Committee Ref

COMMITTEE REF:

EX/08a/18

NOTICE OF MEETING

COMMITTEE : EXECUTIVE

DATE : THURSDAY, 23 AUGUST 2018

TIME : 18:00

PLACE : COMMITTEE ROOM 3 TOWN HALL, LUTON, LU1 2BQ

COUNCILLORS : SIMMONS (CHAIR) HUSSAIN AKBAR A. KHAN BURNETT MALCOLM CASTLEMAN SHAW HOPKINS TIMONEY

QUORUM : 3 MEMBERS

Contact Officer: Matt Hussey (01582 546032)

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.

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Page 1 of 22 AGENDA

Agenda Subject Page Item No.

EMERGENCY EVACUATION PROCEDURE

Committee Rooms 1, 2, 4 & Council Chamber: Turn left, follow the green emergency exit signs to the main town hall entrance and proceed to the assembly point at St George's Square.

Committee Room 3: Proceed straight ahead through the double doors, follow the green emergency exit signs to the main Town Hall entrance and proceed to the assembly point at St George's Square.

INTRODUCTIONS, PHOTOGRAPHY, FILMING & AUDIO RECORDING

1. APOLOGIES FOR ABSENCE

2. PUBLISHED RECORD OF THE MEETING

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.

Page 2 of 22 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) (England) Regulations 2012.

PLACE & INFRASTRUCTURE (REGENERATION)

3. 1. Proposed Chiltern Green Energy Park 5 - 12 (Report of the Service Director, Property and Construction)

PLACE & INFRASTRUCURE (PLANNING & TRANSPORT)

3. 2. EIA M1 to A6 Link Road 13 - 22 (Report of the Service Director, Planning & Economic Growth)

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

REGULATION 4 OF THE LOCAL AUTHORITIES (EXECUTIVE ARANGEMENTS)(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.

Page 3 of 22

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.

Page 4 of 22 Report For: Executive Item No: Date: 23 August 2018 Report Of: Service Director – Property & Construction 3.1 Report Author: Roger Kirk

Subject: Proposed Chiltern Green Energy Park Lead Executive Member(s): Cllr Sian Timoney Wards Affected: All Consultations: Councillors ☐ Scrutiny ☐ Stakeholders ☐ Others ☐

Recommendations 1. That Executive instructs the Corporate Director – Place & Infrastructure to submit a response on behalf of the Council to Central Bedfordshire Council with respect to the request for an Environmental Impact Assessment Scoping Opinion in regard of the proposed Chiltern Green Energy Park development at East Hyde.

2. That, in the event that a formal planning application is lodged with Central Bedfordshire Council in respect of the above proposed development, Executive instructs the Corporate Director – Place & Infrastructure to refer any response to Executive for review prior to submission.

Background 3. Emsrayne Renewable Energy Ltd (a company based in Caddington) intend to submit a planning application to Central Bedfordshire Council to construct and operate a Combined Heat & Power generation facility at New Mill End (East Hyde) that would import up to 500,000 tons of refuse derived fuel (or similar residual waste) per annum.

4. Residual waste is defined as the non-hazardous combustible mixed material that remains after the traditional waste recycling process.

5. This would be incinerated by the “moving grate” combustion process to produce an energy output equivalent to circa 100 MWe.

6. It is proposed that an underground insulated pipeline will carry pressurised hot water from the facility to a connection point close to London Luton Airport.

7. Electricity would be transported via an underground cable to a new substation in the vicinity of London Luton Airport, which would be connected in turn to Luton South substation belonging to UK Power Networks.

The Current Position 8. The Town & Country Planning (Environmental Impact Assessment) Regulations 2017 specify the types of development for which an Environmental Impact Assessment is mandatory. The proposed facility would fall into this category.

Page 5 of 22 9. The intended planning application will therefore have to be accompanied by an Environmental Statement based on a comprehensive Environmental Impact Assessment.

10. As a result Emsrayne Renewable Energy Ltd have submitted a document to Central Bedfordshire Council formally requesting them to provide a scoping opinion on the proposed Environmental Impact Assessment, as provided for by Section 15 of the regulations referred to above.

11. On 27.06.18 Central Bedfordshire Council in turn asked potentially interested parties (including Luton Borough Council) to submit representations as to what areas and issues the Environmental Impact Assessment in question should cover.

12. Representations were originally required by 11.07.18 but this deadline has been extended to 31.08.18.

Goals and Objectives 13. The prime objective is to ensure that the proposed Environmental Impact Assessment fully and critically examines the potential impact of the proposed development on Luton residents and businesses.

Proposal 14. The proposal is for the Corporate Director – Place & Infrastructure to submit a response to Central Bedfordshire Council suggesting that the Environmental Impact Assessment covers the concerns listed in the points below:

15. The proposed route to and from the site is stated as the Lower Harpenden Road B653 to Airport Way A1081 to access the strategic road network i.e. the M1. Airport Way is a traffic sensitive road.

16. The estimated throughput of the proposed plant is 500,000 tonnes per annum. Without knowing the density of the waste it is impossible to predict the likely traffic generation. If the waste is in compressed bales it is likely to generate up 250 two way vehicle movements per day based on a 5 day working week. If it is loose waste the vehicle movements could easily triple.

17. The proposed scope of the network modelling is therefore unacceptable. It is likely that all the junctions on Airport Way including those at M1 junctions 10 and 10a will require assessment. Additionally, no mention is made of modelling the roundabout junctions on Lower Harpenden Road at Gipsy Lane and Parkway.

18. The scoping report mentions looking at the width and alignment of Lower Harpenden Road. While it is a B road, it is relatively narrow and has a number of bends with extremely restricted forward visibility. It could not therefore be considered as a particularly satisfactory route for a large number of two way HGV movements.

19. It appears that the plant will cater for waste from a very wide area, all of which will be arriving by road. This is not a very sustainable way of transporting waste.

20. There is potential for substantial adverse Air Quality and Noise pollution for Luton Residents. This risk will have to be assessed.

Page 6 of 22 21. As the site is close to Luton Hoo Park, the River Lea and the Luton to Harpenden Cycle- Way there will need to be a detailed assessment of any potential related landscape, heritage and public amenity issues as part of the Environmental Impact Assessment.

22. An Aerodrome Safeguarding Assessment should be required with respect to the potential impact on flights to and from London Luton Airport.

23. A Health Impact Assessment should be required for the wider area of population not just that in the immediate vicinity of the proposed development.

24. The Environmental Impact Assessment should take notice of the proposed development of New Century Park and future London Luton Airport expansion plans.

25. The proposed development sits at odds with the Council’s plans to provide a green energy supply to London Luton Airport and surrounding businesses by the construction of solar and wind based electricity generation capacity.

Key Risks 26. Not to respond to the request by Central Bedfordshire Council for input on the scope of the proposed Environmental Impact Assessment would prevent the Council having a say in what it should cover from a Luton residents and businesses perspective.

Consultations 27. None at this stage.

Alternative options considered and rejected (please specify) 28. Not to respond to the request by Central Bedfordshire Council for input on the scope of the proposed Environmental Impact Assessment.

Appendices Attached 29. Letter dated 27.06.18 from Central Bedfordshire Council.

Background Papers 30. Proposed Chiltern Green Energy Park ay East Hyde. Town & Country Planning (Environmental Impact Assessment) Regulations 2017. Request for a Scoping Opinion under Regulation 15. SLR on behalf of Emsrayne Renewable Energy Ltd June 2018.

Page 7 of 22 IMPLICATIONS

For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer

For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required

Legal Clearance Agreed By Dated There are no direct legal implications to what is Kemi Onakoya, Principal 8 August proposed in this report. Solicitor (Property & 2018 Planning)

Finance Clearance Agreed By Dated The report has no direct financial implications. Darren Lambert, Finance 6th August However, should a formal planning application be Business Partner 2018 submitted to Central Bedfordshire Council the Council may need to incur costs dependent on how far the planning process progresses.

Integrated Impact Assessment (IIA) – Key Points

Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated Of itself the Council’s proposed response has no Social Justice Unit 10.08.18 Social Justice implications.

Environment Clearance Agreed By Dated Whilst the principle of energy from waste is clearly Keith Dove, Strategic Policy 8th August beneficial in terms of reducing CO2, this needs to be Adviser 2018 balanced against the emissions as a result of an increase in Heavy Goods Vehicle movements serving the site Health Clearance Agreed By Dated Public Health agree it is important that full Lucy Hubber, Consultant in 7/8/18 investigations to protect the environment and health Public Health [Interim] be carried out with respect to such proposals.

A full health impact assessment for residents of Luton and the wider area be carried out before any planning application is agreed in this context. Alongside a full environmental impact assessment this should support informed decision making in the interests of Luton’s environment and public health. It is also felt that specialist public health opinion should be sought from the Public Health England Centre for Radiation, Chemical and Environmental Hazards

Page 8 of 22 [PHE CRCE] as part of the formal planning process.

The Chief Medical Officer in her 2017 annual report urges policy makers to take the threat to health posed by air pollution seriously and to realise that addressing pollution is disease prevention.

Air pollution is the greatest environmental harm to human health. With estimates of UK annual deaths estimated between 29,000 to 40,000. Luton already has a higher percentage of adult deaths [6%] related to exposure to air pollution than England [5.3%].

Transport is a major source of both air and noise pollution and good air quality and reduced noise pollution are important elements of providing a healthy place and should be protected wherever possible. The health impacts of this possible proposal should be understood fully using full health and environmental impact assessments.

Community Safety Clearance Agreed By Dated

Staffing Clearance Agreed By Dated

Other Clearance Agreed By Dated

Page 9 of 22

Page 10 of 22 Appendix

Luton Borough Council Contact Jerry Smith Development Management (Planning) Direct Dial 0300 300 5881 Town Hall Email [email protected] Luton Your Ref Beds Date 27 June 2018 LU1 2BQ

Dear Sir/Madam,

Application No: CB/18/02363/SCO Location: Proposed Chiltern Green Energy Park, Land off Lower Harpenden Road, New Mill End, East Hyde Proposal: Request for Scoping Opinion in respect of the construction and operation of a Combined Heat and Power (CHP) facility that would import up to 500,000 tonnes per annum of Refuse Derived Fuel (RDF) or similar residual waste including new access off Lower Harpenden Road, ancillary development and installation of underground pipeline and cable for transfer of heat and energy to new connection points/substation near London Luton Airport.

SCOPING OPINION OF THE LOCAL PLANNING AUTHORITY. THE TOWN AND COUNTRY PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) REGULATIONS 2017. (REGULATION 15 (1) )

THIS IS NOT A PLANNING APPLICATION

I have received a request for the Local Planning Authority to provide a 'Scoping Opinion' with regard to the preparation of an Environmental Impact Assessment (EIA) to accompany any future planning application for the above development. The purpose of such a request is to identify what information is considered necessary to be included in the EIA in order to assess the significant environmental effects of the proposal. A planning application has therefore not been received at this stage and any subsequent submission would be subject to separate consultation and publicity.

A copy of the EIA Scoping Details and Plans can be inspected on our website. To view these documents please visit: http://www.centralbedfordshire.gov.uk/PLANTECH/DCWebPages/acolnetcgi.gov?ACTION=UNWR AP&RIPNAME=Root.PgeResultDetail&TheSystemkey=609852

Please can you comment on the information to be included in the Environmental Statement by 11 July 2018.

Yours faithfully,

Page 11 of 22 Andrew Davie Assistant Director - Development Infrastructure

Page 12 of 22 Report For: Executive Item No: Date: 23 August 2018 Report Of: Service Director, Planning & Economic Growth 3.2 Report Author: Sarah Barker

Subject: M1 to A6 Link Road EIA Scoping Opinion Response Lead Executive Member(s): Cllr Castleman Wards Affected: All Consultations: Councillors ☐ Scrutiny ☐ Stakeholders ☐ Others ☒

Recommendations 1. That Executive is recommended to:

(a) Instruct the Corporate Director, Place and Infrastructure to submit the Luton Borough Council response to Central Bedfordshire Council; and

(b) In the event that a formal application is received by Central Bedfordshire Council, instructs the Corporate Director, Place and Infrastructure to refer the proposed Luton Borough Council response to Executive for consideration.

Background 2. Luton Council has received a consultation request from Central Bedfordshire Council for an Environmental Impact Assessment (EIA) Scoping Opinion about the information to be provided in the Environmental Statement which will accompany a planning application for the M1 to A6 Link Road, North of Luton, Bedfordshire.

3. Central Bedfordshire Council has already determined that the development requires an Environmental Impact Assessment.

4. The consultation request particularly seeks comments about the likely effects on the environment and the extent of information required and the impacts that are likely to occur taking into account

(a) the specific characteristics of the particular development;

(b) the specific characteristics of development of the type concerned; and

5. In addition to the Scoping Opinion, Central Bedfordshire Council recently arranged a series of drop in events for the public. This included an event in the Sundon Park area of Luton on Monday 30 July. Central Bedfordshire Council have also arranged an extra drop in event on Tuesday 21 August from 14:00 – 19:00hrs at St Margaret's Parish Centre, Lucas Gardens, Bramingham, Luton, LU3 4BG.

The Current Position

Page 13 of 22 6. Central Bedfordshire Council have received a request for a Scoping Opinion about information to be provided in the Environmental Statement that is required to accompany a planning application for the M1 to A6 link road. Central Bedfordshire Council are consulting on this under the Town and Country Planning (Environmental Impact Assessment) Regulations 2011.

7. The applicants have submitted an Environmental Impact Assessment Scoping Report on the M1 to A6 Link Road. The document, prepared by Jacobs, is 260 pages. It contains an executive summary, introduction, and a series of chapters about the project, Environmental Impact Assessment (EIA) methodology, air quality, noise and vibration, landscape and visual effects, cultural heritage, nature conservation, road drainage and the water environment, geology and soils materials, people and communities, traffic and transportation, human health, cumulative effects and a proposed structure for the environmental statement.

8. The proposed M1-A6 scheme comprises the provision of a new 2.75 mile (4.4km) long road link between M1 junction 11a in the west and the A6 in the east with three intermediate junctions to effectively form a northern bypass for Luton.

9. The proposed scheme will open up land for the potential development of up to 4,000 dwellings, up to 20 hectares of employment land, community facilities and open spaces, and provision of a new sub-regional rail freight interchange incorporating around 40 hectares of associated employment land.

10. The M1-A6 Link Road is constrained by the Chilterns Area of Outstanding Natural Beauty (AONB) to the north and the proposed residential development to the south. The eastern half of the Proposed Scheme is located either within or very near to the AONB. The majority of the M1-A6 Link Road footprint is on land with an Agricultural Land Classification of Grade 2 (very good quality).

11. There are ecologically designated sites in the area, the nearest of which is Sundon Chalk Quarry Site of Special Scientific Interest (SSSI) to the north. There are also non-statutory designated sites within 2 km, including County Wildlife Sites and Local Nature Reserves. Several small unnamed watercourses are located within 1 km of the alignment, along with two Main Rivers, the River Lea and River Flit.

12. Adjacent to the M1, to the south of the proposed scheme, there is an Air Quality Management Area, (AQMA) which is also within a Noise Important Area (NIA). Further NIAs are located at Junction 11a of the M1 and along the existing A6. Other potentially sensitive receptors include local schools, a hospice and residential dwellings. A network of Public Rights of Way (PRoW), including long distance footpaths, cross the area.

13. The Scoping Report is intended to set the scope of work and methods to be applied in carrying out the Environmental Impact Assessment (EIA) and the proposed structure and coverage of the Environmental Statement (ES).

Goals and Objectives 14. To ensure that the proposed Environmental Impact Assessment fully and critically examines the potential impact of the proposed development on Luton residents and businesses.

Page 14 of 22 15. To ensure that Luton Council is fully involved in discussion and decision making about the M1-A6 Link Road going forward. Specifically that the scope of the Transport Assessment is agreed in advance with Luton Council, Central Bedfordshire Council and Highways England. In addition, that Luton Council is involved in scheme design and that active travel (cycling and walking) receives a high priority.

Proposal 16. The proposal is for the Corporate Director – Place & Infrastructure to submit a response to Central Bedfordshire Council suggesting that the Environmental Impact Assessment covers the concerns listed in the points below and asking that a full health impact assessment be completed:

17. As a matter of principle, any planning application for this scheme should be determined after the examination of the Central Bedfordshire Local Plan 2015-2035. As explained in the submitted Central Bedfordshire Local Plan, Policy SA1, part 2, the link road is essential infrastructure for delivery of a strategic mixed-use development site to the north of Luton. The link road and associated strategic development are so substantial that to grant permission would undermine the plan-making process by predetermining decisions about the scale, location or phasing of new development that are central to an emerging plan. Whilst the Central Bedfordshire Local Plan is at an advanced stage, it is not formally adopted and part of the statutory development plan. All circumstances of prematurity described by paragraph 49 of the National Planning Policy Framework are applicable in this instance.

18. The examination of the Central Bedfordshire Local Plan is therefore the appropriate avenue for the significant impacts of this scheme and the associated strategic development site to be assessed.

19. If Central Bedfordshire Council are minded to determine a planning application prior to receipt of the Inspector’s Report following examination of the Central Bedfordshire Local Plan, the scope of the Environmental Impact Assessment must cover both the link road and the strategic development site that it is intended to serve.

20. The scoping report does not consider the impact on Luton at all in transport terms. There is no mention of future links into Luton from the various roundabouts along its length. The suggestion that the scope of the Transport Assessment will only be agreed between Central Bedfordshire Council and Highways England, at para’s 13.1 and 13.7, is wholly unacceptable. The scope needs to be agreed with Luton Council Highways, in addition to Central Bedfordshire Council Highways and Highways England.

21. It is proposed that the SATURN based Central Bedfordshire and Luton Transport Model (CBLTM) be used for the base modelling of the scheme with various junctions modelled using a mix of VISSIM, ARCADY, PICADY etcetera (para 13.2.2). This approach may not produce reliable results and a wider VISSIM network of the whole of the new road and affected junctions should be considered. Additionally, the report proposes to use outputs from the Central Bedfordshire and Luton Transport Model to provide traffic volume data together with additional traffic counts to validate the outputs. It is not clear over what area these counts are to be undertaken but given there will be a direct impact on Luton roads there will need to be count sites within Luton.

22. The EIA scoping report needs to consider the impact of both infrastructure and sustainable transport measures that are covered by a travel plan associated with the development. It is

Page 15 of 22 important that a high priority is placed on active travel (walking and cycling), followed by public transport and other forms of sustainable travel, in accordance with national planning policy framework [para’s 102 c and 110 a].

23. The EIA should include the potential for mitigation of impacts through the delivery of a park and ride site on the A6 north of Luton, serving Luton town centre. It should also consider impacts the M1-A6 link with and without the delivery of a complimentary A6-A505 link road.

24. The EIA needs to include the financial impact of the link road on the ability of the strategic allocation to meet affordable housing needs.

25. In relation to the surface and groundwater impacts, the 1 km buffer around the proposed road forming the initial study area would definitely need to be refined during further stages of the project, especially in relation to downstream impacts on surface and groundwater flood risk.

26. Referring to section 9.4, the flood mitigation scheme pursued by Luton Council (as identified in section 9.2.6) would aim to intercept all three surface water flow paths affecting the proposed routes. This is covered under two critical drainage areas; Greater Bramingham (BRGB); and Sundon Park (SPRL) as identified in a draft Surface Water Management Plan (2012).

27. Luton Council is not only interested in developing a flood mitigation scheme to the north of the borough boundary in a way that would not compromise the viability or delivery of the link road but also in exploring options for joint efforts leading to efficiencies in project design and delivery.

28. In relation to groundwater flooding, Luton Council is aware of local occurrence of perched water aquifers in the study area and is currently pursuing a study to assess impacts of upstream infiltration on properties in the Bramingham and Marsh Farm areas. If infiltration is proposed as part of the link drainage strategy, provisions should be made to investigate groundwater movement within the water-bearing strata to avoid increasing groundwater flooding elsewhere.

29. Luton Council agrees with the assessment of the scheme’s impacts on ground and surface water as medium to high and the need to submit a formal Flood Risk Assessment. To this respect, Luton Council’s Lead Local Flood Authority should specifically be consulted on the Flood Risk Assessment.

Key Risks 30. Not to respond to the request by Central Bedfordshire Council for input on the scope of the proposed Environmental Impact Assessment would prevent the Council having a say in what it should cover from a Luton residents and businesses perspective.

Consultations 31. None at this stage.

32. Central Bedfordshire Council have consulted with a variety of consultees. These include Luton Borough Council, Highways England, Environment Agency, Historic England, Natural England, The Wildlife Trust, Anglian Water, and teams within Central Bedfordshire Council including Landscape Officer, Trees and Landscape, Rights of Way, Archaeology, Conservation and Design Officer and Highways.

Page 16 of 22 33. Further information is available on Central Bedfordshire Council’s website at: http://www.centralbedfordshire.gov.uk/PLANTECH/DCWebPages/acolnetcgi.gov?ACTION= UNWRAP&RIPNAME=Root.PgeConsultees&TheSystemkey=610204

Alternative options considered and rejected (please specify) 34. Not to respond to the request by Central Bedfordshire Council for input on the scope of the proposed Environmental Impact Assessment.

Appendices Attached 35. Appendix A: Letter from Central Bedfordshire Council to Luton Council M1 A6 Link Road EIA Scoping Opinion.

Background Papers 36. EIA Scoping Opinion Report, available at http://www.centralbedfordshire.gov.uk/planning- register, reference 18/02714.

37. Information about the M1-A6 Link Road on Central Bedfordshire Council’s website, including the route and rights of way, available at http://www.centralbedfordshire.gov.uk/transport/m1-a6-link-road/overview.aspx.

Page 17 of 22 IMPLICATIONS

For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer

For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required

Legal Clearance Agreed By Dated There are no direct legal implications to what is Kemi Onakoya, Principal 8 August proposed in this report. Solicitor (Property & 2018 Planning)

Finance Clearance Agreed By Dated There are no financial implications associated with Darren Lambert, Finance 6th August the report at this stage. Business Partner 2018

Integrated Impact Assessment (IIA) – Key Points

Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated An IIA has been completed and it has been identified Sandra Hayes, Service 07/08/2018 that the proposal is neutral in all aspects. Manager SCS

Environment Clearance Agreed By Dated It has been identified that the proposal has some Keith Dove, Strategic Policy 8th August negative impacts on Barbastelle bat and other Adviser 2018 environmental aspects. These will be assessed further at the next stage, an Environmental Statement.

The proposed M1-A6 Link is expected to reduce traffic on some roads in the north of Luton particularly in the Bramingham Road/Icknield Way corridor and therefore reduce congestion and CO2, full details of the traffic impacts of the new road on the highway network are not yet available.

Health Clearance Agreed By Dated Public Health agree it is important that full Lucy Hubber, Public Health 7/8/18 investigations to protect the environment and health Consultant, Interim be carried out with respect to such a proposal.

We ask that in addition to an environmental impact assessment that also a full health impact assessment for residents of Luton and the wider area be carried

Page 18 of 22 out. A full environmental and health impact assessment will provide Luton with information that allows informed decision making in the interests of Luton’s environment and public health.

Luton is already considered one of the fourth congested towns in the country and should look to improve sustainable and active travel options including a park and ride facility, cycle and walking routes and good public transport and infrastructure, taking traffic out of the town.

The Chief Medical Officer in her 2017 annual report urges policy makers to take the threat to health posed by air pollution seriously and to realise that addressing pollution is disease prevention.

Traffic is a major source of both air and noise pollution and good air quality and reduced noise pollution; adequate green spaces and green infrastructure, good housing, with a social, leisure and amenity offer with good transport links are all important elements of providing a healthy place and should be provided wherever possible. The full health implications of this possible proposal should be fully understood with full health and environmental impact assessments.

Taking every opportunity to reduce air pollution and ease traffic congestion from the town should be considered a priority to optimise health benefits and reduce harms to public health, creating a healthier town and therefore improving public health.

Community Safety Clearance Agreed By Dated An IIA has been completed and it has been identified that the proposal is neutral.

Staffing Clearance Agreed By Dated An IIA has been completed and it has been identified that the proposal is neutral.

Other Clearance Agreed By Dated

Page 19 of 22 None.

Page 20 of 22 Appendix A

Page 21 of 22 Page 22 of 22