 5,640 Churchill tanks (made in ‘Y’ block – Gipsy Lane retail park and tested in the grounds of Luton Hoo) and over 2 million helmets.”

When the war ended, its contribution to Britain did not cease: Luton exported hundreds of thousands of vehicles to support the export drive in the late 1940s and 1950s.From the 1930s, Vauxhall had attracted labour from all over Britain, particularly from depressed areas such as South Wales, Scotland and the north of England. However, many employees came from London and the surrounding counties. By the 1960s, the money that men and women could make at Vauxhall became a byword for affluence. Sociologists and industrial journalists conducted surveys and research into this phenomenon. It was noted that Vauxhall employees were buying their own cars and houses; filling their homes with fridges, washing machines, televisions and all manner of domestic appliances; and even had their own Griffin Golf Club (an unusual perk for employees). Academics strived to explain this new trend and came up with the rather clumsy phrase ‘embourgeoisement.’ Meaning Vauxhall workers were becoming more affluent.This became a subject of much debate among intellectuals and commentators at the time. Vauxhall employees also took part in the community providing local councillors, volunteers for charities and communal activities. They had their own football, cricket and other sports teams competing locally and nationally); and their own drama group (The Griffin Players). The influence on Luton life was deep and wide-ranging.” Vauxhall even sponsored the distribution of James Dire’s history book The Story of Luton, ensuring every pupil received a copy and could study local history as part of their curriculum. As well as the town's economic backbone, Vauxhall's social and cultural influence cannot be underestimated: mass economic immigration it created between the 1930s and 1970s has left its mark in the super-diverse demographic we have today.

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"It was great in the 1970s…walking into A/C block felt like being back home in the Caribbean.” (Lutonian – from public consultation heritage workshop March 2021).

Frameworks for protection of Industrial heritage Industrial heritage is both tangible and intangible. Our industrial buildings can be protected through national and local listing and if sited within designated conservation areas. Collections are tangible objects, and like our townscapes, need to be curated to represent our histories. We have two ‘significant’ collections: ‘Hats and Headwear’ and ‘Horse Drawn Vehicles and Road Transport’, underpinning the major project and heritage zone developments in this area. Our museum collections are to some extent protected by being held in accredited museums. Private collections, held as heritage assets, are always at risk of loss, reduction, displacement, preservation, and conservation. Intangible heritage, heritage craft skills and ‘in living memory’, is always at risk of loss. Our heritage implementation plan will prioritise those assets identified as ‘heritage at risk’ on our new cross partner ‘local at risk register’

Our industrial heritage assets – transport and motor trade o Vauxhall War Memorial, Kimpton Road o Vauxhall headquarters – Hart House, Kimpton Road o museum collection – motor vehicle industry o objects and information, including vehicles from Vauxhall, Commer Cars, Bedford Trucks – including the 2012 Stories of the World decorated truck o museum collection – Mossman and museum collection of horse drawn vehicles o significant collection of 55 horse-drawn vehicles, illustrating the development, social and cultural status and variety of horse-drawn transport over 300 years, from the Elizabethan and Cromwellian carriages to the last of the carriages, before engines were added

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o engineering and other industry o museum collection of over 100,000 individual items, most of which relate to the development and life of Luton in the twentieth century and other information and objects from companies including Laporte's, Hayward Tyler, Luton News including: . Franklin Deacon Collection of 270 architectural plans and drawings, mainly Luton, of Major BC Deacon, 1908 to 1939 . George Kent Ltd Collection detailing family firm moved to Luton in 1907 to 1908 and company growth in light engineering becoming the largest industrial instrument and meter manufacturer in the British Commonwealth by the 1950s, employing nearly 3,000 people in Luton and South Wales; and including a small number of oral history interviews recorded between 2000 to 2003 with former employees of George Kent Ltd and other industries including Hayward Tyler as part of the Luton Life gallery

Industrial heritage assets – private collections The Vauxhall Heritage Collection, comprising 50 prototype and vehicle models previously housed at the company’s Vauxhall Heritage Centre, Griffin House, Osborne Road Luton; an extensive collection of Vauxhall related motoring memorabilia and a largely uncatalogued archive of documents and photographs extending back to the early part of the twentieth century. The latter represents a major untapped resource for historians and researchers. The vehicle collection comprises examples of all the significant car products produced since 1903, including chassis number 45 from that first year of production and maintained in correct running condition. o Hats and Hat Industry - private collections o Luton hatters’, blockers and descendants remain the custodians of unique hat industry heritage collections, including: working tooling, machinery blocks, hats, samples and records e.g. Gilman & Son repeating lathe; and

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the only spindles and spares for working the 17 Guinea stitching machine (patented 1830). o Hat industry and headwear collection – museum collection o The collection encompasses in excess of 9,500 items and over 10,000 images representing the straw, felt and silk hat industries of England and includes representative content from the production centres in Belgium, Italy, Switzerland, Germany, and the Far East

Headwear – more than 3,000 items ranging from the 1600s to contemporary design, for men women and children, including fashion and occupational headwear for the working and upper classes

Accessories – including veils, caps, mantillas, lappets, hat pins, trimmings and an unsurpassed collection of feather mounts and pads

Straw plait collection – more than 2,500 well documented examples of local, national and international products; plaited, woven and machine made, providing a unique database to identify and date headwear. This is the only known collection of its size and type

Hat materials – comprehensive range of materials, hoods, fabrics, dyes, colour sample cards

Hat making tools and machines – an extensive range including hat blocks, threads, needles, head gauges representing both home working and industrial aspects of the trade

Hat making processes – unique collections from hat manufacturers showing the stages of straw, felt and silk hat production

Material from the retail trade – shop and factory fittings and a range of advertising materials

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Documentary and archive material – including the world’s most complete run of the industry’s trade journal The Hatters’ Gazette, British millinery journals, fashion plates, catalogues, posters, postcards, books, patents and photographs depicting the import and export trade

Oral history – representing managers and workers from the twentieth century industry up to today, and including reminiscences of businesses in the late 1800s.

Associated items – baskets, reticules and dolls, including objects made for the Great Exhibition in 1851 produced by the industry’s workers

Dedicated hat store – allowing visitor access and facilitating detailed research

Hat research centre – study and research space for hat industry and headwear.

Industrial heritage - strategy areas of focus o Major Project: ‘Made in Luton’, positioning Luton internationally as the home of the Vauxhall Heritage Collection and as a historic site of engineering innovation & excellence. o heritage at risk o The Vauxhall Heritage Collection (at risk of loss to the town) o Hat Industry related heritage craft, design, technology and engineering skills associated with hat manufacturer (block-making and hat-making) became nationally recognised (in May 2021) along with millinery as skills at risk of extinction and were added to the national Heritage Craft Association ‘red list’. Boone & Lane are the only blockers in the world offering skilled craftsmanship in both wooden and metal hat block making o Social history, collective and individual memories

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Recommendations o In the Museums’ Collections Policy and Collections Development Plan review, we need to ensure adequate representation of Luton’s Industrial Heritage: o to address the risk posed by the changes in ownership and disposal of facilities in Luton of Vauxhall headquarters, and support the Industrial Heritage major project emerging. o to support the development of the Culture Trust’s Hat and headwear Museum collection significance seeking designation by Arts Council England. o to recognise the airport as a site of heritage o to urgently record social history memories related to our 20th century industrial heritage

2.2.2 Luton’s cultural and community heritage - the heart of the matter "We are an island. We are quite an irreverent, rebellious people. We should become: The People's Republic of Luton" (Ed Smith – Lutonian- from public consultation heritage workshop March 2021)

National and local context UNESCO (United Nations Educational, Scientific and Cultural Organisation) defines cultural heritage in terms of both tangible moveable & immovable objects and collections, and intangible cultural heritages such as oral traditions, languages, music and performing arts, customs, traditions and rituals. Cultural heritage is an expression of the different ways communities develop by passing on, from generation to generation and from place to place, meaningful objects, artistic expressions and values.

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In our April 2021 public consultation survey, when we asked which category of ‘heritage’ was most important to you ‘cultural heritage’ took the fourth position (after ‘natural’, ‘built’ and ‘industrial’). But when we grouped together votes for ‘Cultural’, ‘Intangible’ and ‘community’ heritages, they came out top. When we asked the open question ‘What IS heritage?’, ‘What does the term mean to you?’ Overwhelmingly (over 90% of) respondents wrote about the lineage of their own cultural identity and the town’s collective shared memories. With comments such as:  “that which shapes us”  “the tradition and story of place”  “the preservation of history”  “shared history”  “ a community’s sense of identity”  ”the history you ‘own”  “my cultural background”  “things we grew up with that form part of our identity”  “the history of each community: the part they play in the development of the town”; “an appreciation of origin… valuing and being enriched by it…and preserving it for generations” Things we grew up with include townscape buildings and collective memories attached to them. This notion will form the heart of our built heritage implementation plan, and our collective cultural heritage will shape our future heritage interpretation plan. We will unwrap the history of each of our communities, the part they play in the development of the town, and what this means for Luton.

National governance frameworks for cultural heritage sit with DCMS and national funding frameworks include Arts Council England (with a remit to support museums and collections), and the National Lottery Heritage Fund, who defines heritage as “anything from the past that you want to pass onto future generations” fulfilling a mandatory outcome that “a wider range of people will be involved in heritage”. The National Lottery Heritage Fund believe that international working is vital for a strong heritage sector; and, because Luton has a long history of attracting people from

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around the world: our key cultural heritage characteristic can be summed up through the word ‘diaspora’. We can learn from international models of connectivity such as the British Council’s ‘Culture in a box’ project or best practice models closer to home, for example, the Luton Irish Forum who have developed a strong relationship with the Irish Embassy in London, who help fund them, and the community they serve.

Luton has a proud history of democracy facilitated by protest, political and social action. Acknowledging this as a cultural characteristic of Luton, the Pilot Year of Culture in 2019 explored themes marking the one hundred year anniversary of Lutonians storming and burning the town hall in protest against the poor treatment of local veterans returning to the town after serving in world war one. The five-month programme followed the chronology of the 1919 Peace Day riots through six diverse and inclusive arts and culture events:  15 June, ‘The People’s Launch’ was a staged heckling of council VIP event by local people with experience of unemployment  16 to 20 July, ‘Riot Act’, a play inside the town hall council chamber about community exclusion featuring participants from a diverse range of ages, ethnicities, sexuality and disability  19 July, ‘The Outdoor Spectacular’ embodied the spirit of ‘People Power Passion’ outside our Grade Two listed town hall and featuring spoken word, dance, and diverse genres of music against a visual backdrop of the burning of the town hall  16 to 17 August, ‘Justice 39’, an outdoor play by young people exploring issues they face today in Luton  14 September, ‘The Children’s Peace Party in historic Wardown Park, inspired by the event of the same name held at Luton Hoo in 1919  12 October, ‘Lutopia’ invited audiences to experience a virtual reality game designed by community groups and children, investigating an alternative future for the town.

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The pilot evidenced improvements for participants in confidence and skills development; audience connectivity to the town centre, civic pride and community cohesion; and economic benefits for the town, including inward investment (66% of the project budget was spent locally and 64% of the audience said they came to town specifically for the events). We will use this home-grown proven exemplar of heritage-led place activation as a best practice model for future place-making activity.

The 19 July performance by post punk Lutonian band UK Decay reminded us of their political protesting of the Falkland’s War in 1982 and how hidden histories, youth movements and emergent music genres have formed the backbone of twentieth and twenty-first century grassroots, multi-racial social and political activities across the town. Luton has a rich cultural history of alternative ‘tribes’, clubs and music scenes, including some more political than others: South Asian Bhangra, Afro-Caribbean house parties, LGBTQI+ communities and the Exodus (Rave) Collective. All of which deserves further heritage-led research.

Our 2021 public consultation workshops lead to lamentations of community-led centres such as the Starlight Club and 33 Community Arts Centre, without which we would not have had the 33 music studio or the jazz record label 33 records. The legacy of jazz within our Plaiter’s Lea Hat District, as embodied at The Bear Club, is just one example of Luton’s rich heritage of music sub-cultures.

Amongst emergent themes from the 2019 Pilot Year of Culture, notions of ‘home- town’ were again emergent in our 2021 heritage consultation workshops. This crucial need to investigate inter-generational connectivity is also the crux of the film Blinded by the Light, a British comedy drama by Gurinder Chadha based on Lutonian journalist Sarfraz Manzoor’s memoir ‘Greetings from Bury Park’, a coming of age story of British Pakistani Muslim teenager in 1987.

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Cultural Histories CIC won two awards for their work in exposing the history of the Peace Day riots; and their 2020/21 legacy work developing ‘Luton Cultural Histories’, connecting primary school children through inter-generational memories with community histories attached to local historic buildings, has revealed the need for deeper research to explore how young people connect or don’t connect to the town in which they live. Understanding connectivity will be the strategic point of departure for our heritage interpretation plan.

Our cultural and community heritage assets, significance and protection Community institutions form the backbone of our cultural heritage assets and sites of cultural heritage: Luton Town Football Club Notions of ‘home-town’ are signified through our Luton Town Football Club (LTFC), founded in 1885, and our Hatters Heritage collections. First in the Southern League to turn professional in 1891, ‘The Hatters’ still reflect the town’s historical connection with hat making through their mascot ‘Happy Harry’ a smiling character in a Luton straw boater hat. The local and community ethos of the football club has been illustrated through turning down gambling sponsorship from the betting industry. Instead, sponsors have traditionally come from within Luton’s historical industries, including: Vauxhall, SKF, Electrolux, easyJet and Ryebridge Construction. Luton Town Football Club operates a development squad, an under 18s team and a youth centre of excellence; and supports Luton Town Ladies Club. The ethos of the football club is illustrated through Trust in Luton (one of 140 supporters trusts in the UK), which owns shares in the club and elects a representative to the club board. Its official charity, The Luton Town Community Trust (reconnecting communities through health, inclusion and education projects); and the Luton 2020 Developments Ltd (the company behind the club’s business re-development intentions to build a new stadium at Power Court). The private collections of Luton Town Football Club and Hatters Heritage, a separate voluntary run charity set up by club historian Roger Wash, represent a significant social history collection for the town.

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Luton and Dunstable Hospital Opened in 1939, when 10 acres of land between Luton and Dunstable were purchased from Electrolux, and new wards were named after Queen Mary (who opened the hospital on 14 February) and benefactors Lady Ludlow (from Luton Hoo) and Arthur Buckingham (a Dunstable grocer). The hospital joined the National Health Service in 1948. It opened a Rehabilitation Centre in 2003, became a university teaching centre in 2012 and opened a state of the art cardiac centre the following year. In 2015 it was named by the Health Service Journal as one of the top 100 NHS trusts to work for, and the Care Quality Commission rated it as ‘good’ in 2016. These medical, nursing and midwifery developments could not have been achieved without the decades of the invaluable and lasting contribution of migrant professionals from throughout the world. After the Second World War, the newly established NHS recruited extensively for midwives and nurses from Jamaica, Barbados and other Caribbean Islands (The Windrush Generation) after facing a hiring crisis in the UK and we have learned about some of these local stories from our 2021 public consultations. Another critical part of the establishment of the NHS came from tens of thousands of young Irish women who crossed the Irish Sea to begin nursing careers. Amongst the earlier Irish trailblazers was Donegal nurse Agnes Jones (1832 to 1868), a contemporary of Florence Nightingale who became the first trained nursing superintendent of the Liverpool workhouse infirmary contributing to the welfare of sick paupers. British Jamaican nurse Mary Seacole was also a contemporary of Florence Nightingale, setting up ‘The British Hotel’ behind the lines of the Crimean War. In Luton, it was a synergy with Mary Seacole that inspired local Councillor Desline Stewart MBE to establish the Mary Seacole Housing Association in 1986. Because of the Covid pandemic, which itself is a moment of history, it has not been possible yet, to discover stories from our South Asian and European medical and care professionals, or develop these heritage links across town. Covid deaths peaked at the hospital between December 2020 and January 2021, and our front-

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line workers have been some of the most affected. ‘Our River’ a photomosaic public art piece on the Mall Wall in Silver Street, is planned to celebrate our key workers and commemorate local lives lost to the pandemic. https://ourriver.uk/ Public art, routed in heritage, will play a key part in our heritage interpretation delivery plan.

The University of Bedfordshire The University of Bedfordshire, another anchor institution, is a social, cultural and educational heritage site, through metamorphosis from its roots as a nineteenth century teacher training college, Luton Modern School, Luton Technical Institute, College of Technology and the University of Luton, www.beds.ac.uk. In our public heritage consultation, when we asked ‘What is your favourite building?’ the university’s £46m library, opened in 2015, was mentioned as a “magnificent landmark building”. Generations of Lutonian’s have been educated on the site, which is now home to the University of Bedfordshire’s Park Street campus. In 1904 a Combined Day Secondary School and Technical Institution opened in an old hat factory in Park Square. In 1908, this was replaced by a new building known as Luton Modern School. By the 1930s, the town was an important centre of industry thanks to the town council’s pro-active efforts to attract large employers to the area. In response, Luton Technical Institute was founded in 1937 on the site to ensure the ongoing availability of vital skills locally. The college has had many name changes over the years, and it has not been possible to date these accurately. We do know that the current building was completed in 1957 and the school became Luton College of Technology in 1958. In 1976 the college merged with Putteridge Bury College of Education to become Luton College of Higher Education. In 1993, the college became the University of Luton, and the University of Bedfordshire was established in 2006 following a merger with Bedford’s de Montford University. Over the past decade the University has invested in significant capital development of its estate that include a new campus centre, a centre for Postgraduate students, Halls of residence, the Library and most recently in 2019 completed a £40m investment to

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teach Science and Technology formally opened by Sir Lord Robert Winston. Today, under the leadership of the Vice Chancellor Professor Rebecca Bunting, the University of Bedfordshire educates over 24,000 students from over 100 countries. It is not only an important historic site itself, it also champions cultural and heritage development across the local community. The University’s Arts and Culture Projects team runs a range of place-based projects and resources, which aim to support local cultural practitioners and organisations, as well as engage Luton’s local young people through various outreach projects and programmes in partnership with local schools. Capacity-building activity that the team leads in order to support the local cultural sectors include development programmes for entrepreneurial, business and fundraising capabilities. In partnership with the National Lottery Heritage Fund, 2021 saw the launch of two new programmes designed to protect and develop Luton’s local heritage sector by ensuring individuals and organisations have the knowledge, capacity, resilience, and support from an infrastructural partner to negotiate the negative impact of Covid-19. Its Heritage Impact Accelerator programme aims to build the capacity of 12 diverse local practitioners or organisations to deliver enhanced community heritage projects and develop a new cultural and cross-sector partnership https://www.beds.ac.uk/arts-and-culture-projects/cultural-sector-support/national- lottery-heritage-fund/. This will run alongside a new Heritage Enterprise Hub, which will provide practical help with issues relating to working across heritage, completing bids, building strategic partnerships and networks, building digital infrastructure, engaging with schools, developing archives, and improving professional resilience and diversifying income. Both of the projects align to the team’s wider outreach activity, including overlapping workstreams to connect heritage sector support work with the team’s involvement in wider regional activity, including the two Local Cultural Education Partnerships that the team deliver on as part of place-based cross sector consortiums, https://www.beds.ac.uk/arts-and-culture-projects/local-cultural- education-partnerships/.

Marsh House

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Marsh House is located close to the source of the River Lea and sits within the scheduled ancient monument Waulud's Bank: a possible Neolithic henge dating from 3,000BC and part of the ‘Beacons of the Past’ and ‘The Chalk-scapes Project’ by the Chilterns Conservation Board. Originally a farmhouse for Marsh Farm, the building now sits within Leagrave Common, a County Wildlife Site.

In the 1960s the land was purchased by Luton Council and in the 1970s the building was turned into a community centre. Since then, the building has cemented its position as an important centre for youth culture in the town, playing host to punk bands in the 70s, Gemini High Power Sound System in the 80s, and Exodus Collective in the 90s. Fast-forward to the present day, and Marsh House is now home to six social enterprises. One of these, Marsh Farm Outreach - which was founded by members of the Exodus Collective - provides jobs through matching disused buildings with disused labour. After reaching an agreement with Luton Council in 2005, Marsh Farm Outreach facilitated the regeneration of the heritage building, which was once bricked up and had developed dry rot. Other organisations operating out of the building today include Revoluton, Luton Urban Radio and Marsh House Studio.

Luton Library Theatre, Hat Factory Arts Centre, Wardown House Museum and Stockwood Discovery Centre The Culture Trust Luton, is an arts and cultural charity that showcases high-quality arts and cultural activity and delivers community-focused public realm art engagement and management in the Hat District and across four inspiring sites of heritage: Stockwood Discovery Centre, Wardown House Museum, Arts Centre and Luton Library Theatre.

The Culture Trust, Luton are also custodians and curators of the town’s museum collections. The Culture Trust, Luton have a collection and curatorial agreement with The Windrush Partnership and have appointed a consultant to address issues of

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demographic representation across all museum’s collections policies addressing how and what we choose to conserve. Stockwood Discovery Centre and Wardown House Museum, house collections that include natural history, archaeology, costume, rural crafts, military history and fine art. Wardown House Museum focuses on local cultural, industrial and community history, including the significant Headwear and Hat Industry Collection. Stockwood Discovery Centre displays regional collections, including archaeology and rural, and houses the significant Mossman Collection of Horse Drawn Vehicles Collection (the largest of its kind in Europe). Cultural heritage assets – museum collections (complied by Elise Naish, Head of Heritage and Collections, The Culture Trust, Luton) include: Archaeology The WG Smith collection of palaeolithic flint work is of national importance, as is the Pagan Saxon cemetery assemblage from Argyll Avenue. Of regional importance are the excavated assemblages from Puddlehill and Grove Priory. The other prehistoric, Romano-British, Saxon and medieval material in the collection is of local importance, including the Tingrith and Shilligton hoards and Wenlok Jug. Luton News and other photographic images Photographic collection of over one million negatives and prints, including the Thurston collection of the nineteenth and twentieth century prints and negatives and the Luton News negatives from the 1920s to 1991. The Luton News negatives are on permanent loan. Textiles The lace collection draws together material reflecting every facet of an industry that was once of considerable economic and social importance across the East Midlands. In addition to fine examples of the completed lace, the museum houses major holdings of lacemaking equipment.

Fine art Our collection of over 400 oil paintings, 800 watercolours oil and acrylic pictures has been published in the Bedfordshire, Cambridgeshire and Northamptonshire catalogue for Public Catalogue Foundation, which aims to record the paintings in

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public ownership. A number of the artists represented in the collection held exhibitions at Luton, including Robert Hill and Theodor Kern, an Austrian artist who settled in Hitchin. Amy K Browning, who held a one-woman show at the museum in 1954, was born into a Bedfordshire farming family at Little Bramingham near Luton. Married to TC Dugdale, also an artist, she gave his painting of ‘Jimmy Messenger’ to the Museum. Edward Callam grew up in Luton and was commissioned to record the town before the construction of the ring road and The Mall. These paintings (e.g. Stuart Street to the North, Luton) were first exhibited at the museum in 1969. The museum service’s collection continues to have a strong local emphasis as reflected in the present collecting policy, encompassing paintings of Bedfordshire scenes or works by local artists, many of which have been given by artists or individual donors. Of local note are a comprehensive set of watercolours, which offer a glimpse of Bedfordshire in the early 1800s as seen through the eyes of Thomas Fisher and George Shepherd. Their paintings show that the focus of life at that time often centred around the country houses on large estates and smaller farms. Today some buildings remain unchanged while others have been greatly altered or have disappeared. These paintings provide an opportunity to look at the lost world of Bedfordshire before railways, tarmac roads, and industrialisation brought irreversible changes to every aspect of life.

Art in the public domain Tangible evidence of our cultural heritage can be found in Luton’s historic public art, an audit of which is currently being undertaken. Protective frameworks for public art are complex: the council have a public art plan to ensure quality and relevance of commissions. Some public art is protected because it exists on the side of listed buildings. Most public art is in the public domain, but some examples are privately owned.

Music and dance in Luton Our production of music and dance are cultural, community and intangible heritage assets. There are many privately owned and hidden archives, and collections,

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representing a whole range of culturally diverse music and dance originating in Luton. From Luton Girls Choir and (South of England) award winning Brass Band, through jazz, punk, house music and the Exodus (rave) Collective; to Bollywood dancers and Kadam Dance, and world-champion Irish dancers Eeamon Kitching and Jason Byrne . This strategy supports further audit and research around development of a demographically representative collection for Luton; acknowledges an opportunity to capture archive material relating to music and dance throughout the year of various festivals and communities; and recognises the need to retrospectively create collection around music created, produced and ‘made in Luton’.

Of course the biggest heritage assets in Luton are its people.

“What you have to understand is that, for many young people in the town…heritage is pain” (Lutonian – from public consultation heritage workshop March 2021).

Luton has an ethnically and culturally diverse population created by a rich history of inward economic migration. Identities and representation can be complex and intersectional. According to the DCMS of visitors to nationwide heritage sites in 2019/20, visiting was reported less often by Black respondents (41%) compared to other ethnicities (60 to 75%). Additionally, it was observed that Asian respondents (60%) were less likely to have visited than White respondents (75%). Those in the most deprived areas (51%) were less likely to have visited heritage sites than those in the least deprived areas (83%) (DCMS). In Luton, one of our heritage strengths is our ‘super-diverse’ population.

Diaspora The early part of the twentieth century witnessed the migration of Scottish and Irish people into the town, followed chronologically by Afro-Caribbean and then Asian peoples. More recently, immigrants from the European Union have made Luton their home. Luton is one of only three towns in the UK (along with Leicester and Slough)

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with a White British population of less than 50%. In the last census, 81% of the population defined themselves as British. Of those who answered the question in our 2021 heritage consultation survey, 69% of respondents viewed themselves as Lutonian. In further public consultation workshops, we investigated common characteristics and, through discussing what it means and feels like ‘to be Lutonian’ discovered the shared and uniting term ‘diaspora’ (the dispersion or spread of any people from their original homeland), experienced by all immigrant communities, who have all at different times faced both discrimination and hospitality. Luton has developed resilience and hope in equal measure. There are now 122 different ethnic languages spoken in Luton, and many different peoples have made it their home. We will have figures from the 2021 national census later in the year and will need to review this strategy, heritage interpretation and collections policies accordingly.

Luton’s South-Asian Community Around 30% of Luton’s population today is people of South-Asian ethnic origin, including large communities of Bangladeshi, Indian, Kashmiri and Sri Lankan descent that have shaped the cultural and physical heritage of the town today.

Luton’s South Asian population contains an exceptionally high proportion of people originating from the Pakistani Azad Kashmir region, many of whom were able to come to the UK in the 1960s with money they received in compensation following the flooding of Mirpur and surrounding villages by the Mangla Dam, when people were being sent in their hundreds from Pakistan occupied Kashmir to come to work in the mills in the UK, it is from these migrations that people came on to work in Luton factories, such as Vauxhall. In the 1960s, many of the migrants were Kashmiri Muslims fleeing sectarian violence. It is estimated that anywhere between 50 to 75% of the population living in Britain originated from Miprur (Ballard 1991), with the remainder from the Punjab and a smaller number from Khyber-Pakhtunkhwa Province. The majority of migrants from Pakistan were unable to speak English on arrival, and like many, diasporic communities had to take unskilled jobs to survive. A small group of professionals came specifically to join the National Health Service.

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Luton and Slough, in the south of England, have the largest Kashmiri communities while London is more diverse and cohorts can be found elsewhere which consist of Punjabis, Kashmiris, Pukhtuns, Sindhis and Urdu speakers.

Bangladeshi migration to the UK also has a long history. Sailors (lascars) from the Sylhet region in Bangladesh arrived on ships through the eighteenth and nineteenth century, some of whom settled in the UK. However, large scale Bangladeshi settlement in the UK is a more recent phenomenon compared to that of other South Asian communities. When India gained its independence from British rule, the country was partitioned, creating a new state of Pakistan. Following partition in 1947, Pakistan comprised of two territories divided by 1,000 miles - the present-day Pakistan, which was then known as East Pakistan, and the present-day Bangladesh, which was then West Pakistan. There was a civil war between East and West from 1970 to 1971, which resulted in the creation of Bangladesh in 1971. Most Bangladeshi families in the UK in the present time are the result of large scale migration in the early 1970s from the Sylhet region of Bangladesh, as people fled from this civil unrest.The Nazima restaurant in Dunstable Road, one of the first “Indian” restaurants operating in Luton in the very early 1970s, was probably the first community hub for Bengali community activity (political and social), comprised mainly of young men at the time. This year (2021) is the fiftieth anniversary of Bangladesh.

Luton’s South Asian Cultural Assets Luton’s South Asian Cultural assets include collections from ‘Pakistani Truck Art’. The following information from Fahim Qureshi: “Pakistani Truck Art was an international art project that explored the shared heritage of Luton and Pakistan through the Bedford Truck. The project was part of the Stories of The World heritage strand of the London 2012 Cultural Olympiad programme and involved two-way artist exchanges and residencies between the U.K and Pakistan, a youth cultural exchange visit to Pakistan and the creation of a highly decorated Pakistani style Bedford Truck by artists and young Lutonian’s for the Luton Museums Service’s

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permanent collections. Truck Art involved partnerships between Culture Trust, Luton, The National College of Arts - Lahore, The Lahore Museum, Phool Phatti - Pakistan, The British High Commission, The British Council, Vauxhall Motors and the Pakistani High Commission.”

Strategic Approach The Bury Park area of Luton is home to the highest number of South Asians in the town: 62.75% of residence in the Dallow and Wards are from Pakistan or Bangladesh descent. (figures April 2019). It is also an area with a high number of listed and non-listed heritage and faith buildings, has hosted world famous performers such as Asad Khan, and was the setting for the 2019 British film ‘Blinded by the Light’: a drama-comedy investigating the intergenerational intersectional complexities of being a British born adolescent of Pakistani descent navigating Luton’s socio-cultural landscape during Thatcher’s England. Our strategic approach will be to develop the Bury Park area as a non-designated heritage interpretation zone. The strategic approach to Bangladeshi heritage will be to develop a legacy from this year’s ‘Freedom 50 coordinating group’ activities.The strategic approach to South Asian cultural heritage will include continuity of linkages with our industrial (Vauxhall) heritage; with Luton’s new (2021) Bollywood production studio (Bunny and Divi Entertainment Ltd); and national connectivity of activities with South Asian Heritage Month (SAHM), mid-July to mid-August every year. Further details can be found at, Southasianheritage.org.

Luton’s Irish Community Luton’s current population includes around 20,000 people of Irish origin, with over 6,000 residents considering themselves to be Irish in the 2011 census. As a percentage of all residents, Luton therefore has the largest Irish community in England, outside of London.

Irish communities have continually settled in Luton since the Second World War, with migration often driven by changing social and economic circumstances in both

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Ireland and the UK. The decline of jobs and opportunities for young people in post- war Ireland, coupled with restrictive social structures, drove many men and women to seek better opportunities in medium-sized industrial towns such as Luton, which was experiencing a post-war economic boom. As a result, the Irish-born population in Luton grew from less than 1,000 people before the war to more than 7,000 by 1961, with many Irish men working for the Vauxhall motor company and in other industrial occupations. Luton’s Irish community has significantly shaped the heritage of the town since the mid-twentieth century. This is particularly true in the area in the north-west of the town, where around a quarter of Luton’s Irish residents lived between 1961 and 1982; most likely due to the close proximity to St. Joseph’s Catholic School. In terms of built heritage pubs, social clubs and churches have all been important to the townscape of Irish communities in Luton. The town' has a number of identifiable and characteristically ‘Irish pubs’ and clubs that have embedded Irish culture in the town. The Celtic Club, which opened close to the town centre in 1977 is one example that helped to bring Irish music, dancing and events such as St. Patrick’s Day to Luton. The growth of Irish communities in the 1960s and 1970s also resulted in the establishment of eight Catholic churches, which along with Catholic schools, have been central to preserving faith-based heritage among Irish people in Luton. The Irish community continues to have an enormous and lasting impact on Luton's cultural and social heritage, with a long-held tradition of social organisation such as the Luton Irish Forum, contributing to the town. The town has also produced world- champion Irish dancers including Eamon Kitching and Jason Byrne.

Luton’s African andCaribbean communities, and the Windrush generation According to the 2011 census, about 10% of Luton’s population were of African and Caribbean descent.

The Culture Trust, Luton custodians of the town’s museum’s collections, have a curatorial partnership with The Luton Windrush Partnership Programme (LWPP). This strategy recognises that Windrush is just one small part of the African Diaspora

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story and recognises the need for inter-generational research and development investigating personal impacts of bonds, disconnects and cultural fusions resulting from African and Caribbean Diaspora. The ‘Curating Luton: Heritage Implementation plan will support the work of youth ambassadors from the Heritage Alliance and from heritage, creatives to research and collate a range of hidden histories throughout the town; seek to re-dress historical narratives, and programme activities not just during national Black history month in October.

European and Eastern European Between the 2001 and 2011 census, Luton witnessed a steady increase of European and East European migrants, mainly Polish. In 2011 there was a high density of people of Polish origin in the High Town and New Town areas of Luton, and a high density of people of Turkish origin living in Farley Hill. Luton is also the home of Luton Roma Trust. Once we have received the data analysis of this year’s census (2021), we will be able to assess the effects of the Brexit referendum on the demographics of Luton’s European and East European populations; and will be able to engage more fully with all European and Eastern European people in the town during our heritage interpretation and implementation planning.

Mixed Race Mixed race is the fastest-growing ethnic minority in the UK. Once we have received the data analysis of this year’s census (2021), we will assess the impact of the increase of mixed-race people in Luton. More than any other evidence, this change evidence that defining the cultural heritage of Luton is a dynamic process. Therefore, our strategic approach must involve frameworks for dynamic engagement and evolution of criteria for auditing heritage assets and developing collections and curatorial decisions.

Protective frameworks for our cultural heritage We can use various frameworks to protect our physical, historical environment (as outlined in the sections above); our cultural heritage is less easy to protect. Physical

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public art can be protected for example by existing on the sides of listed buildings (listing protects the building only, not the art per se). A robust Public Art Plan and public art maintenance agreements can protect physical art in the public domain that is owned by the council. Public art in private collections or owned by other organisations is more difficult to protect. The best framework we have for protecting physical, cultural heritage assets (moveable objects) is the review of our collections policies (in line to reflect and represent our changing demographics).

In terms of our intangible cultural assets (our stories, language, music and dance), Luton has a rich, diverse, abundant and overflowing cornucopia of collections held by local community groups and charities such as Hatters Heritage, Cultural Histories CIC and Kadam Dance. The best frameworks we have for preserving our intangible cultural heritages will be oral history collections and centralised digital archiving.

Cultural heritage - strategy areas of focus: o major project/emerging: o ‘Curating Luton’: heritage interpretation and place-making plan. Throughout our public consultation and focus group workshops, the need to embed our stories of diaspora and diversity within all of our heritage interpretation and place-making intentions; and the need to anchor Lutonian’s with the physical townscape through heritage narratives has emerged as an important necessity. Strategic approach to this major project will be two years of planning, development and pilot projects, including GIS mapping, followed by three years of delivery. o Cultural Heritage at risk o National Centre for Carnival Arts building As identified above in the built heritage section of this strategy: The National Centre for UK Carnival Arts building, significant because of its’ high score on the local list appraisal framework, national significance, its’

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local social and cultural heritage value, and its position within the emergent St Mary’s Quarter (see below) is identified as ‘heritage at risk’. o Program of Cultural Festivals The impact of consecutive Covid lockdown’s on Luton’s previously vibrant and successful program of festivals should not be underestimated. In the past LLAL has sponsored six events: St Patrick’s Day, and Luton Mela (sponsored); St George’s Day, Fireworks and Lighting Up Luton (tendered and managed by the council). Luton’s program of festivals has also included Diwali, Polonia and Eid. Luton’s historic quality offer of a vibrant ten month program of multi-cultural festivals is now identified as heritage at risk. o Collective and individual memories Throughout our public consultation workshops and consequent focus group workshops, one issue was continually raised: the need to record stories from our elders. Community groups representing people of Irish, African and Caribbean, and Bangladesh descent all mentioned this need, and it was raised in reference too economic migrations connected with our NHS hospital,, our Windrush generation andour Vauxhall workers. All agreed and highlighted the urgent need to record, collate and preserve stories from elderly Lutonian’s. These collective recollections and individual memories, including records of customs and traditional food, are recognised as local heritage at risk. o Music and digital archives The digital archives of Luton Community Arts Trust and 33 Jazz Records have been noted as heritage at risk. As heritage engagements continue across town we are sure that more legacy collections of community and music archives perhaps digital collections stored in outdated historic formats will emerge. Recommendations

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 Using heritage to anchor ‘place-making’ within our 5 statutory designated heritage conservation areas; and 5 emergent Heritage Interpretation Zones  Innovative (using AI, GIS & public art) approaches to heritage interpretation, re-addressing and embedding our stories of diaspora and diversity of cultural heritage in early stages of capital developments.  Maintaining a dynamic local list to include public art  Maintaining a dynamic heritage at risk register to frame our heritage implementation planning.  Partner sign up to o ‘Curating Luton’: five year heritage led place-making (Heritage Interpretation and Implementation Plan). o Research potentials: expanding the cultural and heritage valuation framework Frame-work to include intangible cultural heritage; the lineage and evolution of Luton produced music genres; impacts of anchoring heritage in place-making on health and wellness

2. 3. The intangible: making our invisible visible Local and international context The term intangible culture includes I knowledge and skills transmitted through learning, accounts, repetition of traditions and customs. Like other aspects of cultural heritage, music, dance, and festival, intangible culture is dynamic and evolving as new behaviours and beliefs contribute to a group or community's sense of identity and continuity.The best frameworks we have for preserving our intangible cultural heritages will be robust community engagement and innovative curation of our oral history collections and centralised digital archiving.

In addition to the intangible cultural heritages listed above, Luton communities also use a diverse range of languages, the evolutions of which are not recorded. We also know there is a long history of different types of religious faith and beliefs within the

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town, a rich heritage connected to our physical townscape through buildings of worship, many of which should be reviewed for inclusion in our local list. We also know that Covid deaths peaked at the hospital between December 2020 and January 2021Our heritage consultation has identified how residents from all communities and backgrounds have experienced losing loved ones and the loss of cultural and intangible heritages associated with funeral rites and bereavement customs. But we do not yet know the impact of this personal grief and disruption to traditional funeral conventions has had on our community heritage lineage. We heard this from ourAfrican and Caribbean, our Irish, South-Asian and Roma communities, as well as various religious groups, in particular our Islamic population.

Through this year of research and consultation, we have identified a diverse range of digital heritage projects across town, from Hatters Heritage (150 years of the social history of Luton Town Football Club) to Kadam Dance (South Asian art magazine). We have also identified lost and hidden oral history and private digital and memorabilia collections. There is an urgent need for intergenerational and inter- sectional projects to preserve memories of our elders across all of Luton’s different communities. Many digital and oral archives relating to the history of Luton are held by various national, regional and local organisations; others remain hidden in personal collections, and; there are retrospective gaps in collections. There is a need for a strategic approach to create a robust digital archive management framework to audit, collate and preserve Luton community archives; and centralise preservation and access.

Our intangible heritage assets, significance and protection 2.3.1 Heritage craft skills According to Historic England: £140 million GVA was lost due to skills shortages in the heritage sector in 2016 (Historic England).

We begin this section with a much overlooked intangible heritage: knowledge and craft skills. Just as our collective memory and knowledge preservation are at risk

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because our elders are dying, our heritage craft skills are too. Our point of departure for a skills audit within our heritage sector began with evidence of need. In natural heritage, the need for traditional skills of hedge-laying and hazel coppicing was joined by the need for volunteers to hold power tool licenses and the future-proofing need to develop dynamic biodiversity data collection technology.

In the area of built heritage, GIS mapping skills, app and web technology were identified as skills needed alongside traditional historical specialist building conservation and construction skills.

In the area of industrial heritage, vintage and classic car maintenance and heritage engineering skills are needed alongside engineering innovation. The art and engineering skills involved in hat-making, block-making and millinery are now all listed as at risk in the Heritage Craft Alliance National Red Book.

In cultural heritage, heritage interpretation and curation skills, oral history training, and digital archive management skills are needed. Other transferable skills that can be learned and applied through the heritage sector include curation, interpretation, place-making, place-activation, project and programme management. If we include academic research methodologies and professional bid-writing in our list of needed heritage skills, we can see that local modular apprenticeships, from level three through to level six, will be a practical way of helping to improve prospects for our young people.

Luton has one of the youngest demographics (the highest number of under 16s) in the country. Young people are our most valuable asset. Young people, under the age of 30, make up nearly 30% of our town’s population. To maintain our heritage lineage and develop connectivity between our people and our townscape, a meaningful engagement programme that can improve prospects for young people through heritage activity will be crucial in the successful delivery of ‘Curating Luton’: our heritage implementation interpretation and place-making plan.

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Our intangible heritage assets  heritage craft skills These are made up of the skillsets of our current heritage practitioners across all heritage disciplines (natural, built, industrial, cultural and community, and intangible); and those already identified as heritage at risk. Our protective frameworks need to include future skills audits and mechanisms for knowledge share, research dissemination and intergenerational skills development.  Digital archives including oral history archives o Some examples held by national and regional organisations:  Luton Peace Riots oral archives are held by University of Hertfordshire’s Heritage Hub who created a digital heritage hub as part of a research project with funding from the Arts and Humanities Research Council's Connected Communities scheme and run a programme of activities and events to expand these opportunities and develop new partnerships  The Imperial War Museum, hold war time photographic archives relating to Luton; and some Luton Girls’ Choir audio  The National Archives in Richmond, hold over 19,000 results for archive data relating to Luton, Bedfordshire, giving community access “ where signed up users can use digital recordings for free” o Some examples held by local organisations include:  Cultural Histories CIC has oral history records from both People Power Passion and Cultural Histories, intergenerational works linking Lutonian’s with historic buildings  The UK Centre for Carnival Arts in Luton currently holds 23 collections of digital carnival archives relating to Luton. The centre is currently collecting archives relating to the four locations; Luton, Northampton, Norwich and Southend-on-Sea. However, it has a collections policy and long-term aspiration for the archive to be rolled out nationally. Collections are ‘completely digital’: This means the archives are all either born digital

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(they were created in a digital format) or digitised (they have been scanned or photographed); and, unlike more traditional archives, can only be accessed online. through the. Carnival Archives Project  Hatters heritage, a volunteer run charity, has created a digital social history archive relating to Luton Town Football Club.

 Kadam Asian Dance and Music Limited have created a digital 'Pulse Connects' digital photographic archive. o Examples currently in creation locally include:  Luton Heritage Forum is collating and curating a comprehensive digital archive for Luton: ‘Collective Memories’  Luton Council is leading on ‘Our River’, Luton Covid memorial project, which will collate and curate oral history relating to personal impacts of Covid within the town, as a snapshot in time  The Mary Seacole Housing Association is developing intergenerational oral history and research investigating the synergies between the Trust’s founder and life president, former Councillor Desline Stewart MBE and her inspiration and synergy with role model, nineteenth century African- Caribbean nurse Mary Seacole  The Luton Irish Forum has created intergenerational audio-visual recordings celebrating twenty years of St Patrick’s Day festivals in Luton o Examples held in Luton museum’s collections – oral history  The Culture Trust, Luton, are custodians of our museum’s database of Oral History recordings that were collected through Luton Voices (Part of Luton Life exhibition  oral histories are representing managers and workers from the twentieth century hat industry up to today and including reminiscences of businesses in the late 1800s

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Our protective frameworks for oral history will include a review of collections policy and digital archive management framework and a feasibility study towards a digital archive management framework and innovative curation of collections for Luton.

Intangible heritage - strategy areas of focus o major project emerging: A Digital Archive for Luton Digital archive management A strategic approach to digital archive management: creating a robust framework to audit, collate and preserve Luton community archives; and centralise preservation and access. o heritage at risk  Learnings from previous digital archive projects include those of sustainability of policy, preservation and access. A risk is that as collections are digitised: the physical artifacts not preserved, and the digital archives themselves, perhaps held on outdated technical formats or by economically vulnerable organisations or individuals, or by third party platforms are also consequently lost.  Heritage at Risk – Museum Collections and Archive Long-term management and funding agreements and Museum standard stores. In order to sustain museum collections and collecting, adequate on- going provision of resources (budget and staffing) for collection care is needed, including long term, secure and appropriate museum storage, with expansion facility, to account for increase in collecting, including the deposition of Archaeological Archives required under the National Policy Framework, research and documentation, conservation costs for objects, rationalisation and audit of the collections. Recommendations  A feasibility study toward a comprehensive digital archive for Luton, beginning with a full audit and policy review; and development of a robust framework and program of oral history projects to support both:

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o Intergenerational public health and well-being; and o ‘Place-making’, tourism and inward investment using GIS and I technologies  Partnership approach to: o Feasibility & development of modular heritage apprenticeship, skills training and education (levels 3-5); and creation of heritage education packs and pursuing routes to OFSTED accreditation. o Digital archive management as a major emergent heritage project o Review and strengthen the long-term management, funding and accommodation agreements to protect collections, museums and archives. o Research opportunities supporting digital archive feasibility including for example: . the role of emergent technologies, for example dynamic app based GIS and AI technologies, and the role of NFT (Non Fungible Tokens) in the creation and value of digital heritage archives . Public Health Impact assessments of intergenerational oral history archiving.

3. Emergent non-designated heritage zones

"Every place must identify its strongest, most distinctive features and develop them or run the risk of being all things to all persons and nothing special to any" (Licciardi et al. 2012, https://historicengland.org.uk/content/heritage-counts/pub/2019/heritage- and-the-economy-2019/).

Radical reform announced by UK Government ‘Planning for the Future’ consultation (August 2020 updated February 2021) and informed by the ‘Building Better, Building Beautiful Commission’ proposes a new planning system with an emphasis on ‘place-

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making’ and connectivity through “inheritance” and “sense of place”. This notion of place-making, addressing connectivity’s within our physical townscape by developing legally binding planning design codes informed by the heritage of an area, is a powerful opportunity for us to ‘Curate Luton’.Developing non-designated heritage zones, based not on the number of tangible listed heritage assets within an area, but honouring our socio-economic, cultural, and community heritage allows us to embrace change, recover, regenerate, re-connect and re-imagine. Through public consultation, we have identified five non-designated heritage interpretation zones to support the connectivity of people and place.

3.1 St Mary’s Heritage Zone: a significant social history quarter There is risk in enveloping Luton’s only Grade One listed building within a skyline of high density, residential and leisure developments, as positioned in our new Town Centre Masterplan. There is also opportunity. This Heritage Strategy supports the development of a new stadium at Power Court and recognises that repositioning Luton Town Football Club into the town’s centre creates a powerful new emergent non-designated socio-cultural heritage zone placing St Mary’s Church at its’ heart.

Luton 2020 Developments Ltd has received planning permission to site a new football stadium for Luton Town Football Club, a community anchor at Power Court, build residential apartments and other facilities, and re-locate 150 years of social history represented through Luton Town Football Club archive collections and Hatters Heritage. Power Court, itself a heritage site, represents the visionary leadership of the Luton Corporation, who developed a power station, harnessing the river (itself a site of heritage) at the cusp of the twentieth century, producing local energy that powered Luton Corporation tramways until 1938. Acknowledging St Mary’s as an emergent non-designated heritage zone offers us the opportunity to pay homage to this historical strength of vision and leadership.

The Church itself, representing 850 years of social history through its’ multi-faith community and inter-denominational activities at St Mary’s Centre for Peace and

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Reconciliation, is enveloped to its’ south and west by The University of Bedfordshire, another anchor institution.

As a social, cultural and educational heritage site, through a metamorphosis from its roots as a nineteenth century teacher training college, Luton Modern School, Luton Technical Institute, College of Technology and the University of Luton, the University opened a stunning £46m library in 2015.

Adjacent to the medieval church sits the UK Centre for Carnival Arts, signifying our towns’ diverse cultural heritage. Built on the much-lamented Youth House site, a tenth century graveyard was discovered during pre-build archaeological excavations.

The Mall, formerly the Arndale Shopping Centre, represents Luton as a market town to the north of Church Street. The heritage narrative here is one of changing retail habits: from shopping as a social activity through contemporary consumer behaviours; and signifying our ever-changing internal motivations, such as our faith in God, our faith in football, or our faith in Mammon.

Connecting St Mary’s non-designated heritage zone with neighbouring Plaiter’s Lea Hat District, our developing cultural-creative quarter, is our major natural heritage asset: The River Lea, itself embodying a thousand years of social history. Our ambitious challenge now is to pay homage to the visionary courage of the Luton Corporation and work with professional creatives to interpret the area’s social history, embedding our heritage narratives at every stage of re-development.

3.2 Hat Industry Heritage Zone: reconnecting High Town and Plaiter’s Lea Hat District “There is a strong economic case for regenerating historic buildings. The benefits relate not only to the individual building but also to the wider area and community. The impact of successful schemes can be felt beyond the boundaries of the heritage

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asset itself and can boost the economy of the whole town or city”. - Deloitte for the British Property Federation (BPF). High Town and Plaiter’s Lea Hat District are both recognised nationally by English Heritage as areas linked by their shared history of hat making and as areas of ‘heritage at risk’.

The High Town area, as identified by English Heritage, stretches beyond the existing designated conservation area (High Town Rd – a historic ‘high street’) and includes nationally unique configurations of terraced houses built to support hat cottage industries and house hat industry workers. Lutonian hat and block-makers still operate in the wider High Town area; combining artisan craft, design and engineering skills. In connecting the two designated conservation areas and embracing wider geographies into an emergent heritage interpretation zone, this strategy recognises the important role Luton’s railway played in the success and growth of our hat industry; acknowledges The Culture Trust, Luton’s pioneering work developing The Hat District; and seeks to support further commercial and community partnerships and opportunities within the High Town and Plaiter’s Lea Hat District to develop visitor destination opportunities anchored through thee areas shared heritage of hat-making.

Through public consultation and focus group workshops, we discovered hidden histories themes, including ghost signs, Victorian architectural features, secretive trade secrets within the hat making eco-system, and the potential to investigate feasibility studies regarding the opening up of underground war tunnels in time for the hundredth anniversary of the outbreak of World War Two.

3.3. Engineering Heritage Zone: Luton as a site of engineering innovation and excellence (Luton Airport and Vauxhall Motors) Geographically the political wards of Luton most associated with aviation and motor industry innovation and engineering are Luton South, Crawley and Wigmore. The historic sites of London Luton Airport and Vauxhall Motors. Although this area is rich

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in social and industrial heritage assets dating back to the Neolithic period, and history of engineering innovation and manufacturing in Luton is not limited to this area. The combination of the airport as a site of heritage and the significant commercial and social history of Vauxhall within the town form a strong alliance as a combined area for heritage interpretation, research and development. All of thesewill support the continuing story of Luton as a site of engineering innovation and excellence; and evidence, feasibility and development of a Vauxhall Heritage Centre as the major project emergent from the industrial heritage section of this strategy document.

3.4. River Lea Linear Park Heritage Zone The idea of creating a connected linear park following the River Lea as it makes its way through Luton, from sources and convergences at Farm and Leagrave Marsh, through Wardown Park and the town centre is not a new one. Discussed by the council since 2005, ongoing community engagement and river maintenance has been delivered through the Luton Lea Catchment Partnership. Plans to un-culvert the River and create public access points have been developed.

This strategy recognises the importance of Wardown Lake as a historical heritage asset and also recognises the importance of Leagrave Marsh, Waulud’s Bank and Marsh House as an important intersectional site of heritage. The development of a River Lea Linear Park as a heritage interpretation zone supports projects around the river, connecting people and place through industrial, cultural, community, social and economic histories and supports The River Lea as the major project emerging from the natural heritage section of this strategy.

3.5 Bury Park British-Asian Heritage zone While acknowledging a wealth of social history spanning centuries, and Kenilworth road’s historical position of home to Luton Town Football Club, it is the last 50 years that have shaped Bury Park into a ‘British-Asian’ success story.

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Acknowledging also, that although more than 30% of Luton’s population originates from South Asian ethnicities, not all Asian Lutonian’s live in the Bury Park area. Bury Park as an area is sited across two district wards: Biscot and Dallow. According to the 2011 census, these areas together have an Asian population density above 67%.

This strategy supports a deep dive into the complex and intersectional cultural heritages within communities in the Bury Park area; the need to investigate both connectivity’s between people and place, personal impacts of bonds and disconnects in family heritage, and cultural heritage fusions as a result of Asian diaspora. Focussing on Bury Park as a British-Asian Heritage Zone also supports cultural and creative industry entrepreneurs within the area.

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4. Responsibility for delivery - a joined-up partnership approach 4.1 How you can contribute

Everybody in Luton is invited to engage in the conservation, preservation and interpretation of heritage and the delivery of this strategic vision:

 Get involved with the University of Bedfordshire’s Arts and Culture Projects teams’ activity, including the Heritage Impact Accelerator and the Heritage Enterpise Hub  Get involved with The Wildlife Trust's 'Wilder Futures Project' at Bradgers Hill (and Galley Hill)  Get involved with The Chiltern Conservation Board 'Chalkscapes project'  Get involved with Museum Makers  Get involved with Luton Heritage Forum, design code ‘Charettes’, local list review, public meetings, and collective memories project

Or contact [email protected]

The community and voluntary sector can contribute by:  advocating for heritage to be used to anchor the town’s recovery and regeneration  championing and seeking opportunities to resource heritage projects amongst local communities  actively promoting heritage events and activities to users, members and participants

The education sector can contribute by  becoming champions of heritage and nurturing young heritage ambassadors  supporting the work of Luton Cultural Education Partnership to maximise heritage engagement opportunities for all children and young people  using local heritage education packs

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Businesses can contribute by:  developing heritage led research and development  championing heritage led capital regeneration  advocating for heritage  sponsoring heritage projects

4.2 Partnership Infrastructure This strategy will be delivered in partnership. A Heritage Steering Group, including local, national, regional and major funding organisations, will be formed to ensure strategic alliance. An eco-system of community and stakeholder group representatives and heritage ambassadors will be developed to deliver ‘Place- making’: our Heritage Implementation Plan. Currently our strategic key delivery partners are: o Luton Borough Council o The Culture Trust Luton o The University of Bedfordshire o The Chilterns Conservation Board o The Wildlife Trust for Beds Cambs and Northants o Luton Heritage Forum

4.3 Next steps This strategy document spans 10 years 2021 to2031. We will:  revisit and review this strategy within two years  develop ‘Place-making’: our Heritage Implementation Plan  develop a delivery eco-system, and develop a network of heritage ambassadors

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References Centre for Economic and Business Research (Cebr)

Historic England Heritage and the Economy 2019 - Heritage Counts case: The role of culture, sport and heritage in place shaping - Trends Business Research Ltd, NEF Consulting Ltd and Middlesex University, October 2016

National Lottery Heritage Fund, 2010

AMION and Locum Consulting, 2010

Foreign and Commonwealth Office, 2020

Department for Digital, Culture, Media and Sport (DCMS)

English Heritage - Imapct of Historic Envionment Regeneration Final Report 1 October 2010, Amion Consultancy and Locum Consultancy)

Derby Partnership Scheme in Conservation Areas (PSiCA)

Grimsey Review November 2020

Walter 1986

Valuing Heritage Assets, Final Report of a Reserach Project. Examining the case for the Valuation of Heritage Assets. Prepared by Kingston University on behalf of RICS and HM Treasury March 2009

International Public Sector Accounting Standards Board, Consultation Paper ACCA 2006.

Valuing culture and heritage capital: a framework towards informing decision making (January 2021).

HM Government - A Green Future: Our 25 Year Plan to Improve the Environment

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Heritage Fund - Strategic Funding Framework 2019-2024

Luton Hoo Elite hotels website

University of Bedfordshire – Putteridge Bury campus website Wikipedia

Historic England - Wardown Park

Local Plan 2011 - 2031 (November-2017)

Charles Russell Speechlys Planning for the future the white paper glossy presentation beautiful snapshots, glorious intent, but where are the numbers? August 2020

(Hat District Future-scape 2020), Hat District Future-scape 2020 The Future Demands you participation a Hat District Creative Community co-authored paper, 2020

Luton Council (Town Centre Masterplan supporting document 4 - Luton's Past - Urban Vision Enterprise CIC

ACCA Accounting for heritage assets under the accrual basis of accounts June 2006

Valuing heritage assets - Kingston University on behalf of RICS and HM Treasury - March 2009

The Economic Value of Heritage: A Benefit Transfer Study (nesta.org.uk)

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Measuring Economic Value in Cultural Institutions (ukri.org); Guidance Note - How to estimate the public benefit of your Museum using the Economic Values Database_0.pdf (artscouncil.org.uk

Valuing Heritage Assets, Final Report of a Reserach Project. Examining the case for the Valuation of Heritage Assets. Prepared by Kingston University on behalf of RICS and HM Treasury March 2009

https://www.ipsasb.org/publications/financial-reporting-heritage-public-sector-0

International Public Sector Accounting Standards Board, Consultation Paper ACCA 2006 https://www.gov.uk/government/consultations/planning-for-the-future/planning-for- the-future

https://historicengland.org.uk/content/heritage-counts/pub/2020/heritage-and-the- economy-2020/

Walter 1986, from The Long Term Sustainability of Luton Irish Forum, McElhatton 2010

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Appendices A. Local list appraisal framework

Glossary ACCA Association of Chartered Certified Accountants AR Augmented Reality ARTICLE FOUR a planning direction removing all or some of a site’s permitted development rights BAME Black, Asian and Minority Ethnic BPN Building Preservation Notice case The culture and sport evidence programme CEBR Centre for Economic and Business Research CWS County Wildlife Sites DCMS Department for Digital, Culture, Media and Sport DEFRA Department for Environment, Food and Rural Affairs DWS District Wildlife Sites Facadism a practice of protecting only the exterior wall while erecting a new building behind or around it. GPS Global Positioning System GVA Gross Value Added HODs Heritage Open Days LBC Listed Building Consent LWPP The Luton Windrush Partnership Programme Mammon ‘wealth regarded as an evil influence or false object of worship and devotion’ MHCLG Ministry of Housing Communities and Local Government NPPF National Planning Policy Framework PSiCA Derby Partnership Scheme in Conservation Areas QEST Queen Elizabeth Scholarship Trust RICS Royal Institute of Chartered Surveyors RIMAP Research Institute for Media Art and Performance

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RSA Royal Society of Arts SEMLEP South East Midlands Local Enterprise Partnership SROI Social Return on Investment SSSI Sites of Special Scientific Interest STEM Science Technology Engineering and Mathematics

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Page 218 of 284 Appendix 2

Curating Luton:

Heritage Strategy 2021-2031

Page 219 of 284 Contents

Foreword Introduction How we co-produced our Heritage Strategy Our vision for Luton’s Heritage Strategic Priority: Place making Strategic Priority: Embedding diaspora and diversity Strategic Priority: Embracing digital innovation Strategic Priority: Conservation, preservation and valuation Strategic Priority: Improving prospects for young people Strategic Priority: Future proofing – beyond sustainability Strategy Framework Emergent non-designated heritage interpretation zones

Responsibility for delivery - a joined-up partnership approach

Page 220 of 284 Foreword

I am delighted to present Luton’s Heritage Strategy for 2021-2031. This is an important document that, alongside our Arts and Culture Strategy, will be central to our shared ambition to transform lives through arts, culture and heritage as we seek to deliver on our town-wide vision for Luton 2040.

This strategy has been prepared against the backdrop of the COVID-19 pandemic, and I am extremely grateful to everybody who has committed their time and energy to co-produce this strategy, including the hundreds of residents and representatives that took part in our consultation.

This is an extremely timely strategy as we emerge from the pandemic, and I am certain that heritage will be integral to both our economic recovery and our aims to improve the wellbeing of our population as we build a healthier, fairer and more sustainable town where everyone can thrive.

The case for supporting our town’s heritage is clear, with benefits to our local economy, our wellbeing and our environment. Heritage activity adds an estimated £1 billion to the local economy each year, and for every £1 invested by the public sector around £1.60 is generated in return. We also know that retrofitting of historic buildings can result in less carbon emissions than some new buildings.

Besides these benefits, we also know that supporting heritage helps to create a sense of place, strengthening our collective identity and pride in our community.

This strategy sets a clear direction for how we will work collectively with partners and residents to put heritage at the heart of our recovery and our ambitions for Luton 2040.

Heritage will be at the heart of our place-shaping efforts as we reimagine our town centre and transform our communities, our neighbourhoods and our greenspaces. The strategy will also help us to preserve and protect our most valued heritage assets, reflecting and embedding the diversity of all parts of our community. It will also enable

Page 221 of 284 us to promote skills and opportunities that transform lives, especially for our young people.

This is a highly ambitious strategy that will require collaboration, innovation and input from all parts of our community, including residents and organisations across all sectors and I look forward to working closely with everyone in Luton to deliver on this strategy.

Cllr Robert Roche Portfolio Holder for Sustainable Development

Page 222 of 284 Introduction

This new, co-created Heritage Strategy for Luton signifies a collective ambition to curate the town. It is, in effect, a commitment: to a future 10 years of 'joined-up' partnership working to deliver a town-wide vision of making Luton a healthy, fair and sustainable town, where everyone can thrive, and no-one has to live in poverty. This strategy is a commitment to transforming lives through embedding heritage at the heart of post-Covid regeneration planning.

We want to thank more than 300 individuals who took part in our heritage consultation survey and the 30 stakeholder group representatives (including those from business, education, arts, culture and heritage communities) who took part in our strategy co-creation focus group workshops.

This document builds upon the previous draft ‘Foundations for a Luton Built Heritage Strategy’ (2019) to embrace all categories of our town's tangible and intangible heritage (natural, built, industrial, cultural and community) and deliver, as promised, a new heritage strategy driving wider participation in heritage in Luton. Its' co- creation, using public consultation and stakeholder engagement as a point of departure, would not have been possible without The National Lottery Heritage Fund's support for a heritage enabler post.

Results from the public consultation survey can be found on the Let's Talk Heritage Consultation. In a series of workshops designed to open discussion and discover ‘What IS the heritage of Luton’, we investigated what the term 'heritage' means to us as individuals and how we collectively define and identify our tangible and intangible heritage assets: in other words, what we choose to value. Finally, we asked a series of questions to help map our heritage assets, develop a shared vision, a co-created heritage strategy, and shape the consequent implementation plan.

Through research, we have discovered best practice approaches. Through public consultation, we have collated and shared a deeper understanding of our collective

Page 223 of 284 heritage, what it means, where we come from and who we are. Through open discourse, we have discovered hidden heritage assets (and the need to reveal them).

We recognised our award-winning parks, nationally accredited museums, designated conservation areas, listed buildings, monuments and prehistoric earthworks. Beyond our physical landscape, Luton is a proud working-class town, continually re-created through generations of settling economic migrants and re-settled diaspora’s. We are proud of our multi-cultural population. We acknowledged the need to address the re- interpretation of our historical narratives and our commitment to embed diversity in all areas of heritage interpretation. We re-confirmed that resilience, tolerance, and compassion emerge as characteristics of what makes us 'Lutonian' through further discussion.

This has been an unprecedentedly difficult year to embark on community engagement, but it has given us a wonderful opportunity to 'deep-dive', to research and reflect upon the wider meanings of 'heritage'; to discuss what we choose to collect and preserve for future generations, and consider how we cherish and value our collective heritage.

This strategy hopes to address the different frameworks and valuation methodologies we can apply to help us protect local heritage assets. It underpins how we can implement post-Covid recovery by leveraging both our own shared research and monitoring data and the government’s current incentivising of investment in repair, maintenance and public appreciation for heritage. Investing in the historic environment generates economic returns for local places.

There are economic, sustainability, and public health and wellbeing arguments for committed investment in heritage:

“The heritage sector is an important source of economic prosperity and growth with a total Gross value Added (GVA) of £31billion equivalent to 1.9 per cent of national GVA.” (Historic England). “England’s heritage sector generates a larger GVA than the security industry, defence industry, aerospace industry and the arts and culture

Page 224 of 284 industry combined . In addition £7.1 billion in GVA was generated by heritage-related construction activities in England in 2018.” (Centre for Economic and Business Reseaerch (Cebr).

“25% of businesses surveyed agreed that the heritage setting was an important factor in their decision to locate” (case: The role of culture, sport and heritage in place shaping - Trends Business Research Ltd, NEF Consulting Ltd and Middlesex University, October 2016)

“60% of creative industries based in historic buildings are start-ups“ (National Lottery Heritage Fund).

"A study into heritage tourism between 2004 and 2007, estimated that for every £1 spent as part of a heritage visit, 32p was spent on-site and the remaining 68p is spent in local businesses including restaurants, cafes, hotels and shops" (National Lottery Heritage Fund, 2010) " on average every £1 invested by the public sector on heritage-led generation returns £1.60 of additional economic activity…" (AMION and Locum Consulting, 2010).

"When a typical historic building is refurbished and retro-fitted, it will not only create jobs but also emit less carbon by 2050 than a new building" (Heritage Counts 2019). "Investment in environmental adaptations can consistently deliver high returns, with benefits between two and ten times the cost…" (Foreign and Commonwealth Office, 2020).

“Participation in culture, sport, or heritage has positively influenced education choices, health and wellbeing, social cohesion, and economic participation” (Middlesex University).

The NHS saves a yearly total of £11.91 for every person partaking in cultural or sporting activity, from a reduction in GP visits and use of psychotherapy services (Department for Digital, Culture, Media and Sport (DCMS)). Based on this figure, there is the potential to save the NHS £2.5m each year locally through participation in arts and culture (based on Luton’s population of 213,052).

Page 225 of 284 Different types of 'heritage at risk' are acknowledged within this strategy framework and the need for preservation and protection are highlighted within every category. Natural assets tend to be protected nationally through a legal and policy context set by Natural England, reporting to Defra, while national protection for the more ‘historic’ built assets are protected through Historic England, reporting to DCMS (Department of Culture, Media and Sports). While telling our story of place all of our key delivery partners fulfil a range of heritage functions reporting to a range of government bodies, e.g. relating to cultural heritage (Historic England/DCMS), tourism (DCMS), nature conservation (Natural England/Defra), local economies (BEIS and HMT), community vitality (MHCLG).

Identifying our local 'heritage at risk' will be a dynamic process that will help shape our future implementation action plans. As we ‘recover’ our heritage, the risk register will change over 10 years: reflecting our achievements and our priorities.

Like many towns, Luton has felt the impact of Covid. Consecutive lockdown measures have accelerated the decline of our historic high streets (two of which are nationally designated conservations areas). The impacts on retail and hospitality have especially affected the income of young adults, many of whom begin their careers in these sectors. Education has been interrupted, and a move towards homeworking has disrupted the chances of young people to enter into worthwhile training and apprenticeships. This strategy addresses meaningful ways we can use heritage to improve prospects for our young people. For example, investigating how transferable employment skills might be gained through developing a modular heritage apprenticeship, and using the ‘High Street Heritage Action Zone’ model as best practice for our town centre regeneration.

The need for heritage lead place-making and joint arts, culture and heritage place activation has been identified and this will be developed and delivered through our Heritage Implementation Plan, which will compliment the Town Centre Masterplan and emergent planning design codes. This partnership working is essential in our intention to embed our heritage narratives of diaspora and diversity across the town. The delivery of this strategy will harness the passion of key partners already

Page 226 of 284 delivering across all areas of heritage, as well as involving new communities and stakeholders.

The experience of Covid related deaths has impacted all areas of our super-diverse population. For example, our airport (itself a site of heritage) has been in most part closed for a year, preventing people overseas from travelling to honour deceased loved ones, which has been particularly painful for Luton's highly transient population.

Our heritage consultation has identified how residents from all communities and backgrounds have experienced losing loved ones and the loss of cultural and intangible heritages associated with funeral rites and bereavement customs. We heard this from our Afro-Caribbean, Irish, South-Asian and Roma communities and various religious groups, particularly our Islamic population. So to mark this significant period in recent history, a new heritage memorial: a town centre monument, embracing digital innovation, is being created. This will offer our communities a space to reflect upon local lives impacted by Covid; a space for remembrance, and a space for inspiring our hopes for the future. It is the intention that this new Heritage Strategy for Luton may offer the same.

How we Co-produced our Heritage Strategy Stage 1: public consultation survey - first ran February 2021 to March 2021; re- opened for use during public consultation workshops Stage 2: public consultation workshops – 12 community workshops between March and May 2021 Stage 3: 4 stakeholder focus groups – May & June 2021 Stage 4: draft documents and input from key strategic & delivery partners

We have engaged with more than 300 individuals and more than 30 stakeholder group representatives to co-produce this strategy.

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Our formal online consultation ran from February to March 2021, with 152 responses. Of these responses 66% came from people who had never engaged in heritage activity before.

This engagement has helped to widen participation in heritage further:

 almost half of all newly engaged people wanted to be involved in long term strategy development and monitoring;  68 new people asked to be join meetings of the Luton Heritage Forum;  30 individuals wanted to be involved in work to review Luton’s local list;  10 community representatives were invited to take part in testing our local list appraisal framework.

Number of responses by individual or organisation type

140 123 120 100 80 60 40 20 12 7 2 5 3 0 Individuals Business Faith Community Education Charity or VCS Not selected Establishment Group

% of survey respondents by ethnicity- April 2021 (144 people responded to the ethnicity question) 80.0% 69.6% 70.0% 60.0% 50.0% 40.0% 30.0% 20.0% 8.8% 10.0% 2.9% 0.0% African-Caribbean Asian White

Page 228 of 284 At the end of April 2021 - we were not satisfied that engagement with the online survey was representative of Luton demographics. Our intention is to widen engagement with heritage, so we increased:

 African-Caribbean consultation via 3 x specific different community focus groups (involving ACCDF and Heritage Alliance); and several 1:1 meetings involving representatives from ACCDF; UK Centre for Carnival Arts; and Heritage Alliance.  Engaged young people from RevoLuton to facilitate public consultation workshops; and awarded seed funding to fund projects involving young heritage ambassadors.  Re-opened the online survey following specific stakeholder meetings, for example with young people and Luton Irish Forum; and  Increased engagement with individuals and communities of Asian descent through direct invitation to Luton Heritage Forum public feedback sessions.

We are also developing strategies and frameworks for engagement of wider audience participations in heritage decision making and consequent heritage strategy implementation planning; and have developed two specific heritage strategic priorities to support this.

Re: Survey responses to the question: “What is heritage: what does the word mean to you?”

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Survey responses to the question: "Which category of heritage is most important to you?"

50 46 45 40 35 30 27 25 23 20 20 20 16 15 10 5 0 Built heritage Industrial heritage Cultural heritage Natural heritage Intagible heritage Other

On first analysis the most popular genre of heritage was built (tangible); but if we combine cultural, intangible and other (Community) our intangible cultural lineage becomes the most important. The heritage strategy will not prioritise one over the other but seek to address issues of connectivity between individual heritage and the historic townscape.

The consultation report is available to view in full here.

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Strategy Framework - contents

1. Strategic priorities  place-making  embedding diaspora and diversity into heritage interpretation narratives  conservation, preservation and valuation  improving prospects for young people  beyond sustainability – ‘future-proofing’

2. Strategy framework – mapping our assets 2.1 The tangible: our physical environment 2.1.1 Luton's natural heritage 2.1.2 Luton's built heritage 2.2 Where the tangible and intangible connect: 2.2.1 Luton's industrial heritage 2.2.2 Luton's cultural and community heritage 2.3 The intangible: making our invisible, visible 2.3.1 heritage craft skills 2.3.2 a digital archive for Luton

3. Emergent non-designated heritage interpretation zones 3.1 St Mary’s Heritage Zone 3.2 Hat Industry Heritage Zone 3.3 Engineering Heritage Zone 3.4 River Lea Linear Park Heritage Zone 3.5 Bury Park British-Asian Heritage Zone

4. Responsibility for delivery - a joined-up partnership approach

4.1 How you can contribute

4.2 Partnership infrastructure

4.3 Next Steps

Page 231 of 284 Our Vision for Luton’s Heritage:

‘Luton's sense of place is anchored through its heritage; where wellbeing, civic pride and our identity as a proud industrious working-class town can be celebrated and sustained’

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Strategic Priorities

These strategic priorities align with those within the Luton 2040 vision, The Inclusive Economy Strategy, The Population Wellbeing Strategy, The Culture Trust, Luton's Business Plan, The Wildlife Trust (Bedfordshire, Cambridgeshire and Northamptonshire), Chiltern Conservation Trust, the University of Bedfordshire and the corporate values of London Luton Airport. They support project objectives of the University of Bedfordshire’s Heritage Impact Accelerator and Heritage Enterprise Hub, Luton Heritage Forum’s constitution, and the National Lottery Heritage Fund's priority outcomes:

Embedding diaspora and diversity into Place-making heritage interpretation narratives

Conservation, Embracing digital preservation and innovation valuation

Improving prospects for Beyond sustainability –

young people ‘future proofing’

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Strategic Priority: Place-making

There are two grounded reasons for investing in place- making and place-activation:

1. Civic pride and wellbeing – making Luton a better place to live, work and visit.

2. Economic regeneration – growing our local economy through tourism and inward investment.

The Nobel Prize winning economist, Robert Merton Solow stated that “over the long term, places with strong, distinctive identities are more likely to prosper than places without them”. This strategy will endeavour to unwrap Luton and identify its tangible and intangible characteristics. One shared characteristic of Lutonians can be summed up by the word ‘diaspora’: the movement and (re-)settlement of people.

Civic pride and wellbeing Place-making promotes wellbeing through better urban design by identifying the characteristics of, and supporting, the ongoing evolution of each urban area. Place- making is both an ethos and a practical approach to embedding place management through collaboration, communication, connections and mutual responsibilities. This strategy will prioritise well-being and civic pride at the heart of place-making by re-connecting Lutonians with Luton and their individual heritage. In doing so we will help to embed heritage further within Luton’s identity and sense of place.

Economic regeneration Research by AMION Consulting has shown that people spend more money in their local economy after investment in the historic environment. Evidence from the work of the Derby Partnership Scheme in Conservation Areas (PSiCA) further demonstrates that this investment can successfully increase footfall. Between 2008 and 2013, while high street footfall fell nationally by 26%, the Derby PSiCA reversed this trend through

Page 234 of 284 heritage-led regeneration and saw footfall growth of between 12% and 15% over the same period. (Historic England)

As part of our collective ambition to curate Luton, this strategy will prioritise a partnership approach to place-making, embedding our town’s heritage as a place of making as part of our economic recovery from Covid-19 and inviting everyone in our community to collectively reimagine, reinvent and re-connect with their public spaces.

This strategy is a commitment to placing our heritage at the heart of our collective approach to place-making, to enhance civic pride and wellbeing, and to stimulate economic regeneration. This priority is closely aligned to our Arts and Culture Strategy and our ambitious Town Centre Masterplan, as well as our updated Local Plan and new national planning guidelines.

Target outcomes:

 We will work in partnership to develop and deliver ‘Place-making’: our heritage implementation plan, including the use of community charrette style workshops to develop design codes within our heritage conservation areas. (a ‘charrette’ workshop enables civic decision making).

 We will develop a Heritage Fund to support artists, individuals and community groups to initiate innovative heritage-led place activation projects (LBC LEAD).

Strategic Priority: Embedding diaspora narratives and diversity into heritage interpretation

Throughout our public consultation, we discovered a defining characteristic of Luton. This characteristic is best encapsulated by the word ‘diaspora’, defining Luton as a place of re-settlement for people from diverse communities over a long period of time.

Page 235 of 284 From the first migrations of agricultural workers and Scottish straw plaiters arriving as part of the hat industry in the 18th Century, the fabric of Luton is woven through generational stories of economic migration and political displacement. Over the last two centuries, Luton has become a destination and a home for people from every continent, making it one of only four super-diverse towns in the UK.

The heritage of Luton has been shaped by a series of diasporic waves. For example, Luton’s Irish population grew rapidly between 1951 and 1961, reaching a peak of 5.8 per cent of the population by 1971, before declining from 1981. This wave coincided with the growth of Vauxhall, which acted as a magnet providing economic opportunity up to its peak in the 1970s.

Another example is of the Windrush generation, with many people arriving from the Caribbean between 1948 and 1971, with the arrival of many working in nursing professions which helped to develop the Luton and Dunstable Hospital. In more recent decades, Luton has seen the growth of both the African-Caribbean and Asian populations, with Luton’s Bury Park emerging as a British-Asian success story.

Despite the impact of these diaspora in shaping Luton’s heritage, our public consultation highlighted many barriers to engagement in heritage that were linked to ethnicity, as well as the responsibility that lies with everyone to curate Luton’s rich diasporic history. Heritage is the physical embodiment of our story; and Luton has an overflowing cornucopia of stories. Re-addressing our history and heritage narratives is currently a nationwide discourse ignited by international movements such as Black Lives Matter. The Culture Trust Luton has so far taken the lead in addressing current issues around representation through working with a curatorial specialist.

Target outcomes:

 We will work in partnership to widen participation and breaking down barriers to heritage involvement.

Page 236 of 284  We will work in partnership to embed diaspora and diversity narratives into all parts of our heritage implementation plan.

 We will make best use of the 2021 demographic census results for Luton to further shape these narratives (LBC LEAD).

Strategic Priority: Embracing digital innovation

Embracing digital innovation is essential for successful delivery of all of our strategic priorities and our Heritage Implementation planning.

Digital innovation in place-making There is a clear opportunity to embed innovative digital technologies within infrastructure and physical regeneration to support our place-making priority. This includes opportunities to learn from several best practice models that use Augmented Reality (AR) to embed heritage as a key driver in ‘place-making’, inward investment, destination tourism and community engagement. For example, taking inspiration from consortiums developed to deliver Historic England’s High Street Heritage Action Zones, using creative partners and community groups, ‘Sounds UK’ (sound generator artists) have created immersive heritage story worlds. Closer to home, we can build on pilot community-level as well as, student-led as well as research projects by the University of Bedfordshire. Beyond the Arts and Culture Projects team’s heritage activity, a further illustration is activity led by the Research Institute for Media Art and Performance (RIMAP), based within the Faculty of Creative Arts, Technologies and Science, including in-situ cross-media storytelling initiatives; and harness Luton’s home-grown augmented reality and artificial intelligence skills-base. Additionally, The University of Bedfordshire’s Arts and Culture Projects team, based also within the Faculty of CATS, has been an active partner to HSAZ consortiums in other areas of Bedfordshire and this regional activity and learnings can be harnessed for the transactional benefit of Luton.

Page 237 of 284 Digital innovation in conservation and preservation of heritage assets Our heritage implementation plan will also develop the use of GPS technology in the dynamic process of updating, recording and reviewing our designated and non- designated built-heritage assets, and support the use of shared digital technologies by partner organisations, such as the Heritage Forum, in work around both heritage trails and our local list.

Stakeholder engagement also highlighted the need for a coordinated, collective digital archive management to preserve Luton’s oral history and digital collections.

Digital innovation for sustainability and future-proofing Consultation with stakeholder and delivery partners has identified the need for coordinated real-time dynamic natural heritage bio-diversity data collection. Some decisions around managing our natural environment have been based on 10-year-old survey data. Aligned with our ‘Future-proofing: Beyond Sustainability’ priority, this strategy supports local research programmes to develop engineering solutions; and commits to embracing digital innovation in all areas.

Target outcomes:

 We will work in partnership to harness our digital and artificial intelligence skills base locally, building on pilot projects, to embed heritage as a key-driver in place- making.

 We will work in partnership to develop the use of GPS technology to record and review our heritage assets and develop our local list.

 We will work in partnership to establish a coordinated dynamic approach to data collection

 We will work in partnership to use best practice digital archive management.

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Strategic Priority: Conservation, preservation and valuation

The art of curation is the act of selecting, organising and looking after our collective heritage. This strategic priority addresses how we engage community in making decisions about heritage, such as what we choose to preserve, the policies and mechanisms and resources we use to preserve our heritage assets and the methodologies we use to value them.

As part of our consultation process, we asked people to define ‘heritage’ to establish a collective understanding, before asking people which categories and types of heritage were most important to them. This helped us to understand which aspects of Luton’s heritage are valued most by our community, which in turn has helped to prioritise implementation timelines, key milestones and resources. Our consultation also asked people about their favourite heritage features, as well as their favourite Lutonians, to ensure a broader range of heritage assets, both tangible and intangible, were considered as part of this strategy and including hidden and often overlooked assets.

Conservation and preservation of heritage assets

Preserving our heritage assets relates both to conservation, which is generally associated with protecting natural resources, as well as preservation which commonly refers to the protection of buildings, objects and landscapes. All assets, including both cultural and natural heritage, are a part of telling the story of Luton and its people and defining the character and identity of the town. The strategy therefore brings these together to be managed holistically, regardless of which legal or policy regime guides their conservation, restoration, enhancement or other management activity.

Protective frameworks already exist to protect our tangible heritage, including the built and natural environment. These include clear frameworks for establishing nationally designated conservation areas and nationally listed buildings, for built heritage, as well

Page 239 of 284 as selection guidelines for the demarcation of County Wildlife Sites for our natural heritage.

The creation of national Nature Recovery Networks is a major government commitment. In the ‘25 year Environment Plan’(policy paper November 2020), there are no plans to upgrade CWS to Area of Outstanding Natural Beauty (AONB) status, which suggests that protection may be increased through future changes in national planning laws). The Chiltern Conservation Board’s Heritage Funded Natural England are also looking into the possibilities of extending and designating as AONB additional land around the Chilterns. https://www.chilternsaonb.org/chilterns-aonb- boundary-review.html. This strategy supports the extension of the AONB, even though the possibility of extending into Luton Borough itself is quite limited (though not impossible, e.g. at Stopsley Common/Bradgers Hill).This is because, although most of the designated AONB lies outside of the borough boundary, the nearest urban population, the ‘audience’ that benefits most from this landscape comes from Luton. This strategy notes that it is the surrounding Chilterns Chalk-streams that give rise to the source of the River Lee: the very reason Luton exists in the first place. The Chilterns Conservation Board, a statutory public body established to promote the conservation, enhancement, understanding and enjoyment of the Chilterns AONB are a key partner in many of the projects outlined in this Strategy which supports objectives set out in their management plan (link: https://www.chilternsaonb.org/conservation-board/management-plan.html).

Our consultation highlighted the importance of local characteristics that are not protected by existing frameworks, such Victorian architectural features in the High Town area, that create a sense of place and a connection with people and communities. This highlights the need to adjust appraisal frameworks, scoping mechanisms and selection criteria to establish a dynamic local list incorporating physical heritage assets, and develop non-designated heritage interpretation zones that matter to our communities. Our consultation also highlighted the importance of place and street naming as a mechanism for acknowledging our history and to protect and preserve our heritage narratives.

Page 240 of 284 Luton’s museum collections include over two million museum artefacts of tangible heritage objects that also need to be preserved. These collections include artefacts relating to our natural history, archaeology, textiles, fine art, industrial and military collections, archives and records and examples of our social history. There are also many tangible heritage items held as part of private or community collections, including large paintings and significant local artefacts like the Vauxhall Car Collection. Many of these collections have been identified as vulnerable and in danger of being lost to Luton. The Culture Trust is curatorial specialist for & Gallery and Stockwood Discovery Centre and maintains Museum Accreditation and leads on public access, collections management and best practice in these Museums.

Our intangible heritage assets, including community oral histories, digital archives and faiths, customs and traditions, are arguably the most difficult to protect and most at risk of being lost over time. Our consultation has also highlighted a diverse range of digital heritage projects across the town that can be supported to preserve these intangible heritages, including Hatters Heritage (150 years of the social history of Luton Town Football Club) and Kadam Dance (Asian dance and music), as well as a range of hidden community archives.

Valuation of heritage assets The government, via Natural England, has established a Natural Capital Approach to valuing natural heritage, while the Department for Digital, Culture, Media and Sport (DCMS) is developing a framework for valuing heritage using the social cost-benefit analysis principles published in HM Treasury’s Green Boo to establish an asset-based approach that supports decision-making.

Valuation of tangible assets using a range of quantitative and qualitative information helps to create a robust evidence base not just for our built heritage but also across our cultural and industrial heritage.

This strategy also prioritises a partnership approach to investigating collaborative opportunities for asset audit (data monitoring) and research to contribute to this field; and to use the Heritage Capital framework to help us value our heritage, attract inward

Page 241 of 284 investment and deliver our developing Heritage Implementation Plan. This, in turn, supports our strategic priority around sustainability and future proofing.

Target outcomes:

 We will diversify our collection at Wardown House Museum and Gallery, the study centre and young people’s programme in order to widen community audience and engagement in Museum events exhibitions and programmes. (CULTURE TRUST LEAD)

 We will work in partnership to co-produce and update dynamic local lists and heritage at risk registers and will identify heritage management and heritage implementation plans to prioritise protection and care for assets identified.

 We will develop a steering group to lead on the review of conservation, collections policies, protection frameworks and valuation methodologies as part of our implementation plan.

 We will support Museum Makers and other volunteer and community-led activities that widen engagement and awareness in heritage assets.

 We will develop community and stakeholder groups, to help collect and collate socio-economic and cultural evidence to support major heritage projects and protect our heritage assets (LBC LEAD).

 We will prioritise a partnership approach to the audit and valuation of heritage assets, using the Heritage Capital framework.

Strategic Priority: Improving prospects for young people

Page 242 of 284 Children and young people across the country have been disproportionately impacted by the pandemic, including negative impacts on education, employment mental health, social opportunities and emotional wellbeing. Luton has one of the youngest populations in the country and as such has felt this impact more than most places.

The accelerated decline of our historic high streets and the impact on retail and hospitality during the pandemic have disproportionately affected the incomes and opportunities of many people young adults who were working in these sectors and the shift to remote working and learning has disrupted opportunities for young people in education and entering work.

Giving young people a voice in Luton’s heritage Our ability to engage with young people in the consultation process and co-creation of this strategy has been made difficult as schools and youth organisations have been forced to work remotely and prioritise other challenges during the pandemic. Nonetheless we have engaged with young people and their representatives through inter-generational workshops and with youth heritage ambassadors.

As part of our commitment to being a child-friendly town we will ensure further engagement with children and young people by reviewing this strategy regularly and by including them in our co-production of the Heritage Strategy implementation plan.

Skills and opportunities for young people As part of this priority, this strategy also seeks to maximise opportunities and skills for children and young people through heritage engagement.

Luton has been a site of engineering excellence in motor and aviation industries for much of its recent history, as well as having an even longer history and global reputation for design and innovation, through industries such as hat-making. This, alongside current investment in STEM (science, technology, engineering and mathematics) and growing educational opportunities in digital and creative industries presents a clear opportunity to develop heritage apprenticeships for our young people, as well as using our heritage action zones and conservation areas to support various skills training from school to higher education.

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This strategy seeks to address how meaningful heritage engagement might improve prospects for our young people. Considering:

 Luton as a site of engineering excellence in motor and aviation industries, supporting historical equality in STEM (Science Technology Engineering and Mathematics)  the global reputation of our eco-system of hat makers, devastatingly impacted by Covid, as creative designers and international trend-setters  current innovative and engineering opportunities in cultural and creative augmented realities industries  educational opportunities in sustainable science and biodiversity monitoring

We asked: ‘What might a heritage apprenticeship look like in Luton?’ and ‘How might our heritage action zones, and conservation areas, be developed to support skills training from school through to post-graduate level?’

These opportunities might include modules supporting:  a heritage conservation apprenticeship – combining elements such as work experience with our local heritage conservation construction specialists, academic study of heritage science, and Historic England Conservation Accreditation (PARTNERSHIP LEAD);  a natural heritage conservation apprenticeship – combining qualifications and skills relating to power tools and plant machinery with biodiversity monitoring and engineering studies (PARTNERSHIP LEAD);  A hat-making and block-making apprenticeship modules – could combine modular design skills training with STEM disciplines and support business entrepreneurship skills (PARTNERSHIP LEAD);  Aviation and motor innovation and engineering modules e.g. heritage aviation, vintage car mechanics and engineering innovation research and development. (PARTNERSHIP LEAD);  Growing young people’s engagement with heritage and creative enterprise and interconnectivity between the Hat District and formal education into start-up

Page 244 of 284 enterprise for young people at Hat Works, the oldest former hat factory in Luton. (CULTURE TRUST LEAD)

Target outcomes:  We will work in partnership to involve children and young people in the review of the heritage strategy; and in the development of the heritage implementation plan, through appropriate networks and mechanisms.

 We will work in partnership to develop formal apprenticeship opportunities and accredited qualifications for children and young people that help to create opportunities and address Luton’s heritage needs.

 We will work in partnership with educational organisations in Luton and beyond to develop Ofsted accredited local heritage education resource packs.

Strategic Priority: Future proofing – beyond sustainability

Future-proofing our heritage is central to achieving our overall vision to curate Luton as well as our wider vision for Luton in 2040.

Future-proofing and sustainability in terms of heritage needs to achieve a number of things, from meaningful intergenerational engagement so as to preserve our heritage, ensuring that heritage skills, knowledge, collective memory and intangible heritage are not lost, to ensuring financial and environmental sustainability.

To effectively future-proof our heritage it is also important to maintain an understanding of changes to legislation and national planning frameworks, including the governments design codes and selection criteria which will impact on the integrity,

Page 245 of 284 authenticity and characteristics of our conservation areas, as well as influence how we can map collective memories across non-designated heritage zones.

It is also essential for us to develop sufficient infrastructure, governance, resources and capacity within our communities to deliver in partnership around heritage implementation and action plans, as well as supporting a net gain approach to creating ‘heritage capital’ in all areas.

Target outcomes:

 We will work in partnership to embed measures to future-proof our heritage through all aspects of our heritage implementation plan.

 We will work in partnership to promote intergenerational engagement, including skills, knowledge and collective memory in heritage activity

 We will develop greater infrastructure, governance, resources and heritage capital within our communities.

Page 246 of 284 2. Strategy framework – mapping our assets

2.4 The tangible: our physical environment 2.4.1 Luton's natural heritage National and local context

Our Natural Heritage Assets, significance and protection

Natural heritage - strategy areas of focus

o major project emerging: . The River Lea. This strategy recognises the un-culverting of the River Lea and Wardown Lake management as two of the first major capital natural heritage projects. o Heritage at risk . this strategy recognises biodiversity in the River Lea as heritage at risk through low water levels and residual urban pollution . ancient monument and archaeological features Drays Ditches, at risk by impeding road infrastructure, and because of parts sited in private ownership . Lowland meadowland, which needs specialist management in order to maintain the biodiversity of habitat and species . see also ‘Intangible Heritage’ Section - heritage craft skills of hedge-laying skills, and the growing of hazel to supply materials

Recommendations (forming framework for the Heritage Implementation Action Plan)

o that heritage interpretation of the River Lea (embracing its’ chalk-stream origin, biodiversity and socio-economic history and embedding all six strategic priorities) is considered and embedded at every stage of capital planning for un-culverting and developing a River Lea Linear Park. o that the dynamic draft local list framework, attached, is developed to include alongside the current built local assets, ‘green assets’ and ‘archaeological assets’ that are important and valued by local people, but cannot currently be recorded or protected through other/ or national

Page 247 of 284 frameworks, for example: Medieval earthworks in People’s Park, and our ‘pocket parks’ protected o that a local ‘heritage-at-risk register’ is maintained (across all categories of heritage). o that the developing Heritage Implementation Plan includes action plan to prioritise identified natural heritage at risk: Drays ditches; Lowland meadowland; hedge laying heritage craft skills training (and growing of coppiced hazel); and biodiversity within The River Lea. o the Stockwood Discovery Centre gardens has recently being designated by Historic England for its heritage importance and so a specific conservation management plan for Ian Hamilton Finlay public art, the Garden and heritage structures, needs to be developed. o that development of a Stockwood Parkland Master plan considers the historic parkland and Farley fish pond, and its former use and a future plan for public engagement, includes orientation, park landscape design, sympathetic new developments, historic interpretation and the potential expansion of Stock wood Discovery Centre to widen its Museum offer, public facilities and enable future sustainability. o that all partners commit to collectively addressing identified needs for coordinated biodiversity data collection, for environmental and social scientists, for community and volunteer training

o Call for research: engineering research to develop real-time dynamic natural heritage biodiversity analysis

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2.4.2 Luton's built heritage National and local context

Local achievements to date

Luton has five designated conservation areas and 116 nationally listed buildings, four scheduled ancient monuments, and four sites nationally listed as historic parks and garden parks (as detailed in the natural heritage section above).

Since the council’s draft ‘Foundation for Luton Built heritage Strategy’, produced in 2019 and laying out steps we will take to implement our built heritage action plan, we have:

 had three new inclusions on the Historic England national registry  engaged with a wider range of local people to identify what is valued locally and why  adopted a robust scoping methodology and appraisal framework to establish, review and expand our local list  supported the development of Luton Heritage Forum and its’ role in reviewing and developing a detailed directory, including photographic records, of local heritage assets  broadened the local list to include architectural and archaeological features and public art  reviewed the historic environment section within the Luton Local Plan  developed a ‘heritage at risk’ register  developed partnership infrastructure to support vision, and co-create management plans and design guides for our built heritage conservation areas We have also prioritised place-making: positioning heritage interpretation at the heart of a new Town Centre Masterplan and supported The Culture Trust Luton’s best practice in developing the Plaiter’s Lea Hat District Conservation Area and University of Bedfordshire’s role in widening access and participation into higher education and supporting place-making initiatives.

Page 249 of 284 Our Built Heritage Assets, significance and protection

Our 2021 online heritage consultation survey asked: ‘What is your favourite building, and why?’ There was a whole range of answers, including several addresses that were or had once been called ‘home’. Twelve of people’s favourites were nationally listed, including

 Hart Lane and Bailey Water Towers  St Mary’s Hospital (former workhouse)  two pubs (The Painters Arms, High Town and The Moat House (a late fourteenth century manor with moat)  two buildings statemented for their interiors (the former Odeon cinema, now a church  Hart House - the former director’s offices of Vauxhall Motors)  two grand park estates (Putteridge Bury and Luton Hoo)  plus various Georgian buildings in George Street West, including the registrar office

Top of the poll, with 16% of the total vote, was Grade Two listed Wardown House Museum, 15% cited our Grade One listed parish church St Mary’s as their favourite, and 10% our Grade Two listed the town hall. Equal favourites with 6% of the vote each were: The Hat District buildings, and the former ABC Cinema (sited within George Street Conservation Area but not listed). Only two ‘favourites’ were on the pre-existing draft local list: 27 George Street and 28 King Street. Two were twentieth century: St George’s Library and The Mall; and two contemporary (twenty-first century): Inspire Luton Sports Village and the University of Bedfordshire’s new £46 million seven story Library building. This informs us that buildings of all ages are valued not just for their age or architecture but also for their use value.

Thirteen of the public’s ‘favourite’ buildings are neither currently within designated conservation areas, or mentioned on the original draft local list. Many are significant because of their continued historic use value, these include:

 Denbigh High School

Page 250 of 284  UK Centre for Carnival Arts  Marsh House  the former Masonic Lodge (currently Pizza Express) in Church street, admired (like Hart House) for its’ interior  116 Bury Park Road (currently an Islamic Centre, formerly Synagogue, cinema, and aviation factory)  London Luton Airport (itself a site of heritage)  the football ground (Kenilworth Road). Two ‘favourite buildings’ were lamentations because they no longer exist: 33 Arts Centre and the Starlight Club; and one has yet to be built: ‘the new football stadium at Power Court’. This informs us that we need to have a clear strategic approach about the purpose of local list; a clear scoping methodology to identifying our built heritage assets; the need to develop a dynamic process to review our local list and designated heritage conservation areas.

Built heritage - strategy areas of focus o Major projects emerging:  A new Hat Industry Heritage Zone will be created to combine Plaiter’s Lea Conservation area, High Town Conservation Area and the wider High Town hat industry heritage as identified by English Heritage: to include strategic support for hat maker owned historic hat factories in High Town (to make them post Covid safe and publicly accessible destinations). Sited within this wider Hat Industry Heritage Zone:  there is potential for a future capital project to develop access to the town’s most structurally sound underground war tunnel as a visitor attraction, evidenced through substantial national internet interest  the Plaiter’s Lea Hat District will be supported and developed by continuing heritage care and conservation projects that address historic hat industry buildings most in need and which can be adapted into a new use that aligns with the Hat District Creative District not-for profit ecology and completion of the Hat District ‘Hat Studios’ project.  Built heritage at risk:

Page 251 of 284  conservation areas: High Town and the Plaiter’s Lea Hat District are both recognised nationally by English Heritage as areas of ‘heritage at risk’(https://historicengland.org.uk/advice/heritage-at-risk/search-register/list- entry/2231; https://historicengland.org.uk/advice/heritage-at-risk/search- register/list-entry/2233). Full audit to identify all buildings at risk within these areas recommended.  heritage buildings identified through consultation (including but not limited too):  historic pubs; and Victorian villas, significant through ‘group value’, like many local heritage assets in private ownership, remain ‘at risk’ of demolition (other built heritage groups on the local list include ‘art deco style white residential houses’ and ‘ workers terraced cottages with Bedfordshire Blue Brick’, these group characteristics are not ‘at-risk’)  the façade of the former ABC Cinema remains at risk.  the National Centre for UK Carnival Arts, significant because of its’ high score on the local list appraisal framework, national significance, its’ local social and cultural heritage value, and its position within the emergent St Mary’s Quarter is identified as ‘heritage at risk’  hat Industry related heritage craft, design, technology and engineering skills associated with hat manufacturing (block-making & hat-making) became nationally recognised (in May 2021) along with millinery as skills at risk of extinction and were added to the national Heritage Craft Association ‘red list’.

Recommendations (forming framework for the Heritage Implementation Action Plan)

 that a full audit to identify all buildings at risk within the Hat Industry Heritage zone be undertaken;  that the draft local list framework is expanded to include micro-architectural, street furniture design ‘features’, and ghost signs  that local list framework is expanded to adopt blanket group value properties with simple design code recommendations, e.g. . “all commercial and residential flat-roofed art deco buildings, to be automatically locally listed, and to remain white with flat roofs”; all green-

Page 252 of 284 tiled art deco residential buildings to be automatically locally listed, and to remain white with green-tiled roofs” . “all workers cottages dated between 1850 and 1945 and constructed using local Luton Grey/ Bedfordshire Blue bricks to be automatically added to the local list, and if sited within conservation areas to have bricks/ brickwork protected”  that an ‘at-risk register’ is maintained (across all categories of heritage); and implementation plan developed to conserve heritage at risk  that all strategic partners adopt the SROI valuation methodology based upon January 2021 DCMS published 'Valuing culture and heritage capital: a framework towards inspiring decision making'  that the ‘Town Centre Conservation Area’ be renamed ‘St George’s Conservation Area’ to avoid confusion with the Town Centre Masterplan boundary, and to acknowledge that other designated conservation areas exist within the town centre; and because this conservation area roughly embraces the area from George Street south of The Mall, north-west following Upper George Street to Stuart Street, and south following George Street West to the viaduct  that all partners commit to collectively addressing identified needs for example the need for a conservation officer and supporting the organisational infrastructure of community group development and volunteer training to coordinate local list activity and support a conservation area audit data.  calls for research: built heritage valuation case studies using DCMS (Gov UK DCMS) framework.

2.5 Where the tangible and intangible connect: 2.5.1 Luton's industrial heritage National and local context

Our Industrial Heritage Assets, significance and protection

Industrial heritage - strategy areas of focus

Page 253 of 284 o Major Project: ‘Made in Luton’, positioning Luton internationally as the home of the Vauxhall Heritage Collection and as a historic site of engineering innovation & excellence. o heritage at risk o The Vauxhall Heritage Collection (at risk of loss to the town) o Hat Industry related heritage craft, design, technology and engineering skills associated with hat manufacturer (block-making and hat-making) became nationally recognised (in May 2021) along with millinery as skills at risk of extinction and were added to the national Heritage Craft Association ‘red list’. Boone & Lane are the only blockers in the world offering skilled craftsmanship in both wooden and metal hat block making o Social history, collective and individual memories Recommendations

o In the Museums’ Collections Policy and Collections Development Plan review, we need to ensure adequate representation of Luton’s Industrial Heritage: o to address the risk posed by the changes in ownership and disposal of facilities in Luton of Vauxhall headquarters, and support the Industrial Heritage major project emerging. o to support the development of the Culture Trust’s Hat and headwear Museum collection significance seeking designation by Arts Council England. o to recognise the airport as a site of heritage o to urgently record social history memories related to our 20th century industrial heritage

Page 254 of 284 2.5.2 Luton's cultural and community heritage National and local context

Our Cultural and Community Heritage Assets, significance and protection

Of course the biggest heritage assets in Luton are its people.

“What you have to understand is that, for many young people in the town…heritage is pain” (Lutonian – from public consultation heritage workshop March 2021).

Luton has an ethnically and culturally diverse population created by a rich history of inward economic migration. Identities and representation can be complex and intersectional. According to the DCMS of visitors to nationwide heritage sites in 2019/20, visiting was reported less often by Black respondents (41%) compared to other ethnicities (60 to 75%). Additionally, it was observed that Asian respondents (60%) were less likely to have visited than White respondents (75%). Those in the most deprived areas (51%) were less likely to have visited heritage sites than those in the least deprived areas (83%) (DCMS). In Luton, one of our heritage strengths is our ‘super-diverse’ population.

Diaspora

The early part of the twentieth century witnessed the migration of Scottish and Irish people into the town, followed chronologically by Afro-Caribbean and then Asian peoples. More recently, immigrants from the European Union have made Luton their home. Luton is one of only three towns in the UK (along with Leicester and Slough) with a White British population of less than 50%. In the last census, 81% of the population defined themselves as British. Of those who answered the question in our 2021 heritage consultation survey, 69% of respondents viewed themselves as Lutonian. In further public consultation workshops, we investigated common characteristics and, through discussing what it means and feels like ‘to be Lutonian’ discovered the shared and uniting term ‘diaspora’ (the dispersion or spread of any people from their original homeland), experienced by all immigrant communities, who have all at different times faced both discrimination and hospitality. Luton has

Page 255 of 284 developed resilience and hope in equal measure. There are now 122 different ethnic languages spoken in Luton, and many different peoples have made it their home. We will have figures from the 2021 national census later in the year and will need to review this strategy, heritage interpretation and collections policies accordingly.

Cultural and community heritage - strategy areas of focus:

o major project/emerging: o ‘Curating Luton’: heritage interpretation and place-making plan. Throughout our public consultation and focus group workshops, the need to embed our stories of diaspora and diversity within all of our heritage interpretation and place-making intentions; and the need to anchor Lutonian’s with the physical townscape through heritage narratives has emerged as an important necessity. Strategic approach to this major project will be two years of planning, development and pilot projects, including GIS mapping, followed by three years of delivery. o Cultural Heritage at risk o National Centre for Carnival Arts building As identified above in the built heritage section of this strategy: The National Centre for UK Carnival Arts building, significant because of its’ high score on the local list appraisal framework, national significance, its’ local social and cultural heritage value, and its position within the emergent St Mary’s Quarter (see below) is identified as ‘heritage at risk’.

o Program of Cultural Festivals The impact of consecutive COVID lockdown’s on Luton’s previously vibrant and successful program of festivals should not be underestimated. In the past LLAL has sponsored six events: St Patrick’s Day, Luton Carnival and Luton Mela (sponsored); St George’s Day, Fireworks and Lighting Up Luton (tendered and managed by the council). Luton’s program of festivals has also included Diwali, Polonia and Eid. Luton’s historic quality offer of a vibrant ten month program of multi-cultural festivals is now identified as heritage at risk.

Page 256 of 284 o Collective and individual memories Throughout our public consultation workshops and consequent focus group workshops, one issue was continually raised: the need to record stories from our elders. All communities we spoke to including (but not limited too) Irish, African-Caribbean and Bangladesh, whether it was in reference too continual waves of NHS workers, Windrush generation, or economic migration into Vauxhall, highlighted the urgent need to record, collate and preserve stories from our elderly Lutonian’s. These collective recollections and individual memories, including records of customs and traditional food, are recognised as heritage at risk.

o Music and digital archives The digital archives of Luton Community Arts Trust and 33 Jazz Records have been noted as heritage at risk. As heritage engagements continue across town we are sure that more legacy collections of community and music archives perhaps digital collections stored in outdated historic formats will emerge.

Recommendations

 Using heritage to anchor ‘place-making’ within our 5 statutory designated heritage conservation areas; and 5 emergent Heritage Interpretation Zones  Innovative (using AI, GIS & public art) approaches to heritage interpretation, re-addressing and embedding our stories of diaspora and diversity of cultural heritage in early stages of capital developments.  Maintaining a dynamic local list to include public art  Maintaining a dynamic heritage at risk register to frame our heritage implementation planning.  Partner sign up to o ‘Curating Luton’: five year heritage led place-making (Heritage Interpretation and Implementation Plan). o Research potentials: expanding the cultural and heritage valuation framework Frame-work to include intangible cultural heritage; the

Page 257 of 284 lineage and evolution of Luton produced music genres; impacts of anchoring heritage in place-making on health and wellness

2.6 The intangible: making our invisible, visible National and local context

Our Intangible Heritage Assets, significance and protection

2.6.1 heritage craft skills 2.6.2 a digital archive for Luton Intangible heritage - strategy areas of focus

o major project emerging: A Digital Archive for Luton Digital archive management A strategic approach to digital archive management: creating a robust framework to audit, collate and preserve Luton community archives; and centralise preservation and access.

o heritage at risk  Learnings from previous digital archive projects include those of sustainability of policy, preservation and access. A risk is that as collections are digitised: the physical artifacts not preserved, and the digital archives themselves, perhaps held on outdated technical formats or by economically vulnerable organisations or individuals, are also consequently lost.  Heritage at Risk – Museum Collections and Archive Long-term management and funding agreements and Museum standard stores. In order to sustain museum collections and collecting, adequate on-going provision of resources (budget and staffing) for collection care is needed, including long term, secure and appropriate museum storage, with expansion facility, to account for increase in collecting, including the deposition of Archaeological Archives required under the National Policy

Page 258 of 284 Framework, research and documentation, conservation costs for objects, rationalisation and audit of the collections.

Recommendations

 A feasibility study toward a comprehensive digital archive for Luton, beginning with a full audit and policy review; and development of a robust framework and program of oral history projects to support both: o Intergenerational public health and well-being; and o ‘Place-making’, tourism and inward investment using GIS and I technologies  Partnership approach to: o Feasibility & development of modular heritage apprenticeship, skills training and education (levels 3-5); and creation of heritage education packs and pursuing routes to OFSTED accreditation. o Digital archive management as a major emergent heritage project o Review and strengthen the long-term management, funding and accommodation agreements to protect collections, museums and archives. o Research opportunities supporting digital archive feasibility including for example: . the role of emergent technologies, for example dynamic app based GIS and AI technologies, and the role of NFT (Non Fungible Tokens) in the creation and value of digital heritage archives . Public Health Impact assessments of intergenerational oral history archiving.

Page 259 of 284 3. Emergent non-designated heritage zones The purpose of curating 5 non-designated heritage zones in addition to our 5 designated heritage conservation areas is to encourage focussed and meaningful heritage interpretation and activations – using our shared heritage to anchor our place-making.

3.1 St Mary’s Heritage Zone

3.2 Hat Industry Heritage Zone

3.4 Engineering Heritage Zone 3.4 River Lea Linear Park Heritage Zone

3.5 Bury Park British-Asian Heritage Zone

Page 260 of 284 4. Responsibility for delivery - a joined-up partnership approach 4.1 How you can contribute

Everybody in Luton is invited to engage in the conservation, preservation and interpretation of heritage and the delivery of this strategic vision:

 Get involved with the University of Bedfordshire’s Arts and Culture Projects teams’ activity, including the Heritage Impact Accelerator and the Heritage Enterpise Hub  Get involved with The Wildlife Trust's 'Wilder Futures Project' at Bradgers Hill (and Galley Hill)  Get involved with The Chiltern Conservation Board 'Chalkscapes project'  Get involved with Museum Makers  Get involved with Luton Heritage Forum, design code ‘Charettes’, local list review, public meetings, and collective memories project

Or contact [email protected]

4.2 Partnership Infrastructure

This strategy will be delivered in partnership. A Heritage Steering Group, including local, national, regional and major funding organisations, will be formed to ensure strategic alliance. An ecosystem of community and stakeholder group representatives and heritage ambassadors will be developed to deliver ‘Place- making’: our Heritage Implementation Plan.

Currently our strategic key delivery partners are:

o Luton Borough Council o The Culture Trust Luton o The University of Bedfordshire o The Chilterns Conservation Board o The Wildlife Trust for Beds Cambs and Northants o Luton Heritage Forum

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4.3 Next steps

This strategy document spans ten years 2021-2031.

We will:

 Review this strategy again in two years’ time  Develop ‘Place-making’: our Heritage Implementation Plan.  Develop a delivery ecosystem, and develop a network of heritage ambassadors

Page 262 of 284 Appendices

A. Local list appraisal framework

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Page 264 of 284 Appendix 3 Integrated Impact Assessment Form (IIA)

The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement

‘Enabling Luton to be proud, vibrant, ambitious and innovative’.

Why do I need to do an IIA? The aim of this impact assessment process is to:  Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council.  Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens.  Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion.  Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified.

When do I need to do an IIA?

 An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.

 The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA.  If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA.  An IIA must at all times identify those who will be affected by the decision, policy or strategy.  At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens.  Your first early draft is to be sent to the Social Justice Unit for comments and guidance  Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit. If you need further guidance please contact the Social Justice Unit (SJU). Please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.

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Proposal Title: Heritage Strategy Lead Officer Name: Lilly Smith Date of IIA: 29/06/21

Date updated after consultation: Early draft Seen by: Maureen Drummond, Equality and (Please send an early draft of your IIA to the SJU to Diversity Adviser, 29 June 2021 ensure all impacts are being considered at the appropriate time)

Finalised IIA Signed and seen by SJU : Name: Maureen Drummond, Equality and Diversity Adviser Date 5 July 2021

Names of all other contributors and Luton 2040 team; Luton Heritage Forum; stakeholders involved in the preparing of Luton Culture this proposal who have been consulted with and agreed this assessment: (Please note the IIA must not be carried out by one person) If there is any potential impact on staffing please include the name/s of the trade union representative/s involved in the preparation of this assessment or any supporting evidence of request to participate:

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Proposal Outline

Information supporting the proposal (who, what, where, how, why). Breakdown of present users by ethnicity, age, sex, disability, religion/belief, sexual orientation (if recorded). Show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered.

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What: this is a new Heritage Strategy for Luton it covers all geographical areas of Luton. Re: the physical townscape it focusses on tangible designated and non-designated heritage areas which cluster around the town centre because this is where the highest number of heritage assets exist (generally clustered in the oldest parts of town)

Who: It involves engagement with all communities and demographics: Luton is super diverse and one of the youngest populations in the country (re: 2011 census data:45.9% under the age of 30. Across all ages: 44.6% white British; 55.4% BAME incl. 3% white Irish; 29.9% Asian; 9.8% black Afro/Caribbean) via intangible cultural & community heritage.

This new, co-created Heritage Strategy for Luton signifies a collective ambition to curate the town. It is, in effect, a commitment: to a future ten years of 'joined-up' partnership working to deliver a town wide vision of making Luton a healthy, fair and sustainable town, where everyone can thrive and no-one has to live in poverty. This strategy is a commitment to transforming lives through embedding heritage at the heart of post-Covid regeneration planning. More than 300 individuals who took part in our heritage consultation survey and 30 stakeholder group representatives (including those from business, education, arts, culture and heritage communities) took part in our strategy co- creation focus group workshops. This new strategy builds upon ‘Foundations for a Luton Built Heritage Strategy’ (2019) to embrace all categories of our town's tangible and intangible heritage (natural, built, industrial, cultural and community) and deliver, as promised, a new heritage strategy driving wider participation in heritage in Luton. Its' co- creation, using public consultation and stakeholder engagement as a point of departure, would not have been possible without The National Lottery Heritage Fund's support for a heritage enabler post.

Through research we have discovered best practice approaches; and through public consultation, we have collated and shared a deeper understanding of our collective heritage, what it means, where we come from and who we are. Through open discourse, we have discovered hidden heritage assets (and the need to reveal them). We recognised our award-winning parks, nationally accredited museums, designated conservation areas, listed buildings, monuments and prehistoric earthworks. Beyond our physical landscape,

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Luton is a proud working-class town, continually re-created through generations of historically settling migrant Diasporas. We are proud of our multi-cultural population.

Priorities within this new strategy acknowledge the need to address the re-interpretation of historical narratives to better represent our communities through commitment to embed diversity in all areas of heritage interpretation; the importance of intergenerational heritage engagement and the need (in post Covid landscape) to improve prospects for young people in our town

Why now?

A draft Built Heritage Strategy was previously drafted in 2019; a need for a Heritage Strategy covering all areas of heritage:  Natural heritage,  Built heritage  Industrial heritage  Cultural heritage  community/ intangible heritage

This heritage strategy seeks to embrace all areas of heritage.

Following the adoption of the heritage strategy by council a 5 year Heritage Implementation Plan will be developed.

Heritage Strategy proposed Strategic Priorities will facilitate positive impacts:  Place activation (positive impacts on well-being and civic pride)  Embedding diaspora and diversity into heritage interpretation narratives ( positive impacts on inclusion & accessibility)  Embracing digital innovation  Conservation, preservation and valuation (positive impacts physical environment)  Improving prospects for young people (positive impacts for young people)  Beyond Sustainability – ‘Future-Proofing’

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Impact Table The purpose of this table is to consider the potential impact of your proposal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.

Once you have completed this process you should have a clearer picture of any potential significant impacts1, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.

Citizens/Community Staff (for HR related issues) Protected Groups Positive Negative Neutral Positive Negative Neutral Race  Sex ✔ Disability ✔ Sexual Orientation ✔ Age ✔ Religion/Belief ✔ Gender Reassignment ✔ Pregnancy/Maternity ✔ Marriage/Civil Partnership ✔ (HR issues only) Care Responsibilities2 ✔ (HR issues only) Social & Health3 Impact on community cohesion ✔ Impact on tackling poverty ✔ Impact on health and wellbeing ✔ Environment Impact on the quality of the natural ✔ and built environment Impact on the low carbon agenda ✔ Impact on the waste hierarchy ✔ Economic/Business Impact on Luton’s economy and/or ✔ businesses Impact on jobs ✔ Impact on skills ✔

1 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large. 2 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 3 Full definitions can be found in section 3

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Please answer the following questions:

1. Research and Consultation

1.1. Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate. Click here for local demographics and information DCMS (Department of Culture Media and Sport) Valuing Culture & Heritage https://www.gov.uk/government/publications/valuing-culture-and-heritage-capital-a- framework-towards-decision-making https://m.luton.gov.uk/Page/Show/Community_and_living/Luton%20observatory%20censu s%20statistics%20and%20mapping/Census%20information_1/Census%202011_1/Pages/ default.aspx?redirectToMobile=True external evaluator has been commissioned to monitor the strategy consultation and engagement using National Lottery Heritage Fund evaluation framework

1.2. Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate). Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.

Click here for the LBC Consultation Portal Public consultation via LBC engage: public consultation questionnaire interim results: https://engage.luton.gov.uk/luton-2040-team/luton-lets-talk-heritage-heritage-consultation/

Public consultation workshops- through February and March

Online public consultation re-opened to June 30th

Stakeholder focus groups (widening participation/ wider range of people engaged in heritage) -through May and June Key delivery partner consultation - continuing 1.3. Have you carried out any specific consultation with citizens likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document. For advice and support from Consultation Team click here

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The public consultation survey and public workshops (Feb & March) informed the strategy content, framework, major projects emerging and recommendations The stakeholder focus groups(May/June) informed heritage at risk and recommendations (to be turned into action planning) Key delivery partner consultations (continuing) inform the strategic priorities & future Heritage Implementation development

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2. Impacts Identified

2.1. Where you have identified a positive impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. Guidance Notes: By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic?

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This is the current position: we have not previously had a heritage strategy for Luton; Luton Culture are custodians of museum collections; operate cultural venues; and have been focussing on development in Plaiter’s Lea Hat District (1 of 5 nationally registered heritage conservation areas in the town). The council has a management plan for the Plaiter’s Lea-Hat District. The Culture Trust is currently appointing an independent consultant to address issues around demographic representation within collections policy. An underlying theme unifying all areas within the strategy is that of ‘Place-making’: through connectivity of individual heritage within physical environment

Positive impacts will be delivered through embedding the heritage strategy strategic priorities within the future development of the 5 year Heritage Implementation plan.

The Heritage Strategy has several strategic priorities which will be embedded in development of Heritage Implementation Plan: Directly positively impacting upon race:  Embedding diaspora and diversity into heritage interpretation narratives (for example through pro-active engagement of a wider range of people and to address for example museum collections policies to reflect diversity and diaspora of Luton’s history and to represent current demographics)  The following 2 monitoring questions will inform Key Indicators for success in the implementation stage: o 1. Has engagement and decision making represented Luton’s demographic re: age, ethnicity and postcode? o 2. Have narratives of economic migration, diaspora and diversity been considered in each area of heritage interpretation? Directly impacting upon age:  Improving prospects for young people (for example to develop meaningful heritage sector apprenticeship programmes)  In addition to the strategic priority. Through public consultation an urgent need for intergenerational heritage knowledge and skills work has been identified and urgent need for oral histories across all communities and heritage categories, (e.g. Windrush generation, first generation Luton Bangladesh and Irish settlers, collective memories from Vauxhall economic migrant workers (1950s-1980s) This is because our elders are disappearing and our collective and individual memory is heritage at risk.  The following 2 monitoring questions will inform Key Indicators for success in the implementation stage: o 1. Has engagement and decision making represented Luton’s demographic re: age, ethnicity and postcode?

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o Have we considered how planed action might improve prospects for young people (e.g. from wellness, through skills & knowledge, to employment)

2.2. 1 Guidance Notes: By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic? None applicable

2.3. Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. Guidance Notes: By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic The scope of this heritage strategy has not directly addressed, engaged or identified heritage areas involving issues around sexual orientation, disability, low carbon, waste, or poverty. These issues may arise during strategy review (in 2 years time) and during heritage implementation development stage (e.g. Luton’s LGBT history )

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Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.

For advice & support from the Social Justice Unit click here

For advice and support from the Public Health team click here 2.4. If you have identified an impact on community cohesion4’, tackling poverty5 or health and wellbeing6, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children.

4 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 5 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 6 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services? 12 Page 276 of 284

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Re: community cohesion The Local Government Association defines community cohesion as “a common vision and sense of belonging”…”diversity is appreciated and valued”…” social justice – Key indicators of social cohesion relate to how people feel about their local area. This 10 year heritage strategy seeks to address connectivity between people and townscape, and establish a ‘sense of belonging’ through developing a 5 year heritage implementation plan involving communities and using heritage to anchor placemaking and place activation. Embedding the following priorities into heritage implementation plan will help to support community cohesion:  Place activation (positive impacts on well-being and civic pride) o Using heritage as a physical anchor in regeneration design  Embedding diaspora and diversity into heritage interpretation narratives ( positive impacts on inclusion & accessibility) o Engaging all (demographically representative) communities in heritage interpretation  Embracing digital innovation o Allowing for virtual and physical connectivity  Conservation, preservation and valuation (positive impacts physical environment) o Reviewing collections policies and valuation methodologies  Improving prospects for young people (positive impacts for young people) o Considering a wide range of ways the heritage implementation plan might positively impact young people (from wellness & mental health, through inter generational knowledge sharing, to meaningful skills training & employment opportunities)  Beyond Sustainability – ‘Future-Proofing’ o Including developing infrastructure for community stakeholders to be involved in decision making and heritage implementation plan.

Major emergent projects will support community cohesion . For example the River Lea Linear Park physically connects communities; the Digital Archive Management Project will ensure the preservation of digital & oral archives from the as wide a range of communities as possible (representing the demographic make up of Luton)

3. Social & Health Impacts – as above

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4. Environment Impacts

4.1. If you have identified any impacts related to the built and natural environment7, low carbon8 and waste minimisation please describe here what this may be and who or where you believe could be affected Guidance Notes: Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:

Waste Hierarchy

For advice and support from the Strategy & Sustainability Team click here

Re: Impact on the quality of the natural and built environment Heritage Strategy considers mechanisms for enhancement of designated conservation areas; historic natural environment, listed buildings and River Lea

7 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution? 8 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport. 14 Page 278 of 284

Appendix 3 Integrated Impact Assessment Form (IIA)

5. Economic Impacts

5.1. If you have identified any impacts related to Luton’s economy and businesses 9, creating jobs10 or improving skill levels 11, please describe here what this may be and who or where you believe could be affected Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below. Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below.

For advice and support on Economic Development click here

9 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 10 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well-being and the reduction of poverty in the social box. 11 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships? 15 Page 279 of 284

Appendix 3 Integrated Impact Assessment Form (IIA)

This strategy hopes to address the different frameworks and valuation methodologies we can apply to help us protect local heritage assets and underpin and implement post-Covid recovery by leveraging how the government is currently incentivising investment in repair, maintenance and public appreciation for heritage. Investing in the historic environment generates economic returns for local places. There are economic, sustainability and well- being arguments for committed investment in heritage: "a study into heritage tourism between 2004 and 2007, estimated that for every £1 spent as part of a heritage visit, 32p was spent on site and the remaining 68p is spent in local businesses including restaurants, cafes, hotels and shops" (National Lottery Heritage Fund, 2010) "…on average every £1 invested by the public sector on heritage led generation returns £1.60 of additional economic activity…" (AMION and Locum Consulting, 2010).

"When a typical historic building is refurbished and retro-fitted, it will not only create jobs but also emit less carbon by 2050 than a new building" (Heritage Counts 2019). "Investment in environmental adaptations can consistently deliver high returns, with benefits between 2 and 10 times the cost…" (Foreign and Commonwealth Office, 2020).

"Most green measures… (e.g. meadow and riverside land management, tree planting and improving the condition of green spaces generally) …have high benefit: cost ratios, with multiple co-benefits for health and the natural environment as well as the economy" (ccc, 2020).

The heritage strategy implementation steering group will investigate meaningful opportunities for improving prospects for young people such as modular apprenticeships.

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Appendix 3 Integrated Impact Assessment Form (IIA)

Impact Enhancement and Mitigation Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:

Responsible Date Completed Action Deadline Intended Outcome Officer / Ongoing Embedding August 2022  Place activation strategic priorities (positive in implementation plan impacts on well- being and civic pride)  Embedding diaspora and diversity into heritage interpretation narratives ( positive impacts on inclusion & accessibility)  Embracing digital innovation  Conservation, preservation and valuation (positive impacts physical environment)  Improving prospects for young people (positive impacts for young people)

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 Beyond Sustainability – ‘Future-Proofing’

A review of the action plan will be prompted 6 months after the date of completion of this IIA.

Key Contacts Name Position Lilly Smith Heritage Enabler

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Appendix 3 Integrated Impact Assessment Form (IIA)

Next Steps  All Executive Reports, where relevant, must have an IIA attached  All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment)  All reports are to be forwarded to the Social Justice Unit, Legal Department, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline  On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager

Completed and signed IIA’s will be published on the internet once the democratic process is complete

Useful Documents Corporate Plan http://intranet/SupportServices/Document%20library/LBC-corporate-plan.pdf Equality Charter https://www.luton.gov.uk/Community_and_living/Lists/LutonDocuments/PDF/Social%20Justi ce/Equality%20Charter.pdf Social Justice Framework Joint Strategic Needs Assessment (JSNA)

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