Case for Bushwood (Luton West) on Behalf of Luton & Central Bedfordshire Economic and Development Partnership Ltd

Luton & South Beds Core Strategy: Preferred Options Case for Bushwood (Luton West) on behalf of Luton & central bedfordshire economic and Development Partnership Ltd

Prepared by 06.09

Luton & South Beds Core Strategy: Preferred Options Case for Bushwood (Luton West) on behalf of Luton & central bedfordshire economic and Development Partnership Ltd

Prepared by 06.09 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

List of Figures

Site Identification Plan 03

Indices of Deprivation 07

Landscape Designations 22

Habitat Map 25

Proposed Bus Routes 29

M1 tunnel link bus link 31

Overhead Electricity Lines 32

Bushwood Masterplan 40

Luton West – Area M 48

Luton North – Area I 49

Luton East – Area L 49

iv The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Contents

1 Introduction 01

2 Milton Keynes and South Midlands SRS Compliance 05 Meeting the SRS Objectives 05 Strategy for the Luton / Dunstable / Houghton Regis Sub-Area 05 Strategy for the Luton/Dunstable/Houghton Regis Sub-Area 08 General Conformity Matters 09

3 Overview and Objectives of the Bushwood Proposals at Luton West 13 Policy Considerations and Compliance 13

4 Examing the Evidence Base 19 Environmental Considerations 19 Transportation 27 Utilities 33 Sports Facilities 35 Noise 34 Employment 36 Viability and Deliverability 37

5 The Bushwood Masterplan 39 Community Stadium, Hotel and Conference Facilities 41 Dedicated Busway 42 Sports Facilities 43 Strategic Employment Allocation 44 Regeneration Opportunities 45

6 Comparison of Preferred Urban Extensions with Luton West 47

7 Updating the Site Matrix 51

8 Conclusions 53

Appendix Proposed amendments to the JTU Site Assessment Matrix

planning associates

The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Introduction

1.1 Luton and Bedfordshire face a considerable challenge, arising from the strategic planning requirement to deliver some 41,700 new homes by 2031 and 23,000 new jobs by 2021 set out in the Milton Keynes and South Midlands Sub-Regional Strategy and East of England Plan respectively.

1.2 For those preparing the Development Plan Documents required to implement the strategic growth agenda, it is of course essential that policies and proposals are put in place to enable that growth to be effectively delivered, but at the same time it is equally essential not to loose sight of the rationale that underlies the need for the growth in the first place.

1.3 The test of the success of the Core Strategy is not simply whether or not it allocates sufficient growth locations to meet strategic development requirements, but whether those growth locations actually contribute towards the achievement of a more sustainable and prosperous future for the town.

1.4 Communities faced with accommodating substantial amounts of new development often (and understandably) feel threatened by the prospect, and by the significant changes to their local environment that inevitably arises.

1.5 But new development can be a catalyst for beneficial change, and ultimately the purpose of the growth agenda is to assist in the regeneration of Luton, Dunstable and Houghton Regis and improve the prospects and opportunities afforded to the local communities.

1.6 The purpose of this document is to explain why the proposed development at Luton West, known as Bushwood, is an appropriate location for delivering a significant proportion of the growth required (indeed, is the most appropriate location of all the alternatives), and is capable of doing so in a manner than maximises the benefits of growth to the wider community of Luton, Dunstable and Bedfordshire.

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1.7 The location of the proposed development area is shown on the accompanying plan. It extends to about 327 hectares, lying immediately adjacent to the western edge of Luton, and extending north to the southern edge of Dunstable.

1.8 As we explain in this document, it is an area largely free of environmental and technical constraints to development, and which offers unrivalled potential to deliver a sustainable transport strategy alongside new opportunities for leisure, for jobs, for regeneration, and for community enhancement.

1.9 We have prepared a separate document which examines in some detail the content of the current ‘Preferred Options’ Core Strategy and its accompanying evidence base, and which concludes that key elements of it are not ‘sound’ in the context of Government guidance on core strategies.

02 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Site Identifi cation Plan

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The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Milton Keynes and South Midlands SRS Compliance

Meeting the SRS Objectives

2.1 The growth agenda that the Core Strategy is required to deliver stems directly from the objectives of the MKSM SRS. Implementing the SRS is not simply an exercise of allocating land to meet the headline development requirements. It is essential to consider how the growth locations actually contribute to meeting the underlying objectives of the sub-regional planning strategy.

2.2 The table overleaf sets out how the proposed growth location at Luton West performs against those underlying objectives (and includes by way of example a comparison with Luton East and Luton North).

2.3 A key feature of the Luton West proposal is its location in relation to Luton town centre and its proximity to this and other areas suffering from high levels of deprivation. The ability of the scheme to forge new links with those existing communities, and to deliver new opportunities for leisure, employment, and community enhancements, alongside its ability to deliver the necessary social and physical infrastructure to support the development, means that the scheme performs extremely well when compared to the MKSM objectives.

St rategy for the Luton / Dunstable / Houghton Regis Sub-Area

2.4 Policy 2 (a) sets out the sub-area strategy for accommodating the level of growth proposed. This includes that LDDs should review the Green Belt ‘around’ the Luton/Dunstable/Houghton Regis conurbation and should ‘focus’ on two areas of search which would exclude the AONB. Although land west of Luton falls outside of the areas of search the fact that the policy allows for a review of the Green Belt ‘around’ the conurbation and the areas of search may be the ‘focus’ this does not suggest that other areas may not be considered appropriate when considering more locational and site specific matters at the local level of plan making.

planning associates 5 0 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

SRS OBJECTIVES LUTON WEST LUTON EAST LUTON NORTH

Major increase in new Proposals deliver Proposals deliver 5,500 Proposals deliver 4,000 homes, meeting needs 5,500 new homes, homes, with a minimum homes, with a minimum for affordable housing with a minimum 35% 35% affordable 35% affordable and a range of market affordable housing, housing. Mix unknown housing. Mix unknown housing. and wide mix, but potential to include but potential to include including specialist wide range of types. a wide range of types. accommodation.

Provide for economic Proposals will create a Majority of employment Location of employment growth and developing wide range of jobs from proposals related to next to proposed skills (particularly in manual to skilled, to logistics which tend Junction 11a likely to high value sectors). meet local needs, whilst to be low skilled, but encourage low skilled enhancing access proposals also include logistics uses, but also to further education/ science park and links potential for some training. with university. higher skilled jobs.

Locate development Development outside Development outside Development outside in main urban areas to urban area, but strong urban area. Remote urban area. Remote support regeneration links to deprived areas. from deprived areas. from deprived areas. of deprived areas, Will not assist in Will not assist in recycling of land and regeneration or create regeneration or create sustainable travel sustainable travel sustainable travel patterns. patterns. patterns.

High standards Proposal capable Proposal capable Proposal capable of of design and of delivering high of delivering high delivering high standard construction, protecting standard of design, standard of design of design, but proposals environmental assets, and protecting key and new green show limited new green and providing green environmental assets space, but significant space and poor links. space. (incl. ecology/arch/ adverse impact on Northern by-pass likely landscape). Around environmental assets to have significant 40% site is new or and landscape. adverse impact on retained green space/ AONB and ecology. POS.

Meet infrastructure All infrastructure Development unable Development unable needs generated by provided by developer, to deliver highway to deliver highway development, plan to including local road infrastructure required infrastructure required reduce the need to improvements. High to support it. Halcrow to support it. Halcrow travel, and create more quality public transport evidence accepts major evidence accepts major sustainable modes. proposals as part of road schemes harmful road schemes harmful package of sustainable to sustainable modes to sustainable modes modes and trip and trip reduction. and trip reduction. reduction.

Create sustainable Proposals include Proposal potentially Uncertainty regarding communities by front loading of key capable of phased funding for northern by- ensuring economic, physical and social growth in line with pass, and delay likely environmental, infrastructure, as part of infrastructure provision, due to limited access social and cultural balanced Masterplan. but no certainty over in advance of J11a, infrastructure in step by-pass funding or otherwise site capable with growth. delivery. of phasing.

Strongly contributes to objectives Contributes to objectives Contrary to objectives Strongly contrary to objectives

06 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Luton Indices of Deprivation 2007 0%-10% Most deprived 11%-20 % 21%-30% OOffffa BrBraammiinngghhaamm 31%-40% StStrreeaattlleeyy ToToddddiinnggttoonn 41%-50% TTiitthheeF aarrmm SSuunnddoonnPa Parrkk NNoorrtthhwweellll 51%-60% 61%-70% 71%--80 IIcckknniieelldd HHoooo PaParrkkssiiddee 81%-90 LiLimmbbuurryy 91%-100% or 0%-10% least deprived LLeeaaggrraavvee SSttooppsslleeyy HHoouugghhttoonnHa Hallll BaBarrnnffiieelldd

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Luton KKiimmppttoonn Indices of Deprivation 2007 CaCaddddiinnggttoonn,,HHyyddee aannddSl SliippEn Endd 0%-10% Most deprived KKeennsswwoorrtthh aannddTo Totttteerrnnhhooee 11%-20 % 21%-30% OOffffaa Luton BrBraammiinngghhaamm 31%-40% StStrreeaattlleeyy TTooddddiinnggttoonn Indices of Deprivation 2007WaWattlliinngg 41%-50% TTiitthhee FFaarrmm SSuunnddoonnPa Parrkk NNoorrtthhwweellll 0%-10% Most deprived 51%-60% Source: Indices of11%-20 Deprivation % 2007 (Lower Level Super Output Area) 61%-70% This map is based upon Ordnance Survey material with the permission of Ordnance Survey on behalf of the Controller of Her Majesty's Stationery Office © Crown copyright. Unauthorised reproduction21%-30% infringes Crown copyright and may lead to prosecution71%--80 or civil proceedings. ODPM 100018986 2007. IIcckknniieelldd OOffffaa HHoooo PaParrkkssiiddee BrBraammiinngghhaamm 31%-40% 81%-90 StStrreeaattlleeyy TTooddddiinnggttoonn LLiimmbbuurryy 41%-50% 91%-100% or 0%-10% least deprived TTiitthhee FFaarrmm NNoorrtthhwweellll SSuunnddoonnPa Parrkk LLeeaaggrraavvee SSttooppsslleeyy 51%-60% 61%-70% HHoouugghhttoonn HHaallll BaBarrnnffiieelldd Indices of Deprivation 2007 (Lower Level Super Output Area) 71%--80 IIcckknniieelldd HHoooo PaParrkkssiiddee 81%-90 LLeewwsseeyy LLiimmbbuurryy SSaaiinnttss 91%-100% or 0%-10% least deprived HHoouugghhttoonn HHaallll LLeeaaggrraavvee SSttooppsslleeyy ChChaallllnneeyy HHoouugghhttoonn HHaallll BaBarrnnffiieelldd RoRouunnddGr Greeeenn BiisB sccoott IIcckknniieelldd LLeewwsseeyy SSaaiinnttss HHiigghh TToowwnn HHoouugghhttoonn HHaallll DDaallllooww ChChaallllnneeyy RoRouunnddGr Greeeenn WiigW gmmoorree CCrraawwlleeyy planning associates 7 0 BiisB sccoott IIcckknniieelldd MMaannsshheeaadd HHiigghh TToowwnn

DDaallllooww SoSouutthh WaWattlliinngg CCrraawwlleeyy WiigW gmmoorree FFaarrlleeyy

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KKiimmppttoonn SoSouutthh WaWattlliinngg CaCaddddiinnggttoonn,, HHyyddee aanndd SSlliipp EEnndd

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WaWattlliinngg KKiimmppttoonn CaCaddddiinnggttoonn,, HHyyddeean anddSlliip S p EEnndd

Source: Indices of Deprivation 2007 (Lower Level Super Output Area) KKeennsswwoorrtthh aanndd TTootttteerrnnhhooee This map is based upon Ordnance Survey material with the permission of Ordnance Survey on behalf of the Controller of Her Majesty's Stationery Office © Crown copyright. Unauthorised reproduction infringes Crown copyright and may lead to prosecution or civil proceedings. ODPM 100018986 2007.

WaWattlliinngg

Source: Indices of Deprivation 2007 (Lower Level Super Output Area) This map is based upon Ordnance Survey material with the permission of Ordnance Survey on behalf of the Controller of Her Majesty's Stationery Office © Crown copyright. Unauthorised reproduction infringes Crown copyright and may lead to prosecution or civil proceedings. ODPM 100018986 2007. The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

St rategy for the Luton/Dunstable/Houghton Regis Sub-Area

1.5 The areas of search mentioned in the SRS are explained very readily in the Report of the Panel in paragraphs 10.14 and 10.15, in which the Panel explain that:

“In the case of LDHR [Luton/Dunstable/Houghton Regis] we heard some arguments both in favour (and against) a number of directions of growth in a wide and more or less continuous arc from west of Dunstable, through north of Dunstable and Luton, to the east of Luton (including the ‘key reserve site’ in North Hertfordshire), to south of Luton at an area dubbed by its promoters as the ‘Luton Business Triangle.”

2.6 The Panel refused to comment on the relative merits of different growth locations within that arc, commenting quite rightly that far more detailed investigations would be required, and that in respect of the growth locations the Sub-Regional Strategy should provide ‘a mechanism, not an answer’ (paragraph 10.15) for testing appropriate locations.

2.7 Therefore when the Panel referred at the end of paragraph 10.15 to a Green Belt review encompassing land from the west of Dunstable to the south of Luton, whilst expressly refusing to endorse or reject any growth location along that arc, it was simply responding to the representations that had been made to the Examination. The Panel make no mention of growth to the south-west of Luton, because no such representations had been made to the Panel.

2.8 We are of course aware that the area of search from West Dunstable to South-East Luton was also put forward by Roger Tym and Partners as part of their high level assessment of the sub-regional growth options in 2002. Even in the more ‘detailed’ 2003 LDHR Growth Area study, however, the south-west of Luton was appraised only in superficial terms and in the absence of any developer proposals at that time, resulting in a number of erroneous conclusions in the analysis.

08 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

2.9 When considering potential opportunities for growth, Luton and South Bedfordshire Councils (now Central Bedfordshire) have not constrained themselves only to locations that accorded with the areas of search identified in the SRS. The Issues and Options Core Strategy included growth at new locations (including land to the west of Luton forming part of the Luton West area), and the Councils have continued to put west Luton forward as an option for testing in the preparation of the Preferred Options.

2.10 Given the strong correlation between the Luton West proposals and the underlying objectives of MKSM, our conclusion is that the Core Strategy is in general conformity if Luton West is identifies as a Strategic Allocation. This aspect is considered further below.

G eneral Conformity Matters

2.11 The starting point is to consider the guidance in PPS12 which suggests at paragraph 4.2 that the vision that should be included in a core strategy should be in general conformity with the RSS and in devising its strategy, this should be consistent with national policy and in general conformity with the regional spatial strategy (Paragraph 4.3.3). The paragraph continues:

“This means that the choices made regarding, for example where growth should take place should follow national and regional policy. This is not the same as reformulating it in different words as ‘development control’ policies and leaving the spatial decision making to the planning application stage. This focus is because the core strategy should be concentrating on devising a delivery strategy to deal with the particular issues which have been identified as of local importance. Plan making resources are scarce and needs to be concentrated on those tasks which only the core strategy can achieve – especially the co-ordination of the delivery of development and the accompanying infrastructure”.

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2.12 PPS 12 therefore recognises that to be in general conformity with RSS it does not necessarily require the core strategy to simply reiterate those parts of the RSS that is relevant to their area. This is because the clear emphasis in producing a core strategy is on delivery and this requires the assessment of particular local issues that may well have not been identified at the regional (or sub-regional) level when the RSS was prepared.

2.13 This assessment of the guidance in PPS12 in relation to general conformity is supported by Case Law, in particular the Court of Appeal judgement by Lord Justice Laws relating to a case brought by Persimmon Homes against Stevenage Borough Council in November 2005. The appellants’ contention was that a particular policy of the Local Plan, as adopted, was not in general conformity with policies of the adopted Structure Plan Review.

2.14 Lord Justice Laws in considering the correct construction of the expression ‘general conformity’ concluded that whether there is general conformity between the plans is a matter of degree and, of planning judgement, noting that the term is nowhere defined in the legislation.

2.15 The judgement goes on to find in favour of a ‘looser’, rather than a ‘tighter’ approach in applying the general conformity requirement and based on its true construction, the general conformity requirement may allow considerable room for manoeuvre within the local plan in the measures taken to reflect structure plan policy so as to meet the various and changing contingencies that can arise.

2.16 Lord Justice Laws agreed with the observations made by the Judge that the word ‘general’ is likely to have been put in to make it clear that, to a degree, the need for conformity may be balanced against the need for the local plan to take account of and explain the circumstances in which the strategic policy will be given effect. In the first instance it will be for the Local Planning Authority to decide how to strike this balance.

10 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

2.17 This judgement highlights the important of flexibility in determining general conformity with RSS. The sentiments of this judgement are included within paragraph 4.33 of PPS12 in acknowledging the importance of devising a delivery strategy taking into account particular local issues of importance. Based on this judgement and also the particular guidance on general conformity set out in PPS12, then a strategic allocation to the west of Luton would be in general conformity with the SRS if it is considered by a Local Planning Authority, acting reasonably, would assist them in producing their Core Strategy that is capable of being delivered.

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The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Overview and Objectives of the Bushwood Proposals at Luton West

Pl o icy Considerations and Compliance

3.1 There is no disagreement amongst the Joint Technical Unit responsible for preparing the Joint Core Strategy for the Luton and Central Beds Area that there is a confirmed requirement to deliver the scale of growth in terms of both housing and employment set out in the MKSM SRS (supplemented by RSS14, in particular Policy E1 that has refined the jobs requirement to 2021). It remains for the spatial strategy to be tested against policies at national, regional (and sub-regional) and local levels.

3.2 Whilst a whole raft of national planning guidance contained in both PPG’s and PPS’s are of relevance in determining the most appropriate spatial strategy, perhaps those of particular importance are:

»» PPS12 – Local Spatial Planning »» PPS3 – Housing »» PPG13 – Transport »» PPS1 – Delivering Sustainable Development.

3.3 The requirements for Local Spatial Planning are set out in PPS12, with an over-riding requirement to produce a vision for the future of places that is based on evidence and local distinctiveness. This vision is to be translated into a set of priorities, programmes, policies and land allocations, with clear evidence as to the resources to deliver them. Spatial planning also aims to create a framework for private investment and regeneration that promotes economic, environmental and social well being for the area and should also contribute to achieving sustainable development.

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3.4 These aims are achieved by the Bushwood proposals at Luton West which:

»» Have been brought forward supported by a strong evidence base that the Luton West location is appropriate having regard to the reasonable alternatives.

»» Involves the sensitive development of land where the local character and distinctiveness can be enshrined within detailed proposals through the evolution of the strategic master plan, supported by more detailed design codes.

»» A strategic allocation at Luton West is not dependent on public sector resources for its delivery and therefore, importantly, has significant advantage over other Preferred Options in the emerging Core Strategy which are dependent upon significant new road infrastructure for which no private or public resources have been identified.

»» Luton West is strategically well located in relation to the deprived wards in Luton and Dunstable, some of which feature in the top 10 most deprived wards in England based on the statistics of multiple deprivation collated by the DCLG. The opportunity to facilitate the regeneration of these areas through private sector investment in the form of new local job opportunities, sports and leisure facilities will promote social and economic improvements that would otherwise not be achieved.

»» Luton West is the closest potential growth area to Luton town centre so that cycling and walking are reasonable alternatives to the private car.

»» The land controlled at Luton West adjoins the Luton Dunstable Guided Busway making a direct connection deliverable to achieve a fully integrated public transport system that can be achieved without any additional public funding.

»» The Luton West proposals are financially viable based due mainly to the more realistic views land owners have taken on future land values.

14 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

3.5 The Bushwood proposals are not dependent upon any unplanned or uncommitted infrastructure, but rely instead upon the provision of the new Luton Dunstable Guided Busway and localised improvements to the highway network, including increasing capacity at Junction 10A of the M1. The delivery of this proposed strategic allocation is certain, and is capable of being commenced within the first five years of the plan following adoption.

3.6 The integration of the Bushwood development proposals with the Guided Busway is a key component. In relation to major public transport infrastructure provision, this guided busway has secured planning permission, all of the necessary land to implement the scheme has been successfully compulsorily purchased, the capital costs of delivering the guided busway and associated infrastructure is fully funded and the tenders for construction are about to be invited.

3.7 The opportunities to fully integrate the use of the Guided Busway with the dedicated busway serving the Bushwood development will extend the busway network and contribute to meeting the principles of sustainable development. It will also satisfy Strategic Objective SO8 in the emerging Core Strategy which is to use growth to help minimise carbon footprint and to mitigate and adapt to climate change.

3.8 The Joint Technical Unit (JTU) who are responsible for preparing the Core Strategy acknowledge in paragraph 4.13 that:

“In order to deliver a Core Strategy that is sustainable, it is important to ensure that new development and as much existing development as possible is easily accessible by public transport and other alternatives to the private car …”

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3.9 It is regrettable that the same paragraph seeks to contradict this national planning objective by concluding with the following words:

“… as well as ensuring that private car accessibility is also adequately planned for.”

3.10 PPG13 provides clear guidance on the requirement for all new development to be sustainable by relying on accessibility for the majority of journeys by public transport, cycling and walking. To achieve this, development needs to be located in the most accessible places. This guidance has not been followed in the preparation of the emerging Core Strategy, primarily because the preferred urban extensions are on the whole, in the least accessible locations, remote from the new guided busway, at great distances to Luton Town Centre (in relation to the north and eastern extensions) and entirely dependent upon major new road building to provide access which will only encourage private car journeys in preference to public transport, cycling and walking.

3.11 This important objective is carried forward in PPS1 and PPS3 by focusing new development in locations with good public transport accessibility and/or by means other than the private car in identifying suitable locations for housing development. To achieve this, the effective use of land and existing infrastructure and available public and private investment is encouraged. There is no mention in this or any other national planning guidance that new major road infrastructure should be encouraged to ensure that “private car accessibility is adequately planned for” which is, according to paragraph 4.13 of the emerging Core Strategy, “at its heart”.

3.12 In addition to requiring new development to be in sustainable locations and served by non-car modes, PPS3 also makes clear that DPDs should only allocate sites that are suitable and genuinely deliverable. The evidence base prepared for the Bushwood site at Luton West shows that the site is suitable, having regard to a wide range of technical and environmental matters, and deliverable. We consider the evidence studies which support the strategic allocation in the next section of these representations.

The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Examing the Evidence Base

4.1 In order to support a strategic allocation to the west of Luton a series of technical evidence studies by specialist consultants have been prepared in order to test the location and proposals against the following requirements:

»» Environmental Considerations (Landscape, Ecology and Heritage) »» Transportation »» Utilities »» Sports Facilities »» Noise »» Employment »» Viability and Deliverability.

4.2 Environmental evidence on landscape and visual impact, ecology and heritage has been assembled to assess and support Luton West as an appropriate urban extension. A summary of this evidence follows.

E onvir nmental Considerations

Landscape Assessment

4.3 The landscape assessment carried out by CSa Environmental Planning, and included with these representations, is based on site visits and provides a strategic assessment of the character and quality of the landscape and its ability to accommodate development. The assessment takes into account, the Landscape Character Assessment carried out by consultants for South Bedfordshire District Council.

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4.4 The CSa assessment broadly concurs with the South Bedfordshire LCA in evaluating the area as being of ”moderate landscape sensitivity” but CSa note that certain areas are of low landscape sensitivity, principally the areas of vehicle storage and airport parking and the degraded areas of landscape. In relation to the AGLV designation, the point is made that based on the advice in PPS7, such designations should be abandoned in favour of landscape character assessments and whether or not the AGLV designation is maintained is of little relevance as the key landscape assets of the northern portion of the site, such as the areas of woodland and mature hedgerows are protected by other policies and legislation and, importantly, are retained within the Bushwood Masterplan proposals.

4.5 Turning to the AONB, CSa conclude that there will be no direct effect arising from the Luton West development as no part of the site proposed for development lies within the designated area. CSa also confirm that there would be no significant indirect effects as the boundary between the site and the AONB is clearly defined by Chaul End Road, sections of which at the northern end is in cutting. Chaul End Road is also flanked by dense hedgerows or belts of woodland along much of its length. Finally, in relation to AONB considerations, the proposed community stadium, hotel and conference facilities located adjacent to the M1 are of sufficient distance from the AONB and importantly at a significant lower level.

4.6 In relation to visibility, CSa agree with the South Bedfordshire LCA that the area is of moderate visual sensitivity and that development would not have a high visual impact which CSa are in agreement with for the following reasons:

»» The orientation of the land is broadly inclined towards the urban area of Luton.

»» The gently undulating nature of the southern part of the site would allow boundary planting to screen any potential development from the open countryside beyond.

»» There are no significant views from within the AONB and in any event there is very little development that adjoins the AONB boundary.

20 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

»» There are a range of urbanising features within and around the site that reduce the sensitivity of the landscape.

»» The northern portion of the site is well wooded, which serves to limit views of that part of the site.

4.7 At the Community Forum Event in May 2008, the JTU’s assessment of Area M highlighted strengths and weaknesses in relation to landscape, acknowledging as a strength “some potential for development in landscape terms” and the “potential for development to ‘soften’ harsh urban edge”. The landscape weaknesses were that Area M abuts the edge of the AONB and AGLV and the sensitivity of the landscape to the north of Caddington. The evidence of landscape and visual assessment prepared by CSa concludes that:

»» It is highly unlikely, even in the absence of mitigation, that development of the site would give rise to any significant effects on the AONB.

»» The designation of AGLV should not be seen as a bar to development. The masterplan demonstrates how the particular landscape assets of this area, which are considered of value, are protected.

»» The landscape features that occur in the area to the north of Caddington can be retained and incorporated in the development proposals for that part of the site.

»» The setting, character and identity of Caddington and Slip End is protected through the proposal for green separation.

»» The Bushwood proposals do not extend development to the far north of the site, therefore protecting both the scarp slope (an area acknowledged of landscape sensitivity) and also protects the setting of Dunstable.

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NE7 NE7

NE7

NE7 NE2 NE3

NE7

Landscape Designations

Site Location AONB: Area of Outstanding Natural Beauty Area of Great Landscape Value County Wildlife Site

Barn A, Dixies Project: Luton West Drawing Number: CSA/1268/100 High Street, Ashwell Drawing Title: Site Location Revision: A - Site boundary updated Herts SG7 5NT Tel: 01462 743647 Date: December 2008 Drawn By: SG Client: Luton & Central Beds Fax: 01462 743648 Economic & Development Scale @ Size: Not to Scale Checked By: CS Email:[email protected] Partnership Ltd. The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

4.8 The overall conclusion drawn by CSa is that there is no in-principle landscape or visual constraint to development.

Nature Conservation

4.9 AECOM (formerly Faber Maunsell) has carried out a Phase 1 Ecological Habitat Survey of the Luton West site. This survey has considered the ecological value of the following:

»» Woodlands, veteran trees and shrub formations »» Grasslands »» Arable land »» Aquatic habitats

4.10 The conclusions from the survey are that the areas of ancient woodland provide core areas of high value habitat that will require protection by appropriate landscape design and management and set within areas of green space used as a recreational open space.

4.11 Within the site, there exists species rich hedges that in some instances are arranged in a network of corridors for wildlife movement. The network of hedgerows and woodland are dispersed widely across a landscape dominated by extensive arable fields with little intrinsic nature conservation value.

4.12 The northern section of the site is dominated by a smaller-scale mosaic of woods, scrub and grassland on the chalk scarp slopes and represents a more sensitive area with the potential for mainly low-intervention management, in particular the rehabilitation of the areas of chalk grassland. Parts of this area are currently subject to trespass by motor bike enthusiasts who have worn a clear race track into parts of this landscape.

planning associates 3 2 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

4.13 The masterplan proposes that a part of this area will accommodate the new community stadium, conference and hotel facilities and AECOM’s advice is that this development should be kept to the east and south of the compartment, thereby minimising land take from the areas of open calcareous grassland. Similarly, the proposed Park and Ride facility off Hatters Way should be designed to reduce land-take, in particular from habitats on the scarp slope to the south. Any loss of semi-improved grassland here can be compensated for by mitigation measures.

4.14 The majority of the site and the development proposals lie to the south and affects land predominantly in arable use presenting no constraint on development as much of this land is generally low ecological impact. The masterplan should seek to incorporate as many of the network of hedgerows as is possible.

4.15 The recommended approach to mitigation involves an extensive area of arable land to the west of Chaul End Road that will provide a mitigation area which will compensate for habitat loss in the main development area. The ecological approach is to plant new woodland and shrub habitats to reinforce the surrounding hedgerows and provide new woodland habitat along the eastern boundary of the Folly Wood County Wildlife Site. In addition to mitigating the effects of the development, this area will contribute to the network of habitats within the Chilterns AONB and address some of the objectives of the local Biodiversity Action Plan.

4.16 The design principles identified by AECOM have influenced the Bushwood masterplan and will continue to be fully embraced in future iterations of the masterplan as this evolves.

4.17 The Phase 1 survey recommends further study and assessment, the results of which will provide information to assist detailed layout and design of the development and the final approach to mitigation.

24 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Habitat Map

planning associates 5 2 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Heritage Assessment

4.18 The Heritage Assessment Summary Report submitted with these representations is based on the findings of a Heritage Desk-Based Assessment and walk-over inspections of the site. The assessment has established that there are no Scheduled Ancient Monuments or other designated archaeological remains on the site. The nearest SAM is approximately 1 km to the west of the site as Zouches Farm.

4.19 There are no Conservation Areas or listed buildings on the Luton West site, although the Caddington Conservation Area and All Saints Church (a listed building) lie nearby to the west. The English Heritage Registered Historic Park is located approximately 300 metres to the south west of the site and to the east of the M1.

4.20 Research has established that a possible roman road crosses the site and that much of the site has been field-walked, resulting in the discovery of prehistoric flintwork and a number of scatters of roman and Medieval finds. A large find scatter and related documentary evidence suggests a Medieval settlement in the southern part of the site around Woodside. The assessment has identified the following heritage assets, whilst not an over-riding constraint to development, may require further assessment and evaluation as the site is progressed through the planning processes:

»» Roman road crossing the site south of Caddington »» Possible Medieval deserted village and Woodside »» Area around Inions Farm, possibility of Roman and Medieval settlement »» Earthworks to the north of the site probably Iron Age lynchets

26 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

4.21 In accordance with the guidance in PPG16, further assessment and evaluation of these areas will be required. However, based on current evidence, the first three of these potential assets are not candidates for in-situ preservation and will not require archaeological investigation and excavation ahead of development.

4.22 The lynchets are currently in a poor condition, brought about by scrub vegetation, siting of pylons and motorbike activity has cut erosion scars across several of them.

4.23 While the lynchets are an interesting and locally important archaeological feature, in addition to archaeological investigation and recording, it is proposed that the development will afford an opportunity to better manage the lynchets by the removal/management of scrub and fencing to obstruct access by motorbikes.

4.24 Therefore, significantly, archaeological work associated with the development of the site could bring tangible benefits to heritage resources within the site. Further, investigations could help create a ‘sense of place’ within this new community and the better management of the lynchets could halt the decline of these features and restore them as a visual element of the landscape.

Trnpora s tation

4.25 The Transport Strategy for Bushwood has been prepared by Mott MacDonald who has a long association with Luton and Dunstable, having worked on the details of the Luton Dunstable Guided Busway and also the recently completed Eastern Corridor proposals. The Mott MacDonald team therefore have extensive knowledge of transportation issues in the conurbation and in particular, the delivery of sustainable public transport strategies.

4.26 Mott MacDonald have been assisted by Peter Brett Associates who were commissioned to consider the no by-pass option for the Highway Authority and their synopsis of this case is set out in Appendix 1 of the Objection Representations.

planning associates 27 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

4.27 The Transport Strategy is a key component of the evidence base supporting the Bushwood proposals and the identification of Luton West as a preferred urban extension. The starting point for this strategy is twofold.

»» The advantages that Luton West presents in relation to its geographical location and closeness to Luton Town Centre and other key attractors such as the Luton & Dunstable Hospital, employment areas (Dallow Road Estate, Capability Green), Stockwood Country Park and existing/improved education facilities.

»» The opportunity to create an integrated public transport system by directly connecting services to/from the Luton Dunstable Guided Busway to provide a real alternative to use of the private car.

4.28 The strategy is therefore focused on delivering a truly sustainable development with the main focus being on the opportunities for using public transport, cycling and walking as the first priority. This principle has guided the preparation of the Bushwood masterplan which is based on providing strong public transport links to provide an effective alternative to car use and of a quality that makes the bus the first choice for many journeys.

4.29 The layout for the masterplan ensures that the busway through the development provides direct access for buses, but within easy walking distance of all of the planned neighbourhoods and associated uses. In contrast, the masterplan road layout is aimed at the equivalent car journeys being longer and therefore less desirable.

4.30 Good bus links will facilitate movements from Bushwood to employment/retail/leisure and other activities in the existing built up area, as well as within the development and to connect to railway stations for onward journeys. In this way, a fully integrated public transport system can be delivered. Full integration will also mean that existing populations can benefit from the services and facilities offered by Bushwood accessed via public transport.

28 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

4.31 The three core bus routes proposed and illustrated below and are:

» Dunstable and Houghton Regis to Bushwood via the busway, connecting to the Airport via Parkway Station and Capability Green;

» L&D Hospital to Bushwood then into Luton Town Centre via Farley Hill Road; and

» Bushwood to Luton Town Centre via the existing tunnel beneath the M1 and the Guided Busway.

Proposed Bus Routes

planning associates 29 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

4.32 This range provides access to key locations in the conurbation, including Dunstable Town Centre, Houghton Regis and a major health site, employment areas, including the Airport, railway stations and Luton town centre. Significantly, direct access to the Guided Busway at Hatters Way means that services can operate unimpeded towards Dunstable/Houghton Regis and Luton Town Centre. The use of the busway will enhance the reliability of services and extend the quality influence of the busway well beyond the guided section of infrastructure.

4.33 The proposed routes provide a wide range of journey opportunities for all Bushwood residents and business occupiers. It is envisaged that there will be a limited number of stops within Bushwood to maintain good journey times, but the intensive network will be a core feature of the development.

4.34 Farley Hill Road and Chapel Street provide a direct access to Luton Town Centre and bus priority measures such as some parking restrictions and other traffic movements may be necessary.

4.35 As well as a connection to the Guided Busway at the Hatters Way end, a second connection, utilising the existing tunnel beneath the M1 (see photograph), would be used. This would require alternative working through the tunnel.

4.36 The proposal is that each of the three core services operates at a 10 minute frequency throughout the day with a regular evening and Sunday services. Where the routes converge within Bushwood, a very high frequency service could be provided with a bus arriving every 3 to 4 minutes. This level of service is required to achieve a strong mode share.

4.37 Mott MacDonald have identified key junctions in the surrounding area and based on their initial assessment of capacity and performance of these junctions at peak hours, combined with the extent of highway land available, have concluded that improvements to junctions will be achievable to alleviate the effects of the residual traffic generated by the Luton West development.

30 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

M1 tunnel link bus link

planning associates 31 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Overhead Electricity Lines

32 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Ui t lities

4.38 A utilities and servicing strategy has been prepared for the development proposals by Mott McDonald, and has included liaison with all of the key utility providers.

4.39 There are two existing overhead electricity lines that affect the site, being a low voltage line running east-west and a higher voltage line running north-south, alongside the M1. Preliminary discussions have taken place between the developer and EDF regarding the potential to underground these routes. EDF have expressed support for these proposals, and preliminary routes and infrastructure for supporting the power requirements of the development have been discussed.

4.40 The site is not in an area at risk of flooding. The surface water drainage strategy is likely to be based upon the retention of water on-site, using appropriate attenuation facilities (which can provide positive features for strategic landscaping and biodiversity), coupled with evaporation and infiltration.

4.41 A strategy for foul drainage has been examined, and in principle sufficient capacity exists at East Hyde for over 7,000 new dwellings. Although the Water Cycle Strategy had raised a concern regarding potential constraints to routing as a result of the need to cross the M1 and river, crossings of the M1 already exist, and East Hyde can be reached if necessary without the need to cross any existing watercourse.

4.42 Investigations with other service providers have revealed no constraints to development.

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Sorp ts Facilities

4.43 The assessment of sports facilities has been carried out by Michael Presland Sport & Recreation Planning Consultancy. This assessment determines the sports requirements arising from the proposed development and within the wider Luton and Dunstable area. The assessment provides a sound evidence base for the sports facilities proposed as part of the Luton West development and has influenced the Bushwood masterplan.

4.44 The assessment of sports provision comprises four elements:

»» The sports facilities required to meet the needs of the new Bushwood residents.

»» Sports facilities which could also meet the needs of Caddington and Slip End residents, particularly where facilities are lacking.

»» Sports facilities meeting a wider than local need in the Luton and Dunstable area and where essential local facilities can be enhanced relatively cost effectively.

»» Specialist facilities for individual sports identified in existing strategies adding to the sustainability and attractiveness of the Luton West development.

4.45 The urban extension at Luton West is based on delivering a comprehensive sports facilities package and is a key component of the Bushwood masterplan. The sports and recreation elements are aimed at not only meeting the sports requirements arising from the development, but also addressing the issue of access to sports facilities by the local populations, importantly including those living in the most deprived Wards on the east side of the M1. The existing links across the M1 and the opportunity to provide a new overbridge connecting Farley with these facilities will have a direct influence on the regeneration of these areas.

34 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

4.46 Further details of the sports facilities proposed are set out in the next section that deals with the Bushwood masterplan.

Noise

4.47 Bickerdike Allen & Partners have considered the noise environments associated with the M1 and also the activities of London Luton Airport (LLA). Information on current road traffic flows and future traffic predictions have been taken into account and assessed against the guidance in PPG24 : Planning and Noise. Using current traffic flow data, indicative noise calculations have been produced based on recognised conventional methodologies to identify noise exposure levels at certain distances from the motorway with and without noise attenuation barriers.

4.48 In order to ensure robustness, future noise levels from the M1 have been calculated to assess a possible worst case and distances with and without acoustic barriers determined. These calculations have been used to influence the Bushwood masterplan to ensure that noise sensitive development is located with no greater exposure to traffic noise than NEC B in PPG24.

4.49 Turning to aircraft noise from LLA, assessments have been carried out based on current noise exposure levels and also a worst case should the runway be extended on its existing alignment in the future. The guidance in PPG24 in relation to aircraft noise have been followed and an assessment made of the changes proposed by the National Air Traffic Services (NATS) to the departure routes to the west of the Airport.

4.50 The exposure to aircraft noise has influenced the Bushwood masterplan to ensure that all residential development will not be affected by aircraft noise under current exposure levels and also taking into account future worst case scenarios.

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Employment

4.51 The European Research Group at Cushman & Wakefield have considered the employment provision associated with the Luton West development taking into account:

»» Current data on employment land supply

»» The jobs requirement of 23,000 to 2021 set out in RSS14

»» The aspirational requirement to deliver 0.9 jobs per new household created in the emerging core strategy.

»» The appropriateness of the Luton West site as a location to deliver new jobs in the area.

4.52 This work has involved an extensive review of the Employment Land Review carried out by Halcrow which forms part of the evidence base supporting the Core Strategy: Preferred Options. No further employment evidence has been prepared by the JTU and the recommendations of Halcrow to consider a strategic employment allocation at Area M is a firm indication that the Luton West location has the potential to deliver new employment opportunities to achieve a mixed use urban extension.

4.53 The Luton West development comprises of about 5,500 dwellings which is equivalent to about 5,390 households and a population of about 13,750 people. Taking the aspirational requirement to deliver 0.9 new jobs per household, this is equivalent to about 4,850 jobs.

36 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

4.54 Cushman & Wakefield have analysed the existing property market, land supply and take up and have determined the capacity for employment creation at Luton West as follows:

»» Non employment land use jobs created 1,400 jobs »» Strategic employment allocation jobs created 3,450 jobs

4.55 In addition to this job creation, the induced employment (multiplier effect) is assumed to create around a further 1,700 jobs within the wider economy.

V iability and Deliverability

4.56 The assessment of viability of the proposals has been carried out by Allen Dadswell who have a particular expertise in evaluating the viability of strategic projects where detailed design is to follow. A financial viability of the proposals for Bushwood were initially submitted confidentially to the JTU in March 2009. Due to the commercially sensitive information, an updated viability has not been submitted with these representations given the requirement for all representations to be open to public scrutiny.

4.57 As the Bushwood masterplan evolves, updated viabilities will be prepared, the results of which will be shared with the JTU so that this aspect of the evidence base can be properly taken into account.

4.58 The viability and therefore deliverability of the Luton West development has therefore been subject to more robust analysis than the preferred options tested through the DTZ assessment. The promoters of Luton West will continue to provide information on viability to the JTU as the process moves forward.

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The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

The Bushwood Masterplan

5.1 The masterplan for Bushwood has been developed from a sound and robust evidence base that has been summarised in the previous section and the evidence studies submitted with these representations. The key components of the masterplan are summarised below:

»» Community Stadium, Hotel and Conference Centre »» Dedicated public transport route through the development »» Lower, Middle and Upper schools »» Neighbourhood Centres and High Street »» Retirement Village »» Supermarket »» Sports Village incorporating multi-use indoor facilities and swimming pool »» A new ground for Luton Town Rugby Club »» A new pedestrian and cycle bridge over the M1 »» Strategic employment provision »» Open space provision »» Park and Ride facilities »» About 5,500 dwellings including 35% affordable homes

5.2 The evidence supporting the Luton West urban extension includes a masterplan document prepared by LDA Design which explains the approach taken to delivering a sustainable urban extension and the response to the sites characteristics that has emerged from the various evidence studies.

planning associates 9 3 Bushwood Masterplan

The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

14 19

2 1

17 4 18 2 15

18 3 4 LEGEND 13 11 1. Stadium, hotel, conference centre

2. Dedicated public transport route 6 18 7 3. Lower and middle school 2

4. Neighbourhood centre 5 17 5. High street 3 6. Retirement village 16 2 13 7. Supermarket 8

8. Academy school

9. Sport Village - multiuse indoor facilities 12 9 12 and swimming pool 17

10. Luton Town Rugby Club 18 12 11. New pedestrian and cycle bridge 13

12. Employment 18 4 13. Open space to include: parks, children’s play, sports facilities, ecological 3 landscape, allotments.

10 14. Park and ride

15. Landscape and habitat creation

16. High density housing 13 17. Retained woodland/ area of landscape value

18. Allotments

19. Luton Dunstable Busway

Bushwood 40 local solutions for local people Aerial Photography © Google Bushwood Masterplan

The Case for Bushwood (Luton West) BushwoodLuton & South Beds Core Strategy: Preferred Options Masterplan

14 19

2 14 19

2 1 5.3 Key elements of the Bushwood Masterplan are described below:

17 cOMMunity StaDiuM, hOteL anD cOnfeRence faciLitieS 2

17 4 18 2 15

2 18 1 3 4 LEGEND 13 11 1. Stadium, hotel, conference centre 17 2. Dedicated public transport route 6 18 5.4 The Luton West development presents a unique opportunity to deliver a new community 7 3. Lower and middle school 2 stadium. This facility could assist Luton Town Football Club (LTFC) in the event that they wish 4. Neighbourhood centre 5 to pursue their long term aspirations to relocate from Kenilworth Road to a new purpose built 17 5. High street 3 stadium. The existing ground is located within a densely3 populated area which, on match days, 6. Retirement village 2 13 creates substantial traffi c congestion problems. In the event that LTFC take the decision17 to 7. Supermarket 8 relocate to the Luton West site, the area identifi ed on4 the masterplan is an appropriate location 8. Academy school 2 for the following reasons: 18 9. Sport Village - multiuse indoor facilities 12 9 15 and swimming pool 17

10. Luton Town Rugby Club 18 12 » Close proximity to the proposed Park and Ride facilities off Hatters Way and the Luton 11. New pedestrian and cycle bridge 13 Dunstable Guided Busway to achieve access via public transport. 12. Employment 18 18 4 13. Open space to include: parks, 3 children’s play, sports facilities, ecological 3 » The proposed site is within 1.5 km of the existing ground. landscape, allotments. 4 LEGEND 13 10 14. Park and ride 11

15. Landscape and habitat creation 1. Stadium, hotel,» conferenceThe centresite is at a lower level and is screened by existing woodland planting to ensure that there is no impact on the AONB. 16. High density housing 2. Dedicated public transport route 6 18 13 17. Retained woodland/ area of landscape 7 value 3. Lower and middle5.5 schoolAn assessment of potential locations has been carried out which has concluded that Luton West 2 18. Allotments 4. Neighbourhoodpresents centre a unique opportunity for a new community stadium as the site is available, deliverable and5 19. Luton Dunstable Busway environmentally acceptable and presents the most appropriate location in all respects. 17 5. High street 3 6. Retirement village 2 13 Bushwood 7. Supermarket 8 local solutions for local people 8. Academy school planning associates 41 Aerial Photography © Google 9. Sport Village - multiuse indoor facilities 12 9 and swimming pool 17

10. Luton Town Rugby Club 18 12 11. New pedestrian and cycle bridge 13

12. Employment 18 4 13. Open space to include: parks, children’s play, sports facilities, ecological 3 landscape, allotments.

10 14. Park and ride

15. Landscape and habitat creation

16. High density housing 13 17. Retained woodland/ area of landscape value

18. Allotments

19. Luton Dunstable Busway

Bushwood local solutions for local people Aerial Photography © Google The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Bushwood Masterplan

DeDicateD buSWay

14 19

2 1

17 4 18 2 15 5.6 The masterplan shows the proposed route of a dedicated busway fully integrated with the Luton and Dunstable Guided Busway at two locations in the vicinity of the Toland Close 18 stop and at the roundabout junction of Hatters Way and Dallow3 Road. The dedicated busway 4 LEGENDcombined with off site bus priority measures on the connecting13 roads to Luton Town Centre will 11 1.deliver Stadium, hotel, an conference integrated centre public transport system to achieve the maximum PT share. 2. Dedicated public transport route 6 18 7 3. Lower and middle school 2

4. Neighbourhood centre 5 17 5. High street 3 6. Retirement village 2 13 7. Supermarket 8

8. Academy school

9. Sport Village - multiuse indoor facilities 12 9 and swimming pool 17

10. Luton Town Rugby Club 18 12 11. New pedestrian and cycle bridge 13

12. Employment 18 4 13.42 Open space to include: parks, children’s play, sports facilities, ecological 3 landscape, allotments.

10 14. Park and ride

15. Landscape and habitat creation

16. High density housing 13 17. Retained woodland/ area of landscape value

18. Allotments

19. Luton Dunstable Busway

14 19

Bushwood14 Masterplan

2 Bushwood Masterplan 14 19 2 14 1

17 14 19 4 2 14 18 15

2 1

18 3 17 2 4 LEGEND 13 11 1. Stadium, hotel, conference centre The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options 2. Dedicated public transport route 6 18 3 7 3. Lower and middle school 17 2 4 4. Neighbourhood centre 18 2 2 5 1 15 17 5. High street 3 6. Retirement village 2 17 13 7. Supermarket 8 18

8. Academy school 3 4 LEGEND 13 9. Sport Village - multiuse indoor facilities 1112 and swimming pool 3 9 1. Stadium, hotel, conference centre 17 17 18 2. Dedicated10. Luton Town public Rugby transport Club route 6 18 4 12 18 2 7 3. Lower11. New and pedestrian middle school and cycle bridge 13 15 2 12. Employment 4. Neighbourhood centre SPORtS faciLitieS 5 18 4 17 5. High13. Open street space to include: parks, children’s play, sports facilities, ecological 3 3 18 6. Retirementlandscape, allotments.village 3 2 13 10 7. Supermarket14. Park and ride 4 LEGEND 13 8 11 8. Academy15. Landscape school and habitat creation 1. Stadium, hotel, conference centre

9. Sport16. High Village density - multiuse housing indoor facilities 2. Dedicated public transport route 6 18 12 and swimming pool 9 13 17. Retained woodland/ area of landscape 17 7 3. Lower and middle school 10.value Luton Town Rugby Club 18 2 12 4. Neighbourhood18. Allotments centre 5 11. New pedestrian and cycle bridge 5.7 The masterplan identifi es a wide range13 of new sports facilities, strategically located within 17 5. High street 12.19. Employment Luton Dunstable Busway walking distance of the dedicated busway to achieve sustainable trips for those living in Bushwood 3 6. Retirement village and also the existing communities of18 Caddington, Slip End and from4 the wider conurbations. 13. Open space to include: parks, 2 children’s play, sports facilities, ecological 13 7. Supermarket 3 landscape, allotments. 5.8 Opportunities to achieve dual use with proposed8 education facilities are taken and also 8. Academy school 10 14. Park and ride combined trips with those seeking to access the High Street and the neighbourhood centres. In

9. Sport Village - multiuse indoor facilities this way, a sustainable community will be delivered. 12 15. Landscape and habitat creation 9 and swimming pool 17 Bushwood 16. High density housing 10. Luton Town Rugby Club 5.9 The current proposals include a 25 metre leisure pool which addresses18 both the 13 local solutions for local people 12 17. Retained woodland/ area of landscape requirements arising from the development and also helps to address existing defi ciencies. Aerial11. Photography New pedestrian © and Google cycle bridge value In the event that the proposals for an13 Olympic swimming pool at Stopsley are unable to go 12. Employment 18. Allotments forward, then the promoters of Bushwood would consider upgrading the 25 metre pool to an 18 4 13. Open space to include: parks, Olympic size pool but this is not currently part of the masterplan proposals. 19. Luton Dunstable Busway children’s play, sports facilities, ecological 3 landscape, allotments.

10 14. Park and ride

15. Landscape and habitat creation

16. High density housing 13 17. Retained woodland/ area of landscape Bushwood value local solutions for local people Aerial Photography18. Allotments © Google

19. Luton Dunstable Busway

planning associates 43

14 19

2 1

The Case for Bushwood17 (Luton West) Luton & South Beds Core Strategy: Preferred Options 4 18 2 15

18 3 4 LEGEND 13 11 1. Stadium, hotel, conference centre

2. Dedicated public transport route 6 18 7 3. Lower and middle school 2

4. Neighbourhood centre 5 17 5. High street 3 6. Retirement village StRategic eMPLOyMent aLLOcatiOn 2 13 7. Supermarket 8

8. Academy school

9. Sport Village - multiuse indoor facilities 12 9 12 and swimming pool 17

10. Luton Town Rugby Club 18 12 11. New pedestrian and cycle bridge 13

12. Employment 18 4 13. Open space to include: parks, children’s play, sports facilities, ecological 3 landscape, allotments.

10 14. Park and ride

15. Landscape and habitat creation 5.10 The masterplan identifi es areas for new employment which has been strategically located,

16. High density housing again maximising access to the dedicated guided busway, but also to ensure that in the worst case scenario involving the existing runway13 at LLA, then the consequential extended noise 17. Retained woodland/ area of landscape value shadow across the M1 would not impact on the proposed residential areas or other noise sensitive development such as schools, but would be confi ned to the area identifi ed for new employment. 18. Allotments

19. Luton Dunstable Busway 5.11 The evidence supporting this employment provision demonstrates how the aspirational target of delivering 0.9 jobs per new household created can be achieved.

44 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Regeneration Opportunities

5.12 The regeneration opportunities that the Bushwood proposals provide may be summarised as follows:

»» Forward funding of the Junction 10A improvements will enable proposals such as Ballymore’s extension of the Arndale Centre and Explore’s proposals at Napier Park to move forward.

»» Facilitating the relocation of LTFC from Kenilworth Road by identifying an opportunity site for a new community stadium will enable the regeneration of the Bury Park area and the delivery of much needed local affordable homes and traffic improvements.

»» Improvements to Brashe Sparta facilities.

»» Overspill parking for the L & D Hospital.

»» New and improved local community facilities in Dallow and Farley and a New Community Hub.

»» New overbridge linking the new Barnfield South Academy and the provision of new sports facilities.

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The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Comparison of Preferred Urban Extensions with Luton West

6.1 In Section 2 of these representations, we set out a comparison of the Luton East, North and West proposals against the objectives of the Milton Keynes and South Midlands Sub Regional Strategy. Below we identify some of the key differences between these three potential growth locations, tested against key environmental and planning considerations.

»» Deliverability – Both the Luton North and Luton East proposals require the provision of major new highways infrastructure, identified in the Transport Evidence Base as being unfunded and untested. In respect of Luton East in particular, the costs associated not just with the substantial length of by-pass required but also the need to cross Luton Airport make this option undeliverable. By contrast, the proposals for Luton West can assist with forward funding improvements to Junction 10A, but is not dependent upon other major infrastructure.

»» Landscape – Both the Luton North and Luton East proposals have a significant adverse impact on areas of high quality and sensitive landscape. In the case of Luton North, both the development itself and the new by-pass will have a significant effect on views in to and out of the AONB. The landscape east of Luton is rightly recognised as being of high quality, and the scale of development proposed (again including the proposed by-pass) would breach a key landscape threshold, namely over-topping the Breachwood Green ridge, resulting in a development area poorly related to the existing urban area, and exacerbating the extent to which the development encroaches in to the Hertfordshire countryside. By contrast, the proposals at Luton West utilise land recognised as being of moderate sensitivity, and as explained in our evidence base, would not adversely impact upon the AONB.

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A I G

F The Case for Bushwood (Luton West) D Luton & South Beds Core Strategy: Preferred Options B L

PROJECT Luton West – Area M

TITLE

» Green Belt – Luton West is the only development option that makes use of land that is not within the Green Belt. It results in far less Green Belt land being used when CLIENT compared to Luton East (more than 50% less land take), and (unlike Luton East) does not SCALE result in coalescence with any existing settlement. DATE

DRG NO. » Public Transport – Luton West is the only growth location that allows for a direct and JB jb planning associates Potential Areas of Development (indicative) Road Scheme (underunencumbered construction) connection with the Luton DunstableArea Guided NOT covered Busway. by the TheJoint Southextension Bedfordshire and Luton Local Development Framework Chells Manor, Chells Lane, Stevenage, SG2 7AA of Guided Busway services to Luton North is a token gesture only, since a bus route e-mail [email protected] url www.jbplanning.com Luton–Dunstable Guided Bus Way Proposed Road Schemes – 2 Options (no funding committed) tel 01438 312130fax 01438 312131 running east-west towards Houghton Regis will be of limited appeal, particularly given the © Crown copyright | All rights reserved | Licence No. 100039935 Proposed M1–A5 link (funding committed) Potential Road Schemeproposed (subject new to testing)road infrastructure which will make car use a more attractive alternative in any event (as proved by the Halcrow modelling). On road services to Luton Town Centre would require a bus trip of over 7km, and again would fare poorly when compared to the alternatives by car. Luton East is also a long way from the town centre (around 5.5 km), and again will be primarily dependent upon on-road services (the prospect of segregated bus services using a tunnel is highly unrealistic). Although Luton West will require a short section of on-road bus route to the town centre, the shorter distance (around 3km) plus the option of using the Luton Dunstable Guided Busway directly, make public transport an attractive alternative option.

» Sustainable Travel – Both Luton North and Luton East rely on the provision of substantial new highway capacity, which will both encourage car use as an alternative to public transport from the development sites, and will attract new vehicle trips to the area as a result of the new capacity, thereby encouraging non-sustainable travel modes;

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C The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options J11A H

A I G K F J D B C L J11A E H

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F Luton North – Area I Luton East – Area L D B » Walking and Cycling – whilst all three development locations will no doubt provide L for walking and cycling to on-site facilities, Luton West offers unrivalled access to E destinations within the existing urbanM area, via segregated pedestrian and cycle links across over the M1. Local employment, community, leisure and education facilities are all readily within walking and cycling distances. By the same token, residents from the existing communities will have access to the facilities provided within the new development, encouraging genuine two way linkages and encouraging walking and

PROJECT cycling within the existing population.

TITLE » Tackling Deprivation – Luton West is the closest of the three potential growth locations to the principal areas of deprivationM in Luton, and via investment both on and off-site, and the creation of new jobs and new facilities, is the only option that will make a direct and CLIENT signifi cant contribution towards assisting these communities. In contrast Luton North and SCALE Luton East are adjacent to the most affl uent Wards in the conurbation. DATE

DRG NO.

PROJECT » Unlocking the potential for urban regeneration – Luton West is the only growth JB jb planning associates Potential Areas of Development (indicative) Road Scheme (under construction) Area NOT covered by the Joint South Bedfordshire

TITLE location with the potential to provide a direct stimulus towards urban regeneration, Chells Manor, Chells Lane, Stevenage, SG2 7AA and Luton Local Development Framework e-mail [email protected] url www.jbplanning.com Luton–Dunstable Guided Bus Way Proposed Road Schemes – 2 Options (no funding committed) tel 01438 312130fax 01438 312131 including by unlocking the potential of key regeneration sites by forward funding

© Crown copyright | All rights reserved | Licence No. 100039935 improvements to Junction 10A, and by making provision for the potential relocation of Proposed M1–A5 link (funding committed) Potential Road Scheme (subject to testing) Luton Town Football Club to facilitate regeneration in Bury Park. The scheme also uses CLIENT ‘white’ land within the existing urban area of Luton. SCALE

DATE » Sports and Leisure – Luton West is the only growth location to provide sports and leisure DRG NO. facilities designed to meet the wider needs of the community, with a wide variety of exciting Potential Areas of Development (indicative) Road Scheme (under construction) Area NOT covered by the Joint South Bedfordshire JB jb planning associates opportunities for encouraging community participation in sporting and leisure activities. Chells Manor, Chells Lane, Stevenage, SG2 7AA and Luton Local Development Framework e-mail [email protected] url www.jbplanning.com Luton–Dunstable Guided Bus Way Proposed Road Schemes – 2 Options (no funding committed) tel 01438 312130fax 01438 312131

planning associates 49

The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Updating the Site Matrix

7.1 To assist in the selection of growth locations, Officers of the Joint Technical Unit prepared a Site Assessment Matrix, setting out broad findings in relation to each of the main potential growth locations against a range of environmental and technical criteria.

7.2 Unfortunately, this assessment was undertaken prior to the preparation of the new proposals for Luton West, and the assessment relates only to a hypothetical scheme prepared by the JTU for the smaller parcel of land referred to as ‘Area M’.

7.3 We have therefore taken the opportunity to update the Site Assessment Matrix having regard to the proposals set out in this submission. The results are shown in Appendix 1.

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The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

Conclusions

8.1 The Bushwood proposals represent a highly sustainable urban extension that warrants full and proper consideration as part of the preparation of the Core Strategy. It is important to acknowledge that the Luton West site brings with it, inherent advantages over Area M, identified by the JTU at the Issues and Options stage. Notwithstanding this, an important part of the JTU’s evidence, in the form of the Halcrow Employment Land Review, identified Area M as one of three appropriate locations for strategic employment provision. Luton West also has clear advantages over the other preferred locations for growth (especially Luton North and Luton East).

8.2 The sustainability credentials of the proposals are underpinned by the integration with and increased patronage of the Luton Dunstable Guided Busway to achieve deliverable sustainable public transport provision.

8.3 The other unique attribute of the Luton West location is its close proximity to key attractors such as Luton Town Centre, Parkway Station and London Luton Airport. The close proximity of the site means that for trips to the Town Centre cycling and walking are real alternatives to the use of the private car.

8.4 Overall, the Bushwood proposals represent a viable and deliverable urban extension, the inclusion of which within the Core Strategy will ensure its soundness.

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Appendix Proposed amendments to the JTU Site Assessment Matrix Some Opportunity development for between M1 and Caddington/Slip End, subject retention to important woodland, of avoidance impact on scarp of slope, and the appropriate mitigation to site boundaries. South East of the to site adjacent M1 to accompanied by extensive mitigation to M1 corridor to ensure separation urban areas. of Limited Limited constraints development. to Key (primarily woodland) features north and south to of site protected. to be Conclusion 1 Mix Mix of wooded, arable and pastoral farmland rolls down from chalk escarpment. Denuded hedgerow arable cover with fields. large Caddington scale Area open and is Woodside, Slip Aley centred Green End and around Slip Approaches with to End settlements suburban existing linked with additional more to development valley villages and landform. linear urbanisation of settlements of strongly roads. impacted of by major roads / M1 Eastern and influence greater of urban Caddington Luton. fringe Pylon line running & across the plateau Slip forms prominent a End visual feature. expanded modern post war settlements. Caddington Views to M1 from eastern and Slip part of area End affected by lighting, traffic noise are and a major junction both at Slip End. yet quality views exists to Winsdon Park Hill (to east). / and Stockwood links to smaller scale countryside in Herts. (to southwest / south). There are landscape value few that remain. intrinsic Limited views features to the of urban Dunstable with Escarpment. Chalk Dunstable the South edge positive of (NB additional text in Character Assessment this prepared on behalf of Bedfordshire section County taken from Council) LUC Landscape Predominantly Predominantly arable land and limited known value. biodiversity Land to the north and south of the paddocks with hedges. Overall area contains a number of woods and lanes. Two County Wildlife Sites at northern including a Sites Wildlife number ofCounty end of site, to be retained and protected. Assessment Factors Measurement Beds CC Assessment of landscape/LUC Landscape Impact Character Assessment on Beds CC Assessment of biodiversity/Developer Site Assessment Impact on

Impact Impact important areas of landscape on Impact Impact important areas of biodiversity on Site M Luton Site West M Luton Level Sector at Development of Impact - Development the of Suitability 1 1 Title Criteria Source Principal Site M Luton West

Assessment Factors 1 Criteria Title Principal Source Conclusion Measurement Mix of wooded, arable and pastoral farmland rolls down from chalk Some escarpment. Denuded hedgerow cover with large scale open Opportunity for arable fields. Area is centred around existing villages of development Caddington and Slip End with more linear settlements of between M1 and Woodside, Aley Green and Slip End linked to valley landform. Caddington/Slip Approaches to settlements suburban with additional development End, subject to and urbanisation of roads. Eastern Caddington & Slip End retention of strongly impacted by major roads / M1 and greater urban fringe important influence of Luton. Pylon line running across the plateau forms a woodland, prominent visual feature. Caddington and Slip End are both avoidance of Beds CC Assessment expanded modern post war settlements. Views to M1 from eastern impact on the Impact on of Impact on part of area affected by lighting, traffic noise and a major junction scarp slope, and important areas of landscape/LUC at Slip End. yet quality views exists to Winsdon Hill / Stockwood appropriate landscape Landscape Character Park (to east). and links to smaller scale countryside in Herts. (to mitigation to site Assessment southwest / south). There are few intrinsic features of positive boundaries. to landscape value that remain. Limited views to the urban edge of South East of the Dunstable with the South Dunstable Chalk Escarpment. site adjacent to M1 if (NB additional text in this section taken from LUC Landscape accompanied by Character Assessment prepared on behalf of Bedfordshire County extensive Council) mitigation to M1 corridor to ensure separation of urban areas.

Limited constraints to Predominantly arable land and paddocks with hedges. Overall development. Beds CC Assessment Impact on limited known biodiversity value. Land to the north and south of the Key features of Impact on important areas of area contains a number of woods and lanes. Two County Wildlife (primarily biodiversity/Developer biodiversity Sites at northern end of site, to be retained and protected. woodland) to Site Assessment including a number of County Wildlife Sites north and south of site to be Suitability of the Development the of Impact - Development Level Sector Development at Suitability of protected. 1 Assessment Factors 1 Criteria Title Principal Source Conclusion Measurement Nationally important Palaeolithic remains have been found in this Largely area and there are potential for contemporary deposits to survive unconstrained. Impact on Beds CC Assessment in their zone. Density and scale of development should be important areas of of Impact on moderated and designed to preserve the historic pattern of the heritage and heritage/Developer dispersed rural settlements. To the north of the site, the cultivation townscape Site Assessment terraces are an interesting and locally important archaeological feature, to be retained. The opportunity should be taken to manage the site. Views to Caddington largely contained by woodland and position Limited set back on plateau. Key spatial connections / views to be constraints to Beds CC Assessment conserved across the River Lee and Ver valleys to plateaus development. Impact on of Impact on beyond. Elevated location of Caddington needs to be taken into important views Landscape/Developer consideration regarding design / height of built forms and Site Assessment extensive mitigation.

Low No risk of flooding from rivers and surface water. Some Potential for Potential to flood or SFRA/Developer Site potential risk from ground water flooding requiring further some No impact on flood risk Assessment investigation, but no significant risks likely. constraints to areas. development Foul Water infrastructure constraints a cost to development The sewage treatment works at Caddington is not capable of Presence of major Constraints but included in sustainably supporting this scale of growth. This will require infrastructure Assessment/Developer developer’s substantive investment in new infrastructure to link it to the Hyde constraints Site Assessment viability Treatment works. Capacity exists at East Hyde. assessment.could significantly impact on sustainability. Site has good proximity to local facilities at Caddington and Slip Site is quite well Proximity to End. Centre of site lies approximately 1.5 km 2 miles from Farley located to local neighbourhood Accession/Developer Hill Local Centre and approximately 2.5 km miles from Luton town centres centre or local Site Assessment centre. Site also well placed in relation to other existing facilities centre such as new Academy. Masterplan provides wide range of on-site facilities. 2

Assessment Factors 1 Criteria Title Principal Source Conclusion Measurement Site has good proximity to local facilities at Caddington and Slip Site is quite well Social and Community End. Centre of site lies approximately 1.5 km 2 miles from Farley located to local Proximity to core Infrastructure Hill Local Centre and approximately 2.5 km miles from Luton town centres facilities1 Assessment/Developer centre. Site also well placed in relation to other existing facilities Assessment such as new Academy. Masterplan provides wide range of on-site facilities.

3 Assessment Factors 1 Criteria Title Principal Source Conclusion Measurement Nationally important Palaeolithic remains have been found in this Largely area and there are potential for contemporary deposits to survive unconstrained. Impact on Beds CC Assessment in their zone. Density and scale of development should be important areas of of Impact on moderated and designed to preserve the historic pattern of the heritage and heritage/Developer dispersed rural settlements. To the north of the site, the cultivation townscape Site Assessment terraces are an interesting and locally important archaeological feature, to be retained. The opportunity should be taken to manage the site. Views to Caddington largely contained by woodland and position Limited set back on plateau. Key spatial connections / views to be constraints to Beds CC Assessment conserved across the River Lee and Ver valleys to plateaus development. Impact on of Impact on beyond. Elevated location of Caddington needs to be taken into important views Landscape/Developer consideration regarding design / height of built forms and Site Assessment extensive mitigation.

3 Assessment Factors 1 2 Criteria Title Principal Source 1 Score Measurement This site lies primarily beyond the M1. The principle congestion problem areas within the vicinity of this site are around the town Limited on and Contribution to the Luton and South centre and the access roads to Junction 10a, and to the north at Significant off improvement and Bedfordshire LDF Hatters Way. The roads linking the site to the urban area are site easing of congestion Transport constrained by the presence of the M1 and Stockwood Park contributions in in known problem Appraisal/Developer which will put significant pressure on existing roads. Access on to form of Junction areas1 Assessment junction 10a will be difficult to achieve. Proposals include 10a measures to relieve congestion at Junction 10a and to improve improvements. flows on Hatters Way. The current level of public transport provision in this area is limited and the scale of the proposed development will therefore assist significantly in raising demand. However, the constraints of Luton and South the road network are considered to limit the scope and capacity to Contribution to the Bedfordshire LDF deliver these services, particularly to Luton Town Centre. Some improvement of Transport Appraisal Significant scope exists to provide dedicated public transport links Significant on existing public Bus through the site, integrating with the Luton Dunstable Guided Bus and off site transport provision Operators/Developer to the north, and with the town centre, airport, and key contributions Assessment employment locations to the south. Closest of all the urban extension options to Luton Town Centre, helping to reduce journey times (along with bus priority measures) and increase the attractiveness of public transport when compared to the car. Transport Officer The development of site would not directly contribute to the Contribution to the Luton and South delivery of the extension of a high quality public transport network No or limited delivery of major Bedfordshire LDF serving the south and west of Luton with the objective of Significant transport Transport achieving significant modal shift and high levels of public contribution infrastructure Appraisal/Developer transport patronage. major infrastructure improvements unless Assessment contributions are made by CIL or similar. Contribution to The area currently has some access across the site and to Significant on delivery of strategic neighbouring AONB. The development of this site offers G I Plan and off site Green Infrastructure significant opportunity to deliver strategic green infrastructure in

Suitability of Development - Contribution of Development at PAD PAD at Level Development of Suitability of Contribution Development - contribution provision this location.

The scale of potential development on the site is capable of Contribution to Social and Community supporting significant additional social and community Some meeting social and Infrastructure infrastructure. The presence of the M1 does not means that Significant on community Assessment/Developer linking this new infrastructure with the existing urban area will be and off site infrastructure needs Assessment difficult, due to the number and quality of existing/proposed contribution linkages. The scale of potential development on the site is capable of supporting significant additional open space provision. The Some Contribution to Green Space existing area already has reasonable access to open space owing Significant on meeting existing Strategy/Developer to Stockwood Park. The presence of the M1 does not means that and off site open space needs Assessment linking this new infrastructure with the existing urban area will be contribution difficult, due to the number and quality of existing/proposed linkages. This Area was identified as a potential location for new employment land in the Employment Land Study owing to potential access and links with the airport. its proximity to the M1 but it recognised that this was dependent on being able to again access from the M1 Junction 10a. At present no solutions have Contribution to Limited Employment Land been identified that would secure this access. Proposals include provision of strategic Significant on Study/Developer provision of high quality public transport services connecting with employment land and and off site Assessment and extending the Luton-Dunstable Guided Busway, alongside premises. contribution improvements to access (including resolution of congestion issues at Junction 10a), creating desirable location for business with close links to existing key employment areas. Links with existing deprived areas and multiplier effect likely to have significant benefits for neighbouring communities. Contribution to The scale of the potential development means that this site offers Significant on affordable and local Housing Needs significant potential to contribute to the affordable housing needs and off site housing needs of the Surveys/ SHMA of the area. contribution area. Contribution to the delivery of an Water Cycle Study & The scale of the proposed development could provide the critical Significant on integrated Resource Efficiency scale and mass needed to support significant new sustainable and off site sustainable Study infrastructure and renewable energy technology contribution infrastructure system

5 Assessment Factors 1 2 Criteria Title Principal Source 1 Score Measurement This site lies primarily beyond the M1. The principle congestion problem areas within the vicinity of this site are around the town Limited on and Contribution to the Luton and South centre and the access roads to Junction 10a, and to the north at Significant off improvement and Bedfordshire LDF Hatters Way. The roads linking the site to the urban area are site easing of congestion Transport constrained by the presence of the M1 and Stockwood Park contributions in in known problem Appraisal/Developer which will put significant pressure on existing roads. Access on to form of Junction areas1 Assessment junction 10a will be difficult to achieve. Proposals include 10a measures to relieve congestion at Junction 10a and to improve improvements. flows on Hatters Way. The current level of public transport provision in this area is limited and the scale of the proposed development will therefore assist significantly in raising demand. However, the constraints of Luton and South the road network are considered to limit the scope and capacity to Contribution to the Bedfordshire LDF deliver these services, particularly to Luton Town Centre. Some improvement of Transport Appraisal Significant scope exists to provide dedicated public transport links Significant on existing public Bus through the site, integrating with the Luton Dunstable Guided Bus and off site transport provision Operators/Developer to the north, and with the town centre, airport, and key contributions Assessment employment locations to the south. Closest of all the urban extension options to Luton Town Centre, helping to reduce journey times (along with bus priority measures) and increase the attractiveness of public transport when compared to the car. Transport Officer The development of site would not directly contribute to the Contribution to the Luton and South delivery of the extension of a high quality public transport network No or limited delivery of major Bedfordshire LDF serving the south and west of Luton with the objective of Significant transport Transport achieving significant modal shift and high levels of public contribution infrastructure Appraisal/Developer transport patronage. major infrastructure improvements unless Assessment contributions are made by CIL or similar. Contribution to The area currently has some access across the site and to Significant on delivery of strategic neighbouring AONB. The development of this site offers G I Plan and off site Green Infrastructure significant opportunity to deliver strategic green infrastructure in

Suitability of Development - Contribution of Development at PAD PAD at Level Development of Suitability of Contribution Development - contribution provision this location.

5 The site lies within the primary catchment area and close proximity to Luton Town centre which is in need of regeneration. The scale of potential development in this area is likely to be Contribution to the Town Centre significant and could make a significant contribution to the regeneration of the Some Strategies, Retail improvement and vitality of the town centre if appropriate access town centres of Significant Study/Developer can be achieved. At present no solutions have been identified that Luton, Dunstable, contribution Assessment would secure this access Proposals include provision for Houghton Regis improved access between the development area and town centre, in particular via the extended strategic bus network. Closest of all urban extension options to the Town Centre. The site lies within the vicinity of the priority ward of Farley Hill but is segregated by the M1. The potential development of new facilities and employment opportunities, as well as off site Contribution to contribution to existing facilities, could make a significant Regeneration Limited on and reinvigoration and contribution to the regeneration and rejuvenation of this ward. if plans/Developer Significant off rejuvenation of access can be achieved. At present no solutions have been Assessment site contribution deprived wards identified that would secure this access Proposals achieve close integration notwithstanding the M1 due to number and quality of linkages, including pedestrian/cycle links as well as public transport and vehicle links. Limited Good Urban Design The severance presence of the M1 does not makes integration potential for Potential to contribute Guidance/Developer with the existing urban area difficult to achieve, due to the number place shaping to place making. Assessment and quality of existing/proposed linkages. related to urban area. The site lies within the Green Belt. The development of this site would reduce the openness of the area and the extent of separation between Caddington and Slip End, but Masterplan proposals show green space retained to provide separation and a No Limited setting to both settlements, which can retain a separate identity. Contribution to Green Belt contribution in Proposals offer an effective use of land which minimises Green retention Green Belt Review/Developer terms of Belt land take, whilst scheme also uses land within Luton principles Assessment avoiding Borough already excluded from the Green Belt. and lies beyond coalescence. the M1 which forms a physical barrier to development. The development of this site would significantly reduce the openness of this area and could lead to the coalescence of the settlements of Caddington and Slip End.

Assessment Factors 3 Criteria Title Principal Source Score Measurement Developers Forum The majority of Site M is in the control of a number of different Availability of the landowners which may delay the delivery of the site. Unknown Legal land for development The Area is in control of multiple landowners in a consortium and is Immediately Contracts/Developer being promoted by a developer. Assessment This site is mainly agricultural land so it is unlikely to be Contamination of the Contaminated Land contaminated. Some minor contamination could exist near to farms Immediately land Assessment but this is unlikely to be at a significant scale. Initial conclusions show that development would require upgrading Water Cycle and of utilities infrastructure works. However, likely that initial phases Within 5 years Availability of utilities Energy Resource (e.g. east of the M1) could be served from existing services. could with phasing or infrastructure Study/Developer cause significant issues for utilities infrastructure in this area which within 5 to 10 Assessment may delay the commencement of development and impact on the years. phasing. Transport Officer Access arrangements into the site from the existing urban area are Highways Authority not suitable or capable of accommodating significant numbers of Unknown Suitability of access Luton and South new development without upgrade. At present no solutions have Immediately arrangements Bedfordshire LDF been identified that would secure this access. available which will phasing Transport enable the early delivery of the site, alongside highway and public Appraisal/Developer transport enhancements. Assessment Developers The lack of an appropriate means of accessing the site coupled Within 5 years Physical Constraints Submissions/ with the uncertainty of the infrastructure to connect the area to the with phasing or addressed Forums/Developer sewage treatment works could significantly delay the development within 5 to 10 Assessment of the site None to be addressed years. Transport officers Access arrangements into the site from the existing urban area are available which will enable the early delivery of the site, alongside Dependence on Unknown Highways Agency highway and public transport enhancements. Proposals are not Major Transport Within 5 years Luton and South dependent upon major new road construction. At present no Infrastructure with phasing Bedfordshire LDF solutions have been identified that would secure access to this Deliverability of development – Delivery within the plan period PADat period Level plan within the Delivery – Deliverability development of Transport Appraisal site. This could significantly delay the delivery of development.

7 The site lies within the primary catchment area and close proximity to Luton Town centre which is in need of regeneration. The scale of potential development in this area is likely to be Contribution to the Town Centre significant and could make a significant contribution to the regeneration of the Some Strategies, Retail improvement and vitality of the town centre if appropriate access town centres of Significant Study/Developer can be achieved. At present no solutions have been identified that Luton, Dunstable, contribution Assessment would secure this access Proposals include provision for Houghton Regis improved access between the development area and town centre, in particular via the extended strategic bus network. Closest of all urban extension options to the Town Centre. The site lies within the vicinity of the priority ward of Farley Hill but is segregated by the M1. The potential development of new facilities and employment opportunities, as well as off site Contribution to contribution to existing facilities, could make a significant Regeneration Limited on and reinvigoration and contribution to the regeneration and rejuvenation of this ward. if plans/Developer Significant off rejuvenation of access can be achieved. At present no solutions have been Assessment site contribution deprived wards identified that would secure this access Proposals achieve close integration notwithstanding the M1 due to number and quality of linkages, including pedestrian/cycle links as well as public transport and vehicle links. Limited Good Urban Design The severance presence of the M1 does not makes integration potential for Potential to contribute Guidance/Developer with the existing urban area difficult to achieve, due to the number place shaping to place making. Assessment and quality of existing/proposed linkages. related to urban area. The site lies within the Green Belt. The development of this site would reduce the openness of the area and the extent of separation between Caddington and Slip End, but Masterplan proposals show green space retained to provide separation and a No Limited setting to both settlements, which can retain a separate identity. Contribution to Green Belt contribution in Proposals offer an effective use of land which minimises Green retention Green Belt Review/Developer terms of Belt land take, whilst scheme also uses land within Luton principles Assessment avoiding Borough already excluded from the Green Belt. and lies beyond coalescence. the M1 which forms a physical barrier to development. The development of this site would significantly reduce the openness of this area and could lead to the coalescence of the settlements of Caddington and Slip End.

7 The Case for Bushwood (Luton West) Luton & South Beds Core Strategy: Preferred Options

planning associates town planning and development consultants

Chells Manor Chells Lane STEVENAGE SG2 7AA

01438 312130 www.jbplanning.com