Luton and South Bedfordshire Local Development Framework

Home , Bedfordshire, South Bedfordshire, Sundon Chalk Quarry, Totternhoe Knolls

Sustainability Appraisal Draft Scoping Report

May 2007

Luton and South Bedfordshire Local Development Framework

Sustainability Appraisal Scoping Report

Contents Amendment Record This report has been issued and amended as follows:

Issue Revision Description Date Signed

01 00 Draft SA Scoping Report 24/1/07 JPW

02 01 Draft SA Scoping Report 6/02/07 JPW

03 02 Final SA Scoping Report 14/3/07 JPW

04 03 Final SA Scoping Report 25/4/0 JPW

Contents

1 INTRODUCTION 1 1.1 Background 1 1.2 Luton and South Bedfordshire Local Development Framework 2 1.3 Background to SEA and SA 3 1.4 Health Impacts 5 1.5 Health and Sustainable Development 5 1.6 Equality Impacts 5 1.7 Purpose of this Scoping Report 6 1.8 Structure of this Report 7

2 Stage A1- Identifying other relevant plans, programmes and sustainability objectives 9 2.1 Background 9 2.2 Purpose 9 2.3 Economic Factors 13 2.4 Social Factors 14 2.5 Water 15 2.6 Biodiversity 15 2.7 Air Quality 16 2.8 Soil 16 2.9 Climatic Factors 16 2.10 Population 17 2.11 Human Health 17 2.12 Material Assets 19 2.13 Cultural Heritage 19 2.14 Landscape and Townscape 19

3 Stage A2- Collecting Baseline Information 21 3.1 Background 21 3.2 Collection Methodology 22 3.3 Baseline Analysis 22 3.4 Economic Factors 22 3.5 Social Factors 26 3.6 Water 31 3.7 Biodiversity 33 3.8 Air Quality 39

3.9 Soil 43 3.10 Climatic Factors 44 3.11 Population 45 3.12 Human Health 48 3.13 Material Assets 53 3.14 Cultural Heritage 55 3.15 Landscape 55 3.16 Townscape 57

4 Stage A3- Identifying Environmental and Sustainability Issues 58 4.1 Introduction 58

5 The SA Framework 66 5.1 Introduction 66 5.2 SA Appraisal Methodology 66

6 Consultation 79 6.1 Introduction 79

7 Next Steps 80 7.1 Introduction 80 7.2 Stage B: Developing and refining options and assessing the effects of the DPDs 80 7.3 Stage C: Preparation of the final Sustainability Report 82 7.4 Stage D: Consultation with the public and statutory bodies 84 7.5 Stage E: Monitor the effects of the plan on the environment/ sustainability 84

8 Summary of Questions for Consultees 85

Appendix A: Plan and Programme Review

Glossary

AGWP Average Gross Weekly Pay AMR Annual Monitoring Report AONB Area of Outstanding National Beauty AQMA Air Quality Management Area BAP Biodiversity Action Plan BVPI Best Value Performance Indicator CDRP Crime and Disruption Reduction Partnerships CO Carbon monoxide CO2 Carbon dioxide CPRE Campaign to Protect Rural England DEFRA Department for the Environment, Fisheries and Rural Affairs DETR Department of the Environment, Transport and the Regions dph Dwellings per Hectare DPD Development Plan Document EA Environment Agency ESDP European Spatial Development Perspective EC European Commission EU European Union GB Great Britain GCSE General Certificate of General Education GIS Geographical Information System GSS Green Space Strategy Ha Hectares IMR Infant Mortality Rate JPTC Joint Planning and Transportation Committee JSA Job Seekers Allowance LDD Local Development Document LDF Local Development Framework LDS Local Development Scheme LTP Local Transport Plan NAQS National Air Quality Strategy NOx Nitrogen Oxides NO2 Nitrogen dioxide NVQ National Vocational Qualification ODPM Office of the Deputy Prime Minister PDL Previously Developed Land PM10 Particulate matter PPG Planning Policy Guidance PPS Planning Policy Statement QoL Quality of Life RPG Regional Planning Guidance RSS Regional Spatial Strategy SA Sustainability Appraisal SAMs Scheduled Ancient Monuments

SCI Statement of Community Involvement SEA Strategic Environmental Assessment SFRA Strategic Flood Risk Assessment SO2 Sulphur dioxide SPD Supplementary Planning Document SPZ Source Protection Zones SSSI Site of Special Scientific Interest SUDS Sustainable Urban Drainage Systems UK United Kingdom UN United Nations VAT Value Added Tax

1 INTRODUCTION

1.1 Background Milton Keynes and the South Midlands (MKSM) was identified as one of the four growth areas in England in the “Sustainable communities: building for the future” report published by the Government in February 2003. The other three areas are London-Stansted- Peterborough- Cambridge, Ashford and Thames Gateway. Luton/ Dunstable/ Houghton Regis and Leighton Linslade is part of the wider MKSM growth area.

The growth requirements for MKSM are set out in the Draft Regional Spatial Strategy for the East of England, June 2006. The draft RSS allocation for Luton, Dunstable, Houghton Regis and Leighton Linslade is 26,300 dwellings between 2001 and 2021 and the safeguarding of land for a further 15,400 houses in the period 2021-2031. In terms of employment, the draft RSS refers to the provision of 23,000 new jobs in the period to 2021, and a further 12,000 to 2031.

A Luton/Dunstable/Houghton Regis and Leighton Linslade Joint Planning and Transportation Committee (JPTC) has been established to deliver and coordinate these growth requirements. Luton Borough Council, South Bedfordshire District Council and Bedfordshire County Council are working together to produce a Joint Local Development Framework (LDF) covering the whole of Luton and South Bedfordshire.

Given Luton and South Bedfordshire’s position on the Sustainable Communities agenda, which identifies the importance of Luton and South Bedfordshire in delivering the Government’s planning and housing agenda for the South East, the LDF and Sustainability Appraisal (SA) represent a critical opportunity to drive forward the sustainability agenda and to present a high-level vision for sustainable development throughout Luton and South Bedfordshire. This SA will be used at key stages in the evolution of the development options and during policy preparation.

The SA will primarily focus on identifying the significant effects arsing from the LDF within Luton and South Bedfordshire but the SA will also consider

the effects of the LDF on the neighbouring districts of North Hertfordshire and Aylesbury Vale.

1.2 Luton and South Bedfordshire Local Development Framework The Local Development Framework (LDF) is the emerging development plan for Luton and South Bedfordshire. LDFs are the new form of spatial development plan introduced by the Government’s planning reforms in the Planning and Compulsory Purchase Act (2004) (The Act). The LDF will eventually replace the existing Local Plans.

The LDF will consist of a portfolio of Local Development Documents (LDDs) which will include Development Plan Documents (DPDs) which will collectively guide development in Luton and South Bedfordshire. Central to this portfolio is the Core Strategy DPD, which sets out the overall vision and objectives for future development in Luton and South Bedfordshire and provides a framework for later DPDs, including the Growth Area DPD which will make housing land use allocations.

In addition to these statutory DPDs there will be a number of non-statutory Supplementary Planning Documents, setting out more detailed guidance at a more specific level. The JPTC is also required to prepare a number of further documents as part of the LDF process, including:

• Local Development Scheme (LDS) - 3 year project plan for the preparation of the LDF, it sets out key milestones in DPD and SPD production.

• Statement of Community Involvement (SCI) – outlines how the Council aims to involve local communities and stakeholders in the DPD and SPD preparation process (the SCI has been submitted to the Secretary of Sate for approval)

• Annual Monitoring Report (AMR) – this report will outline and monitor the progress made with the preparation of the LDF.

The JPTC have appointed Halcrow Group Ltd to undertake a Strategic Environmental Assessment (SEA) and Sustainability Appraisal (from here on referred to as SA) of all the emerging LDF LDDs. To ensure the integration of health issues into the SA, Ben Cave Associates are providing specialised health inputs. This Scoping Report comprises the first stage of the SA process. This Report is the overarching Scoping Report for the SA

of both the Core Strategy and the Growth Area DPDs. It is intended that this SA will provide a sustainability framework to be taken forward and used for undertaking SAs for future DPDs, SPDs and Area Action Plans.

In this Report the acronym SA is used to denote the SEA process as prescribed by the EC SEA Directive and UK Environmental Assessment of Plans and Programmes Regulations (2004), as well as including consideration of broad sustainability issues which would usually be considered in a SA, as set out in ODPM guidance1.

1.3 Background to SEA and SA Under The Act and the SEA Regulations2 which came into force in England and Wales in July 2004 SA and SEA are mandatory for Regional Spatial Strategies (RSS), DPDs and SPDs.

The Act requires SAs to be carried out on all DPDs and SPDs. SAs help planning authorities to fulfil the objective of contributing to the achievement of sustainable development in preparing their plans through a structured assessment of the objectives and policies against key sustainability issues for their area.

The Environmental Assessment of Plans and Programmes Regulations (2004) which implement European Directive 2001/42/EC, known as the Strategic Environmental Assessment (SEA) Directive, requires SEA of a wide range of plans and programmes, including LDFs. The objective of the SEA Directive is to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans, with a view to promoting sustainable development.

SEA and SA are very closely linked. SA aims to integrate sustainability issues into decision making by appraising the plan or strategy using environmental, social and economic objectives. SEA also aims to facilitate sustainable development but its emphasis is on integrating environmental considerations into decision making through a thorough analysis of environmental issues.

1 Sustainability Appraisal of Regional Spatial Strategy and Local Development Documents, ODPM 2005 2 The Environmental Assessment of Plans and Programmes Regulations 2004

Although the requirement to carry out both an SA and SEA is mandatory, it is possible to satisfy the requirements of both pieces of legislation through a single appraisal process. The Government has produced guidance for both undertaking SEA generally3 and for SA on Development Plan Documents4 in particular which sets out details of how SA and SEA should be integrated into one process. This SA therefore incorporates the requirements of the Planning and Compulsory Purchase Act and the SEA Regulations. Figure 1.1 illustrates the DPD preparation process and its relationship with the key SA tasks.

Figure 1.1: The DPD Preparation Process5

3 "A Practical Guide to the Strategy Environmental Assessment Directive" (ODPM, 2005) 4 Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents, ODPM, November 2005 5 Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents, ODPM, November 2005.

1.4 Health Impacts The SEA Directive is very important for health as it explicitly requires the consideration of the likely significant effects on population and human health. Health issues arising from the Luton and South Bedfordshire LDF are being looked at as part of this wider SA process. There is also a discrete objective on health and wellbeing within the overall SA Framework. We are not conducting an autonomous Health Impact Assessment.

1.5 Health and Sustainable Development Good health is a key condition to enable both economic growth and sustainable development.6 Longer, healthier, more productive human lives deliver concrete economic benefits. Similarly, economic growth and sustainable development have a crucial role in alleviating poverty and deprivation which are important influences on health and well-being. Good health in this sense is the very foundation of thriving modern societies and economies and needs to be defined in much broader terms than simply the prevention of illness.

There is increasing political commitment, internationally and domestically, to tackling inequalities in health.7 Many of the determinants of these inequalities are entrenched within the wider social structures such as the economy and labour market.

Improving human health is not solely about the provision and delivery of health services, but also about reducing social exclusion and enhancing access to good quality jobs and housing. Health issues need to be taken into account at all levels at the strategic level to the household and from the community to the individual.

Individuals must also assume responsibility for their health but it is the role of the Luton and South Bedfordshire LDF to create a framework within which individuals are able to make healthy choices.

1.6 Equality Impacts As part of the SA process a Sustainability Appraisal Framework has been prepared (refer to chapter 5 for further details) to appraise the emerging

6 David Byrne, European Commissioner for Health and Consumer Protection 7 Department of Health 1999; World Health Organization 2005

DPDs against a range of social (including equality issues), economic and environmental objectives and criteria. To ensure integration of equality issues specific equality objectives and criteria have been incorporated. The social criteria aim to ensure that the LDF does not discriminate against people on the basis of disability, race, gender, sexual orientation, age and religion/faith/belief. Equality issues arising from the Luton and South Bedfordshire LDF are therefore being integrated into the SA process.

Any equality issues identified by the SA process and ways to address them will be outlined in the Sustainability Report.

1.7 Purpose of this Scoping Report The SEA regulations require that the consultation bodies8 shall be consulted when deciding on the scope and level of detail of the information that must be included in the Sustainability Report – this being the main written output from the SA process. The consultation does not have to be in the form of a published Scoping Report. For this project a Scoping Report is considered the appropriate method of presenting the results of the initial stages of the SA process. It will also assist in helping to identify the issues relevant to stakeholders. The Scoping Report will be made available to others than those required by statute, so that the subsequent assessment can take account of issues raised from a wider spectrum of consultees. This will be particularly important when looking at the social and economic issues which fall outside the remits of the environmental bodies.

Specific questions have been asked in each section of the Scoping Report to aid responses, these are summarised in section 8.

This Scoping Report relates to Stage A of the process outlined in the latest ODPM guidance9. Future tasks relate to Stages B to E.

Stages and tasks

Stage A: Setting the context and objectives, establishing the baseline and deciding on the scope A1: Identifying other relevant plans, programmes and sustainability

8 Natural England, Environment Agency and English Heritage 9 Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents (ODPM, November 2005)

Stages and tasks

objectives

A2: Collecting baseline information

A3: Identifying sustainability issues and problems

A4: Developing the SA Framework

A5: Consulting on the scope of the SA

Stage B: Developing and refining options and assessing effects B1: Testing the DPD objectives against the SA framework

B2: Developing the DPD options

B3: Predicting the effects of the draft DPD

B4: Evaluating the effects the draft DPD

B5: Considering ways of mitigating adverse effects and maximising beneficial effects

B6: Proposing measures to monitor the significant effects of implementing the DPD

Stage C: Preparing the Sustainability Appraisal Report C1: Preparing SA Report

Stage D: Consulting on draft DPD and Sustainability Appraisal Report D1: Public participation on the SA Report and the draft DPD

D2: Assessing significant changes

Stage E: Monitoring the significant effects of implementing the DPD E1: Finalising aims and methods for monitoring

E2: Responding to adverse effects

1.8 Structure of this Report The report is structured in the following sections:

• Chapter 1: Sets out the context and purpose of the SA, considering the legal requirement for SEA and SA;

• Chapter 2: Outlines the relationship between other relevant plans and Programmes;

• Chapter 3: Presents a summary of the environmental baseline relevant to the DPDs;

• Chapter 4: Presents the environmental and sustainability issues and opportunities have been identified during the review;

• Chapter 5: Presents the proposed SA Framework that will be utilised in the subsequent assessment process;

• Chapter 6: Outlines the Scoping Report consultation procedures;

• Chapter 7: Outlines a proposed methodology for the remaining steps of the SA; and

• Chapter 8: Provides a summary of the questions for consultees that have been posed during the rest of the Scoping Report.

2 Stage A1- Identifying other relevant plans, programmes and sustainability objectives

2.1 Background The SEA Directive requires that the SA should provide information on the plan’s relationship with other relevant plans and programmes as defined in the SEA Directive:

The ‘Environmental Report’ required under the SEA Directive should include:

“An outline of the contents, main objectives of the plan or programme and relationship with other relevant plans and programmes” (Annex 1(a))

The context review must also make reference to environmental objectives set out in the plans, policies and programmes.

The ‘Environmental Report’ required under the SEA Directive should include:

“The environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme...” (Annex 1 (e))

2.2 Purpose The purpose of this task is to provide information on relevant plans and programmes and the sustainability objectives established at International/European, National, Regional or local level which are relevant to the Luton and South Bedfordshire LDF. A review of relevant policy documents is an essential component of setting the baseline. It also helps to establish the economic, social and environmental context for the Core Strategy DPD and the Growth Area DPD and other future DPDs and SPDs.

Together, plans can be constraints (i.e. set formal limitations, policy contexts, requirements) or can be sources of useful background information as part of evidence gathering. These act together in a hierarchy where a

sequence of precedence is established in a nesting, or tiering of plans. A review of relevant policy documents is required to establish environmental objectives that they contain, and this stage allows opportunities and synergies to be identified, as well as potential conflicts between aims, objectives or detailed policies. There is no definitive list of plans that must be reviewed, although the ODPM’s SA guidance suggests a number that will be commonly be reviewed in most SA’s. These and others which are deemed relevant to Luton and South Bedfordshire have been included in the review. Table 2.1 below lists all reviewed policies, plans and programmes.

Table 2.1: List of reviewed relevant Policies, Plans and Programmes International/ European European Sustainable Development Strategy (EDS), (European Union, 2001) Bonn Convention on the Conservation of Migratory Species of Wild Animals, (1979) Bern Convention on the Conservation of European Wildlife and Natural Habitats, (1979) The Convention on Biological Diversity, Rio de Janeiro (1992) Kyoto Protocol on Climate Change (UN, 1997) The UN Millennium Declaration and Millennium Development Goals (2002) World Summit on Sustainable Development - Earth Summit (2002) EU Directive on the Conservation of Wild Birds (79/409/EEC) EU Waste Framework Directive (91/156/EEC) EU Nitrates Directive (91/676/EEC) EU Habitats Directive (92/43/EEC) EU Directive on Ambient Air Quality and Management (1996/62/EC) European Spatial Development Perspective (ESDP), EU Ministers for Spatial Planning, (1999) EU Waste to Landfill Directive (99/31/EC) EU Council Directive on Environmental Noise, 2002/49/EC, ( EC, 2002) EU Directive Establishing a Framework for the Community Action in the Field of Water Policy (2000/60/EC) – The Water Framework Directive European Commission White Paper on the European Transport Policy (EC, 2001) EU Sustainable Development Strategy, EU, (2001) Arhus Convention (2001) EU Directive to promote Electricity from Renewable Energy (2001/77/EEC) Environment 2010: Our Future, Our Choice - EU Sixth Environment Action Programme (2002) EU Directive for the Promotion of Bio-fuels for Transport (2003/30/EC) European Biodiversity Strategy, European Commission, (1998) EC Council Directive on the Conservation of Habitats and of Wild Fauna and Flora 92/43/EEC EU Council Directive on Environmental Noise, 2002/49/EC, EC, (2002) EU Sixth Environmental Action Programme, EU, (2001) Water Framework Directive, EU, (2000)

National Wildlife and Countryside Act 1981 (as amended) Choosing Health: Making Healthier Choices Easier, (Department of Health, 2004) ‘Working with the Grain of Nature’: A Biodiversity Strategy for England (2002) Biodiversity Strategy for England, Central Government, (2002) UK Biodiversity Action Plan - UK BAP (Defra, 1994) England Forestry Strategy (1999) The Air Quality Strategy for England, Scotland, Wales and Northern Ireland: Addendum, Defra, (2003) UK Air Quality Strategy (ODPM, 2000) Countryside and Rights of Way Act – CRoW (ODPM, 2000) Government Urban White Paper: Our Towns, Our Cities, the Future. Delivering an urban renaissance (DETR, 2000) UK Waste Strategy (2000) Government Rural White Paper: Our Countryside, the future – A deal for rural England (DETR, 2000) UK Climate Change Programme (2006) The Historic Environment: A Force for Our Future (2001) UK Fuel Poverty Strategy (2001) Our Energy Future - Creating a Low Carbon Economy' - UK white paper on energy (2003) The Future of Transport – UK white paper on transport (2004) UK Climate Change Programme Review: Consultation (Defra, 2004) England Rural Strategy (2004) Choosing Health: making Healthier Choices Easier – Health White Paper (2004) Securing the Future – Delivering UK Sustainable Development Strategy, Central Government, (2005) PPS1 – Delivering Sustainable Development, ODPM, (2005) Planning Policy Statement: Planning and Climate Change, Supplement to PPS1, Consultation Document, Communities and Local Government, (13th December 2006- 8th March 2007) PPG2 – Green Belts, (1995) PPS3 – Housing, (2006) PPG4 – Industrial and Commercial Development and Small Firms, ODPM, (1992) PPS6 – Planning for Town Centres, ODPM, (2005) PPS7 – Sustainable Development in Rural Areas, ODPM, (2004) PPG8 – Telecommunications, ODPM, (2001) PPS9 – Biodiversity and Geological Conservation, ODPM, (2005) PPS10 – Planning for Sustainable Waste Management, ODPM, (2005) PPS 12 – Local Development Frameworks, (2004) PPG13 – Transport, ODPM, (2001) PPG14 – Development on Unstable Land, ODPM, (1990) PPG15 – Planning and the Historic Environment, ODPM, (1994) PPG16 – Archaeology and Planning, ODPM, (1990) PPG17 – Planning for Open Space, Sport and Recreation, ODPM, (1991) PPG19 - Outdoor advertisement control, ODPM, (1992) Good Practice Guide on Planning for Tourism, DCLG, July 2006 PPS22 – Renewable Energy, ODPM, (2004) PPS23 – Planning and Pollution Control, ODPM, (2004) PPG24 – Planning and Noise, ODPM, (1994)

PPS25 – Development and Flood Risk, Communities and Local Government, 2006 Building a Greener Future: Towards Zero Carbon Development, Consultation Document, Communities and Local Government (2006) Sustainable Communities Plan (February 2003) Regional Milton Keynes and South Midlands Sub Regional Strategy, (2005) The Draft East of England Plan (December 2004) The Draft East of England Plan Examination in Public Panel Report (June 2006) Sustainable Development Framework for the East of England (2001) Sustainable Communities: Building for the Future - Communities Plan (2003) Our Environment, Our Future – The Regional Environmental Strategy for the East of England (2003) Regional Transport Strategy for the East of England (draft published in 2004 as part of the East of England Plan) Regional Social Strategy: A strategy to achieve a fair and inclusive society in the East of England (launched in May 2004) A Shared Vision: The regional economic strategy of the East of England (formally released on 1 December 2004) Regional Planning Guidance for the South East (March 2001 Sustainable Futures: The Integrated Regional Strategy for the East of England (2005) Revised Regional Housing Strategy for the East of England 2005-2010 (2005) Creating Sustainable Communities in the East of England (2005) Towns and Cities – Strategy and Action Plan: Urban Renaissance in the East of England A Housing Strategy for the London Commuter Belt Sub-Region 2005-2008 County Bedfordshire Structure Plan 2011, (1997) Bedfordshire’s Community Strategy 2003 – 2013, (2003) Bedfordshire Local Transport Plan 2006/7 – 2010/11 The Bedfordshire and Luton Minerals and Waste Local Plan, (2005) Local South Bedfordshire Local Plan Review, (January 2004) Luton Local Plan 2001-11, (March 2006) Luton and South Beds Retail Study, (2005) Luton’s Community Plan 2002-2012, (2005) Draft Joint Statement of Community Involvement, (June 2006) ‘A better quality of life in South Bedfordshire’: South Bedfordshire’s Community Plan, (2001) Luton, Dunstable and Houghton Regis Local Transport Plan 2006-2011 Luton Parking Strategy, (July 2003) Luton Walking Strategy, (July 2003) Luton Cycling Strategy, (2006) Luton School Travel Plan Strategy 2006-2008, (2005) Luton Provisional Bus Strategy, (2006) Luton Regeneration Strategy, (2004) Bedfordshire and Luton Biodiversity Action Plan, (2001) Luton Borough Council’s Draft Environmental Strategy: Looking after our environment, (2005) South Bedfordshire’s 2003 Housing Strategy South Bedfordshire’s Environmental Statement, 2006

This section provides a summary of the key issues and messages arising from the review of the plans, policies and programmes and is set out according to SEA and SA Topics as identified in the SEA Directive and ODPM guidance. Table 2.1 illustrates the relationship between the SEA Directive and SA topics.

Table 2.1: The relationship between the SEA Directive and SA topics.

SEA Directive Topic Sustainability Appraisal Topic10

Biodiversity, fauna & flora Biodiversity Landscape Landscape, townscape and archaeology Water Land and Water resources Population - Air - Human Health Healthy Communities Soil - Climatic Factors Climate Change and Pollution Cultural Heritage Landscape, townscape and archaeology Material Assets - - Inclusive Communities - Economic Activity

The complete Policies, Plans and Programmes review is shown in Appendix A of this report. The review in Appendix A outlines the relevant sustainability objectives of the plan, programme or sustainability objective followed by a column summarising the implications of these sustainability objectives on the SA and the LDF. The Policy matrix has been designed so it can be up-dated over the life cycle of the LDF.

2.3 Economic Factors The UK Government’s approach to sustainable development recognises that a better quality of life for all includes economic growth and employment as well as more widely available goods and services. This requires the creation of a stable and competitive economy. Over the past three

10 Sustainability Appraisal topic as set out in the ODPM’s draft guidance on the Sustainability Appraisal of Regional Spatial Strategies and Local Development Frameworks, September 2004.

decades, UK output and inflation has been highly volatile. Economic instability has significant costs, making it difficult for individuals and firms to plan and invest, with damaging effects on long-term economic growth. It involves social costs that often fall heavily on people on lower incomes. The sensible response to this kind of economic uncertainty and turbulence is an emphasis on resilience - that is, on enabling the economy to cope with a range of possible shocks and changes. Economic resilience entails maintaining portfolios of diverse options and solutions rather than aiming for a single optimum, and maintaining the capacity of smaller and simpler subsystems to perform basic tasks if larger and more complex systems fail.

Tourism has been and increasingly will be an important component of the local economy. The Good Practice Guide on Planning for Tourism, DCLG outlines the economic significance of tourism along with its potential environmental impacts. The combination of these two factors makes it an important consideration for all DPDs.

The LDF Core Strategy should include measures which ensure the ability to satisfy all basic needs with minimum dependence on single economic sectors. This entails, ensuring economic diversity, promoting sites for small and local businesses and enhancing capacity for local sufficiency, including food sufficiency.

A further key objective from the review is to promote creativity, innovation and enterprise but without compromising environmental objectives. Economic growth and a high quality environment go hand in hand and the growth of the economy is not an end in itself, but rather leads to a better quality of life and the chance to appreciate the environment around us. Therefore the challenge is not to tackle economic growth and improved environment in isolation, but to integrate the two.

2.4 Social Factors The review underlines the fact that a sense of community is essential for the wellbeing and quality of life of existing and future residents of South Bedfordshire and Luton. Social inclusiveness includes the provision of decent, affordable housing. Shelter is a basic human need and the quality, range and affordability of housing within Luton and South Bedfordshire can foster a sense of place and help ensure a mixed and balanced community. Forthcoming DPDs should provide details of the mix of housing types and

tenures to be provided, ensuring that the proposed mix is appropriate and affordable.

2.4.1 Accessibility Basic facilities are an important part of our communities. They provide essential services such as food and medical provisions. They contribute to the sense of place in communities and provide a focal point for community interactions and social cohesion and also provide employment, often for locally based people. Limiting access and availability to these services can make people feel socially excluded, isolated and reduce interactions in the community.

2.4.2 Education Improving educational achievement, the overall skills base, access to learning opportunities across Luton and South Bedfordshire should be a key objective of the LDF.

2.5 Water Issues such as delivery of adequate water supply, measures to reduce water consumption, wastewater treatment and the need to reduce run off rates from development need to be given specific consideration as part of all DPDs and subsequent Area Action Plans.

Water supply is a critical issue affecting the sustainability of future development. The detailed design stage of future Area Action Plans should clearly address how measures to reduce per capita water usage will be integrated into design (through provision of water buts, retrofitting of grey water recycling). If this is not proactively addressed at this stage, there is a risk that it will be overlooked in the future.

2.6 Biodiversity The main themes coming out from the review with regard to the environment are for the protection, enhancement and improved access of the natural environment. This can be done through a variety of means but the main driver is through sustainable development.

It is recognised that sustainable patterns of development can assist in protecting the environment through reducing the need to travel, by the

careful location of different land uses. Reducing the need to travel cuts the number of trips made by private car and hence vehicle emissions.

The respective Local Plans highlight the need to conserve and enhance biodiversity and the natural environment. An improved environment leads to increased vitality and viability in town and neighbourhood centres and links to an improved economy, better health and reduced social exclusion.

2.7 Air Quality One of the key aims of the Government with regard to improving air quality is to promote more sustainable modes of transport for people and freight and to ensure that jobs, shopping, leisure facilities and services are accessible by public transport, walking, and cycling, thus reducing the need to travel by the use of the private car.

In particular, initiatives to promote modal switch and the necessary public transport measures should be included as part of DPD preparation.

2.8 Soil Besides the ‘big’ environmental issues, such as climate change and loss of biodiversity, impacts on soil seem often to have a lower priority. This is despite the fact that soil is the foundation of the environment, landscape, wildlife and food production. Soil loss is likely to be a pertinent issue given the anticipated levels of greenfield development within Luton and South Bedfordshire. Protecting soil resources should be a key consideration within the LDF. Future detailed mitigation must ensure soil re-use.

2.9 Climatic Factors Ensuring that new development addresses climate change is a critical issue which needs to be addressed in the LDF Core Strategy and in Area Action Plans. Consideration should be given to the inclusion of creative solutions for managing extreme weather events.

The LDF should promote the use of renewable energy and encourage the implementation of methods that will enable individuals to save energy, use more renewable energy and promote the use of cleaner energy.

2.10 Population Population primarily relates to demographics, about which there are very few specific plans, policies or strategies. However, many other types of plans and policies will have secondary impacts on the population, e.g. housing strategy policies on accommodation for the elderly. Therefore, when taking into account effects on the SA topic of ‘population’, cross reference will be made to plans covered within plans and policies relating to housing, education, social deprivation, crime (safety), recreation, leisure and sports.

2.11 Human Health The planning process can significantly affect and be affected by the health of the population of the area. An unhealthy population may place increasing demands on the requirement for services and resources (such as doctor’s surgeries) whilst the provision of the infrastructure to support healthy lifestyles can be encouraged by the provision of public open space or leisure facilities.

Objectives regarding human health are embodied at the highest tiers of plan making, indeed the EU Sustainable Development Strategy (2001) include, ‘Address threats to public health’, amongst its headline objectives.

At a national level this is tackled through a number of documents, including PPG17 ‘Planning for Open Space, Sport, and Recreation’, which recognises the health and wellbeing value of recreational and open spaces, and PPG13 ‘Transport’, which aims to encourage walking and cycling. However, the primary document relating to human health at this level is the Government Health White Paper – ‘Choosing Health: making Healthier Choices Easier’. This document contains a number of priorities which should be taken into account by the SA, in particular those relating to ‘increasing exercise’. Our Health Our Care Our Say is a recent Department of Health White Paper that directs Health and social care services to provide better prevention services with earlier intervention, give people more choice and a louder voice, do more on tackling inequalities and improving access to community services, and provides more support for people with long-term needs.

2.11.1 Healthcare Health is a universal basic human need. High levels of public health lead to fitter, happier and healthier people. Health services are nationally high on citizens’ list of political priorities. Other benefits include employment provision and contribution to the local economy, training and research opportunities, reduced burden on social services and public finances. Addressing the effects to public health, and, dealing with the social and economic implications of an ageing society, are both key objectives of the EU Sustainable Development Strategy (2001), and will both have implications on future healthcare provision.

2.11.2 Recreation, Sport and Leisure The way in which green spaces are treated within land-use development documents are vital to an areas recreation, leisure and sports capacity. National guidance exists in the form of PPG17 ‘Planning for Open Space, Sport, and Recreation’. This guidance acknowledges that the recreational quality of open spaces can be eroded by insensitive development, and therefore local authorities should weigh up any benefits being offered to the community against the loss of open space that will occur (and the benefits that it too provides to the local community).

In general, all plans and policies that relate to the improving of human health through exercise are relevant to this section. This strong link between recreation/sport and health is illustrated within the Health White Paper (2004), Choosing Health: making Healthier Choices Easier, with one of its priorities being ‘increasing exercise’.

2.11.3 Noise There are a number of EU Directives in place which control noise from transport sources, for example from vehicles and outdoor machinery. EU Directive 2002/49/EC relating to the assessment and management of environmental noise – the Environmental Noise Directive – is the latest piece of European legislation. Its aim is to define a common approach across the European Union to avoid, prevent or reduce the harmful effects of environmental noise from road, rail and air traffic and industry. By 2007 strategic noise maps have to be prepared and by 2008 action plans have to be developed for how to reduce environmental noise where necessary. In a national context, PPG 24 ‘Noise’ sets out how the planning system can be used to minimise the adverse impacts of noise and PPG 13 ‘Transport’

aims to reduce the need for travel, possibly leading to a reduction of noise from transport.

2.12 Material Assets Good design and efficient use of land are the key themes in relation to material assets. Good design can help promote sustainable development which has positive knock on effects for the environment, the economy and health and social issues. It can attract new business to Luton and South Bedfordshire as well as improving the quality of the existing environment and reinforcing civic pride.

With regard to design of buildings the main themes are for innovation and creativity in order for new development to compliment the existing environment. Mixed development is encouraged and in particular, flexible floorspace that can easily have its use changed in the future according to market and economic demands. Mixed- use development will enable facilities to be reached on foot or by bicycle and thus reduce the number of car journeys made.

2.13 Cultural Heritage The key objective relating to heritage is to reconcile the need for economic growth with the need to protect the historic environment.

The European Spatial Development Perspective aims for balanced and sustainable development in the European Union. As part of that the conservation and management of natural resources, cultural heritage is set out as one of three fundamental goals. In the UK, ‘The Historic Environment: A force for our future’ states the intention of the government to protect the historic environment and recognises its major contribution to the rural economy, where as PPG15 ‘Planning and the Historic Environment’ and PPG16 ‘Archaeology and Planning’ set out specific guidance on how the planning system can foster the conservation of historic environmental and cultural heritage.

2.14 Landscape and Townscape The key objective is to conserve and enhance the character, quality and value of the landscape and townscape, ensuring new development within the urban areas, around the urban edge, or in the countryside is located and designed to ensure it does not have significant adverse impacts,

particularly on designated and other sensitive landscapes and townscapes and positively contributes to local character and distinctiveness.

Landscape character contributes to the quality of place at the regional, county and local levels. New development should be sympathetic to and guided by the character of traditional development in the vicinity. Development should also reflect local character in the use of building materials, the relationship of buildings to one another and to the surrounding landscape.

Consultation question Q1: Are there any other policies, plans or programmes (PPPs) that contain environmental protection objectives or identify issues that have not been covered?

3 Stage A2- Collecting Baseline Information

3.1 Background The SEA Directive requires a significant level of understanding of the baseline environment. The baseline information informs both the evolving DPDs and future stages of the SA. As defined in the SEA Directive:

The SEA Directive requires the Environmental Report to include:

“ the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme”

“ the environmental characteristics of areas likely to be significantly affected”

(Annex 1 (b) and (c))

Establishing the economic, social and environmental baseline characteristics of Luton and South Bedfordshire provides the basis for establishing the following:

• An understanding of existing sustainability problems and the key environmental, social and economic characteristics and issues of Luton and South Bedfordshire;

• Feeding back into the SA objectives to reduce these problems;

• To enable the prediction of likely future effects of the DPDs and other SPDs; and

• Highlights how Luton and South Bedfordshire compare to regional and national trends.

The Scoping Report should not be considered as a full Environmental Baseline Report for Luton and South Bedfordshire. The baseline section offers a broad strategic overview of Luton and South Bedfordshire to highlight the key issues which could be addressed through development plan preparation.

3.2 Collection Methodology Baseline data was typically supplied in three formats:

• GIS or other statistically displayed formats provided by for example Environment Agency and Natural England;

• Numeric or statistical format – largely downloaded from government or agency websites e.g. http://www.statistics.gov.uk and

• Report format e.g. Annual Monitoring Reports.

In order to focus the baseline data collection stage, a number of principles were considered:

(a) Relevance – is the data helpful for undertaking the SA of the DPDs? (b) Current – is the baseline up to date? (c) Accessibility – is the data easily accessible? (d) Interpretation – is it easy to understand the data?

If data did not fall within the principles listed above, it was omitted from the baseline review.

3.3 Baseline Analysis This section outlines the key issues arising from the baseline analysis and is set out under the SEA and SA topics. Where practical for ease of understanding and clarity the data has been presented in diagrammatic format.

3.4 Economic Factors Luton and South Bedfordshire has an increasingly diverse economy largely as a result of job losses in the manufacturing sector, including the end of Vauxhall car production in Luton and other closures such as Trico and Hertz BTR in Dunstable. The unemployment rate for the working age population varies significantly across Luton and South Bedfordshire. The average unemployment rate between 2005 and 2006 in Luton was 7.3%. This is above the regional (4%) and national averages (5%). South Bedfordshire’s unemployment rate (4.1%) is below the national average but slightly higher than the regional average.

Table 3.1 suggests that economic rates amongst the working age population in Luton are currently worse than the regional and national

average. Economic rates in South Bedfordshire are slightly above regional and national averages.

Table 3.1: Economic Activity11 (2005-2006)12

Luton (%) South East of Great Bedfordshi England Britain (%) re (%) (%) Economically active 73.3 81.1 80.9 78.3 In employment 67.7 78 77.6 74.3 Employees 58.7 68.6 66.8 64.6 Self employed 8.5 8.9 10.5 9.2 Unemployed 7.3 4.1 4 5

3.4.1 Unemployment Claimant Count13 The unemployment claimant count for Luton in September 2004 was 2.8%, when for England the average was 2.2%. The unemployment claimant count for South Bedfordshire for September 2004 was 1.4%, which is below regional (1.6%) and national averages.

Table 3.2: Claimant Count, 200414

Luton South East of England Bedfords England hire Claimant Count (%) 2.8 1.4 1.6 2.2 Claimant Count rate of 3.22 3.52 4.45 4.89 those aged between 18-24 and claiming for more than 6months (%)

As illustrated in Figure 3.1 there has been a declining trend of unemployment claimant count within Luton and South Bedfordshire between 1996 and 2003.

11 People aged 16 and over who are either in employment or unemployed 12 NOMIS, cited November 2006: http://www.nomisweb.co.uk/reports/lmp/la/2038431745/report.aspx

13 The proportion of people declaring themselves as ‘out of work, capable of, available for and actively seeking work during the week 14 National Statistics website, cited November 2006, “How exactly is unemployment measured?”, 2006, http://www.statistics.gov.uk/downloads/theme_labour/unemployment.pdf and http://neighbourhood.statistics.gov.uk/dissemination/LeadTableView.do?a=7&b=276882&c=South+Bedfordshire&d=13& e=15&g=423906&i=1001x1003x1006&k=employment&m=0&enc=1&domainId=46&dsFamilyId=799

Figure 3.1: Claimant Count Unemployment Rates, December 1996- 200315

3.4.2 Registered Businesses VAT registrations and de-registrations are the best official guide to the pattern of business start-ups, closures and to the general health of the economy. The number of VAT registered businesses in Luton and South Bedfordshire is higher than regional, national averages and above the number of de-registrations. However the number of de-registrations is slightly above regional and national averages.

Table 3.3: VAT Registered businesses (2005)16

Luton (%) South Bedfordshire(%) East of England (%) Great Britain(%) Registrations 10.4 10.5 9.5 9.7 Deregistrations 8.8 8.3 7.8 8.3

15 ONS, cited in Luton/ Dunstable/Houghton Regis, Economic Development Vision & Implementation Study, Draft Final Report, GHK, 2004

16 NOMIS: http://www.nomisweb.co.uk/reports/lmp/la/2038431748/report.aspx

3.4.3 Employee Jobs by Sector Table 3.4 illustrates the strong distribution, transport and communications base within Luton and South Bedfordshire. In 2004 approximately 8,000 people were employed within the London Luton Airport campus boundary and a further 2,50017 employed due to the airport’s presence and this figure is expected to grow inline with airport expansion.

The public and financial services sectors also provide a significant and growing proportion within Luton and South Bedfordshire. These two sectors have achieved healthy growth rates in Luton and South Bedfordshire between 1998 and 2005. The recent growth in the service sector has helped reduce the impact of manufacturing losses within Luton and South Bedfordshire. Energy and Water and construction which in 2005 provided 178 and 5,094 jobs respectively, have also declined in Luton and South Bedfordshire between 1998 and 2005.

Table 3.4: Actual employment figures for Luton and South Bedfordshire from 1998 to 200518

Industry 1998 1999 2000 2001 2002 2003 2004 2005 Agriculture & fishing (SIC A,B) 85 78 87 87 85 94 85 85 Energy and water (SIC C,E) 357 261 256 211 197 161 162 178 Manufacturing (SIC D) 28,739 25,745 24,540 24,257 20,261 19,006 17,510 15,457 Construction (SIC F) 6,451 5,019 3,544 4,794 5,226 4,612 4,605 5,094 Distribution, hotels and 32,122 28,051 28,803 31,044 30,768 30,152 33,466 31,485 restaurants (SIC G,H) Transport & communications 10,234 11,924 11,667 13,157 10,754 11,719 12,602 12,941 (SIC I) Banking, finance & insurance, 19,418 22,069 22,994 21,483 24,610 26,727 27,171 29,354 etc (SIC J,K) Public administration, education 19,201 19,329 25,295 23,594 23,961 25,496 25,861 28,533 & health (SIC L,M,N) Other services (SIC O,P,Q) 4,301 4,442 4,270 5,001 5,308 5,547 5,255 5,477 Total 120,908 116,918 121,456 123,628 121,170 123,514 126,717 128,604

17 The Joint Economic Development Strategy for Bedfordshire and Luton, 2005 18 Annual Business Inquiry, NOMIS, ONS

3.4.4 Job Seekers Allowance The numbers of people claiming jobseekers allowance (JSA) varies across Luton and South Bedfordshire. Within Luton 3.4% of the population who are available for work are claiming JSA, which is above the regional (1.9%) and national averages (2.5%). 1.6% of South Bedfordshire’s population who are available for work are claiming JSA.

3.4.5 Earnings Average Gross Weekly Pay (AGWP) varies across Luton and South Bedfordshire. AGWP per person in Luton stands at £430.30, which is below the regional and national averages. AGWP in South Bedfordshire is £510.30 which is significantly higher than Luton, regional and national averages.

Table 3.5: Gross Weekly pay (2006)19 South East of Luton Bedfordshire England England Gross pay per week (£) 430.3 510.3 470 449.6

3.5 Social Factors The remit of this topic is broad and considers the role that the LDF can have on improving the overall well being and quality of life of existing and future residents of Luton and South Bedfordshire. Issues of social cohesion and equality are considered important in encouraging community togetherness. This could be achieved by providing access to housing, services and other opportunities and understanding the need of particular social groups and maximising their level of involvement in various community activities.

3.5.1 Housing Results from the 2001 census showed that there were 116,420 households in Luton and South Bedfordshire. Under the emerging Draft RSS housing requirements the number of households in Luton and South Bedfordshire will rise by approximately 23% by 2021 and a further 13% approximately by 2031.

19 NOMIS, http://www.nomisweb.co.uk/reports/lmp/la/2038431748/report.aspx

Table 3.6: Household Numbers (2001)20

South Luton Bedfordshire East of England England All Households 70,755 45,665 2,231,974 20,451,427

3.5.2 House Prices Average house prices within Luton and South Bedfordshire fall below the UK average21 (£211,452). The average house price in Luton is £193,746 compared to £158,820 in South Bedfordshire. Luton has experienced a significant rise in house prices in the last year, with an increase of 6.8%. Conversely to this, the house prices in South Bedfordshire fell by 1.1% in the same period.

Table 3.7 below illustrates the house price to average earnings (based on gross household earnings and mean house prices for two and three- bedroom dwellings). High ratios of house prices to income makes houses less affordable for first time-buyers. The figures recorded in Table 3.7 below show that Luton and South Bedfordshire has ratios below the regional and national averages, making it a relatively affordable place to live. 22

Table 3.7: House Price to Income Ratio23

South Bedfords East of Luton hire England England House Price to income ratio 4.09 3.98 4.27 4.11 Number of working households 22,839 15,164 572,729 5,002,470

20 National Statistics: http://neighbourhood.statistics.gov.uk/dissemination/LeadTableView.do?a=7&b=276843&c=Luton&d=13&e=15&g=4049 78&i=1001x1003x1006&k=illness&m=0&enc=1&domainId=15&dsFamilyId=57 21 BBC News, cited Nov 2006, http://www.newsbbc.co.uk/ 22 JRF website, cited Nov 2006, http://www.jrf.org.uk/knowledge/findings/housing/024.asp

23 Joseph Rowntree Foundation, http://www.jrf.org.uk/knowledge/findings/housing/024.asp

3.5.3 Owner Occupancy The owner occupation levels in Luton and South Bedfordshire are lower than regional and national averages. However the number of people who own their property with a mortgage in Luton and South Bedfordshire is higher than regional and national averages. In addition, there is a slightly higher proportion of social rented accommodation across Luton and South Bedfordshire compared to the regional and national average.

Table 3.8: Housing Tenure (2001)24

South East of Bedfords England England Luton (%) hire (%) (%) (%)

Owned outright 24.02 28.35 30.67 29.19 Owned with a mortgage or loan 46.26 49.22 41.53 38.88 Shared ownership 0.54 0.65 0.51 0.65 Rented from council 12.59 11.62 11.61 13.21 Rented from Housing Association 3.84 2.97 4.91 6.05

Rented from agency or landlord 10.56 5.01 7.57 8.8 Other 2.2 2.17 3.2 3.22

Luton and South Bedfordshire both rate well in relation to the number of Local Authority homes that are non-decent at the start of 2002. 8% for South Bedfordshire and 19% for Luton, which are both significantly below the national average (34.9%)25.

24 National Statistics: http://neighbourhood.statistics.gov.uk/dissemination/LeadTableView.do?a=7&b=276843&c=Luton&d=13&e=15&g=4049 78&i=1001x1003x1004&m=0&enc=1&dsFamilyId=53 25 BVPI, cited November 2006, http://www.bvpi.gov.uk/pages/keyFacts_BVPI.asp?lastpage=1&aid=394

3.5.4 Affordable Housing The provision of affordable housing is an important issue. There is a significant shortfall between the need for affordable housing and the amount being built. Ensuring everyone has a decent home is a national priority and delivering affordable housing is an important part of this. The provision of affordable housing across Luton and South Bedfordshire is a major issue; the problem is particularly acute in the rural areas and within Luton.

The results of Housing Requirements Study’s undertaken by both Luton Borough Council and South Bedfordshire District Council in 2006 and 2005 respectively show that there is an annual need for 1480 affordable homes across Luton and South Bedfordshire.

3.5.5 Deprivation Deprivation varies across Luton and South Bedfordshire with South Bedfordshire ranking 253rd and Luton 101st out of 354 local authority areas in England on the 2004 Index of Multiple Deprivation (a rank of 1 being the most deprived).

3.5.6 Crime Within the UK as a whole, burglaries and vehicle crime have dropped over the last two years, although racial crime rose. Within Luton and South Bedfordshire the BPVI data indicates that burglaries and racial crime has dropped but is still above the regional and national averages and vehicle crime rose.

Table 3.9: Crime Rates26

South South Luton Luton Beds Beds UK 2003-04 2005-06 2003-04 2005-06 2003-04 UK 2005-06 Number of burglaries per 1000 households 26.1 22.6 13.2 10.9 11.6 10.8

Number of vehicle crimes per 1000 population 19.6 21.4 13 14.6 12 11.5 Number of recorded racial incidents per 100,000 population 200.9 152.2 0.9 0.9 34 36.6

3.5.7 Education Attainment levels at school are key indicators of understanding the aspirations of an area’s future workforce. Education attainment levels vary across Luton and South Bedfordshire. Table 3.10 highlights that Luton performs below the regional and national averages in all recorded NVQ levels however South Bedfordshire achieves qualifications that are higher than the national and regional averages. The table also indicates the significantly higher than average proportion of people of a working age in Luton having no qualifications compared to regional and national averages.

Table 3.10: Qualifications (2005)27

Luton South East of Great (%) Bedfordshire (%) England (%) Britain (%) NVQ4 or higher 20.3 26.7 24.8 26.5 NVQ3 or higher 38.6 46.6 42.4 44.4 NVQ2 or higher 55.6 69.1 62.6 62.9 NVQ1 or higher 70.9 87.1 78.9 77.2 Other Qualification 10.7 5.5 7.8 8.4 No Qualification 18.4 7.4 13.2 14.3

26 BVPI, http://www.bvpi.gov.uk/pages/keyFacts_BVPI.asp?lastpage=1&aid=394

27 NOMIS, http://www.nomisweb.co.uk/reports/lmp/la/2038431745/report.aspx

3.5.8 Recreation, Sport and Leisure Luton and South Bedfordshire has a wide and varied selection of recreational and leisure facilities. With a total of 11 leisure and sport centres- 8 within Luton28 and 3 in South Bedfordshire29.

3.5.9 Open Space Provision There are open space accessibility issues across Luton and South Bedfordshire. The 2005 Open Space Study for South Bedfordshire concluded that the District is well served by public open space but there is a shortage of open space in Luton.30

The JPTC have commissioned consultants to undertake a Green Space Strategy (GSS) for Luton and South Bedfordshire. The outcomes of the GSS will feed into the SA, the Core Strategy and Growth Area DPDs as it is prepared.

3.6 Water Water is an essential natural resource and water quality is a key indicator of the overall health of the environment. There are direct links between water quality, water supply and flooding and increased demand for water for domestic purposes, industry and agriculture has direct impacts on the health of rivers and the aquatic environment.

3.6.1 Water Quality Defra’s Biological Report and Chemistry Report are a result of river quality surveys adopted throughout the UK. For the purposes of this report, data on chemical and biological quality of rivers have been collected. There is no data available for phosphate or nitrate.

In general, chemical water quality in Luton and South Bedfordshire between 1995 and 2005 has declined. There appears to be no obvious trend regarding biological water quality for Luton and South Bedfordshire. Biological water quality in South Bedfordshire has declined but improved in Luton.

28 Luton Borough Council Website, Cited November 2006, http://www.luton.gov.uk/internet/references/A_Z/S/Sports_facilities 29 South Bedfordshire District Council, Cited November 2006, http://www.southbeds.gov.uk/lgcl-leisure-and- culture/sports/facilities.html 30 The Environment and Non-Executive functions scrutiny Committee, 20th January 2005.

Table 3.11: Chemical Water Quality31

1995 2000 2005 %Good %Fair %Poor %Bad %Good %Fair %Poor %Bad %Good %Fair %Poor %Bad Luton 66.94 33.06 0.00 0.00 8.13 0.00 91.87 0.00 8.13 0.00 91.87 0.00 South Bedford shire 0.00 100.00 0.00 0.00 8.13 0.00 91.87 0.00 8.13 0.00 91.87 0.00 East of Englan 39.747.312.80.245.846.96.90.4----

Table 3.12: Biological Water Quality32

1995 2000 2005 %Good %Fair %Poor %Bad %Good %Fair %Poor %Bad %Good %Fair %Poor %Bad Luton 0.00 8.13 91.87 0.00 0.00 100.00 0.00 0.00 0.00 100.00 0.00 0.00 South Bedfords hire 7.97 92.03 0.00 0.00 90.81 9.19 0.00 0.00 75.68 24.32 0.00 0.00 East of England 71 27.9 0.9 0.2 80.9 18.1 0.9 0.1 - - - -

3.6.2 Flood risk The Environment Agency Flood Risk areas show that areas within Luton and South Bedfordshire (Figure 3.1) -particularly close to Leighton Linslade/Buzzard and Houghton Regis are at risk from flooding. Besides risk of natural flooding, impermeable surfaces created during development might increase the rate and volume of surface run off and cause flooding. These potential sources of flooding will have implications for the way that development is undertaken and will affect locations for development, ground floor levels and uses and drainage design.

A Strategic Flood Risk Assessment (SFRA) for Luton and South Bedfordshire is due to be completed shortly which will provide further guidance.

31 Defra, http://www2.defra.gov.uk/db/rq/rqdata/rq2005EastofEngland.xls 32 Defra, http://www2.defra.gov.uk/db/rq/rqdata/rq2005EastofEngland.xls

Definition of Flood Zones (refer to Flood Risk Map for areas at risk)

PPS25 defines the Flood Risk Zones as :-

Zone 1 - Low Probability - Land assessed as having a less than 1 in 1000 chance of river or sea flooding any year (<0.1%AEP)

Zone 2 - Medium Probability - Land assessed as having between a 1 in 100 and 1 in 1000 chance of river flooding (1% - 0.1%) and between a 1 in 200 and 1 in 1000 chance of sea flooding (0.5% - 0.1%) in any year

Zone 3 - High Probability - Land assessed as having a 1 in 100 or greater chance of river flooding (>1%) and a 1 in 200 or greater chance of flooding from the sea (>0.5%) in any year

Zone 3b - Functional Floodplain - Land where water has to flow or be sorted in times of flood

3.6.3 Trends The Chemical river water quality in Luton has definitely improved since 2000. There has also been an improvement in the Biological quality of river water in Luton over the years; however the change has not been as significant as with Chemical water quality.

South Bedfordshire’s Chemical River water quality is better than Luton’s and it has consistently improved over the last ten years, however it’s biological quality has declined.

3.7 Biodiversity Luton and South Bedfordshire include a range of very important chalk grassland, heathland, ancient woodland and wetland habitats and various nationally important /protected species e.g. water voles, skylarks, dormouse etc. However many of the habitat areas are small and scattered, or poorly managed and wildlife corridors such as hedgerows, road verges, water-courses in many areas have been lost or degraded. The growth agenda offers important opportunities to enhance biodiversity by creation of a network of accessible, multifunctional spaces and the better management of existing spaces.

Figures 3.2 and 3.3 highlight areas within Luton and South Bedfordshire that are rich in biodiversity. 18 Sites of Special Scientific Interest (SSSIs) can be found in Luton and South Bedfordshire (set out in Table 3.13). In

addition the area contains 90 County Wildlife Sites. The location of these sites are shown in Figure 3.4.

Natural England maintains statistics on the condition of all SSSIs in the country, and they have a Public Service Agreement target to have 95% of the SSSI area in “favourable” or “unfavourable recovering” condition by 2010. As illustrated in Table 3.1333 all the SSSIs within Luton and South Bedfordshire are in favourable or unfavourable recovering condition apart from Totternhoe Chalk Quarry which is in unfavourable declining condition and there is no data available for Houghton Regis Quarry.

English Nature (English Nature as was at the time, but now Natural England) undertook a national study to find out the reasons for adverse conditions of SSSIs (see Table 3.14). These reasons for adverse SSSI conditions should be considered during LDF preparation. (Note not all reasons are relevant to Luton and South Bedfordshire. i.e. inappropriate coastal management)

Table 3.13: Condition of SSSIs in Luton and South Bedfordshire

SSSI Name Condition Last Assessment Name Smithcombe, Sharpenhoe Unfavourable recovering 23 Jan 2006 and Sundon Hills Deacon Hill Favourable 1 June 2005 Fancott Woods and Unfavourable recovering 16 Feb 2006 Meadows Sundon Chalk Quarry Unfavourable recovering 22 March 2006 Galley and Warden Hills Favourable 18 July 2003 Houghton Regis Marls Unfavourable recovering 09 June 2006 Lakes Blow’s Down Unfavourable recovering 11 July 2003 Kensworth Chalk Pitt Favourable 30 March 2006 Barton Hill* Favourable 16 June 2006 Kings and Bakers Wood and Favourable 6 June 2006 Heaths Double Arches Pit Favourable 11 July 2001 Nares Gladley Marsh Favourable 27 June 2005

33 http://www.english-nature.org.uk/special/sssi/searchresults.cfm?sssi_name=&frmcounty=1002

SSSI Name Condition Last Assessment Name Houghton Regis Quarry No Data Available No Data Available Tebworth Marsh Unfavourable recovering 14 March 2006 Totternhoe Knolls – Unit 1 Unfavourable recovering 29 Sept 2004 (4.76ha) Totternhoe Knolls – Unit 2 Favourable 29 Sept 2004 (8.67ha) Totternhoe Chalk Quarry Unfavourable declining 14 June 2006 Totternhoe Stone Pit Favourable 11 Jan 2002 Dunstable and Whipsnade Unfavourable, no change 3 July 2006 Downs *Barton Hill is also designated as a National Nature Reserve

Table 3.14: Reasons for adverse conditions of SSSIs

Reason for adverse % of unit Reason for adverse % of unit condition area not condition area not meeting meeting PSA target PSA target Overgrazing 34.38% Inappropriate CSS/ESA 1.02% prescription Moor burning 26.42% Fire – other 0.95% Drainage 8.98% Siltation 0.84% Sea fisheries 6.93% Water abstraction 0.79% Air pollution 6.73% Inappropriate water levels 0.76% Forestry and woodland 6.45% Inappropriate dredging 0.67% management Inappropriate scrub control 6.10% Inappropriate 0.63% cutting/mowing Undergrazing 5.89% Inappropriate pest control 0.52% Other - specify in comments 5.88% Pesticide/herbicide use 0.29% Coastal squeeze 5.71% Peat extraction 0.26% Inappropriate ditch 5.10% Game management - 0.22% management pheasant rearing Water pollution - 3.21% Vehicles - other 0.21% agriculture/run off Inappropriate weed control 2.55% Military 0.20% Water pollution – discharge 2.44% Game management – 0.20% other Public access/disturbance 1.49% Earth science feature 0.18% obstructed Inappropriate coastal 1.47% Vehicles - illicit 0.18% management Agriculture – other 1.44% Planning permission – 0.16% other mineral and waste

Reason for adverse % of unit Reason for adverse % of unit condition area not condition area not meeting meeting PSA target PSA target Deer grazing/browsing 1.41% Earth science feature 0.11% removed Fertiliser use 1.34% Planning permission - 0.10% general Inappropriate stock-feeding 1.04%

Figure 3.2: Biodiversity Action Plan Priority Habitats in Luton and South Bedfordshire34

34 Natural England, http://www.natureonthemap.org.uk/map.aspx?m=bap

Figure 3.3: Sites of Special Scientific Interest in Luton and South Bedfordshire35

3.7.1 Woodland Cover Woodlands cover in Luton and South Bedfordshire is relatively low and reflects the below average coverage for Bedfordshire of 6.2%36 as compared with the England average of 8.4%37.

35 Natural England, http://www.natureonthemap.org.uk/map.aspx?m=sssi 36 National Inventory of Woodland and Trees, England, County Report for Bedfordshire, Forestry Commission, 2002, http://www.forestry.gov.uk/pdf/bedfordshire.pdf/$FILE/bedfordshire.pdf, cited January 2007 37 National Inventory of Woodland and Trees, England, Forestry Commission, 2001, http://www.forestry.gov.uk/pdf/niengland.pdf/$FILE/niengland.pdf, cited January 2007

Figure 3.5: Woodland Coverage in Bedfordshire by Forest Type38

3.7.2 Trends The condition of the majority of the SSSIs in Luton and South Bedfordshire meet the English Nature’s (English Nature as was at the time, but now Natural England) Public Service Agreement targets.

3.8 Air Quality Clean air is vital to human health and is an indicator of overall pollution levels. Certain aspects of air quality (ozone, green house gas emissions) may have implications for human health and climate at the global level. Local residents and businesses experience air quality at the local level, which affects health and amenity.

38 Forestry Commission, http://www.forestry.gov.uk/pdf/bedfordshire.pdf/$FILE/bedfordshire.pdf

The Environment Act 1995 places a statutory duty on local authorities to monitor air quality in their areas and to assess whether levels of identified pollutants remain below national standards and targets defined in the National Air Quality Strategy (NAQS). Identified pollutants include:

Nitrogen oxides (NOx); Nitrogen dioxide (NO2); Particulate matter (PM10) Sulphur dioxide (SO2); Benzene; Carbon monoxide (CO); and 1,3 butadine.

For the purpose of this report, data on these pollutant levels has been collected and presented in Table 3.15 below. The data was calculated from the average ambient air concentrations at monitoring stations in Luton and

South Bedfordshire. Data was not available for NOx and NO2 in 2003 and

2004, PM10 in 2003 and 2005, SO2 in 2003, 2004, 2005 and 2010, Benzene in 2004 and 2005, CO in 2003, 2004, 2005 and 2010 and 1, 3-butadeine in 2004, 2005 and 2010. Table 3.15 illustrates that there has been a trend of decreasing air pollutant levels in Luton and South Bedfordshire over the last 5 years and predictions for 2010 show that this trend is likely to continue.

Table 3.15: Pollutant Levels39

Luton South Bedfordshire Pollutant 2001 2003 2004 2005 2010 2001 2003 2004 2005 2010 NOx 67.12 - - 55.92 44.76 49.08 - - 40.89 32.91

NO2 34.92 - - 30.79 26.40 28.07 - - 24.77 21.32

PM10 22.38 - 21.47 - 19.61 21.22 - 20.36 - 18.71

SO2 3.80 - - - - 3.36 - - - - Benzene 0.71 0.63 - - 0.48 0.46 0.41 - - 0.32 CO 0.42 - - - - 0.32 - - - - 1, 3-butadeine 0.29 0.23 - - - 0.20 0.16 - - -

Units: NOx (ugm-3 as NO2 annual mean); NO2 (ugm-3 annual mean); PM10 (ugm-3 grav). Annual mean); SO2 (ugm-3 annual mean); Benzene (ugm-3 annual mean); CO (mgm-3 annual mean); 1, 3- butadeine (1, 3-butadeine 2001 ugm-3 annual mean)

39 UK Air Quality Archive, http://www.airquality.co.uk/archive/laqm/laqm.php?action=submit&map_name=beds&la_id=234

Areas with notably poor air quality as a result of high levels of particular pollutants are declared by Local Authorities as ‘Air Quality Management Areas’ (AQMA). There are three AQMAs in Luton and South Bedfordshire. One in South Beds, which includes Dunstable Town Centre and a section 40 of the A5 which suffers from high levels of Nitrogen Dioxide (NO2) and two in Luton, one including 24 dwellings adjacent to the M1 which suffer from

high NO2 levels. The second incorporating 431 premises adjacent to Junction 11 of the M1.

The Core Strategy should take into account impacts of development on atmospheric integrity and air quality, not only in relation to transport impacts, but also economic activity and construction.

Traffic generation, accessibility and movement pose key problems for Luton and South Bedfordshire; including severe traffic congestion, particularly on the A5 through Dunstable, the A6 through Luton, and the A505 between Dunstable and Luton. The anticipated growth could increase the number of traffic congestion hotspots within Luton and South Bedfordshire. Promotion of more sustainable transport modes, such as walking, cycling and public transport, will be a key issue for the Core Strategy.

3.8.1 Car Ownership Table 3.16 shows car ownership levels in Luton and South Bedfordshire. From the table it is apparent that car ownership levels vary dramatically through Luton and South Bedfordshire. South Bedfordshire has a higher percentage of households with access to a car compared to Luton, regional and national averages. 41 Although traffic congestion is an issue for Luton and South Bedfordshire, there are low car ownership levels in Luton compared to South Bedfordshire and the East of England.

40 Local Air Quality Management, cited November 2006, http://www.airquality.co.uk/archive/laqm/aqma.php?aqma_id=266 41 Local and Regional CO2 Emissions Estimates for 2003, produced by Netcen for Defra, cited November 2006, http://www.defra.gov.uk/environment/statistics/globatmos/galocalghg.htm

Table 3.16: Car and Van Ownership42

South Bedfords East of Luton (%) hire (%) England (%) England (%) All Households (number) 70,755 45,665 2,231,974 20,451,427

Households with: No Cars or Vans 26.4 16.85 19.8 26.84 One Car or Van 46.33 42.43 44.1 43.69

Two Cars or Vans 22.25 32.04 28.31 23.56

Three Cars or Vans 3.99 6.56 5.86 4.52 Four or more Cars or Vans 1.03 2.12 1.93 1.39

Table 3.17 shows the modes of travel to work. Mode share in Luton and South Bedfordshire shows that in terms of commuter trips, there are high levels of people using the private car or van to travel to work compared to UK averages and low levels of bicycle use. This has serious implications if modal shift in favour of public transport is to be achieved. Luton has high levels of walking and public transport use compared to South Bedfordshire, the rest of the eastern region and the UK. However there exists scope for promoting and improving public transport links. Translink will help modal shift to public transport.

Luton and South Bedfordshire has high levels of in and out commuting. The 2001 Census shows that 36,800 people commute into Luton and South Bedfordshire and 50,800 commute out of the area43. The high levels of in and out commuting has major implications for air quality, congestion, traffic noise and the environment.

42 National Statistics: http://neighbourhood.statistics.gov.uk/dissemination/LeadTableView.do?a=7&b=276843&c=Luton&d=13&e=15&g=4049 78&i=1001x1003x1004&m=0&enc=1&dsFamilyId=51

43 Luton, Dunstable & Houghton Regis Local Transport 2, 2006-2011