Legal & General Property Representations on soundness Economy, Airport, Green Belt and landscape policies of the Draft Luton Local Plan for Public Consultation (2011-2031)

Savills August 2014 August 2014

Representations on Behalf of Legal & General Property

Economic, Airport, Green Belt and Landscape Policies of the Draft Luton Local Plan (2011 – 2031)

Soundness

1. Introduction

1.1. This Statement of Representation is submitted by Savills UK Limited on behalf of

Legal & General Property (LGP) in relation to Policy LP 4 (Green Belt), Policy LP 29

(Landscape and Geological Conservation); Policy LP 6 (London ), Policy

LP 31 (Sustainable Transport Strategy), the Key Diagram and Policies Map, and

Policy LP 13 (Economic Strategy) of the Draft Luton Local Plan for Public

Consultation (2011 – 2031) (June 2014) (DLLP). The representation justifies why it is

considered that the DLLP is not sound in relation to these policies.

1.2. LGP owns approximately 23 ha of land at Someries Farm occupying a strategic

location south of London Luton Airport with direct frontage to the Airport operational

boundary. Appendix 1 contains a Site Location Plan and a copy of the DLLP Key

Diagram showing a proposed amendment.

1.3. The Statement is arranged in the following sections:

• Section 2 sets out the case on soundness – this addresses economic, Airport, Green Belt, landscape, and site specific considerations.

• Section 3 provides conclusions.

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2. Soundness – Economic Policies, Green Belt and Airport

Economic policies

2.1. The economic strategy seeks to provide land that can deliver about 18,000 B class

jobs over the plan period to 2021. This is below the target identified to achieve

Luton’s economic growth potential (20,000 jobs), so a constrained target was

adopted to reflect the ‘limited supply of employment land’. It identifies several sites

for this purpose at Butterfield Green Technology Park, Napier Park, Stockwood Park

and Century Park east of London Luton Airport (Policy LP 13).

2.2. The Luton Employment Land Review (ELR) confirms the available employment land

in Luton, including a new site associated with the relocation of Luton Town FC to

Stockwood Park near M1 Junction 10A, as being 69.2 ha: these produce a total of

275,370 sq m of floorspace. Table 7.2 of the ELR provides a quantitative

assessment of the demand and supply of employment floorspace, finding a shortfall

of floorspace/land up to 2031 under two of the growth scenarios. It also states that a

large proportion of the available land supply is at Napier Park (40,000+ sq m);

Century Park (150,000 sq m) and Butterfield Park (55,700 sq m) and concludes (para

7.8) by stating that ‘if some of these large sites did not deliver over the plan period...

this could mean a sizable deficit under all scenarios.’ Para 7.12 specifically refers to

Century Park stating it ‘requires costly infrastructure before development can take

place, including provision of a new access road which could involve a new surface

road or a tunnel beneath Luton Airport...the prospects of this new road being

developed in the medium term appear uncertain...there appears some risk of this site

not coming forward in the next 20 years or not delivering all its potential floorspace in

that period’.

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2.3. A key reference figure that can be derived from the Luton ELR is that the deficit of B

class employment space arising under the different growth scenarios ranges from

47,230 - 83,430 sq m (Table 7.2). Using the plot ratio indication set out at para 7.4 of

the ELR (1 ha produces approx 4,363 sq m) an unmet employment land

requirement of between 10 and 19 ha would be produced.

2.4. There are significant concerns over the deliverability of Century Park east of London

Luton Airport: this relates to the need to fund a tunnel under the airport to gain

access to the land. The 42 ha would need to generate funds of £1,190,000/ha to

fund £50,000,000 of abnormal infrastructure costs (tunnel) without other costs being

taken into account. This makes the site undeliverable without additional development

land as a source of extra funding: such land has been proposed in North

Hertfordshire’s area east of the airport, but has not been progressed by that Council.

2.5. The land south of the Airport could address the unmet need for employment land;

provide land specifically to meet the growing needs of the Airport for landside

facilities and aviation / airport-related uses, and in part to compensate for the

undeliverable land at Century Park. The Airport is currently the subject of proposals

to expand its operation to 18 million passenger per annum (mppa): with this will come

demand for land to accommodate primary, secondary and catalytic employment

related to the Airport’s growth. The site could be accessed via a new road from the

airport access road network (Airport Way) and the Airport (landside access) to serve

23 ha of employment development on land well related to the Airport. Policy LP 13

should be amended to include this site for aviation / airport related employment uses.

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Green Belt

2.6. The site forms part of the Green Belt south of Luton known as Someries identified in

Policy LP 4 (Green Belt). The land forms part of a flat plateau area south of the

Airport; land to the south east and south falling away towards Lower Harpenden

Road and Chiltern Green. The site therefore forms a relatively discrete area more

closely related to the Airport than the surrounding landscape to the south east and

south. The principle of releasing land from the Green Belt around Luton has been

established through the release of significant areas of land to accommodate the

SUEs north of Luton and , and east of Leighton in the

Development Strategy for Central . In this context, it is considered that

the site could be released from the Green Belt without prejudicing the purpose of the

Green Belt in this area as noted at paragraph 80 of the NPPF.

Area of Local Landscape Value (ALLV)

2.7. The site is identified as one of several Areas of Local Landscape Value (ALLV) under

Policy LP 29. The site is located adjacent to and at the same level as the Airport; it

has very limited landscape qualities; is not a tranquil area; is isolated from the town

by the Airport, and is topographically distinct from the wider landscape to the south.

Based on these characteristics, it is considered that its identification as a candidate

ALLV through the Luton Landscape Character Assessments (2013) was not justified.

Furthermore, the land to the south within Council is no longer

proposed as an Area of Great Landscape Value (AGLV) in the emerging

Development Strategy for Central Bedfordshire (DSCB): is instead identified as a

Green Infrastructure Priority Area within which the intention is to secure contributions

from acceptable development to provide expanded / enhanced green infrastructure.

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On this basis, the site should be removed from the ALLV list in Policy LP 29 (‘(viii)...

Land south of the Airport’).

London Luton Airport

2.8. Policy LP 31 (Sustainable Transport Strategy) supports the continued economic

success of the Airport with reference to safeguarding related highway capacity and

surface access potential. The Policy goes on to identify Safeguarded Land for

strategic infrastructure schemes, including the tunnel to serve the Century Park site.

If the land south of the Airport is identified for employment use related to the Airport,

then Policy LP 31 would need to be amended to include this as a strategic

infrastructure scheme. Policy LP 6 (London Luton Airport) identifies Century Park for

airport and aviation related uses. Given the uncertainty surrounding the deliverability

of this site, the policy should be amended to identify the land south of the Airport for

airport or aviation related uses consistent with the need for more employment land

noted in this Statement.

Soundness

2.9. Given the quantitative and qualitative deficiencies in the employment provision in the

DLLP, it is considered that it is not sound as it has not addressed the objectively

assessed need for employment land. Further, with Century Park being undeliverable,

the DLLP has not addressed the employment land requirements related to the

Airport.

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3. Conclusion

3.1. For the reasons stated in this Statement, the DLLP is not considered to be sound. It

was not therefore positively prepared taking account of the quantitative and

qualitative need for employment land; has not been prepared on a credible evidence

base; does not contain the most appropriate economic strategy; is not effective

insofar as some provisions are undeliverable; does not incorporate a flexible

approach to employment land provision to accommodate changes in circumstances,

and is inconsistent with the guidance in the NPPF on building a strong and

competitive economy.

3.2. The site south of London Luton Airport is well placed to address the employment land

deficiencies of the DLLP: it can provide a high quality site to serve the needs to the

Airport; it can provide a more flexible employment land strategy; it can compensate

for the Century Park site, and it can support the growth of the Airport up to and

beyond 18 mppa. The site could be release from the Green Belt without prejudicing

the purpose of the Green Belt in this area.

3.3. In order to address the soundness issues noted above, the policies of the DLLP

should be amended as follows:

• Include for employment use in Policy LP 13, and in Policy LP 6 as ‘Land south of London Luton Airport, E’.

• Delete ‘Someries’ from the list of Green Belt locations listed in Policy LP 4 and delete ‘Land south of the Airport’ from the ALLV list in Policy LP 29.

• Add ‘London Luton Airport Strategic Allocation – access from Airport Way;’ to the list of Safeguarded Land at Policy LP 31.

• Amend the Key Diagram to show the land south of the Airport as part of the SA and not Green Belt (Appendix 1) and make the equivalent change to the Policies Map.

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Appendix 1 Land south of Luton Airport Site Location Plan Amended Key Diagram

Savills August 2014

Addition to SA and removal from Green Belt