In terms of Infant Mortality Rate (IMR) - deaths up to 1 year per 1,000 live births, Luton and South has mixed results compared to the 2004 national (5.1%) and regional averages (4.2%)54. In 2003 Luton records a figure of 4.2% and South Bedfordshire 5.9%55. (2004 IMR rates for Luton and South Bedfordshire are not currently available). IMR as a whole can be used as a proxy measure against which deprivation can be measured.

Table 3.25 shows the percentage of resident population that classify themselves as being in either good, fairly good or not good health, it also provides the percentages of people working age with a limiting long term illness.

54 ONS, http://www.statistics.gov.uk/cci/nugget.asp?id=1154 55 audit commission, http://www.areaprofiles.audit-commission.gov.uk/ (wqzntt3yqdqb3xmvfg4bhu45)/DetailPage.aspx?entity=10001026

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56 Table 3.25: Health conditions (2001)

South East of Luton Bedfordshire England

People of a working age with a limiting long term illness (%) 12.33 10.13 11.4 13.29 General health: good (%) 69.64 72.34 70.35 68.76 General health: fairly good (%) 22.31 20.84 22.05 22.21 General health: not good (%) 8.05 6.82 7.6 9.01

Approximately 1 child in every 7 lives in a low income household in South Bedfordshire, whereas in Luton, 1 in every 4 children (approximately 11,000) live in low income households.57

The LDF will need to consider how health profiles and demand for services will alter resulting from the growth proposals. Individual living conditions will also change as people move through the life cycle. Deprivation is not a static phenomenon; people move in and out of it.

3.12.1 Trends The proportion of people that describe themselves as being in good health in Luton and South Bedfordshire is approximately 71% which is above the national (69%) and regional average (70%).

Further to this, health inequalities in Luton and South Bedfordshire prevail with a 5.2 year life expectancy gap between the worst and best wards in South Bedfordshire and 5.9 years in Luton.

3.13 Material Assets Material assets include resources such as land, building materials and other resources, many of which are non-renewable. This topic is concerned with the efficient use of resources, including the re-use of brownfield sites

56 National Statistics, Cited November 2006 http://neighbourhood.statistics.gov.uk/dissemination/LeadKeyFigures.do?a=5&b=276882&c=south+bedfordshire&d=13 &e=6&g=423906&i=1001x1003x1004&o=219&m=0&enc=1 57 Department of Health website, Cited November 2006, http://www.communityhealthprofiles.info/profiles/09UE-HP.pdf

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and sustainable waste management. Waste is the “flip-side” of the consumption of material assets, and is itself a symptom of resource depletion. This is aggravated by the disposal of material to landfill which, in turn, uses up valuable land. Waste is recognised as being an opportunity for resource recovery (through re-use and recycling for example).

3.13.1 Previously Developed Land (PDL) The national target is that 60% of new housing is to be on built on PDL. Luton and South Bedfordshire both perform particularly well in relation to this target. 98.9% of new homes in South Bedfordshire and 100% of new homes in Luton between 2004 and 2005 were built on PDL. This is a good performance when compared to the National average of 73.5%58.

3.13.2 Waste Table 3.26 indicates the recycling habits and waste production of households in Luton and South Bedfordshire compared to the UK. From this data it can be seen that the percentage of household waste recycled and composted has increased between 2003 and 2006. However, the amount of household waste collected per head has increased. The cost of collection per household has also risen since 2003/04.

Table 3.26: Recycling Rates59

Luton Luton South South 2003- 2005- Bedfordshire Bedfordshire 2004 2006 2003-2004 2005-2006 UK 2003-2004 UK 2005-2006 % Household waste recycled 14.3 15.2 15 15.7 15.2 17.6 % Household waste composted 6.3 9.6 0.5 13.5 6.5 9.1 Kg household waste collected per head 429.4 480.2 429.5 453.2 444.5 438.5 Cost of waste collection per household (£) 52.1 52.8 40 42 43.4 47.7

58 Communities and Local Government, cited Nov 2006, http://www.bvpi.gov.uk/pages/keyFacts_BVPI.asp?lastpage=1&aid=119 59 http://www.bvpi.gov.uk/pages/keyFacts_BVPI.asp?lastpage=1&aid=119

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3.13.3 Trends The percentage of household waste recycled, composted and amount of waste being collected is increasing.

3.14 Cultural Heritage In order to plan for the future it is necessary that we understand the past. Historical assets are irreplaceable and enrich our understanding of the past and present. They help record local distinctiveness, to create an attractive environment and are of considerable tourism and recreational value. Development should reflect local character in the use of building materials, the relationship of buildings to one another and to the surrounding landscape. Luton and South Bedfordshire contain many buildings of historic quality and interest. Including:

ƒ 26 Scheduled Ancient Monuments (24 in South Bedfordshire60 and 2 in Luton61)

ƒ 619 listed buildings (518 in South Bedfordshire and 101 in Luton)

ƒ 26 Conservation Areas (22 in South Bedfordshire and 4 in Luton)

ƒ Three registered Historic Parks and Gardens- Putteridge Bury - Luton, Grade II, Wardown Park - Luton, Grade II and Luton Hoo – South Bedfordshire, Grade 2 **

3.15 Landscape Landscape character contributes to the quality of place at the regional, county and local levels. Luton and South Bedfordshire encompasses a varied landscape including a dramatic chalk escarpment, rolling chalk farmlands, chalk valleys, greensand ridges and valleys, and clay hills.

60 South Bedfordshire Annual Monitoring Report, South Bedfordshire District Council, 2004/2005, cited November 2006, http://www.southbeds.gov.uk/lgcl-environment/planning/pdf/SouthBedfordshireDistrictCouncil- AnnualMonitioringReport.pdf 61 Luton Borough Council, Cited November 2006, http://www.luton.gov.uk/internet/business/economic_development/Environment%20and%20Heritage

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The Countryside Agency’s Character of England Map identifies 3 national Countryside Character Areas within Luton and South Bedfordshire, the Chilterns, the Bedfordshire Greensand Ridge and the Bedfordshire and Cambridgeshire Claylands. These Character Areas are illustrated on the map overleaf. The detailed Draft South Bedfordshire District Landscape Character Assessment Report (June 2006) identifies 8 distinctive landscape character types and 24 landscape character areas reflecting more subtle changes in character relating to topography, geology, soils, land use, woodland pattern etc.

Landscape features such as the escarpment, small patches of ancient woodland, historic field patterns, flood meadows, parkland, historic settlements and buildings, and other intrinsic landscape qualities including small pockets of tranquillity all contribute to local character and distinctiveness. However parts of the farmland landscape have been affected by intensive arable farming with an associated loss of hedgerow boundaries, ponds, wetlands and natural grassland. In addition there are localised parts of the landscape that have been affected by minerals extraction-chalk and sand and gravel,

Luton and South Bedfordshire includes the nationally designated Chiltern’s AONB, south of Luton and , and to the north east an outlier of this AONB. It also includes a number of Areas of Great Landscape Value e.g. north of and south of Luton, as well as Areas of Local Landscape Importance. (However it should be noted that current government policy in PPS7 is that the justification for retaining more local designations needs to be rigorously assessed).

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Mid Bedfordshire

9C

6A 9C

8A 7B 10B 10C 6A 9D

8A 7B South Bedfordshire 5A 9B Luton 8B 9E

10A 11D 11B 9A 12B 12D 12C

11A 11C

Urban Areas Landscape Character Areas 12A 5. Clay Vales 10. Rolling Chalk Farmland 5A: 10A: - Dunstable Downs 5B: Barton-le-Clay 10B: - North Luton 6. Wooded Greensand Ridge 10C: Barton Hill 6A:Woburn 11. Chalk Dipslope 7. Greensand Valley 11A: 7B: Ouzel 11B: - 8. Clay Hills 11C: Luton Hoo 8A:Toddington - 11D: - Chiltern Green 8B: Billington 12. ChalkValleys 8C: Harlington - 12A: Gade 9. Chalk Escarpments 12B:Ver 9A: Dunstable Downs 12C: Slip End 9B:Totternhoe 12D: Lea 9C:The Clappers 9D:Warden Hill - Stopsley Common 9E: South Dunstable

Key

County boundary District boundary

1km 4km Source: South Bedfordshire Landscape Character Assessment, Landuse Consultants

3.16 Townscape The townscape of the area is equally varied with Luton and Dunstable and Leighton Buzzard including to different extents historic market town centres, Victorian terraces, high rise estates, large scale industrial estates/business parks and a range of 20th century suburban townscapes. Some of these areas have distinctive historic qualities (designated as Conservation areas-see Cultural heritage section) and/or are of good design, whilst others have considerable potential for regeneration and enhancement. Major historic parks and other open spaces are also a distinctive feature of some townscapes, although in others their current visual quality is poor. Small villages and hamlets within South Bedfordshire include distinctive historic townscapes and settings but some closest to the main urban areas have been particularly affected by suburban development,

Consultation question Q2: Are there any other issues or information related to the topics covered in sections 3.4 to 3.16 that are relevant to the Core Strategy and Growth Area DPDs that should be included?

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4 Stage A3- Identifying Environmental and Sustainability Issues

4.1 Introduction The SEA Directive has a requirement to identify and list any relevant existing environmental problems. As defined in the SEA Directive:

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

“any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC [the ‘Birds Directive’] and 92/43/EEC [the ‘Habitats Directive’]” (Annex 1(d))

The review of plans and programmes and the collation of environmental baseline data informed the identification of environmental problems or issues that could be addressed by, or affect the LDF. Such issues, problems and opportunities have been confirmed through:

• Review of the baseline data and plans and policies, and;

• Tensions/ inconsistencies with other plans, programmes and sustainability objectives.

These are illustrated in Table 4.1 overleaf. The issues have been arranged under the three broad pillars of sustainability- social, economic and environmental and SEA Topic.

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Table 4.1: Luton and South Bedfordshire Key Issues and Opportunities

SEA/SA Topic Key Issues Opportunities Inter relationships ECONOMIC FACTORS

• Decline in the manufacturing sector however • Regenerate existing town and local • Good economic base creates the impact of this loss has been reduced by centres opportunities for the local the growth in the Service sector population and address • Provide a range of quality employment issues. This further • Failure to provide appropriate transport employment sites and employment has effect in improving the infrastructure will prevent economic potential opportunities throughout Luton and general living standards of being fulfilled and will cause congestion South Bedfordshire people

• Unemployment rate varies across Luton and • Support employment opportunities in • Qualification has a direct South Bedfordshire. Unemployment in Luton higher value activities, e.g. implication on employment and is 7.3% and South Bedfordshire is 4.1% knowledge based industries skill development for the economy • High number of VAT registered businesses in • Provide a range of employment sites Luton and South Bedfordshire in 2005- above that will be attractive to knowledge • Improved vehicular movement regional and national averages based and high tech industries (such attracts residential and as Butterfield) commercial investors • Earnings across Luton and South Bedfordshire vary- £430.30 gross weekly pay • Raise skills base in Luton and £510.30 gwp in South Beds • Provide premises for an Enterprise Hub

• London Luton Airport is a key economic asset to Luton and South Bedfordshire and the planned expansion will offer further economic benefits

• Growth agenda offers opportunity to improve east-west links across Luton and South Bedfordshire

• Rural diversification

• Ensure that employment buildings are ICT Enabled

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SEA/SA Topic Key Issues Opportunities Inter relationships SOCIAL FACTORS • The number of households in Luton and • Promote and provide accessible • Low levels of education affect South Bedfordshire is set to rise by community facilities – plan for new economic opportunities and approximately 23% by 2021 and a further transport modes and infrastructure thereby income levels impacting 13% by 2031 the social status of people • Regenerate deprived areas • Average house prices are below the UK • Good access to various average • Need to ensure access to services services like schools, health and amenities for existing and new facilities reduces chances of • House prices to income ratio is below regional residents deprivation. If the access is and national average- making it a relatively linked to public transport, affordable place to live • Adopt ‘planning out crime’ design potential to reduce traffic principles, e.g. encourage volumes and improve • Rural accessibility-poor east-west overlooking of space etc environmental conditions exists

• Luton is ranked 101 and South Bedfordshire • Ensure appropriate housing • Education, skills and 253 out of 354 local authorities (a rank of one provision for the elderly, e.g. through unemployment are inter-related, being most deprived) in the Index of Multiple Life-long homes and appropriate hence should be addressed in a Deprivation forms of affordable housing holistic way

• Deprivation levels vary significantly across • Ensure that such housing is located Luton and South Bedfordshire near to the necessary services and facilities and public transport • Crime rates have been dropping in Luton and South Bedfordshire but still above national • Ensure provision of a range of average education facilities

• Parts of Luton and South Bedfordshire lacks • Planning obligations used to access to public open space enhance existing educational facilities • Luton has a high level of residents with no qualification (18.4%) WATER • Unprecedented demands on water resources • Recognise and implement • Climate change is resulting in Environment Agency’s surface water more extreme weather • Meeting present and future water demand- protection policies conditions and will heighten growth proposals will place further pressures flood risk and demands on on supply • Consider overall siting of water resources development schemes in order to • Surface water/storage already constrained in minimise potential effects on water Luton and South Bedfordshire quality

• Chemical water quality has declined between • Encourage the use of Sustainable 1995 and 2005 Drainage in new developments

• Parts of Luton and South Bedfordshire are • Ensure efficient use of water identified in the Environment Agency’s resources in development schemes, indicative flood plain map (see figure 3.1) this includes the use of recycled water

• New developments should incorporate rainwater re-use

• Ensure new polluting processes are

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SEA/SA Topic Key Issues Opportunities Inter relationships located in areas where groundwater is not vulnerable

• Improve river quality by using sustainable drainage schemes

• Management of ground contamination and ensure that it would not pollute the ground water

• Ensure new polluting processes are located in areas where groundwater is not vulnerable

• Introduce EcoHomes/BREEAM targets- all development to achieve Very Good or Excellent rating

• Ensure development proposals do not exacerbate flooding elsewhere by adopting the policies and principles contained in PPS 25

BIODIVERSITY

• Existing areas/habitats under threat from • Create new, and improve existing • The diversity of habitats and population influx and infrastructure habitats, Green Infrastructure species enriches people’s lives

• Additional stress/damage to existing habitats, • Compensation for features lost to • A healthy natural environment irreplaceable loss of biodiversity development where loss is improves quality of life. It adds completely unavoidable to the aesthetic value of space • 18 SSSIs- all are in either favourable or and provides economic benefits unfavourable recovering condition apart from • Protection of existing networks of through attracting inward Totternhoe Chalk Quarry which is an natural habitats including buffer investment unfavourable declining condition areas, migration routes and landscape features of major • Economic growth if undertaken • Woodland cover is low importance for wildlife unsustainably could adversely impact upon these assets. • Restoration of existing habitats and landscape features

• Linking and connecting isolated and fragmented habitats, important species populations and landscape features through creation of wildlife corridor network

• LDF to promote the use of management agreements for designated sites, where this can be linked to development.

• Detail plans for Green Infrastructure will be required within future AAPs

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SEA/SA Topic Key Issues Opportunities Inter relationships AIR QUALITY • Decreasing air quality in Luton and South • Ensure that jobs, retail, leisure • Air quality influences human Bedfordshire between 2000 and 2005 (three facilities are accessible by public health which affects quality of AQMAs) transport, walking and cycling life and also economic activity thereby reducing the need to use the • Potential Increased air pollution from growth car • Local residents and businesses traffic and congestion experience air quality at the • Provide more sustainable modes of local level, which affects health • Congestion on radial routes transport and amenity.

• Transport infrastructure deficit-concerned that • Ensure new urban extensions are • Increased public transport growth development will take place in well served by public transport usage reduces vehicular advance of appropriate transport emissions and in turn CO2 infrastructure • Opportunities to encourage more emissions sustainable modes of travel should • Lack of safe pedestrian and cycle routes be explored and implemented

• A high dependency on private car for • Pedestrian network of links and commuting results in congestion and negative routes can be expanded and ‘green impacts on air quality spaces’ (linked to flood plains…) could be used to improve town centre quality and provide pedestrian and cycle ways

• Improve cycle and pedestrian routes and links

• Promote the development of Green Travel Plans

SOIL • Greenfield development could lead to • Safeguarding and reusing soils • Soil resources are key to irreplaceable loss of soil resources generated from housing and road sustaining the agricultural construction –e.g. for landfill, mineral economy restoration

• Protect best and most versatile land

• Promote good soil handling practices

CLIMATIC FACTORS • Increase in greenhouse gas pollution/waste • Sustainable Urban Drainage – • Climate change is likely to affect production porous surfaces, greenspace, water resources (supply and wetlands, flood storage areas, urban demand), alter habitats, affect

• Domestic CO2 emissions per capita in Luton forestry air quality and public health and and South Bedfordshire are below regional increase flood risk. These could and national averages • Opportunity to decrease greenhouse all adversely impact upon Luton gas emissions through reduced and South Bedfordshire’s • Domestic energy efficiency improving reliance on the private car economy

• Promote recycling and protection of natural resources

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SEA/SA Topic Key Issues Opportunities Inter relationships • Encourage sustainable water usage practices like re-use, recycling, desalination and rainwater harvesting in new developments

• Promote the use and generation of renewable energy and promote energy efficiency

POPULATION AND HUMAN HEALTH • Luton and South Bedfordshire’s population is • Population growth will add pressure • The benefits of improved human increasing and set to increase under the to transport infrastructure health include a healthy growth proposals workforce, a reduced burden on • Enhance access to health services social and health services and • Life expectancy is lower than regional and contributions to the local national average • Increased provision of green spaces economy, through training and that encourage walking and cycling research opportunities • Increasing proportion of residents aged 0-4 and access to leisure and and over 65 recreational facilities

• Elderly people will need ongoing education • Provision for additional allotments in opportunities urban extensions

• 71% of Luton and South Bedfordshire’s • Provide and maintain safe and population states to be in good health-above available infrastructure for healthy regional (70%) and national (69%) average pursuits – cycleways, dedicated walkways. • Potential for new populations to merge with existing communities/villages • Provide space/sites for convenience stores in urban extensions and in • Social infrastructure and community facilities other accessible locations unable to cope, stress from noise, congestion, pollution • Encourage working from home by providing the necessary infrastructure

MATERIAL ASSETS • Between 2004 and 2005 99% of new homes • Support alternative methods of • A clean environment promotes were built on PDL waste management, e.g. good health and also attracts minimisation and recycling by people and investments from • Increased demand on land and natural incorporating facilities within outside resources development schemes • Material assets include • The percentage of household waste recycled • LDF to encourage/promote re-use resources such as land, building is increasing but remains below national and recycling of construction waste materials and other resources average in development schemes through the which are non renewable use of planning conditions • Amount of household waste is increasing • The topic is also concerned with • Devise mechanisms to encourage the efficient use of resources, • High growth will be resource dependent recycling options including re-use of brownfield leading to importation of materials which has sites and sustainable waste high traffic impact, loss of recourses management

• The quality of the material

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SEA/SA Topic Key Issues Opportunities Inter relationships assets in Luton and South Bedfordshire contributes to overall quality of life and can impact upon the economy

CULTURAL HERITAGE • Protection and enhancement of the built • Recognise the importance of cultural • Cultural heritage contributes to environment heritage and archaeological features the overall diversity and value of and the importance of regenerating the landscape • Damage/additional stress to existing and re-using important buildings protected built features, loss of existing • Also provides economic benefits protected and unprotected features, visual • Be proactive in preparing by helping attract inward impact of new development, potential damage development briefs to renew, restore investment and is a source of to undiscovered sites and redevelop neglected and enjoyment and entertainment deteriorating sites of historic for the population • Growth proposal could erode the character character and setting of historical areas • Ensure there are strong and robust • 26 SAMs design standards for new development • 619 Listed buildings • Ensure that new and existing • 26 Conservation Areas developments have regard to settlement patterns, the local • 3 registered Historic Parks and Gardens vernacular style and incorporate local materials

• Ensure that the public realm is effectively designed using quality materials that maintain or add to the character/ distinctiveness of the area

• Recognise the importance of archaeological features and advocate a programme of archaeological investigation prior to initial earthworks

• Retain features of historic landscape significance, where possible

LANDSCAPE AND TOWNSCAPE • Three national countryside character areas in • Locations for compensatory green • An attractive landscape Luton and South Bedfordshire- the Chilterns, belt should be identified in the DPDs improves quality of life which in the Bedfordshire Greensand Ridge and the turn could contribute to increase Bedfordshire and Cambridgeshire Claylands. • Recognise value of all landscapes, inward investment. Also includes the nationally designated not just designated sites Chilterns AONB- these designations will play a critical part in shaping future development • Ensure landscape proposals for development schemes reflect local • Potential coalescence of the rural settlements landscape character in the greenbelt • To enhance the quantity and quality • Development pressures both threaten the of existing open spaces charter and purpose of the greenbelt

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SEA/SA Topic Key Issues Opportunities Inter relationships • To create a strategic network of • Damage/additional stress to existing greenspace to fulfil multipurpose protected natural features, loss of existing recreational, landscape, wildlife, protected features, visual impact of new sustainable drainage and wildlife development, threat to AONB and loss of needs setting for ancient woodlands and hedgerows, also urbanization of countryside • Important to recognise the wider fabric of the landscape • Development or land use change inconsistent with landscape character • Building design will reflect the spectrum of users and consider • Poor access to the countryside in some the needs of older people, and areas people with disabilities

• Urban design will affect the way in which • There will be an active users interact within buildings and their encouragement for people to surroundings obtain light physical exercise

through the course of their interaction of the site e.g. safe pedestrian areas, clear connecting routes between access areas, the encouragement of stair use instead of lifts etc

Consultation questions Q3: Are there any other opportunities or issues that are relevant to the Core Strategy and Growth Area DPDs that have not been covered?

Q4: Are there any further interrelationships between topics that have not been identified?

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5 The SA Framework

5.1 Introduction Current guidance on SA of land use and spatial plans advocates the use of objectives in the appraisal process. This section provides an outline of the objectives, criteria and indicators formulation process of the SA in order to provide a focused and clarified approach to appraising the emerging DPDs at a later stage in the SA process. This SA Framework includes broad sustainability objectives, criteria explaining the broader objective in a more localised manner and indicators.

In order to facilitate legibility, ease of understanding and use, the sustainability objectives, criteria and indicators have been set out in the form of an Appraisal Framework, outlined in Table 5.1. This approach is recommended in government good practice on carrying out environmental and sustainability appraisals62. An explanation of the methodology for formulating the Appraisal Framework is presented below.

5.2 SA Appraisal Methodology The Regional Assembly (EERA) has developed a Sustainable Development Framework (SDF) for the East of England63. The SDF sets out the sustainable development vision for the region. EERA recommend that the SDF should be used as a central reference point for ensuring that regional and local strategies are consistent with the sustainable vision for the East of England. The approach set out in the SDF has been adopted for this SA process. Although the SDF is set to be revised during 2007, the current SDF is still valid and it is recommended that it should continue to be used until the revised version is published. On publication of the revised SDF the SA Framework will be revised and up- dated as appropriate. The SDF sets out a series of high level objectives, key objectives under key themes and performance indicators for the region.

62 A Practical Guide to the SEA Directive (September 2005) ODPM 63 A Sustainable Development Framework for the East of England, East of England Regional Assembly, 2001

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The SDF High Level Objectives

• To achieve sustainable levels of prosperity and economic growth

• To deliver more sustainable patterns of location of development, including employment and housing

• To protect and maintain our most valuable regional assets such as designated habitats, landscapes of natural beauty, and our historic built heritage, and to improve the wider environment by means of adequate investment and management

• To reduce our consumption of fossil fuels

• To achieve a more equitable sharing of the benefits of prosperity across all sectors of society and fairer access to services, focusing on deprived areas in the region

• To use natural resources, both finite and renewable, as efficiently as possible, and re-use finite resources or recycled alternatives wherever possible

• To minimise our production of by-products or wastes, aiming for 'closed systems' where possible

• To avoid using the global environment to underwrite our own unsustainable way of life (e.g. dependence on unsustainably produced and/or transported food imports or timber)

• To revitalise town centres to promote a return to sustainable urban living

5.2.1 SA Topic The sustainability objectives outlined in the SA Framework have been arranged under SA and SEA topics.

5.2.2 Objectives (Column 1) The next step was to identify and develop the sustainability objectives which will underpin the DPDs. The objectives form the basis for the appraisal. The objectives have been focussed on those issues, which are directly relevant to Luton and South Bedfordshire and the scope of the DPDs. To make the SA process more manageable, the Appraisal Framework has been restricted to 19 objectives. The SA objectives were drawn from the high level objectives set out in the SDF. The SA team

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identified some gaps in the high level objectives and in order to ensure that the full range of sustainability issues have been covered a number of additional objectives have been added to the SA Framework.

5.2.3 Criteria (Column 2) Following on from the identification of objectives, a range of associated criteria and indicators were identified to provide further clarity in respect of future development directions as well as to assist in the appraisal process. The criteria provide a more specific elaboration of the individual objectives. They focus specifically on the items which are of direct relevance to the DPDs. The criteria were based on the relevant key objectives set out in the SDF. The wording of some of the key objectives was tweaked to ensure the assessment criteria are directly relevant to the Luton and South Bedfordshire LDF.

5.2.4 Potential Assessment Indicators (Column 3) Indicators are the means by which the environmental and sustainability performance of the DPDs and subsequent SPDs can be monitored. The indicators outlined in the SA Framework were derived from SDF and supplemented where necessary with other relevant indicators already identified at the European, national, regional and local level. The indicators have been set under the SA objectives rather than under each individual criterion.

Note that work on developing the indicators is ongoing and will not be finalised until submission of the final DPDs.

The proposed SA Framework is outlined in Table 5.1 overleaf. Note: The SA objectives are not set out in order of priority.

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Table 5.1: The Draft SA Framework

Objective Criteria Indicators

Biodiversity

1. To protect and maintain our To protect, maintain and enhance designated wildlife and Populations of wild birds most valuable regional assets geological sites (international, national and local) and protected such as designated habitats, Area of semi-natural habitat lost to species to achieve favourable condition landscapes of natural beauty development and to improve the wider environment by means of To restore characteristic habitats and species, to achieve BAP Area of new semi-natural habitat adequate investment and targets created management Wildlife sites affected by water To support farming and countryside practices that enhance wider abstraction biodiversity and landscape quality by economically and socially valuable activities (e.g. grazing, coppicing, nature reserves) Loss/damage to Sites of Special Scientific Interest (SSSIs) To manage woodlands and other habitats of value for biodiversity Species at risk in a sustainable manner and protect them against conversion to

other uses Buildings of Grade I and II* at risk of decay To recognise the social/environmental value and increase access Changes in landscape features - to woodlands, wildlife & geological sites and green spaces woodland, hedges, stone walls and ponds particularly near/in urban areas

Area of ancient semi-natural To encourage people to come into contact with, understand, and woodland

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enjoy nature

Water

2. To protect, maintain and To raise awareness and encourage higher water efficiency and Household water use and peak enhance water resources conservation by for instance promoting water reuse in new and demand (including water quality and existing developments quantity) while taking into Low flows in rivers account the impacts of climate To ensure water consumption does not exceed levels which can change be supported by natural processes and storage systems Margin between water supply and projected demand To manage water quality and water resources to maximise value to people and wildlife

To improve flow of rivers

3. Ensure that new To avoid developments in areas being at risk from fluvial, sewer Number of properties at risk from developments avoid areas or groundwater flooding (for instance natural flood plains) while flooding which are at risk from flooding taking into account the impacts of climate change and natural flood storage areas To ensure that developments, which are at risk from flooding or are likely to be at risk in future due to climate change, are sufficiently adapted

To promote properly maintained sustainable drainage systems to reduce flood risk and run off in areas outside Source Protection 70

Zones 1 (SPZ)

Soil

4. Minimise development of To safeguard high quality soils, such as agricultural land grades Amount of high quality agricultural land with high quality soils and 1, 2 and 3a) from development land degraded/lost to development minimise the degradation/loss of soils due to new To limit contamination/degradation/loss of soils due to developments development

Climatic Factors

5. Reduce the impacts of To minimise greenhouse gas emissions (particularly CO2) for Output of greenhouse gas and climate change, with a instance through more energy efficient design and reducing the particularly CO2 particular focus on reducing the need to travel Weather-related insurance claims consumption of fossil fuels and Regional energy consumption levels of CO2 To promote increased carbon sequestration e.g. through compared with population and GDP increases in woodland cover Energy use per household

To adopt lifestyle changes which help to mitigate and adapt to (For indicators regarding renewable climate change, such as promoting water and energy efficiency energy see section on material assets)

6. Ensure that developments To promote design measures which enable developments to Percentage of new developments are capable of withstanding the withstand and accommodate the likely impacts and results of considered to be ‘climate change

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effects of climate change climate change (for instance through robust and weather resistant proof’ (adaptation to climate change) building structures)

Air Quality

7. Achieve good air quality, To reduce the need to travel by car through planning settlement Number of days per year any especially in urban areas patterns and economic activity in a way that reduces dependence parameter exceeds its National Standard on the car and maintains access to work and essential services

for non-car-owners Distance travelled to work and mode of travel To integrate land use and transport planning by for instance: Number and length of journeys by ƒ Promoting Green Transport Plans, including car pools, car environmentally damaging modes: sharing as part of new developments car, lorry, plane

ƒ Ensuring services and facilities are accessible by Proportion of journeys by 'green' sustainable modes of transport modes: walking, cycle, bus, passenger rail, rail freight To ensure that development proposals do not make existing air

quality problems worse Traffic congestion

Material Assets

8. Maximise the use of To concentrate development through the reuse of previously New homes built on previously previously developed land and developed land and buildings and by urban extensions where the developed land development of greenfield land is unavoidable buildings, and the efficient use Number of vacant properties

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of land Number of residential units created above shops

To maximise the efficient use of land and existing buildings by measures such as higher densities and mixed use developments

To encourage the remediation of contaminated and derelict land and buildings

9. To use natural resources, To encourage maximum efficiency and appropriate use of Proportion of electricity generated both finite and renewable, as materials, particularly from local and regional sources from renewable sources efficiently as possible, and re- Level of minerals and aggregate use use finite resources or recycled To require new developments to incorporate renewable, replaced by recycled or substitute alternatives wherever possible secondary, or sustainably sourced local materials in buildings and materials infrastructure Number of buildings designed to sustainability principles To promote renewable energy sources as part of new or

refurbished developments

To safeguard reserves of exploitable minerals from sterilisation by other developments

10. To minimise our production To increase recycling and composting rates and encourage easily Household waste and recycling of by-products or wastes, accessible recycling systems as part of new developments Construction and demolition waste aiming for ‘closed systems’ going to landfill 73

where possible To promote awareness regarding waste/recycling and renewable energy issues through education programmes in schools and the community

Cultural Heritage

11. To identify, maintain and To safeguard and enhance the historic environment and restore Buildings of Grade I and II* at risk of enhance the historic historic character where appropriate, based on sound historical decay environment and cultural assets evidence Number and condition of SAMs

To promote local distinctiveness by maintaining and restoring Number and condition of Registered historic buildings and areas, encouraging the re-use of valued Parks and Gardens buildings and thoughtful high quality design in housing and mixed use developments – to a density which respects the local context and townscape character, and includes enhancement of the public realm

To promote public education, enjoyment and access of the built heritage and archaeology

Landscape

12. To conserve and enhance To protect and enhance landscape character Areas of designated landscapes landscape character and affected by/lost to development encourage local distinctiveness To evaluate the sensitivity of the landscape to new/inappropriate developments and avoid inappropriate developments in these 74

areas

To minimise the visual impact of new developments

Population and Human Health

13. To encourage healthier To promote the health advantages of walking and cycling and Increase in number of illness-free lifestyles and reduce adverse community based activities years health impacts of new Variations in GDP per head within the developments To identify, protect and enhance open spaces, such as rivers, region parks and gardens, allotments and playing fields, and the links between them, for the benefit of people and wildlife Index of local deprivation

Access to local green space To include specific design and amenity policies to minimise noise Noise levels and odour pollution, particularly in residential areas

To narrow the income gap between the poorest and wealthiest parts of the area and to reduce health differential

14. To deliver more sustainable To reduce the need to travel through closer integration of housing, Availability of public services - patterns of location of jobs and services transport, shops, banks, heath facilities by area development To promote better and more sustainable access to health facilities

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Social Factors

15. Achieve a more equitable To include measures which will improve everyone’s access to Proportion of working age people in sharing of the benefits of high quality health, education, recreation, community facilities and work, by area, age band, gender and ethnicity prosperity across all sectors of public transport society and fairer access to Dependency on working-age benefits, services, focusing on deprived To ensure facilities and services are accessible by people with by region, ward and district areas in the region disabilities and to ethnic minorities Percentage of working-age people in workless households

To encourage people to access the learning and skills they need for high quality of life Proportion of housing unfit or lacking appropriate insulation, by area To ensure that the LDF does not discriminate on the basis of disability, ethnic minority, or gender Affordable housing completions

Promote a range housing types and tenure, including high quality affordable and key worker housing

16. Enhance community identity To recognise the value of the multi-cultural/faith diversity of the % households stating their and participation peoples in the region neighbourhood has 'community spirit'

To improve the quality of life in urban areas by making them more attractive places in which to live and work, and to visit

17. Reduce both crime and fear To reduce all levels of crime with particular focus on violent, drug Rates of fear of crime of crime

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related, environmental and racially motivated crime Recorded crime (by type) per 100,000 population To plan new developments to help reducing crime and fear of crime through thoughtful design of the physical environment, and by promoting well-used streets and public spaces

To support government-sponsored crime/safety initiatives, maximising the use of all tools available to police, local authorities and other agencies to tackle anti-social behaviour

Economic Factors

18. Achieve sustainable levels To promote and support economic diversity GDP per head of prosperity and economic To foster an innovation culture, encourage world-class skills and GDP per worker growth improve access to innovation and technology support. % of businesses recognised as Investors in People To promote and support economic diversity, small and medium

sized enterprises and community-based enterprises and leading Proportion of working age people in edge infrastructure work

To improve the competitiveness of the rural economy Number and survival of business start-ups (urban and rural)

Participation in training

Qualifications at age 19

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19. Revitalise town centres to To promote town centre regeneration and encourage the role of Vacant land and properties and promote a return to sustainable local centres as centres for sustainable development providing derelict land urban living services, housing and employment Proportion of new retail in town centres versus out-of-town To encourage well-designed mixed-use developments in the heart of urban areas, create viable and attractive town centres that Proportion of population living in town have vitality and life, and discourage out-of-town developments centres

Consultation questions Q5: Do the SA objectives provide a reasonable framework through which the likely significant environmental effects of the Core Strategy and Growth Area DPDs can be assessed?

Q6: Are their any other indicators which are relevant to the Core Strategy and Growth Area DPDs?

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6 Consultation

6.1 Introduction For the purposes of complying with the SEA Regulations, Part 3 Section 13, the following statutory consultees will be consulted on the Scoping Report:

• Environment Agency • Natural England • English Heritage

Responses received from the consultation exercise will be used to inform the assessment of the forthcoming LDF Core Strategy and Growth Area DPDs.

TheConsultation final Sustainability question Report will document how the Scoping Report responsesQ7: How havewould been your taken organisation into account. like to be involved in the rest of this SA process?

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7 Next Steps

7.1 Introduction This section of the report sets out the methodology for the future stages of the SA and suggested outputs at various stages. The subsequent stages after the production of and consultation on the scoping report are:

• Stage B: Developing and refining options and assessing the effects of the emerging DPDs; • Stage C: Documenting the appraisal process in the Sustainability Report; • Stage D: Consultation with the public and statutory bodies; and • Stage E: Monitor the effects of the plan on the environment/ sustainability. Each of these stages has been summarised in the sections below.

7.2 Stage B: Developing and refining options and assessing the effects of the DPDs It is considered that this provides the first opportunity for the appraisal of the emerging DPDs in terms of their potential to meet sustainable objectives and satisfy individual criteria. It is considered that in principle the appraisal will ascertain the impacts of each of the Plan’s options as well as providing recommendations and suggestions for mitigation measures to be included, which could improve the sustainability performance of the options under consideration. By means of this process the SA will contribute to the selection of the preferred option.

7.2.1 Assessment of the Issues and Options Reports Both the Issues and Options Reports produced as part of the Core Strategy and Growth Area DPD preparation process will be tested against the SA Framework. This will help the assessors determine their performance in sustainability terms and identify their significant environmental effects. The process will be iterative with the assessors working closely with the plan makers to strengthen options as the assessment continues.

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At this stage the strategic options will be assessed at a relatively broad scale using expert judgement, indicating which issues and options are likely to be of concern and what assumptions have been made. The setting out of the assumptions made by the team will help manage the uncertainty inherent in a strategic level assessment.

During the assessment of the Issues and Options Report a judgement based approach to prediction that is transparent and auditable will be taken. This will be guided by the criteria and indicators. A variety of tools will be used to aid assessment and these include:

• Participation of environmental/sustainability experts; and • Geographical Information Systems (GIS).

The results will be presented in a matrix format to ensure clarity and transparency. It is proposed that the SA Framework, outlined in section 5 will provide the basis for predicting the effects of the options. This matrix will identify the changes to the sustainability baseline which are predicted to arise from the options. The final output of this stage is a SA Working Paper. An individual SA Working Paper will be prepared for each DPD. The Paper will provide the appraisal results (in matrix format), recommendations and potential mitigation measures. The SA process will help facilitate selection of a preferred option.

7.2.2 Assessment of the Preferred Options This stage provides the first opportunity to appraise the emerging preferred options of the DPDs. The assessment will ascertain the impacts of each of the Plan’s preferred options and provide recommendations and suggestions for mitigation. Similar to the Issues and Options stage the process will be iterative with the assessors working with the plan makers to further strengthen the preferred options. The identified preferred options will be tested against the SA Framework.

The results will be presented in a matrix format. The changes in the baseline which are predicted to arise from the preferred option will be summarised in the matrix. The assessment will describe changes in terms of their magnitude, their geographical scale, the time period over which they will occur, positive or negative and whether or not they are cumulative and/or synergistic effects. For each significant effect identified, mitigation

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measures (including avoidance, offsetting and enhancement measures) will be suggested.

The final output at this stage will be a series of matrices and commentary, identifying:

• Preferred Options appraisal results; • Mitigation measures; • Measures to enhance positive outcomes; and • Recommendations.

These appraisal results and commentary will form part of the final Sustainability Report.

7.3 Stage C: Preparation of the final Sustainability Report The SEA Regulations requires an environmental/sustainability report (for the purpose of this SA-the final output will be known as the Sustainability Report) be prepared which should include information on “the likely significant effects of the plan on the environment, including issues such as bio-diversity, population, human health, fauna, flora, soil, water, air climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors…” In addition, “the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme” should be set out. In order to fully meet the requirements of the Directive (Article 9.1(b)), the Environmental Report must specifically document:

• How environmental considerations have been specifically integrated into the plan development process, where mitigation measures have been taken on board, and reasons why mitigation measures have not been taken on board; and,

• Background to the selection of the preferred option(s).

The preparation of the Sustainability Report will constitute the final task of the SA. Again an individual Sustainability Report will be prepared for each DPD. This Report will include a summary of the SA process as well as a

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summary of all the appraisal results, the consideration of combined effects and proposals for a monitoring strategy. As such, it will provide the final audit trail of decisions taken and will set out the anticipated environmental impacts of the DPD. It is envisaged that the Sustainability Report will supplement the final DPDs.

The Sustainability Report will broadly follow the recommended structure as set out in the ODPM’s SA guidance. The environmental/sustainability report will be made up of the following chapter headings:

Table 7.1: Proposed structure and contents of the Sustainability Report Section of report Contents 1.Summary and 1.1. Non-technical summary outcomes 1.2. A statement of the likely significant effects of the plan 1.3. Statement on the difference the process has made 1.4. How to comment on the report

2.Appraisal methodology 2.1. Approach adopted to the SA 2.2. When the SA was carried out 2.3. Who carried out the SA 2.4. Who was consulted, when and how 2.5. Difficulties encountered

3. Background 3.1. Purpose of the SA and the SA Report 3.2. Plan objectives and outline of contents 3.3. Compliance with the SEA Directive/Regulations

4. Sustainability 4.1. Links to other strategies, plans and programmes and sustainability objectives, baseline and objectives context 4.2. Description of the social, environmental and economic baseline characteristics and the predicted future baseline 4.3. Main social, environmental and economic issues and problems identified 4.3. Study limitations, assumptions made 4.4. The SA framework, including objectives and indicators

5. Plan options 5.1. Main strategic options considered and how they were identified 5.2. Comparison of the social, environmental and economic effects of the options 5.3. How social, environmental and economic issues were considered in choosing the preferred options 5.4. Other options considered, and why these were rejected 5.5. Proposed mitigation measures

6. Preferred Option 6.1. Significant social, environmental and economic effects of the preferred option 6.2. How social, environmental and economic problems were considered in developing the preferred option

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Section of report Contents 6.3. Proposed mitigation measures 6.4. Uncertainties and risks

7. Implementation 7.1. Links to other tiers of plans and programmes and the project level (environmental impact assessment, design guidance, etc) 7.2. Proposals for monitoring

7.4 Stage D: Consultation with the public and statutory bodies The SEA Regulations set specific requirements for consultation with the Statutory Environmental Bodies, the public and other interested parties (these could include community groups, Primary Care Trust). The final Sustainability Report will be made available for all these parties so that they can provide a response to the contents of the report.

7.5 Stage E: Monitor the effects of the plan on the environment/ sustainability The SEA Regulations includes a requirement for the monitoring of “the significant environmental effects of the implementation of plans… in order, inter alia, to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action” (Article 10.1). The Environmental Report should provide information on “a description of the measures envisaged concerning monitoring…”

The development of a monitoring strategy will allow the actual effects of the DPDs to be tested against the predicted impacts, enabling significant problems to be identified and tackled over time, and environmental baseline information to be gathered for future plans. The indicators set out in the SA Framework and existing monitoring programmes (AMR) will form the basis for the monitoring strategy, and will be linked to measuring progress towards the SA objectives.

Consultation questions Q8: Do you believe that the significant impacts of the Core Strategy and Growth Area DPDs can be identified using this approach?

Q9: Are there other/additional methodologies that could be used to identify the significant impacts of the Core Strategy and Growth Area DPDs?

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8 Summary of Questions for Consultees

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

Q2: Are there any other issues or information related to the topics covered in sections 3.4 to 3.16 that are relevant to the Core Strategy and Growth Area DPDs that should be included?

Q3: Are there any other opportunities or issues that are relevant to the Core Strategy and Growth Area DPDs that have not been covered?

Q4: Are there any further interrelationships between topics that have not been identified?

Q5: Do the SA objectives provide a reasonable framework through which the likely significant environmental effects of the Core Strategy and Growth Area DPDs can be assessed?

Q6: Are their any other indicators which are relevant to the Core Strategy and Growth Area DPDs?

Q7: How would your organisation like to be involved in the rest of this SA process?

Q8: Do you believe that the significant impacts of the Core Strategy and Growth Area DPDs can be identified using this approach?

Q9: Are there other/additional methodologies that could be used to identify the significant impacts of the Core Strategy and Growth Area DPDs?

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APPENDIX A PPP Review Plan/Strategy/Policy Key Aims, Relevant Objectives or Targets / Implications for Sustainability Indicators Appraisal and the LDF International/ European The environmental objectives and priorities of this strategy fall out of the EU Sixth Environmental Action Programme which was developed by the EU. This strategy focuses on the need to: • Limit climate change and increase the use of clean energy European Sustainable • Address threats to public health (e.g. hazardous chemicals, The EDS emphasises action to promote sustainable Development Strategy food safety) development must be taken and at all levels. (EDS), EU, 2001 • Combat poverty and social exclusion • Deal with the economic and social implications of an ageing society • Manage natural resources more responsibly (including biodiversity and waste generation) • Improve the transport system and land use management The Bonn Convention aims to improve the status of all threatened Bonn Convention on the migratory species through national action and international Conservation of Migratory Agreements between range states of particular groups of species. It The LDF should try to avoid or minimise impacts on Species of Wild Animals aims to: migratory species and their habitats. (1979) • To conserve/restore habitats and control other factors that might endanger the listed migratory birds The convention aims: • To conserve wild flora, fauna and natural habitats • To promote co-operation between states • To give particular attention to endangered and Bern Convention on the vulnerable species, including endangered and Conservation of European vulnerable migratory species The LDF should take the conservation of biodiversity Wildlife and Natural • Appendices provide detailed information on species and into account. Habitats (1979) habitats protected under the convention.

Obligations for contracting parties: conservation of wild flora and fauna and all natural habitats in general, by • Promoting national conservation policies Plan/Strategy/Policy Key Aims, Relevant Objectives or Targets / Implications for Sustainability Indicators Appraisal and the LDF • Taking conservation into account in regional planning policies and pollution abatement • Promoting education and information The convention is designed to conserve biological diversity, ensure the sustainable use of this diversity and share the benefits generated by the use of genetic resources.

The Convention on Each contracting party should (article 6a) The LDF should aim to facilitate the protection and Biological Diversity, Rio de • Develop national strategies for the conservation and enhancement of biodiversity. Janeiro (1992) sustainable use of biological diversity • Integrate the conservation and sustainable use of biological diversity into relevant sectoral and cross-sectoral plans, programmes and policies The Kyoto Protocol supports the United Nations Framework Convention on Climate Change which sets an overall framework for intergovernmental efforts to tackle the challenge posed by climate change.

Articles 2(a-vii) & Article 3: Applies the Protocol to reduction of ozone-depleting gases produced by the transport sector not covered Ensure all reasonable opportunities are taken forward Kyoto Protocol on Climate by the Montreal Protocol (CFCs and fluorocarbons). Article 3 to reduce greenhouse gas emissions and promote Change (UN, 1997) contains the key obligation requiring reduction in anthropogenic CO 2 renewable energy and higher energy efficiency. levels to at least 5% below 1990 levels by 2012. Article 10(b-1): Requires signatories to implement and publish regular plans detailing how reduction targets will be met in specific sectors, including transport. It might be argued that sustainable transport policies RTSs and LTPs might contribute to this commitment.

The UN Millennium All 191 UN member states set out eight millennium development Declaration and goals which should be met by 2015. The LDF can help in achieving those objectives. Millennium Development Goals (2002) ‘We must tackle, issues of climate change, preserving biodiversity, Plan/Strategy/Policy Key Aims, Relevant Objectives or Targets / Implications for Sustainability Indicators Appraisal and the LDF managing our forests and water resources, and reducing the impacts of natural and man-made disasters.’ The Johannesburg Summit 2002 – the World Summit on Sustainable Development – aimed to address difficult challenges, including improving people's lives and conserving our natural resources in a world that is growing in population, with ever- increasing demands for food, water, shelter, sanitation, energy, World Summit on health services and economic security. The LDF can have significant impacts on the issues Sustainable Development - mentioned and should try to contribute towards their Earth Summit (2002) Fundamental goals include: achievement locally. • Greater resource efficiency • Waste reduction • Promotion of renewable energy • Significantly reduce loss of biodiversity by 2010 Aims to define a common approach across the European Union to The noise impacts of new developments should be EU Council Directive on avoid, prevent or reduce the harmful effects of environmental noise given consideration. Environmental Noise, from road, rail and air traffic and industry. By 2007 strategic noise 2002/49/EC, EC, 2002 maps have to be prepared and by 2008 action plans have to be Strategic noise maps and action plans should be developed for how to reduce environmental noise where necessary. reflected in the appraisal Directive 79/409/EEC and its amending acts aim at providing long- term protection and conservation of all bird species naturally living in the wild within the European territory of the Member States (except EU Directive on the The LDF should promote this aim, for example, by Greenland). Conservation of Wild Birds promoting biodiversity and avoiding/reducing habitat

(79/409/EEC) fragmentation. Imposes duty on Member States to sustain populations of naturally occurring wild birds by sustaining areas of habitats in order to maintain populations at ecologically and scientifically sound levels. The Waste Framework Directive (WFD) requires Member States of LDF should consider these impacts when deciding on the EU to establish both a network of disposal facilities and locations for waste disposal or processing. This would EU Waste Framework competent authorities with responsibility for issuing waste feed into SA objectives for noise, air, landscape, and Directive (91/156/EEC) management authorisations and licenses. Member States may also biodiversity. introduce regulations which specify which waste recovery operations and businesses are exempt from the licensing regimes and the