COMMITTEE REF:
EX/09/18
NOTICE OF MEETING
COMMITTEE : EXECUTIVE
DATE : MONDAY, 20 AUGUST 2018
TIME : 18:00
PLACE : COMMITTEE ROOM 3 TOWN HALL, LUTON, LU1 2BQ
COUNCILLORS : SIMMONS (CHAIR) HUSSAIN AKBAR A. KHAN BURNETT MALCOLM CASTLEMAN SHAW HOPKINS TIMONEY
QUORUM : 3 MEMBERS
Contact Officer: Matt Hussey (01582 546032)
INFORMATION FOR THE PUBLIC
PURPOSE: The Executive is the Council’s primary decision-making body dealing with a range of functions across the Council’s activities and services.
This meeting is open to the public and you are welcome to attend.
For further information, or to see the papers, please contact us at the Town Hall:
IN PERSON, 9 am to 5 pm, Monday to Friday, or
CALL the Contact Officer (shown above).
An induction loop facility is available for meetings held in Committee Room 3.
Arrangements can be made for access to meetings for disabled people.
If you would like us to arrange this for you, please call the Contact Officer (shown above).
NOTE: Members of the public are entitled to take photographs, film, audio-record and report on all public meetings in accordance with the Openness of Local Government Bodies Regulations 2014. People may not however act in anyway considered to be disruptive and may be asked to leave. Notice of these rights will be given verbally at the meeting, as appropriate.
Page 1 of 478 AGENDA
Agenda Subject Page Item No.
EMERGENCY EVACUATION PROCEDURE
Committee Rooms 1, 2, 4 & Council Chamber: Turn left, follow the green emergency exit signs to the main town hall entrance and proceed to the assembly point at St George's Square.
Committee Room 3: Proceed straight ahead through the double doors, follow the green emergency exit signs to the main Town Hall entrance and proceed to the assembly point at St George's Square.
INTRODUCTIONS, PHOTOGRAPHY, FILMING & AUDIO RECORDING
1. APOLOGIES FOR ABSENCE
2. PUBLISHED RECORD OF THE MEETING
1. 16th July 2018
SECTION 106, LOCAL GOVERNMENT FINANCE ACT 1992
Those item(s) on the Agenda affected by Section 106 of the Local Government Finance Act 1992 will be identified at the meeting. Any Members so affected is reminded that (s)he should disclose the fact and refrain from voting on those item(s).
DISCLOSURES OF INTERESTS
Members are reminded that they must disclose both the existence and nature of any disclosable pecuniary interest and any personal interest that they have in any matter to be considered at the meeting unless the interest is a sensitive interest in which event they need not disclose the nature of the interest.
A member with a disclosable pecuniary interest must not further participate in any discussion of, vote on, or take any executive steps in relation to the item of business.
A member with a personal interest, which a member of the public with knowledge of the relevant facts would reasonably regard as so significant that it is likely to prejudice the member’s judgment of the public interest, must similarly not participate in any discussion of, vote on, or take any executive steps in relation to the item of business.
Disclosable pecuniary interests and Personal Interests are defined in the Council’s Code of Conduct for Members and Co-opted members.
Page 2 of 478
3. BUSINESS NOT COVERED BY CURRENT FORWARD PLAN: GENERAL EXCEPTION
The Executive Leader to report on any business which it is proposed should be considered by the Executive following compliance with Regulation 10 of the Local Authorities (Executive Arrangements) (Meetings and Access to Information) (England) Regulations 2012.
4. BUSINESS NOT COVERED BY CURRENT FORWARD PLAN: SPECIAL URGENCY
The Executive Leader to report on any business which it is proposed should be considered following compliance with Regulation 11 of the Local Authorities (Executive Arrangements) (Meetings and Access to Information) (England) Regulations 2012.
5. REFERENCES FROM COMMITTEES AND OTHER BODIES
1. REFERENCE FROM OVERVIEW AND 5 - 10 SCRUTINY BOARD MEETING -PILOT OF RED ROUTES IN LUTON
(Report of the Service Director, Policy, Communities & Engagement)
6. RECOMMENDATIONS FROM SCRUTINY REVIEWS
7. PETITIONS
BUSINESS ITEMS
EXECUTIVE LEADER
8. APPOINTMENT OF REPLACEMENT MEMBERS ON THE 11 - 14 CORPORATE PARENTING PARTNERSHIP BOARD AND AIRPORT BOARD (Report of the Servcie Director, Policy, Communities & Engagement)
CUSTOMER & COMMERCIAL (FINANCE)
9. TREASURY MANAGEMENT ANNUAL REPORT - YEAR 15 - 28 ENDED 31ST MARCH 2018 (Report of the Service Director, Finance & Audit)
CUSTOMER & COMMERCIAL (HOUSING & ENVIRONMENT)
Page 3 of 478 10. HOUSING REVENUE ACCOUNTS BORROWING 29 - 34 (Report of the Service Director, Housing)
11. LUTON HOUSING STRATEGY - CONSULTATION DRAFT 35 - 136 (Report of the Service Director, Housing)
PEOPLE (ADULTS)
12. REVIEW OF ADULT SOCIAL CARE SCALE OF 137 - 160 CHARGES FOR NON-RESIDENTIAL SERVICES (Report of the Service Director, Adult Social Care)
PEOPLE (CHILDREN'S SERVICES)
13. SURREY STREET PRIMARY SCHOOL - EXTENSION OF 161 - 194 AGE RANGE (Report of the Corporate Director, People)
PLACE & INFRASTRUCURE (PLANNING & TRANSPORT)
14. REMOVAL OF VEHICLES ILLEGALLY PARKED 195 - 214 (Report of the Service Director, Public Protection)
15. RED ROUTE - CONSULTATION REPORT 215 - 384 (Report of the Service Director, Public Realm)
16. ROAD SAFETY AUDIT POLICY 2018 385 - 430 (Report of the Service Director, Public Realm)
PLACE & INFRASTRUCTURE (SAFER, STRONGER COMMUNITIES)
17. FOOD LAW SERVICE PLAN 2018-19 431 - 478 (Report of the Servcie Manager, Specialist Operations)
18. REGULATION 4 OF THE LOCAL AUTHORITIES (EXECUTIVE ARANGEMENTS)(MEETINGS & ACCESS TO INFORMATION)(ENGLAND) REGULATIONS 2012 To consider whether to pass a resolution under Regulation 4 of the Local Authorities (Executive Arrangements) (Meetings and Access to Information) (England) Regulations 2012 to exclude the public from the meeting during consideration of the item(s) listed below as it is likely, that if members of the public were present during the transaction of the item(s), exempt information within the meaning of the Paragraph(s) of Part 1 of Schedule 12A to the Local Government Act 1972 indicated next to the item, would be disclosed to them.
Note: Five days’ notice is hereby given of items to be considered in private as required by Regulations (4) and (5) of the Local Authorities (Executive Arrangements) Meetings and Access to Information) (England) Regulations 2012.
Details of any representations received by the Executive about why any of the above exempt decisions should be considered in public: none at the time of publication of the agenda. If representations are received they will be published separately, together with the statement given in response.
Page 4 of 478 Report For: Executive Item No: Date: 20 August 2018 Report Of: Service Director, Policy, Communities & 5.1 Engagement Report Author: Eunice Lewis-Okeowo
Subject: Reference from the Overview and Scrutiny Board – PILOT OF RED ROUTES IN LUTON Lead Executive Member(s): Councillor Castleman Wards Affected: All Consultations: Councillors ☒ Scrutiny ☒ Stakeholders ☐ Others ☐
Recommendations: 1. That the Executive be advised that the Overview and Scrutiny Board is of the view that:
a) The scheme outlined in the report of the Service Director, Public Realm on “Pilot of Red Routes in Luton” submitted to the Overview and Scrutiny Board meeting on 2nd August 2018 will do absolutely nothing to deal with congestion in the town because it is not directed to roads where parking causes congestion.
b) Resources should be concentrated on enforcement of existing regulations and to various roads where congestion is caused by parking.
c) The Recommendations outlined in the report of the Service Director, Public Realm referred to at 1a) should be rejected.
Background 2. At the meeting of the Overview and Scrutiny Board (OSB) held on 2nd August 2018 a report of the Service Director Public Realm was considered entitled “Pilot of Red Routes in Luton”. The report requested the Board to endorse the following Recommendations to the Executive:
• To implement the Town Centre pilot scheme with minor modifications based on the comments received by introducing an Experimental Traffic Regulation Order (ETRO).
• To implement (old) Airport Way only part of the pilot scheme by introducing an ETRO.
• To put the other schemes on hold while the issues brought up in the consultation are considered and implemented as appropriate.
3. The Council as Highway Authority has a duty under the Traffic Management Act 2004 to ensure expeditious movement of traffic (including pedestrians).
Page 5 of 478 4. As part of this duty it has been proposed that a network of Red Routes is considered for implementation in Luton to reduce the amount of parking and stopping on strategic routes in Luton and thereby improve the movement of traffic.
5. On 5 March 2018 the Executive agreed to take forward three trial routes to (informal) public consultation which took place between 11th May and 8th June 2018.
6. The agreed trial routes are:
• Kimpton Road and (Old) Airport Way to reduce the inconsiderate parking on the route to London Luton Airport from the Town Centre.
• Dunstable Road (from Telford Way) to Birch Link, Leagrave Road and Marsh Road (to Three Horseshoes roundabout) to reduce the inconsiderate parking at these locations and improve bus punctuality on a key route from the north of Luton.
• New Bedford Road, Wellington Street, Gordon Street, Upper George Street, Alma Link, Inkerman Street, Dunstable Road (to Telford Way) to reduce inconsiderate parking, reduce congestion and improve bus punctuality around the Town Centre.
REPORT
7. The Board debated the proposals to introduce red routes in the identified areas of Luton as outlined in the report including the outcome of the public consultation and comments and views received from members of the public.
8. Some Members of the Board were in support of red routes for the purpose of managing and controlling congestion caused by parked vehicles but not in the areas where the proposed trials were being introduced as there were no parking problems. Congestion in those areas was mainly caused by the number of cars on the road and not as a result of people parking their cars on the roads.
9. It was also noted Luton is the third most congested place in the UK with similar experiences to London which has introduced red routes proven to be effective and enforced through cameras.
10. However, the majority of Members opined that the proposal if implemented would be an absolute waste of money and resources and not make any difference or improve the congestion problems in the proposed red route areas; especially as the traffic congestion in the proposed areas was not as a result of congestion caused by parked vehicles.
11. Furthermore, resources should not be wasted on a scheme like this especially at a time of financial constraints.
12. Members proposed that resources should be concentrated on the enforcement of existing traffic regulations and to other areas in Luton where parking has been identified as the cause of congestion.
PROPOSAL/OPTION 13. The following proposals were moved by Councillors Franks and Chapman:-
• The scheme outlined in the report of the Service Director, Public Realm on “Pilot of Red Routes in Luton” submitted to the Overview and Scrutiny Board meeting on 2nd August
Page 6 of 478 2018 will do absolutely nothing to deal with congestion in the town because it is not directed to roads where parking causes congestion.
• Resources should be concentrated on enforcement of existing regulations and to various roads where congestion is caused by parking.
• The Recommendations outlined in the report of the Service Director, Public Realm “Pilot of Red Routes in Luton” as submitted to the Board be rejected.
14. Members of the Overview and Scrutiny Board voted to support the Board’s view that the scheme will do absolutely nothing to deal with congestion in the town because it is not directed to roads where parking causes congestion.
15. That available resources, should be concentrated on enforcement of existing regulations and to various roads where congestion is caused by parking.
16. The Officer Recommendations for the Board to support the proposed scheme on red routes was therefore rejected by the Board.
17. Members of the Board however, commended Officers for a robust consultation.
Goals and Objectives 18. To consider the recommendations from the Overview and Scrutiny Board meeting held on 2nd August 2018 in respect of Pilot of Red Routes in Luton due for consideration at the Executive meeting on 20th August 2018.
Proposal 19. That the Executive is requested to consider the recommendations from the Overview and Scrutiny Board meeting held on 2nd August 2018.
Alternative options considered and rejected (please specify) 20. To agree the recommendations of the Overview and Scrutiny Board in full
21. To reject all or some of them or request further information
Background Papers and Appendices 22. Report of the Overview and Scrutiny Board on 2nd August 2018 – Item 10 – Pilot of Red Routes in Luton Report
Page 7 of 478 IMPLICATIONS
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated The Council has a duty (as the Highway Authority) Raj Popat-Principal 7th August under the Traffic Management Act 2004 to ensure Solicitor 2018 expeditious movement of traffic in their area. Red Routes have been brought into line with yellow line restrictions as a parking management tool without the need for special Government approval. Any proposals for waiting restrictions would need to be advertised under the Road Traffic Regulation Act 1984.
Finance Clearance Agreed By Dated If the Executive were minded to support the views of Darren Lambert, Finance 7th August the Overview and Scrutiny Board and not implement Business Partner 2018 the recommendations for red routes, there would be a saving of £285,000 in the 2018/19 capital programme.
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated Currently there are no direct equality issues Sandra Hayes Strategic 7th August associated with the report Community Services 2018 Manager Environment Clearance Agreed By Dated The implementation and enforcement of Red Routes Keith Dove, Strategic Policy 6th August will improve traffic movement and reduce congestion/ Adviser. 2018 vehicle idling in these areas, resulting in less vehicle pollution and CO2 emissions. It should improve the punctuality of public buses which indirectly could encourage more people to use buses and result in reduction in the use of the private car and contribute to further reductions in emissions. Health Clearance Agreed By Dated th Public Health recommends that red routes may Lucy Hubber, Public Health 6 August have a part to play in reducing town vehicle Consultant [Interim] 2018 congestion but only as part of a comprehensive package of measures.
Page 8 of 478
The package of measures that are known to reduce congestion and therefore outdoor ambient air pollution include: Integrated public transport systems, park and ride schemes, restricted and charged parking permit allocation, incentives for staff to cycle, walk, car share or promoted discounts to use public transport. The public consultation responses calling for more car parks in the town centre, public health feel will encourage more vehicles not less coming into the town and will increase vehicle congestion, therefore feel it is at risk of exacerbating poor air quality and health harms.
Recently Luton was considered the fourth most congested urban area in the country, raising significant concerns for human and environmental health.
Nitrogen dioxide gas pollution is mostly as a consequence of emissions from diesel cars and vans and particulate matter from exhausts as well as from brake and tyre wear and road surface abrasion with highest concentrations along urban busy roads. Road vehicles are the main pollution source that people in urban environments, like Luton, are exposed to and the pollutants they emit have the greatest health impacts. Harmful outdoor ambient air pollutants particularly harmful to health in Luton are from traffic congestion.
It contributes to cardiovascular disease, lung cancer and respiratory diseases. A study quantifying the air pollution effects estimates that nitrogen dioxide burden is equivalent to approximately 23,000 deaths and particulate matter [PM] approximately 29,000 deaths in the UK per year [the latter being three times that of passive smoking and five times more than the number of deaths on roads].
Air pollution increases the chances of hospital admissions, visits to emergency departments and respiratory and cardiovascular symptoms which interfere with everyday life, especially for people who are already vulnerable and can cause premature death. Air pollution can reduce lung development in children.
Air pollution is a risk factor for asthma and can exacerbate conditions such as Chronic Obstructive Pulmonary Disease [COPD]. Luton’s statistical data shows emergency admissions rates significantly
Page 9 of 478 worse than the England average and significantly worse than some of our statistical neighbours. The emergency admission rates are for both adults and children patients in asthma [2014/15] and COPD [2016/17] with a cost per emergency admission amounting to £927 and £2,558 per patient respectively [2010/11].
In 2016 Luton’s annual concentration of fine particulate matter [PM2.5], adjusted to account for population exposure, was10.5% higher than nationally [9.3%]; 6% of adult mortality attributed to air pollution is significantly greater than recorded in England [5.3%]. In 2014/15 only 76% of adults in Luton did any walking at least once a week significantly worse than nationally where 80.6% of adults walk at least once per week; and 9.4% of adults do any cycling in Luton at least once per month significantly worse than nationally [14.7%].
Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
Page 10 of 478 Report For: Executive Item No: Date: 20 August 2018 Report Of: Service Director, Policy Communities and 8 Engagement Report Author: Angela Fraser
Subject: Appointment of Replacement Member on the Airport Board & Corporate Parenting Partnership Board Lead Executive Member(s): Councillor Simmons Wards Affected: All Consultations: Councillors ☐ Scrutiny ☐ Stakeholders ☐ Others ☐
Recommendations 1. The Executive is recommended to note and approve the replacement of Councillor Rowlands on:
a) The London Luton Airport Board of Directors with Councillor Agbley with immediate effect.
b) The Corporate Parenting Partnership Board with Councillor Rivers with immediate effect.
Background 2. At the Annual Meeting of Full Council held on 22nd May 2018, Councillor Rowlands was appointed as the Council representative on the London Luton Airport Board of Directors and the Corporate Parenting Partnership Board.
The Current Position 3. Following the resignation of Councillor Rowlands it is necessary to appoint a replacement representative on the London Luton Airport Board of Directors and the Corporate Parenting Partnership Board.
Goals and Objectives 4. To appoint a replacement for Councillor Rowlands as the Council’s representative on the London Luton Airport Board of Directors and the Corporate Parenting Partnership Board.
Proposal 5. It is proposed that Councillor Rowlands be replaced by Councillor Agbley on the London Luton Airport Board of Directors and Councillor Rivers as the representative on the Corporate Parenting Partnership Board on with immediate effect.
Key Risks 6. The Council would not be represented on the London Luton Airport Board of Directors or Corporate Parenting Partnership Board.
Page 11 of 478 Consultations 7. N/A
Alternative options considered and rejected (please specify) 8. None, other than to alter the membership as proposed in accordance with the wishes of the political group.
Appendices Attached 9. N/A
Background Papers 10. N/A
Page 12 of 478 IMPLICATIONS
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated There are no direct legal implications to the Raj Popat-Principal 02/08/2018 proposal contained within the report. Solicitor
Finance Clearance Agreed By Dated There are no direct financial implications to the Darren Lambert, Finance 2nd August proposal contained within the report. Business Partner 2018
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated There are no direct equalities implications to the Maureen Drummond, 2 August proposal contained within the report. Cohesion and Equalities 2018 Adviser Environment Clearance Agreed By Dated There are no direct environmental implications to Katarzyna Wysocka, 02/08/18 the proposal contained within the report. Strategy and Sustainability Service Health Clearance Agreed By Dated There are no direct health implications to the Patsy Richards, Public 3/8/18 proposal contained within the report. Health Programme Manager Healthy Lives Community Safety Clearance Agreed By Dated
Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
Page 13 of 478
Page 14 of 478 Report For: Executive Item No: Date: 20 August 2018 Report Of: Service Director, Finance & Audit 9 Report Author: Angela Bush
Subject: Treasury Management Annual Report – Year Ended 31st March 2018 Lead Executive Member(s): Councillor Malcolm Wards Affected: None Consultations: Councillors ☐ Scrutiny ☐ Stakeholders ☐ Others ☐
Recommendations 1. Executive is RECOMMENDED; (i) To approve the Treasury Management Annual Report and prudential indicators for the year ended 31st March 2018 which summarises and reviews the Council’s treasury management activities for the 2017/18 financial year. (ii) To submit the report to Full Council for approval.
Background 2. The Council is required under the Local Government Act 2003 to produce an annual treasury report reviewing treasury management activity and the actual prudential and treasury indicators. This report meets the requirements of both the CIPFA Code of Practice on Treasury Management, and the CIPFA Prudential Code for Capital Finance in Local Authorities and is submitted in accordance with Treasury Management Strategy Statement for 2017/18 approved at decision EX/13/17 and the Annual Investment Strategy approved by Full Council at minute 26/5.3.
The Current Position 3. This report covers the following areas:- • capital activity for the financial year 2017/18; • the Council’s overall borrowing need (capital financing requirement); • prudential indicators throughout the report and Appendix A; • overall treasury position identifying how the Council has borrowed in relation to its indebtedness, and the impact on investment balances Appendix B; • borrowing strategy and activity; and • investment strategy and activity.
The Council’s Capital Expenditure and Financing 2017/18 4. The Council undertakes capital expenditure on long term assets. These activities may either be:
Page 15 of 478 • Financed immediately through the application of capital or revenue resources (capital receipts, capital grants or revenue contributions), which has no resultant impact on the Council’s borrowing need; or • If insufficient financing is available, or a decision is taken not to apply resources, the capital expenditure gives rise to a borrowing need.
5. The actual capital expenditure forms one of the council’s required prudential indicators. The table below shows the actual capital expenditure and how this was financed.
2016/17 2016/17 2017/18 2017/18 General Fund Estimate Actual Estimate Actual £million £million £million £million Capital Expenditure 58.710 56.839 179.682 49.704 Financed in Year 31.348 31.672 38.486 30.060 Subsidiary Investments 5.000 5.000 108.200 10.000 Unfinanced Expenditure 22.362 20.167 32.996 9.644
2016/17 2016/17 2017/18 2017/18 Housing Revenue Estimate Actual Estimate Actual Account (HRA) £million £million £million £million Capital expenditure 25.183 19.920 22.559 17.667 Financed in Year 15.893 12.898 13.559 13.019 Unfinanced Expenditure 9.290 7.022 9.000 4.648
6. The majority of the capital expenditure, relating to the financing of major subsidiary projects, which did not incur in 2017/18 has been re-profiled to 2018/19. More details on this can be found in the Provisional Revenue Capital Outturn Report 2017-18 reported to Executive on the 4 June 2018. The Council’s overall borrowing need
7. The Council’s underlying need to borrow for capital expenditure is termed the Capital Financing Requirement (CFR). This figure is a gauge of the Council’s debt position. The CFR results from the capital activity of the Council and what resources have been used to pay for the capital spend. It represents the 2017/18 unfinanced capital expenditure (see above tables) and prior year’s net or unfinanced capital expenditure which has not yet been paid for by revenue or other resources.
8. Part of the Council’s treasury activity is to address the funding requirements for borrowing need. Depending on the capital expenditure programme, the treasury service organises the Council’s cash position to ensure sufficient cash is available to meet the capital plans and cash flow requirements. This may be sourced through borrowing from external bodies (such as the Government, through the Public Works Loan Board (PWLB) or the money markets, or utilising temporary cash resources within the Council.
9. The Council’s non-HRA underlying borrowing need (its CFR) is not allowed to rise indefinitely. Statutory controls are in place to ensure that capital assets are broadly charged to revenue over the life of the asset. The Council is required to make an annual charge to revenue, called the Minimum Revenue Provision (MRP) to reduce the CFR. This is effectively a repayment of the non-Housing Revenue Account (HRA) borrowing need (there is no
Page 16 of 478 statutory requirement to reduce the HRA CFR). This differs from the treasury management arrangements which ensure that cash is available to meet capital commitments. External debt can also be borrowed or repaid at any time, but this does not change the CFR.
10. The total CFR can also be reduced by :- • the application of additional financing resources ( such as unapplied capital receipts);or • charging more than the statutory charge (MRP) each year through a Voluntary Revenue Provision (VRP).
11. The Council’s MRP Policy for 2017/18 was approved in February 2017. The actual MRP for the financial year was £9.654 million.
12. The Council’s CFR for the year is shown below, and represents a key prudential indicator.
2016/17 2016/17 2017/18 2017/18 CFR General Fund Estimate Actual Estimate Actual £million £million £million £million Opening Balance 204.446 273.275 224.550 289.036 Capital Expenditure 58.710 56.839 179.682 49.704 Capital Financing (31.348) (31.672) (38.486) (30.060) MRP (incl. PFI & leases) (7.258) (8.356) (9.014) (9.654) VRP 0.000 (1.050) Appropriation of Buckle (0.725) Close to HRA Closing Balance 224.550 *289.036 356.732 298.301
2016/17 2016/17 2017/18 2017/18 CFR Housing Revenue Estimate Actual Estimate Actual Account £million £million £million £million Opening Balance 124.348 111.596 133.638 118.618 Capital Expenditure 25.183 19.920 22.559 17.667 Capital Financing (7.061) (4.066) (1.780) (3.434) Major Repairs Reserve (8.832) (8.832) (11.779) (9.585) HRA Previously Funded (9.000) Appropriation of Buckle 0.725 Close from General Fund Closing Balance 133.638 *118.618 133.638 123.991 The CFR for 2016/17 has been restated in the Statement of Accounts due to an audit adjustment
13. The borrowing activity is constrained by prudential indicators for net borrowing and the CFR, and by the authorised limit.
14. To ensure that borrowing levels are prudent over the medium term and only for a capital purpose the Council should ensure that its gross external borrowing does not, except in the short term, exceed the total of the capital financing requirement in the preceding year (2016/17) plus the estimate of additional capital financing requirement for the current
Page 17 of 478 (2017/18) and the next two years. This essentially means that the Council is not borrowing to support revenue expenditure. This indicator allows the Council some flexibility to borrow in advance of its immediate needs in 2017/18. The table below highlights the Council’s Gross borrowing position against the CFR and the Council has complied with this prudential indicator. Gross Borrowing compared with the Capital Financing Requirement
2016/17 2016/17 2017/18 2017/18 Estimate Actual Estimate Actual £million £million £million £million Borrowing 273.092 273.092 277.192 277.192 Other Financial Liabilities 24.561 23.929 23.028 23.030 Total Debt 297.653 297.021 300.220 300.222 CFR 358.188 407.654 490.370 422.292
15. The authorised limit is the affordable borrowing limit required by section 3 of the Local Government Act 2003. The Council does not have the power to borrow above this level. The table below demonstrates that during 2017/18 the Council has maintained gross borrowing within its authorised limit.
16. The operational boundary is the expected borrowing position of the Council during the year. Periods where the actual position is either below or over the boundary is acceptable subject to the authorised limit not being breached.
2016/17 2016/17 2017/18 2017/18 General Fund Debt Estimate Actual Estimate Actual £million £million £million £million Total Debt 297.653 297.021 300.220 300.222 Operational Boundary 297.653 294.630 326.816 326.816 Authorised Limit 327.653 324.630 403.100 403.100
The Council’s Treasury position at 31st March 2018 17. The Council’s treasury position is shown at Appendix B to this report. At all times the treasury management service will seek to ensure adequate liquidity for both revenue and capital activities security for investments and to manage risks within all treasury management activities. Procedures and controls to achieve these objectives are well established within the Council’s Treasury Management Practices. Borrowing Strategy for 2017/18 18. The expectation for interest rates in 2017/18 was for the Bank rate to experience marginal increases following its fall to a record low of 0.25% on 4th August 2016. They are now on the rise following the increase back to 0.50% in November 2017. 19. The inherent strategy was to, utilise maturing investments and therefore reduce the Council’s exposure to counterparty credit risk, and postpone new borrowing and the resultant costs involved. This strategy was prudent as investment returns were low and counterparty risk was still an issue that needed to be considered. Regard would be had, though, to the potential for incurring additional long term extra costs by delaying borrowing until later years when rates may have increased.
Page 18 of 478 The Economy and interest rates in 2017/18 20. During the calendar year of 2017, there was a major shift in expectations in financial markets in terms of how soon Bank Rate would start on a rising trend. After the UK economy surprised on the upside with strong growth in the second half of 2016, growth in 2017 was disappointingly weak in the first half of the year which meant that growth in the first half of 2017 was the slowest for the first half of any year since 2012. The main reason for this was the sharp increase in inflation caused by the devaluation of sterling after the EU referendum, feeding increases into the cost of imports into the economy. This caused a reduction in consumer disposable income and spending power as inflation exceeded average wage increases. Consequently, market expectations during the autumn rose significantly that the MPC would be heading in the direction of imminently raising Bank Rate. The MPC meeting of 14 September provided a shock to the markets with a sharp increase in tone in the minutes where the MPC considerably hardened their wording in terms of needing to raise Bank Rate very soon. The 2 November MPC quarterly Inflation Report meeting duly delivered on this warning by withdrawing the 0.25% emergency rate cut which had been implemented in August 2016 increasing the rate back to 0.50%. Market debate then moved on as to whether this would be a one off move for maybe a year or more by the MPC, or the first of a series of increases in Bank Rate over the next 2-3 years. Link Asset Services, the Council’s treasury consultant, along with other economists are forecasting that the current bank rate of 0.50% will remain in place until November 2018, to be followed by further increases in September 2019, June 2020 and November 2020. The forecasts are based on the assumption that the UK will make progress with concluding a satisfactory outcome over the Brexit negotiations with the EU by March 2019.
Borrowing rates in 2017/18
21. PWLB borrowing rates increased correspondingly to the above developments with the shorter term rates increasing more sharply than longer term rates. The table shown below shows, for a selection of maturity periods, the high and low points in rates, spreads and individual rates at the start and end of the financial year.
Public Works Loan Board Borrowing Rates 2017/18
9.5 to 24.5 to 49.5 to 1 to 1.5 2.5 to 3 3.5 to 4 4.5 to 5 1 month 1 year 10 25 50 years years years years variable years years years
03/04/17 0.850% 0.870% 1.000% 1.120% 1.250% 1.930% 2.620% 2.370% 1.100%
29/03/18 1.470% 1.520% 1.670% 1.760% 1.850% 2.230% 2.570% 2.290% 1.090%
Highest 1.510% 1.600% 1.790% 1.900% 2.010% 2.530% 2.930% 2.640% 1.310% Rate 21/03/18 21/03/18 21/03/18 21/03/18 15/02/18 15/02/18 15/02/18 15/02/18 21/03/18
Lowest 0.800% 0.820% 0.940% 1.030% 1.140% 1.780% 2.520% 2.250% 1.040% Rate 03/05/17 03/05/17 30/05/17 15/06/17 15/06/17 15/06/17 08/09/17 08/09/17 04/04/17
Average 1.107% 1.143% 1.276% 1.384% 1.503% 2.083% 2.688% 2.415% 1.157%
Spread 0.710% 0.780% 0.850% 0.870% 0.870% 0.750% 0.410% 0.390% 0.270%
Page 19 of 478 Borrowing outturn for 2017/18 22. There was additional long term borrowing of £4.095m from the PWLB in March 2018 in accordance with the Housing Revenue Account determination 2018, this has resulted in an over borrowed position for the HRA due to slippage of the Marsh Farm project to 2018/19. No short term fixed or variable borrowing has been undertaken in the financial year. 23. Appendix B items 1 & 2 show a comparison of the treasury borrowing maturity profile for the years 2016/17 and 2017/18 split between the General Fund and Housing Revenue Account. Investment Strategy for 2017/18 24. The Council’s investments are mainly cash flow derived with an element of core reserve balances. 25. The Council’s inherent strategy is to reduce the level of investments held, by using maturing investments to help fund cash flow. It was not considered likely that new long term investments (over one year) would be a prominent feature going forward but a limit of 25% of total investments was set should the opportunity arise. Investments in the main would be kept liquid in reserve accounts and money market funds. Investment Rates in 2017/18 26. Investment rates for 3 months and longer have been on a rising trend during the second half of the year in the expectation of Bank Rate increasing and it was duly raised from 0.25% to 0.50% on 2.11.17 and remained at that level for the rest of the year. However, further increases are expected over the next few years. The table below shows a range of rates prevailing during the financial year. Money Market Investment Rates 2017/18 7 day 1 month 3 month 6 month 1 year % % % % % 01.04.2017 0.111 0.132 0.212 0.366 0.593 31.03.2018 0.364 0.386 0.587 0.704 0.878 0.366 0.390 0.587 0.704 0.879 Highest Rate 27/02/18 22/03/18 29/03/18 29/03/18 28/03/18 0.099 0.122 0.140 0.273 0.461 Lowest Rate 04/07/17 10/08/17 07/08/17 07/09/17 06/09/17 Average 0.215 0.233 0.286 0.401 0.606 Spread 0.267 0.268 0.447 0.432 0.418
Investment Outturn for 2017/18 27. The Council’s investment policy is governed by MHCLG guidance, each year the Council sets the investment strategy approved by the Council. The policy sets out the approach for choosing investment counterparties, and is based on credit ratings provided by the three main credit rating agencies, FITCH, Standard and Poors and Moodys, supplemented by additional market data such as credit default swaps and rating outlooks all provided by the Council treasury adviser Link Asset Services. The approved countries for investment are included as Appendix C.
Page 20 of 478 28. The investment activity during the year conformed to the approved strategy, and the Council had no liquidity difficulties. The internally managed funds earned an average rate of return of 0.29% as shown in Appendix B. The comparable performance indicator is the average 7- day LIBID rate, which was 0.21%. This compares with a forecast average rate of 0.25%. In cash terms this outperformance equates to £67k, however £73k was paid to 3rd parties. 29. As expected much of the Council’s investments were kept short in instant access money market fund accounts at rates ranging between 0.16% and 0.46%. 30. Funds were also invested on behalf of London Luton Airport Limited at times when concession income created investment opportunities and these investments are shown in the London Luton Airport Limited accounts. Similarly surplus funds on the schools National Westminster Bank account, mainly arising from half yearly payments transferred in by the Council were invested on a daily basis in a Goldman Sachs money market fund for cash flow liquidity and a longer term basis for excess funds not immediately required for cash flow purposes. In both cases investments were only made with institutions included on the Council’s approved lending list. Appendix B shows the performance for the year against the benchmark of 0.25% of 0.30% for Schools. Implications of the Brexit Vote on Council’s Treasury Activities 31. With Brexit due to be implemented during 2019, it would be fair to say that banking in the UK, and particularly in London, may be hugely different to what has existed over the past couple of decades. However, the immediate implications for Local Authorities are quite minimal. As the impact of Brexit unfolds, consideration will be given to whether the Council treasury strategy should be revised to minimise any potential risks. Revised CIPFA Codes 32. In December 2017, the Chartered Institute of Public Finance and Accountancy, (CIPFA), issued a revised Treasury Management Code and Cross Sectoral Guidance Notes, and a revised Prudential Code. A particular focus of these revised codes was how to deal with local authority investments which are not treasury type investments e.g. by investing in purchasing property in order to generate income for the Authority at a much higher level than can be attained by treasury investments. One recommendation was that local authorities should produce a new report to members to give a high level summary of the overall capital strategy and to enable members to see how the cash resources of the Authority have been apportioned between treasury and non-treasury investments. Officers will report to members when the implications of these new codes have been assessed as to the likely impact on this Authority. Markets in Financial Instruments Directive II (MiFID II) 33. The EU set the date of 3 January 2018 for the introduction of regulations under MIFID II. These regulations govern the relationship that financial institutions conducting lending and borrowing transactions will have with local authorities from that date. This has had little effect on this Council apart from having to complete application forms issued by each institution the Council deals with. Audit & Governance 34. As Audit and Governance Committee have been delegated responsibility for the scrutiny of Treasury Management Activity a copy of this report will be forwarded to their next meeting on 5th September 2018.
Goals and Objectives 35. To enable the Executive to review the Treasury Management Activity for the year
Page 21 of 478
Proposal 36. That Executive note the report
Key Risks 37. Treasury Management is an area of significant risk. In relation to security and probity of investments all activity has been undertaken in accordance with the provisions of the Council’s treasury Management Practices (TMP’s) which include a substantial section on risk, in order to manage and minimise, so far as possible, the risks involved.
Consultations N/A
Alternative options considered and rejected (please specify) 38. To reject the recommendations and request further information.
Appendices Attached Appendices and additional background papers attached: Appendix A – Prudential Indicators Appendix B – Treasury Performance & Current Status Appendix C – Approved Countries for Investment
Background Papers There are no background papers to this report.
Page 22 of 478 IMPLICATIONS
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated There are no direct legal implications arising Raj Popat 13.07.2018 from the recommendations in this report which are not covered in the body of the report. The Local Government Act 2003 and supporting regulations require the Council to have regard to the CIPFA Prudential Code and the CIPFA Treasury Management Code of Practice to set Prudential and Treasury Indicators to ensure that the Council’s capital investment plans are affordable, prudent and sustainable.
Finance Clearance Agreed By Dated The financial implications are set out in the body Dev Gopal 12.07.2018 of the report.
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated There are no equalities implications within this Maureen Drummond, 17.07.2018 report. Cohesion and Equalities Adviser Environment Clearance Agreed By Dated There are no direct environmental implications of Keith Dove, Strategic 12.07.2018 this report. However, indirectly some of the Policy Adviser projects funded during 2017-18 could have environmental implications. Health Clearance Agreed By Dated
There are no obvious health implications as a Lucy Hubber 19.7.2018 consequence of this report. Consultant in Public Health (Acting) Service Director – Healthy Lives and Children’s Joint Commissioning (Interim) Public Health,
Page 23 of 478 Commissioning and Procurement
Community Safety Clearance Agreed By Dated
Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
Page 24 of 478
APPENDIX A
2016/17 2016/17 2017/18 2017/18 PRUDENTIAL INDICATORS Estimate Actual Estimate Actual (1). CAPITAL FINANCE
1. Gross Debt (including other financial liabilities) £million £million £million £million Non HRA 168.000 166.471 194.565 165.575 HRA 129.543 130.550 134.647 134.647 Total Gross Debt 297.543 297.021 329.212 300.222
2. Capital Financing requirement £million £million £million £million Non-HRA 224.550 289.036 356.732 299.026 HRA 133.638 118.618 133.638 123.266 Total Capital Financing Requirement 358.188 407.654 490.370 422.292
3. Estimate of capital expenditure £million £million £million £million Non-HRA 58.710 56.839 179.682 49.704 HRA 25.183 19.920 22.559 17.667 Total Capital Expenditure 83.893 76.759 202.241 67.371
(2). TREASURY MANAGEMENT
4. Authorised limit for external debt - £million £million £million £million Borrowing 304.796 300.701 380.072 380.070 Other long term liabilities 22.857 23.929 23.028 23.030 Total Authorised Limit 327.653 324.630 403.100 403.100
5. Operational boundary - £million £million £million £million Borrowing 274.796 270.701 303.788 303.786 Other long term liabilities 22.857 23.929 23.028 23.030 Total Operational Boundary 297.653 294.630 326.816 326.816
6. Interest rate exposure £million £million £million £million i) Upper limit for fixed interest rate exposure on net debt 25.000 8.510 25.000 8.241 ii) Upper limit for variable interest rate exposure on net debt 7.500 0.871 7.500 1.226 iii) Upper limit for fixed rate investments 5.000 0.093 5.000 0.005 iv) Upper limit for variable rate investments 5.000 0.136 5.000 0.135 v) Upper limit for total principal sums invested for over 364 25.00% 0.00% 25.00% 0.00% days - maximum percentage of outstanding investments
Page 25 of 478 APPENDIX B TREASURY POSITION COMPARISON – 31/03/17 to 31/03/18 GENERAL FUND HOUSING REVENUE ACCOUNT Balance 2016/17 Balance 2017/18 Balance 2016/17 Balance 2017/18 Sheet Rate/ Sheet Rate/ Sheet Rate/ Sheet Rate/ 31/03/2017 Return 31/03/2018 Return 31/03/2017 Return 31/03/2018 Return £million % £million % £million % £million % BORROWING 1 Fixed Rate Funding PWLB - Fixed rate (79.242) 4.03 (79.242) 4.03 (120.860) 3.64 (124.955) 3.82 Money Market (41.219) 3.88 (32.449) 3.97 (5.781) 3.88 (4.551) 3.97
2 Variable Rate Funding Money Market (20.697) 4.26 (29.467) 4.05 (2.903) 4.26 (4.133) 4.05 3 Other Financial Liabilities PFI (22.609) (22.244) Leases (1.320) (785) 4 Accrued Interest (1.384) (1.387) (1.007) (1.009) Total Borrowing (166.471) (165.574) (130.551) (134.648)
5 Accrued Interest adj 1.384 1.387 1.007 1.009 6 CFR 289.036 298.301 118.618 123.991 (Over)/Under Borrowing 123.949 134.114 (10.926) (9.648)
INVESTMENTS 7 Luton Borough Council 6.939 0.48 15.533 0.29 8 Schools 15.189 0.48 11.346 0.30 22.128 26.879
Net Debt (144.343) (138.695) (130.551) (134.648)
Investments on behalf of other 19.120 0.56 0.620 0.59 organisations
Page 26 of 478 APPENDIX B (Continued)
TREASURY POSITION COMPARISON – 31/03/17 to 31/03/18
Maturity Structure of Debt Portfolio GENERAL FUND HOUSING Actual Estimate Actual Actual Estimate Actual 31/03/17 31/03/18 31/03/18 31/03/17 31/03/18 31/03/18 £million £million £million £million £million £million Up to 12 months 1.384 1.384 1.387 1.007 1.009 1.009 12 months and within 24 months 0 0 0 0 0 0 24 months and within 5 years 2.982 2.982 2.982 45.146 89.874 89.874 5 years and above 138.176 138.176 138.176 84.397 43.764 43.764 ***Actual figures include interest on loan accruals at 31st March 2018
Overall Maturity Structure of investment Portfolio Actual Estimate Actual 31/03/17 % 31/03/18 % 31/03/18 % £million £million £million longer than 1 year 0 0 0 0 0 Under 1 year 21.989 100.00 17.000 100.00 23.886 100.00
APPENDIX C
Approved countries for investment
AAA
Australia Canada Denmark Germany Netherlands Singapore Sweden Switzerland USA
AA+
Finland
AA
U.K
Page 27 of 478
Page 28 of 478 Report for: Executive Item No: Date: 20 August 2018 Report of: Service Director, Housing 10 Report author: Claire Astbury, Head of Housing Strategy & Development and Atika Chowdhury, Finance Adviser
Subject: Housing Revenue Account Borrowing Lead Executive Member(s): Cllr Tom Shaw Wards Affected: All Consultations: Councillors ☐ Scrutiny ☐ Stakeholders ☐ Others ☐
Recommendations
1. That the Executive is recommended:
(i) To approve in principle the bidding for additional borrowing headroom in the Housing Revenue Account (HRA).
(ii) To Authorise the Service Director of Housing Services and the Service Director of Finance & Audit (Section 151 Officer), in consultation with the Portfolio Holders for Housing and Finance, to bid for and take up appropriate borrowing within the Housing Revenue Account.
Background
2. Councils with housing stock, including Luton Council, have a Housing Revenue Account (HRA) which is ring fenced from the General Fund and subject to specific rules. This includes a cap on borrowing imposed by central government.
3. Luton Borough Council has borrowed to the level of its cap in order to fund the Marsh Farm Central Regeneration. This means that our ability to build more homes is restricted within the HRA business plan as it is funded through surpluses and reserves, alongside recycled Right To Buy (RTB) receipts.
4. The council’s current programme is based on capacity in the HRA and scheduled to meet both funding and development timescales. The forward programme has been through scheme appraisal which assumes a cost of funds and repayment of debt funding at 5% interest even though at present they are funded through the HRA rather than borrowing.
5. In the Autumn Statement 2017 the government announced that it would be offering £1bn additional HRA borrowing permissions to support housebuilding in high demand areas up to 2022. The details of the funding bid were released on 26 June 2018 and the deadline for bids is 7 September 2018.
The current position
Page 29 of 478 6. Luton is one of the “high demand” councils permitted to bid for additional headroom. Each development scheme will count separately and all bids will be assessed via Homes England on criteria such as value for money and deliverability. It is possible that none or all of our bids may be successful.
7. There is £500M to share between all eligible councils outside of London over 3 years 2019/20 to 2021/22. Bids must be for rented or shared ownership homes on specific schemes on identified sites with details of scheme mix and costs.
8. Headroom can be mixed with Homes England grant or RTB receipts (but not both at the same time), and also Section 106 contributions. Luton’s programme assumes the use of RTB receipts at 30% of eligible scheme costs.
9. Bids cannot be made for Joint Ventures, housing companies, housing for sale, conversions or acquisitions.
Goals and objectives
10. Luton Council has been pressing the government for additional borrowing capacity in the HRA to support new council housing so it is important to take the opportunity to bid. The council should seek all opportunities to bring forward additional affordable homes to meet local acute housing needs.
11. As a member of ARCH, the Association of Retained Council Housing, the council also recognises the importance for the £1bn borrowing opportunity to be fully bid to demonstrate the ambition and appetite of councils nationally to grow their affordable housing stock.
Proposal
12. It is proposed to enter bids for all the council’s current programme to 2022. Headline information on these proposed schemes is shown at Appendix 1. We also sought advice from the Ministry of Housing, Communities & Local Government (MHCLG) regarding the potential to bid for additional costs at Marsh Farm Central Regeneration, as identified in the report to 4 June 2018 Executive. At this point it does not look likely that a bid for Marsh Farm would be successful.
13. The bid process requires the council to confirm that the bid has in principle support from councillors and the Section 151 Officer. It is therefore proposed to delegate authority to the Section 151 Officer (with the Director of Housing Services) to sign off on bids, and to arrange for any approved headroom borrowing to service our development programme. Individual schemes should continue to meet the agreed parameters of (a) a positive Net Present Value (NPV) (b) payback within 35 years (c) Internal Rate of Return minimum 4%.
14. Whatever capacity is released by achieving borrowing permissions can be directed at capital projects including future housebuilding or major repairs. In particular, to support the purchase of land and sites for future years as there are not many additional sites in ownership.
15. The council’s modelling assumes that any borrowing in this headroom bid will be repaid to create new headroom in the future.
16. The above schemes are in the current HRA capital programme and are affordable to the HRA.
Page 30 of 478 Key risks
17. The main risk relates to bidding for homes which then face development delays which push them beyond the timeframe for the headroom permissions. All but one of the sites in the programme are within ownership but only two have planning permission at this point. One site requires the repurchase of garages, potentially via compulsory purchase orders (CPO), to progress the development. There are pre-construction checks still to do on a number of sites and any requirements for land remediation for example could also delay sites beyond the funding window.
18. There is a risk that if the council borrows to fund new homes, delays to development or increases in cost impact on the viability of the development and therefore the payback time, impacting on the HRA more widely.
19. Servicing the debt will need to be factored in the HRA Business plan which is being revised in August with the need to ensure there is sufficient revenue to fund this debt.
Consultations
20. Finance team, Councillor Shaw.
Alternative options considered and rejected (please specify)
21. The council could choose not to bid for one or all of these schemes. However, as this is the first time that bids have been appraised in this way by Homes England, it is suggested that the best approach is to include our entire programme so that as many schemes as possible have the chance of approval.
22. Another option would be to bring forward more schemes which were scheduled later in our programme. However, the development schemes which are scheduled for completion beyond 2022 are far less deliverable at this point, mainly due to mixed land ownership. In practice, even if these schemes were bid for, it is very likely that Homes England would decide that their deliverability was uncertain and refuse borrowing permission.
Appendices attached
Appendix A - Outline Development programme sites 2019-2022
Background papers
23. There are no background papers to this report.
IMPLICATIONS
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
Page 31 of 478 For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated There are no additional legal implications other than Raj Popat-Principal 31/07/2018 those involved in the borrowing arrangements for the Solicitor HRA.
Finance Clearance Agreed By Dated No direct financial implications at this stage as this is Darren Lambert, Finance 2 August an agreement in principle. If our bids are successful Business Partner 2018 further reports with full business case will have to be prepared to ensure that the additional borrowing is affordable and sustainable and will form part of the Council’s HRA business plan
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated This bid round (if borrowing is permitted) can support Maureen Drummond, 30 July 2018 additional affordable housing which contributes to Cohesion and Equalities inclusive growth in Luton. If borrowing permission are Adviser granted it could support more new affordable homes in the future by releasing HRA capacity to assemble land. Otherwise at this point a neutral effect on protected characteristics since this decision is only in principle for a bid. Environment Clearance Agreed By Dated No direct environmental implication to the financial Katarzyna Wysocka, 31/07/2018 delegation. New homes built as a result of this bid Strategy and Sustainability round will be built to good environmental standards. Service Health Clearance Agreed By Dated Good quality affordable housing is central to Lucy Hubber MFPH 30/07/2018 wellbeing and health. Specifically, home Consultant in Public Health environments have an impact across the life course (Acting) on health and wellbeing. If permissions are granted Service Director – Healthy there is a potential to improve health and wellbeing Lives and Children’s Joint outcomes. Commissioning (Interim) Public Health, Commissioning and Procurement Community Safety Clearance Agreed By Dated
Staffing Clearance Agreed By Dated
Page 32 of 478
Other Clearance Agreed By Dated
Page 33 of 478 Appendix A
Outline Development Programme 2019-2022 All schemes yet to achieve planning permission unless indicated.
Scheme Units Estimated Borrowing NPV Payback IRR Completion Cost requirement time year
Birdsfoot 6 £1.749M £857K* £104K 30 years 5.46% 19/20 Lane (planning granted)
27 Bristol 1 £368K £102K* £78K 30 years 6.40% 19/20 Road (planning granted)
Fitzwarin/ 2 £505K £354K £70K 30 years 5.98% 19/20 Wauluds
44-46 1 £312K £218K £45K 30 years 6.03% 20/21 Bristol Road
Mangrove 3 £1.007M £705K £176K 30 years 6.23% 20/21 Road
Buckle 34 £7.889M £5.72M £98K 30 years 5.9% 21/22 Close
Adj Sherd 17 £7.686M £5.381M - 35 years 2.4% 21/22 Lodge £1.69M
Wetherne 5 £1.478M £1.034M £711K 28 years 8.01% 21/22 Link
Totals 69 £20.994M £14.371M
* denotes sites which start on site in 2018/19 hence borrowing requirement will only cover the development costs which fall within 2019/20.
denotes site where we do not currently have full ownership of the land. For this reason, the site represents a higher delivery risk and may not be included in the borrowing bid.
Page 34 of 478 Report for: Executive Item No: Date: 20 August 2018 Report of: Head of Housing Strategy & Development 11 Report author: Claire Astbury
Subject: Luton Housing Strategy Consultation Draft Lead Executive Member(s): Cllr Tom Shaw Wards Affected: All Consultations: Councillors ☒ Scrutiny ☐ Stakeholders ☒ Others ☒
Recommendations 1. That the Executive is recommended to:
(i) Approve the draft of the Luton Housing Strategy 2019-2022.
(ii) Authorise the Head of Housing Strategy & Development to undertake a formal public consultation on the draft strategy for a period of 8 weeks to commence on 28 August 2018, before considering the responses and producing a finalised strategy.
(iii) Note that following the consultation period the revised strategy will be presented to Executive for formal adoption.
Background 2. Housing is a central issue in achieving sustainable and inclusive growth in Luton, and in supporting wellbeing for residents.
3. The previous Housing Strategy is being superseded by a new strategy which flows from the council’s overarching strategic framework of the Luton Investment Framework (LIF) and Corporate Plan
4. The Luton Housing Strategy will set out the council’r ambitions and priorities for the next three years in relation to housing supply, quality and support. .
The current position 5. A consultation draft of the housing strategy is attached for approval. The document has been discussed with members and amended accordingly to reach the consultation draft version which is now ready for public discussion.
Goals and objectives 6. The overall vision for the strategy is: Reflecting the aspirations of the LIF, Luton will be a vibrant and ambitious town which offers good quality housing for residents in homes and communities which support wellbeing, integration and opportunity.
Page 35 of 478 7. Parallel with the housing strategy the council is looking to update the Affordable Housing Supplementary Planning Guidance to reflect the new local plan and to improve our affordable housing delivery through planning.
Proposal 8. The draft strategy covers four main themes, developed from extensive local engagement:
(i) Right Homes, More Homes (ii) Reducing Homelessness (iii) Good Quality Homes & Places (iv) Supporting Wellbeing
9. The housing strategy also includes an equalities audit setting out how equalities have been taken into account in the production of the strategy.
Key risks 10. Risks for the delivery of strategy ambitions are identified throughout the strategy including changes to the housing market, availability of appropriate sites for housing, external funding availability, welfare reform impacts and ability to sustain partnerships for delivery.
Consultations 11. Substantial engagement took place with internal and external stakeholders between March and May 2018. The draft strategy document has also been reviewed by CLMT and councillors.
Alternative options considered and rejected (please specify) 12. The strategy has been discussed and amended with a range of key stakeholders. The current version balances ambition and deliverable targets. There may be additional changes as a result of consultation, which is an opportunity to identify items which are not sufficiently addressed.
Appendices attached Appendix A – Housing Strategy Consultation Draft (Enclosed for Members Only)
Appendix B - Integrated Impact Assessment
Background papers 13. There are no background papers to this report.
IMPLICATIONS
Page 36 of 478
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated In accordance with the Local Government Act 2003 Raj Popat-Principal 31/07/2018 Section 87, the Council previously had a statutory Solicitor duty to publish a Housing Strategy, which set out its vision for housing in the Borough. While the Deregulation Act 2015 abolished the statutory requirement for English authorities to produce a housing strategy, as previously required, the aim of the new Housing Strategy 2019-2023 is to support the priorities for housing in Luton over the next three years, across all tenures to meet housing need. It will contribute to the Council’s overarching strategic objectives.
Finance Clearance Agreed By Dated There are no direct financial implications of the Darren Lambert, Finance 2 August report. The financial implications of the strategy Business Partner 2018 support delivery of the Council’s aim of continuing to deliver a balanced budget.
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated A full IIA is attached which has identified a positive Maureen Drummond, 30 July 2018 outcome for all key groups. The Housing Strategy Cohesion and Equalities aims to improve housing outcomes for some of the Adviser, most vulnerable communities. The provision of the right mix of homes for our whole community supports cohesion. Environment Clearance Agreed By Dated The strategy promotes environmental improvements Katarzyna Wysocka, 01/08/18 as part of the focus on quality of homes and Strategy and Sustainability communal open spaces. Activities to support better Service energy efficiency will help to reduce CO2. Health Clearance Agreed By Dated Having a home which is safe and affordable is Lucy Hubber MFPH 30/07/2018 generally considered to be a basic need. The main Consultant in Public Health themes of the strategy will support good health (Acting) outcomes, as home environments have an impact Service Director – Healthy across the life course on health and wellbeing. The Lives and Children’s Joint
Page 37 of 478 strategy considers vulnerable populations, which will Commissioning (Interim) directly reduce the risk for respiratory and Public Health, cardiovascular diseases, poor mental health and Commissioning and excess winter deaths. Procurement Community Safety Clearance Agreed By Dated
Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
Page 38 of 478 APPENDIX A
0 Page 39 of 478 Foreword
Our Housing Vision The Luton Housing Strategy 2019-2022 marks Luton We are investing in improvements to our homes to make them Council‘s commitment to leading the way in providing good and our estates attractive places to live. Our repairs and quality homes for people on all incomes. maintenance division, BTS, invested over £11 m per year in investment in our stock, and have started building new homes Housing is an essential part of our inclusive growth strategy and has a 97% approval rating from our residents. Our tenant so that Luton is a good place to live and thrive. We have seen participation activity has been growing so that we can be significant progress over the last three years with substantial closer to our communities and adapt our services to respond. investment in Luton through the Luton Investment Framework (LIF) which sits at the heart of this Housing Strategy. The council is becoming more active in tackling housing issues directly through our own development activities but we Luton is regenerating and growing, and we recognise the also rely on good partnerships to ensure that this strategy is challenge of making good quality housing accessible and delivered. We will continue to nurture and grow our affordable for a diverse and dynamic population. relationships with housing providers, third sector partners, and statutory bodies such as Luton Clinical Commissioning Group Our recent housing achievements are highlighted in the (CCG) in order to realise our ambitions. strategy. We have eliminated the use of bed and breakfast accommodation for homeless households, with a shift to Tom Shaw, Executive Member for Housing leased homes and more stable accommodation. Our enforcement activity is transforming the private rented sector and tackling rogue landlords.
1
Page 40 of 478 Contents 8.1.1. Children, Care Leavers and Looked After Children 8.1.2. Domestic Violence and : Page Abuse 1. Foreword by Tom Shaw 1 8.1.3. Ex Offenders 2. Our Vision 3 8.1.4. HIV+ 3. Executive Summary 5 8.1.5. Learning Disabilities 4. Introduction 7 8.1.6. Mental Health
4.1. Strategic context 7 8.1.7. Migrants 4.2. Overview of Luton 7 8.1.8. Older People 4.3. National Policy Changes 13 8.1.9. Physical and Sensory 4.4. Affordability Statement 14 Disabilities 4.5. Housing Strategy Family Tree 16 8.2. Priorities and Actions 38 4.6. Recent achievements 17 8.2.1. Children, Care Leavers 5. Right Homes, More Homes 18 and Looked After Children 5.1. Overview and Evidence 18 8.2.2. Domestic Violence and 5.2. Recent Changes 19 Abuse 5.3. Best Use of Stock 21 8.2.3. Ex Offenders 5.4. Joined Up Ambitions 22 8.2.4. HIV+ 5.5. Priorities and Actions 22 8.2.5. Learning Disabilities 5.6. Risksand mitigations 23 8.2.6. Mental Health 6. Reducing Homelessness 24 8.2.7. Migrants 6.1. Overview and Evidence 24 8.2.8. Older People 6.2. Recent Changes 25 8.2.9. Physical and Sensory 6.3. Joined Up Ambitions 25 Disabilities 6.4. Priorities and Actions 26 8.3. Risks and Mitigations 41 6.5. Risks and Mitigations 27 9. Equalities Statement 42 7. Good Quality Homes and Places 28 Appendices 54 7.1. Overview and Evidence 28 1: Action Plan 7.2. Recent Changes 29 2: Commissioning Priorities 7.3. Joined Up Ambitions 30 3: Consultation Summary 7.4. Priorities and Actions 30 7.5. Risks and mitigations 31 8. Supporting Wellbeing 32 8.1. Overview and Evidence: 32 2
Page 41 of 478
2.0 Our Vision Reflecting the aspirations of the Luton Investment Framework, Luton will be a vibrant and ambitious town which offers good quality housing for residents in homes and communities which support wellbeing, integration and opportunity.
To achieve this, we will focus on four themes:
Right Homes, More Homes Reducing Homelessness We work with a wide range of partners to We actively prevent homelessness and secure the delivery of the right mix of homes provide pathways into appropriate housing to meet Luton’s needs and will achieve at and support for people who are homeless or least 3500 new homes by 2022 of which 700 at risk of homelessness. will be affordable. .
Good Quality Homes and Places Supporting Wellbeing Luton residents are proud of their homes and The right housing options are in place so that neighbourhoods and improvement of poor people in Luton can live well by feeling quality homes is helping the most vulnerable included and supported to live independent households. lives.
3
Page 42 of 478 3.0 Executive Summary We set out ambitious targets for new housebuilding and the council is an active part of the local housing market, building Luton is a dynamic and diverse town which is growing and a mixture of high quality homes for sale and to rent. We improving. Housing is essential to our wider vision for expect 3500 homes to be built in Luton by 2022, of which 700 investment, economic development and wellbeing. will be affordable homes provided by the council or its Our housing challenges include reducing homelessness and partners. rough sleeping, getting more homes built to meet local needs, improving Luton as a place to live and ensuring that people We will measure our success by feedback from residents with differing needs can live well. about their experience of living in Luton and from key performance indicators such as the number of households in We have limited land within the borough for new homes and temporary accommodation and the investment in we need to maximise this by building the right range of homes improvements to homes across the borough. for our current need and future aspirations. Partnerships will be central to our delivery of services and Luton has seen housing costs rise significantly over the last capital projects. We work positively both across the council two years. Higher house prices and rents have made it more and with external partners from the business, voluntary and difficult for some people to afford a suitable home. Incomes statutory sectors. Many of our ambitions will be met through are rising in Luton but there are areas of deprivation and clear both local and subregional partnerships. evidence of housing pressures such as overcrowding and homelessness which impact on wellbeing. Our population is By 2022, there will be a greater range of affordable and changing fast and we have a high proportion of young people aspirational homes in Luton, in neighbourhoods which are and a growing older population too. Matching housing to the quality places to live. Homes will meet the variety of specialist specific needs of our ethnically diverse and ageing population needs which exist and be warm and safe so everyone can is a core ambition of our strategy. have a good quality of life.
Our housing strategy sets out the issues and what we plan to do to deliver the quality homes and housing services our residents need.
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Page 43 of 478 Our Recent Achievements 2. We will reduce the number of households in temporary Ended the use of Bed and Breakfast accommodation for accommodation by 100 per year and reduce our use of homeless households and saved over £4m in costs nightly rate accommodation to zero by 2020. Adopted a new Local Plan 3. We will work with partners to deliver specialist support for Refreshed our tenant engagement activity homeless people including a Housing First scheme and a Completed Phase 1 of Marsh Farm Regeneration with review of supported accommodation. shops and affordable homes 4. We will improve our processing time for homelessness 97% satisfaction levels with our repairs service BTS applications to help people move on more quickly. Established a housing company, Foxhall Homes Tackled rogue landlords and poor quality private sector Quality Homes and Places homes through licensing schemes 1. We will commission a housing condition survey to inform our activity in improving private sector housing conditions. Our Headline Strategic Ambitions 2. We will reduce fuel poverty by 25% over three years. 3. We will build new homes to high quality standards and Right Homes, More Homes manage our estates well. 1. We will support the delivery of 3500 new homes by 2022. 4. We will secure external funding to improve the quality of At least 700 will be affordable homes. homes across the town. 2. The council will be a significant local developer, completing 400 homes by 2022. Supporting Wellbeing 3. We will work with developers to build more of the right 1. We will work in partnership across the council and with homes for Luton – larger family homes, homes for older others to deliver the homes and services which meet people and high quality homes . specialist needs including people affected by domestic 4. We will work strategically with partners on wider growth violence and mental illness, children leaving care and opportunities which deliver transformational growth. migrants without recourse to public funds. 2. We will deliver services, adaptations and new homes Reducing Homelessness which meet the needs of disabled and older people. 1. We will reduce rough sleeping by 50% over 2 years. 3. We will support wider initiatives such as Transforming Care which provide housing options for people with learning disabilities. 6
Page 44 of 478 contributing to a transformation of Luton as a place, both in reality and in the perceptions of our residents. 4.0 Introduction The council’s Corporate Plan sets out our organisational 4.1 Strategic Context: Luton Investment Framework and direction across all our services and identifies the how we Corporate Plan best target our resources to improve.
The Luton Investment Framework, launched in 2016, Already, significant improvements have been made. Luton underpins our ambitions to deliver sustainable growth and has seen the fastest private sector job growth, largest opportunities for our town. With the LIF on course to exceed increase in real wages and highest number of new enterprises our target of £1.5bn of inward investment over the next two anywhere in the country. Life expectancy is rising, our schools decades, we have a clear focus and determination that the delivered the best key stage 2 improvements in the country for benefits of this programme will be felt by the whole Maths in 2017 and our Prevent and counter extremism community. Combined with the fact that we are now home to agendas were rated as outstanding by the Home Office in the UK’s fifth largest airport, alongside major businesses in 2018. the aviation and engineering sectors, there is a growing confidence that Luton is the ideal place to live, work and 4.2 Overview of Luton invest. Luton is a vibrant, modern and diverse town in the East of Our LIF strategic priorities are: England. Thirty miles north of London, and at the centre of the 1. Building economic growth and prosperity Oxford-Cambridge strategic growth corridor, the town has 2. Enhancing skills and education excellent transport links by road, rail and air. London Luton 3. Improving health and wellbeing Airport is the fifth largest airport in the UK today, with over 15 4. Developing quality homes and infrastructure million passengers annually. Luton is situated by the M1 5. Supporting safe, strong and cohesive communities motorway, just 10 miles from the M25 and is 22 minutes from London by train. Alongside the LIF, we have successfully rebranded our organisation, forming our new mission statement, a renewed vision and fresh strategic priorities which are already 7 Page 45 of 478 4.2.1 A Diverse and Dynamic Population Population turnover is greatest in South, Farley and High Luton has a particularly dynamic and diverse population. Town wards. Recent research into population movements1, found a high level of movement in and out of the borough. There is also a Biscot and Dallow wards have the highest birth rates. high birth rate. This is significant for the delivery of council services and across the wider public sector particularly the NHS. Age Demographics in Luton 2011
It is estimated that approximately 50 to 60 per cent of the Under 15 15-64 65+ current population were either not born or not living in Luton at 12% the time of the 2011 Census. 22%
The population of Luton increased from 203,400 in 2011 to 216,800 in 20162 In this time, international migration has 66% grown and the population of Luton has become more diverse. Internal migration is showing an increase of people moving from North London boroughs to Luton, but the highest number Luton has a younger population than the rest of England and is from Central Bedfordshire. the Eastern Region, with 22% of the population under 15, compared to 18% regionally and nationally. Between 2011 and 2016: 43,000 people moved to Luton from elsewhere in the UK The over 65 age group represents 12% of the Luton and 53,000 people left population compared with 16% nationally and 18 % regionally. 19,000 international migrants arrived in Luton and 6,000 left There is now an recognition that Luton is one of a few ‘super- There were 18,000 births and 7,000 deaths diverse’ places. The town is ethnically diverse, with approximately 55% of the population being of Black and Minority Ethnic (BME) origin, with significant Pakistani, 1 Population Churn in Luton 2018. 2 ONS Mid Year Census estimates 2016 8
Page 46 of 478 Bangladeshi, Indian, Eastern European and African 4.2.2 Economic Challenges Caribbean communities The LIF is showing signs of success with the town In recent years the diversity of the population has increased. increasingly recognised as a leading place for innovation4. There has been a significant shift in the population, primarily Wages are rising and there is significant investment in skills driven by those arriving from the eight countries that joined and training. Employment is growing and GVA per head grew the EU during its enlargement in 2004. Since then, there have by 3% between 2016 and 2017. been over 30,000 new National Insurance registrations in Luton by people originating from these eight countries, with However, low incomes remain a concern. Average incomes more than 75% coming from Poland. A study by Mayhew for those who live in Luton are lower than those who work in Harper Associates showed there are concentrations of new Luton. The borough is ranked as the 59th (out of 326) most communities of Congolese, Somalis, Ghanaians, Nigerians, deprived local authority. In 2010 Luton was ranked as the Turks and Zimbabweans in Luton3. Foreign students coming 69th most deprived local authority and in 2007 as the 87th. to study at the University of Bedfordshire have also This indicates that Luton is becoming relatively more deprived contributed to the increased diversity in the town. in comparison to the other local authorities of England
Luton has nine output areas in the top ten % most deprived Ethnic Origin in Luton areas in the country. Three of these are in Northwell ward, two each in Farley and South ward, and one in Biscot and Dallow wards. Research by the Centre for Research in Social Policy showed that about a third of children in Luton are living in White poverty. 45% BME 55% 4.2.3 Housing
The affordability, liveability and transport links for Luton have led to an increase in internal migration, with the average
3 3The Growth and Changing Complexion of Luton’s Population, Mayhew Harper Associates, 4 2011 Open Data Institute: UK Tech Innovation Index, June 2018 9
Page 47 of 478 house price gaining an extra £41,702 in value in 20165. Numbers leaving London are at the highest level since 2006 The council recently adopted a Key Worker Housing Strategy (ONS). This has also impacted on rent levels, affecting which supports target professions including teaching and homelessness and making it challenging to place homeless social work. Housing affordability and availability are crucial families in accommodation. to support some of the priority services the council provides.
The relative affordability of Luton compared to other nearby The average house price in Luton at £242,912, recently areas and London has created competition for the provision of exceeded the national UK house price which is £226,906 accomodation for homeless households. This has had wider although it is below the average for the East (£286,447) and impacts on Luton including resource challenges for schools, South East (£324,530)9. social services and advice services.
Housing issues impact more widely on other aspects of life. House Prices Increases Jan16-Jan18 Among families approaching the Flying Start family support 450,000 service in 2017/18, a quarter were experiencing housing 400,000 6 350,000 problems, the single largest area of concern for families . 300,000 250,000 Detached Nationally, overcrowding is more prevalent among minority 200,000 Semi Detached ethnic groups, particularly Bangladeshi, Pakistani, Black Other Thousands 150,000 and Black African communities7. In Luton, research found 100,000 terraced 50,000 that Asian families8 were more likely to be living in larger flats/maisonette 0
household groups, so the accessibility and availability of Jul-17
larger homes is an issue which impacts on some ethnic Jul-16
Jan-16 Jan-17 Jan-18
Oct-16 Oct-17
Apr-16 Apr-17 groups more than others. Provision of larger homes and good Month & Year space standards within homes are therefore important locally. 10
5 https://www.bbc.co.uk/news/business-38554793 6 Source: Flying Start Service Request Data 7 MHCLG data, 2017 9 Source: Land Registry April 2018 8 Mayhew & Waples, 2011 10 Source: Hometrack data, June 2018 10
Page 48 of 478 We can see from the graph, that since 2016, house prices in in the private sector, as LHA rates are based on 30th Luton have increased significantly and the bigger properties percentile rates and many landlords charge rents at average have shown a bigger increase compared to the smaller units to upper quartile rates, therefore making it difficult for many such as terrace and flats. people to live in private rented accommodation. In addition, our analysis of local costs (in the Housing Ladder diagram on Detached properties are higher in resale price then the other page 14) shows that Local Housing Allowance (LHA) costs lag property sizes. The growth has been gradual and it shows that behind 30th percentile costs – creating a gap of over £50 per Luton is a place that people are moving into, possibly week for one bedroom properties, and over £30 per week for attracted by lower prices than surrounding areas. two bedroom properties.
Rents for Luton Home Ownership in Luton12 Home ownership has remained predominant. 61% still own a Rent Prices from 2014-17 property in Luton in comparison to the other forms of housing. 1,600 1,400 Social and Affordable rented 1,200 Social and affordable rented housing has remained consistent 1,000 at 16% since 2001 to 2011 as the census information shows. 800 600 400 Private rented 200 There has been an increase in private renters to 22% which 0 has overtaken the social and affordable rented market as many people look for alternative housing in the private sector.
mean lower quartile upper quartile The SHMA (Strategic Housing Market Assessment).
11 The Strategic Housing Market Assessment (SHMA) was The rents for Luton as of 2014 to 2017, have shown a steady introduced in 2010. The evidence from these documents increase for all properties. Many people cannot afford to rent
11 12 2011 Census data 11
Page 49 of 478 helps to inform policy making at local and regional levels and 3 bedroom 10910 255 2 it shows the housing requirements in a given area. It provides 4 bedroom 2590 274 10 evidence on the tenure and size of mix of housing required All dwellings 17,800 2121 12 which includes market, intermediate and social rented housing. These figures demonstrate the oversupply of one bedroomed homes and the undersupply of larger family homes. There is Luton and Central Bedfordshire councils have worked a clear need to deliver more larger homes in the town to together for many years to commission ORS (Opinion address this imbalance. Resources Services) to carry out this research to support Local Plan development. The most recent SHMA update for 4.3 National Policy Changes Luton was published in 2016. There have been several legislative and policy changes in the 13 The SHMA has calculated the need for housing in the last few years which have changed the operating environment borough of Luton, as follows: for housing.
Dwellings % Welfare Reform and Benefit Cap Market housing 10,600 59.5 The full rollout of Universal Credit to Luton in the later part of Affordable 7,200 40.5 2018 has implications for many households which could housing/rent increase rent arrears and create financial challenges. Luton All dwellings 17,800 100 Council has been working cross departmentally and in partnership with other organisations to prepare for Universal The size mix of homes required was identified as follows: Credit.
Required by Delivered to % delivered Homelessness Reduction Act 2017 2031 2016 2011-2016 The Act came into force for many local authorities in April 1 bedroom 420 917 218 2018, and has emphasised the need for local authorities to 2 bedroom 3880 675 17 provide concise advice and assistance at an earlier stage when customers approach the council for assistance with
13 SHMA - 2016 housing. 12
Page 50 of 478 Affordable Housing Programme Housing and Planning Act 2016 The Homes and Communities Agency, now Homes England, The Housing and Planning act introduced a number of has gradually returned to funding affordable rented homes but changes to the housing sector, including right to buy for funding is reduced compared to previous investment Housing Association tenants, end of lifetime tenancies and programmes. tackling rogue landlords. Sustainability and Transformation Plans (STPs) A reduction of local authority funding One of a range of health sector reforms in recent years, the Local authorities are under pressure to transform service STPs aim to support the long term sustainability of health delivery, generate additional income and respond to services. Luton is an active partner in the Bedfordshire, Luton reductions in central government funding. Luton’s Medium and Milton Keynes (BLMK) STP and has strategic Term Financial Plan has helped the council maintain a engagement across a range of programme priorities including comparatively advantageous position despite being the sixth transforming primary care, reviewing estates and supporting worst affected unitary authority in terms of central government health and care integration. cuts. Government limits to borrowing in the Housing Revenue Account which covers council housing have limited the 4.4 Affordability Statement council’s ability to build new affordable homes. Meanwhile the financial impacts of rising homelessness and use of temporary Property Income Ladder14 accommodation has led to significant costs to council tax payers through the General Fund. Analysis of local housing costs and income levels allows us to plot affordability in Luton and clarify what is genuinely Social rent reductions affordable for households in different income brackets. From 2015 to 2019, social rents have been reducing by 1% per year. This impacted significantly on social landlords The affordability ladder overleaf shows weekly costs of capacity to develop, including Luton Council. A new rent different tenures of housing at one, two and three bedroom settlement from 2019 will allow additional income to be sizes. It also shows what would be considered affordable on channelled into new homes. local incomes, as reported by the Annual Survey of Hours and
14 Data from Hometrack and local authority rents 2018, ASHE 2017 13
Page 51 of 478 Earnings (ASHE) for incomes in Luton, taking 35% of gross agreements. We will also continue to monitor and challenge income as the maximum that a household should pay for the growing gap between LHA rates and actual rents. housing. The information in this chart will be updated annually to track the affordability of homes in Luton.
The ladder model demonstrates how private renting is increasingly unaffordable. People with incomes in the bottom half in Luton would not be able to afford a family sized property of 2 bedrooms and above in the private rented sector. For most, housing benefit and the housing element of Universal Credit does not bridge the gap to the actual cost of lower 30% rents. LHA rates are well below actual rental costs.
Social rented homes are demonstrably more affordable and most Affordable Rent homes are also within reach. New council homes are capped at LHA rates to retain affordability.
The figures also demonstrate the significant potential for shared ownership to play a role in offering stable and affordable housing for lower income groups. At a relatively low equity level of 40%, shared ownership (Homebuy) compares well to private renting or renting at Affordable Rents, which means that for households in the bottom 30% of incomes could afford a two bedroom property, assuming that they could provide a 10% deposit on their 40% share.
We will use the information to guide our own programme and to press for more affordable options within planning
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Key - Number of bedrooms 30% - Lowest 30% of private rents LQ – Lower quartile Med – Median (average) UQ – Upper quartile HA – Housing Association LA – Local Authority
The Housing Affordability Ladder shows the costs of different types of homes and how this compares to incomes for Luton residents. Housing costs are expressed as cost per week. Affordability is shown for each 10% of local income levels.
For example it would be affordable to buy a lower quartile priced 2 bedroom home if the household was in the 40th percentile of income and above. At this income range, most affordable and social rent is also affordable but not a lower priced 1 bedroom home in the private rented sector.
Sources of data are: Hometrack for housing association and private sector rents, shared ownership costs and newbuild and resale open market costs. Shared ownership costs include both mortgage and rental costs per week. Local authority information for Council rents, Annual Survey of Hours and Earnings (ASHE) for incomes in Luton.
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Page 53 of 478 4.5 Housing Strategy Family Tree
The following diagram places the housing strategy in context within wider corporate and local strategies.
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Page 54 of 478
4.6 Recent achievements
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Page 55 of 478 5.0 Right Homes, More Homes Our local plan 2011-2031 was adopted in 2017. It includes provision for 8,500 homes from the 17,800 identified as
objectively assessed need for the borough. We work with a wide range of partners to secure the delivery of the right mix of homes to meet This leaves 9,300 homes outstanding. We will be working Luton’s needs and will achieve at least 3500 new with neighbouring authorities in the broader Luton Housing homes by 2022 of which 700 will be affordable. Market Area to support the delivery of those additional homes. In addition, we recognise the strategic location of Luton within 5.1 Overview and evidence the Oxford-Cambridge Arc area and continue to co-operate with other local authorities in that growth area to support Luton needs affordable, good quality homes for rent and to transformative housing growth projects. buy. They must be in safe and harmonious communities and meet local needs. Delivery rates in Luton have been above target in the last two years, in part as a result of office to residential conversions. Evidence from the Strategic Housing Land Availability Assessment SHLAA15 has outlined the delivery of housing from 2011-2017.
Year Delivery 2011/2012 490 2012/2013 351 2013/2014 147
2014/2015 415 The LIF includes a number of strategic sites and a target to 2015/2016 624 deliver the remaining 5700 homes from our local plan within 2016/2017 798 timescale. Total 2825
15 SHLAA Nov 2017
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Page 56 of 478 attracted funding towards land remediation, feasibility and Much of the housing growth in recent years has been for regeneration projects. smaller homes. This has exacerbated an undersupply of larger and family homes, and homes across the price Homes England spectrum. Our relationship with Homes England encompasses strategic growth, grant and loan finance and market engagement. We support registered provider bids for funding in Luton to enable additional affordable homes and also have the capacity to apply for funding for our own development projects.
Self-Build Homes The council holds a Self-Build Register, whereby potential After an assessment in 2017 by the Housing Finance Institute, self-builders can register their interest in developing their own Luton Council achieved Housing Business Ready homes. In the last 12 months the register has grown from one Accreditation in recognition of our strategic focus on growth. to seven expressions of interest. The council will support individuals and community led organisations to develop Partnership working additional housing through publicising potential sites, consultation on planning issues and brokering local The council works with a wide range of partners to enable and relationships to support new schemes. promote housing delivery and the provision of affordable homes. We have active liaison arrangements with housing 5.2 Recent Changes associations and the third sector, providers of temporary accommodation, landowners and developers of sites in the Housing delivery is significantly impacted by confidence in the town. local housing market. Following the introduction of the LIF and adoption of the Local Plan, values and delivery certainty One Public Estate for sites in Luton have improved. Luton Council is an active partner in the One Public Estate programme, working with other public land holders in the town The council has become more proactive in housing delivery to bring forward sites and co-location of services. We have with the establishment of a new housing company, Foxhall 19
Page 57 of 478 Homes, and additional council housebuilding including a Initial development is on council land with additional land major redevelopment at Marsh Farm. We will continue to purchase required from 2021. Our council housing maximise our ability to bring forward new homes of all tenures management service is integral to our ability to develop more to support housing growth in the town. homes as efficiencies in our operational costs generate additional income to support new housebuilding. Our commissioning priorities for new council homes are set out in Appendix 1 to ensure that council housing is meeting our full range of needs.
Foxhall Homes is a development company wholly owned by Luton Council. Funding is provided from the council’s prudential borrowing capacity and the company generates a return to the General Fund, whilst developing high quality homes and a mix of outright sale and affordable homes. The business case for the first six schemes on council owned land has been developed and first scheme is on site. Further schemes will be added as feasibility studies are completed. At this point, there are some elements of the Housing and
Planning Act 2016 yet to be fully implemented, such as the The Housing Revenue Account (HRA) Business Plan also high value levy and the extension of right to buy to housing provides funding for more affordable council homes on a association tenants. These policies could affect our ability to range of sites, supported by receipts from Right To Buy sales. 20
Page 58 of 478 deliver more affordable housing if implemented as initially We offer discretionary grants to overcrowded households who conceived. own their homes, to create loft extensions. We aim to secure good space standards within new homes and build our own homes to Nationally Described Space Standards.
Our Aids and Adaptations service also ensures that existing homes are fit for purpose for those who live in them.
Empty Homes 16 have always been a part of Luton’s housing policy, and we aim to bring 20 homes per year back into use through liaison with owners and use of local government powers such as compulsory purchase and empty dwelling 5.3 Best Use of Stock. management orders. The current Empty Homes Strategy is being updated. In addition to securing new homes, it is essential to get the best from the homes and buildings in the town to meet housing needs. This applies to our own stock as well as other housing in Luton.
We have developed an offer to council tenants who are looking to downsize into smaller accommodation. We have a focus on the provision of age-appropriate accommodation and surrounding services which will help to create more movement in the housing market and free up family sized homes.
To maximise the availability of council accommodation for those who are waiting, we strive to recover homes which are illegally sublet and minimise void periods.
16 Empty Homes Strategy for Luton 2015-2020 21
Page 59 of 478 5.4 Joined up Ambitions We will strengthen our wider partnerships to support access to land, development finance and skills to Our ambition for Right Homes, More Homes align with other maximise housebuilding in Luton and consider the Council priorities around bringing forward the quality of homes potential for specific joint ventures as appropriate. we need and the housing which supports the local economy We will implement a policy for shared ownership homes and broader wellbeing. which helps the council to deliver additional affordable homes and meet the needs of a wider range of households A growing development programme also supports the including key workers. council’s commercial ambitions through generating business We will work with developers and partners to support more revenue for BTS which constructs new council housing and by of the larger homes that the town needs. supporting Foxhall Homes business plan. We will update our supplementary planning guidance on affordable housing to reflect our new local plan in order to We work with other partners such as the CCG to ensure that secure an appropriate mix of homes on development sites. homes support wider strategic objectives for public health and We will advocate for and seek to provide age-appropriate independence. More detail on this strand of work is in section accommodation which helps to free up family sized homes 8 Supporting Wellbeing. of all tenures. We will maximise all funding opportunities and strategic 5.5 Priorities and Actions growth discussions to deliver homes which meet the wider housing needs of the Luton housing market area. We will continue to press for delivery on all major sites We will refresh our Empty Homes strategy and continue to identified in the LIF to support economic growth and bring homes into use at a rate of 20 per year. regeneration in the town. We will develop our offer to self builders to support these We will be an active developer, delivering at least 400 schemes. homes via our housing company and council house building programme as part of a total delivery of 3500 homes by 2022. We will secure the delivery of 700 affordable homes by 2022.
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Page 60 of 478 5.5 Risks and mitigations
Key risks in terms of the wider housing market are broadly outside of the council’s control. These include economic conditions, market confidence and availability of finance for purchase and development of homes. However, the LIF and investment in local skills, employment pathways and infrastructure would help to mitigate some of these issues and keep Luton as a place which continues to attract external investors. Our ability to negotiate affordable housing within development sites is closely linked to site viability so a dip in values or significant rise in construction cost (for example as a result of leaving the EU) could limit our ability to enforce local plan targets.
Other risks include the loss of skilled labour for construction projects, through a low uptake of young people entering the sector, more older, skilled, workers retiring and loss of migrant labour especially from EU countries.
Our ability to meet broader housing needs for Luton residents also depends on provision in local plans of neighbouring authorities so it is essential to grow our positive working relationships. This will also facilitate opportunites arising from wider strategic growth intiatives.
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Page 61 of 478 6.0 Reducing Homelessness Luton CCG. The need to respond to homelessness in an multi agency coordinated way is now much greater. We intend to We actively prevent homelessness and provide support our residents as early as possible to ensure they are enabled to help themselves in finding appropriate solutions to pathways into appropriate housing and support prevent homelessness. for people who are homeless or at risk of homelessness. Regular dialogue between statutory and third sector partners has developed from the Homelessness Prevention Strategy 6.1 Overview and Evidence which has facilitated additional projects and funding bids to tackle homelessness issues in the town. The effect of homelessness can extend beyond the devastating loss of accommodation and impact individuals for Homelessness in Luton – Key Facts17 years. We recognise it is often related to complex issues that The numbers of homeless applications in Luton has hinder financial, education, social wellbeing and create health increased by 65 per cent between 2014 and 2017. inequality. Applications fell in 2013-14 and have gone back up again. The numbers accepted as being in priority need in Luton Through early intervention and prevention and proactive have reduced by 10% between 2014 and 2017, falling solutions we expect to halve the levels of homelessness and from 439 to 391 households in that time. rough sleeping in Luton. Already the council has ceased the The main reason for homelessness in 2017/18 is the end use of bed and breakfast accommodation, moving homeless of an assured shorthold tenancy, which accounted for 98 households into more appropriate accommodation. cases in 2017/18. Luton has been successful in the number of cases of Homelessness remains a major problem in the town however, homeless prevention, with an increase from 119 cases in and Luton has over twice the number of people living on the 2014-15 to 876 cases in 2016-17 and 801 in 2017/18 with streets than in any other town in the East of England the majority of the interventions keeping people in their according to homeless charity Shelter. home.
The Homelessness Prevention Strategy 2016 – 2021 is the 17 first shared homelessness strategy for Luton Council and Source: Luton Council, MHCLG returns
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Page 62 of 478 Two thirds of homeless cases are female with dependent A successful bid for a Rough Sleepers Initiative was recently children being the most frequent reason for priority need awarded by the Ministry of Housing, Communities and Local The black ethnic group are over represented in homeless Government (MHCLG). This funding of £310,940 will assist in applications. This trend is the same in all comparator reducing the number of Rough Sleepers from 87 to 44 in the regions. forthcoming year.
A successful bid for the development of a Housing First 6.2 Recent Changes project in Luton was awarded £210,00 from improved Better Care Fund (iBCF). This project will support 20 homeless The key change has been the Introduction of the individuals with complex needs in accommodation through Homelessness Prevention Act. The act introduces stronger allocated council stock. prevention and relief duty for eligible households regardless of priority need status. The extension of the definition of 6.3 Joined Up Ambition threatened and homeless from 28 to 56 days gives local Homelessness and vulnerable housing has an impact on authorities a more realistic period to carry out prevention health so our work to reduce homelessness supports our work. strategic ambitions on Public Health and Children and Families. In particular the council’s Health Inequalities Action The number of households in nightly lets has been reduced Plan sets targets to address homelessness and poor housing. from 336 to 265 between January and June 2018, a reduction of 20%. Luton Council worked with Luton Clinical Commissioning Group to set out a five-year strategy which aims to reduce Number of Frontline Homeless Preventions have risen from levels of homelessness and the human cost of homelessness 61 to 560 cases over three years. across the borough. A multi-agency group supports the 18 ongoing implementation of this strategy . The time taken to make a decision on homeless applications has reduced so that the number of people waiting over 33 Because homelessness impacts disproportionately on women days for a decision has fallen from 200 to 12 over the last two and black people in Luton, activities to tackle homelessness years.
18 Homelessness Reduction Strategy 2016 25
Page 63 of 478 also supports the council’s wider work on community Improving Temporary Accommodation outcomes cohesion, equalities and community engagement. We will expand our Temporary Accommodation Purchasing Scheme to provide an additional 20 homes by Engagement activities with primary care and community 2020 to grow our portfolio to 80 homes. organisations demonstrated that reducing homelessness was We will improve the quality of temporary accommodation a high priority for Luton. by working closely with our private sector property owners and leasehold providers. 6.4 Priorities and Actions We will support the introduction of supported temporary accommodation offering higher support for those with Homelessness Reduction complex needs. We wil support our implementation of the Homelessness We will reduce our use of nightly lets to zero by 2020 Reduction Act with the introduction of new software and through establishing more leased accommodation. focus on homelessness prevention. We will reduce the number of households in temporary We will reduce rough sleeping by 50% over 2 years and accommodation by 100 per year. work with key partners to ensure that no-one new sleeps We will ensure that residents of temporary accommodation rough for a second night. are benefitting from the skills, and training support We will maintain and develop effective reconnection available via the Luton Investment Framework and career services back to home countries and cities for those pathfinder team. without a local connection. We will meet our income collection target of 93% for We will review supported housing services to prevent temporary accommodation. repeat homelessness and rough sleeping amongst people We will implement an affordable charging policy for with mental and complex health needs. temporary accommodation. Ensuring that local public and voluntary sector services We will continue to lobby for increased LHA rates to reflect prioritise homelessness prevention when designing and Luton housing market and limit the council’s exposure to commissioning services for vulnerable individuals and temporary accommodation costs. families. We will reduce time in temporary accommodation by We will reduce homelessness costs by a minimum of £2m improving our processing time for homelessness between 2018 and 2020.
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Page 64 of 478 applications and supporting people to move out into Our LIF is the key mechanism to mitigate against low income independent accommodation. and precarious employment in the town and support more high skilled stable jobs. Partnership We will continue to build on partnership working with Many of our projects to reduce homelessness and support charities, third sector, statutory and faith organisations to homeless people are funded through government and address homelessness challenges and attract investment external funding. When these funding streams come to an for through a variety of projects and initiatives, taking up all end, the sustainability of services particularly to rough opportunities to support sustainable prevention of sleepers, is at risk. homelessness and routes out of homelessness. We will work with women’s organisations to improve Success in delivery of more affordable housing in Luton will emergency housing and move on options for victims of also help to reduce time in temporary accommodation and violence and exploitation. create more opportunities for stable housing options. Develop jointly with third sector organisations a “Move On” strategy which will offer long term support We will bid to be part of the Making Every Adult Matter network co ordinated through Homeless Link.
6.5 Risks and Mitigations
There are many drivers of homelessness in Luton but affordability and accessibility of the private rented sector in particular is a challenge. Our ability to prevent homelessness, and respond to it, is hampered by rising rents, short term tenancies and low local incomes. Hence, a major risk for our ambitions to reduce homelessness is any economic shock which impacts on incomes without reducing housing costs, and the separate issue of rising housing costs.
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Page 65 of 478 7.0 Quality Homes and Places quarter of homes. The quality of privately rented homes is Luton residents are proud of their homes and therefore a high priority locally. neighbourhoods and improvement of poor The council itself owns one in ten homes in the town and is quality homes is helping the most vulnerable committed to investment in council housing stock, to maintain households high quality affordable homes and neighbourhoods.
7.1 Overview and Evidence A major consideration in housing quality is thermal comfort Across Luton, the quality of homes and neighbourhoods and fuel poverty. Fuel poverty has been falling but still affects impacts on health, safety and life chances for our residents. an estimated one in eleven of households21 and impacts on both physical and mental health. Although most residents are satisfied with the town, where dissatisfaction exists, the condition of neighbourhoods is a key Key Facts reason. Through the LIF, the council is working to improve According to latest available data, 32%22 of private homes and quality of place and change perceptions of residents and less than 1% 23of council homes in Luton fail the decent visitors to Luton. Housing and neighbourhood quality are both homes standard. key to achieving the ambitions of the LIF. 11.8% of households experienced fuel poverty in 201624 Our most recent information on private housing quality is in the Housing Condition Survey from 2009 which identified that 20% of people are dissatisfied with Luton as a place to live, privately owned homes in Luton were better than the England with over a quarter of those citing quality of place reasons25. average, and that poor conditions were concentrated in 19 central areas . Information collected in 2017 from enforcement teams shows that the wards of Biscot, Dallow, Farley, Hightown and South Luton has had a higher than average private rented sector 21 which has grown in the last 10 years to 23%20; nearly a Luton Council, Joint Strategic Needs Assessment, 2015 22 Luton Council, Private Sector Stock Condition Survey, 2009 23 Local Authority Housing Statistics, 2018 24 Dept of Business, Energy and Industrial Strategy, Sub-regional Fuel Poverty 19 Luton Council Private Sector Stock Condition Survey, 2009 Data, 2018 20 Luton Council, Selective Licensing Research, 2017 25 Perceptions of Luton Survey, 2017 28
Page 66 of 478 are particularly affected by issues such as noise, crime, fly our council homes, as well as funding to transform Marsh tipping and poor housing conditions. These are the four wards Farm and build new high quality homes. with the highest proportion of privately rented homes. We are implementing projects to improve neighbourhoods on Local engagement highlighted that the quality of homes in the our estates including parking enforcement, new cleaning private rented sector was a particular concern for family contracts and concierge services. workers and health partners. We have installed 52 boilers and carried out 32 heating works Neighbourhood issues such as inappropriate parking, to 84 homes of people who are vulnerable and in need of community safety and exploitation of vulnerable people were affordable warmth over the past 2 years (2016-2018) raised by residents and third sector groups. We have attracted £105,000 over 2 years iBCF funding for an Energy Doctor scheme which will support vulnerable people 7.2 Recent Changes with heating advice and access to Healthy Heating grants. This follows up to £2m inward investment secured through The council has a strong focus on enforcement and housing ECO initiatives since 2011 quality has recently been incorporated in a broader approach to community enforcement. Our private sector housing team We have delivered over 150 measures in low income has been proactive in bringing rogue landlords to task, having households, covering small repairs, garden maintenance and a dedicated Rogue Landlord team. In addition to serving home security. statutory notices we have succeeded prosecuting in 19 cases, the largest fine of which amounted to over £70,000, relating to Our recent research into the housing needs of older residents over 30 homes since the Rogue Landlord Project began in identified a requirement to improve advice and guidance for June 2015. Our selective licensing scheme is impacting on older homeowners to maintain their homes in good and safe standards in the private rented sector. condition and we are actively working with the CCG to target frailer households with support and information. Our 30 year HRA business plan has been developed with a focus on investment. In the first five years of the business plan Our wholly owned housing company, Foxhall Homes, is we have allocated £124m investment to maintain and improve bringing high quality family homes to surplus land sites, which contribute to the quality of place in Luton. 29
Page 67 of 478 7.4 Priorities and Actions 7.3 Joined Up Ambitions The health impacts of poor housing are well understood and Commission an updated housing condition survey which for this reason, our Joint Strategic Needs Assessment (JSNA) specifically identifies conditions in the private rented sector identifies improvements to housing quality, especially in the to improve the targeting of our work to improve housing private rented sector, as a priority. Addressing poor housing quality. is also incorporated into the Luton Health Inequalities Review the council’s grants policy to reflect the findings of Strategic Plan our stock condition research and target the most vulnerable households. Initiatives to support affordable warmth are also central to Reduce levels of fuel poverty by 25% over three years. Luton Council’s Public Health approach with targets including Provide services to vulnerable homeowners who need the improvement of all homes in Luton especially private help to maintain their own home by relaunching rented sector homes. handyperson services and better targeted advice. Establish the Energy Doctor scheme and support over 250 Our Corporate Energy Strategy seeks to reduce CO2 clients by 2020 with affordable warmth and wellbeing emissions, support greener initiatives and improve our initiatives. performance in reducing energy use. Domestic energy use is Build strategic partnerships with health organisations, a part of this strategy which drives projects in Photovoltaic installers and funders to increase our impact in tackling energy generation, insulation and energy efficiency fuel poverty, and improving housing conditions, installations. demonstrated by increases in EPC ratings across the town. The Council owns one in ten properties in the town and has Seek all opportunities to maximise external investment in planned a significant investment in its homes. This includes low energy initiatives. the regeneration of some areas such as High Town and Commission new homes built to good quality through both Marsh Farm to make broader neighbourhood improvements, Foxhall Homes and new council housing with a minimum including a new community room hub in Marsh Farm. of 400 homes completed by 2022
Invest in council homes to ensure that all homes reach
EPC Band D by 2020 and Band C by 2025.
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Page 68 of 478 We will implement a new tenancy agreement for council tenants by 2019/20 setting out rights and responsibilities to support good neighbourhood management. Continue to improve estate management for council homes, based on feedback from our tenants, including new contracts for cleaning and grounds maintenance. Capture improvements in the private rented sector to demonstrate effectiveness of our improvement activities such as licensing. Deliver tenancy sustainment intiatives which support vulnerable tenants at risk of hoarding, self-neglect and cuckooing, and minimise the impacts on wider neighbourhoods.
7.5 Risks and Mitigations Financial resources are a primary risk for our grant programmes as our private sector grants are discretionary. The focus on attracting inward investment will help to mitigate against any loss of public funding. However, we note that funding programmes for energy works have often been through EU programmes such as European Regional Development Funding. It’s not clear at this point how these would be replaced after the UK leaves the EU.
In order to ensure that eligible households take up services which are available, we will work with community partners and embed a communications plan to target hard to reach and vulnerable households.
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Page 69 of 478 8.0 Supporting Wellbeing 8.1.1 Children, Looked After Children and Care Leavers The right housing options are in place so that Luton is a young town with a high proportion of residents people in Luton can live well by feeling included under 15. There are three main groups relating to children’s and supported to live independent lives. services: looked after children, 16-25-year olds living with a disability and asylum seekers 16-18 years old. As at 8.1 Overview and Evidence November 2017, there were 350 looked after children in Luton and the council takes very seriously its role as a corporate Housing’s essential role in supporting health and wellbeing is parent. For example we recently changed our housing well evidenced and recognised by Luton Health and Wellbeing allocations policy to give greater priority to young people Board. The Health and Wellbeing Board has identified a leaving care. focus on housing and homelessness in its Health and Wellbeing Strategy and these issues are also reflected in our Good quality housing options for care leavers are very JSNA. Overarching themes include promoting healthy important to ensure good outcomes and life chances. At lifestyles, reducing health inequalities and poverty, and present, staff provide support in developing independence, supporting people to meet health needs through housing. money skills, education, training and employment options in Broader work across Luton council including our Health order to transition successfully from care to adulthood. Inequalities Strategic Plan also aim to address the health impacts of deprivation, many of which are housing related. Challenges currently exist in identifying appropriate accommodation for care leavers where hostels are This section of the housing strategy includes information, inappropriate. The council is also seeking to supporting 52 priorities and actions relating to ten different groups which care leavers from hostel accommodation to other independent may require specific housing responses. accommodation.
As Luton council and Luton CCG continue to align their work, 8.1.2 Domestic Violence and Abuse the role of housing in supporting health and wellbeing is crucial to the delivery of the Sustainability and Transformation Tackling domestic violence and abuse is a priority for the Programme and wellbeing aspects of the LIF. council. We are looking at new ways to reducing domestic 32
Page 70 of 478 violence and abuse and its effects on families in Luton and average of 5 years. One in twenty women had more than one recently committed to the Chartered Institute of Housing’s perpetrator. 197 women with 231 children received face to Make A Stand campaign. Under this commitment we seek to face support. respond to domestic abuse which affects our residents or staff. Victims of abuse require a secure and consistent 8.1.3 Ex-Offenders pathway to flee domestic abuse into refuge and onto secure accommodation as well as options to stay safely in their Too many prisoners leave custody without a job, training, existing homes. and/or a place to live; this can lead to mental health issues and re-offending. As a matter of good practice, statutory and Domestic violence accounts for around a quarter of all voluntary services should engage with a prisoner’s housing recorded crimes and is one of the leading causes of needs at the earliest opportunity. There is evidence that homelessness for women nationally including nearly half of all helping offenders to secure suitable housing before the point repeat homessness applications26. Nationally, the number of of release and creating opportunities for specialist support people fleeing domestic violence and making homeless alongside this is crucial to break the cycle of offending. applications has risen in actual terms, although the percentage of acceptances due to domestic violence has Data provided by HM Prison and Probation Service for decreased27. Violence and abuse is a factor which leads to Bedfordshire in June 2018 showed: women sleeping rough and is also present for rough sleepers. Approximately 80 individuals to be released from prison in next 12 months, 70% of which were in Luton Aspects which impact on abuse and the routes out of it Insufficient housing and support available to ex-offenders include of culture, language, family structures, racism and in to support rehabilitation and manage risk effectively. some instances the insecure immigration status of abuse Specific locations required for certain offenders for victims. example away from schools and childcare settings.
In 2017, Luton Women’s Aid received 625 calls for support. 78% of which came from women who were experiencing current domestic violence which had been present for an
26 Birmingham Coucil Domestic Violence Strategy 27 Birmingham Council Domestic Violence Strategy 33
Page 71 of 478 8.1.4 HIV+ and Other Chronic Conditions 8.1.5 Learning Disabilities and Autism The East of England is one of the regions with the highest prevalence (19%)28 of new HIV diagnoses outside of London. There are currently estimated to be around 800 adults in Rates of HIV infection in Luton at 4.6% are over twice the Luton recorded by their GP as having a learning disability and national average of 2%. The communities most affected are there is a core group of 200-300 known people who require Black African men and gay men who make up around two care and support. Luton has a number of supported housing thirds and one third respectively of local cases. schemes providing for this client group and the longer term need for these is being reviewed. Because of the stigma associated with HIV, many people affected are also suffering from mental health problems and However, the true picture of all those with learning disabilities discrimination which can make for chaotic lifestyles. is much larger; there were over 3,37030 people with a learning disability in Luton in 2017 and this is estimated to increase to HIV medication has improved significantly and helps to 3,870 by the year 2035. In addition there is a hidden cohort of prolong life, although over time this also comes with side people with learning disabilities living at home with ageing effects such as brittle bones and mobility difficulties. parents. Appropriate housing solutions will reflect these needs as well as supporting a stable and healthy home environment. This group of people are getting older and requiring more help as they progress into old age. People with learning disabilities Luton has one of the highest rates of tuberculosis (TB) in the are increasingly seeking personalised options, including East of England, generally in excess of 20 cases per 100,000 sharing a home with a partner or spouse and housing options population. However, TB rates dropped to 201629. People need to adjust to facilitate this. with TB often require supported housing options when leaving hospital in order to stabilise and manage their condition. Lack Luton council is currently working with Luton CCG on a of stable housing can lead to further emergency admissions. strategy for people with learning disabilities. This strategy will assess the needs, including accommodation and support
28 Terrence Higgins Trust Bulletin Nov 2017 29 Public Health England, Tuberculosis in the East of England, 2016 30 PANSI figure. 34
Page 72 of 478 needs, and develop commissioning priorities for specialist (LGBT) people, disabled people, and people who have had accommodation. contact with the criminal justice system (ex-offenders). Mental ill health is a major factor in rough sleeping and our rough Luton Council is also part of the Transforming Care sleeper intiatives include mental health support to ensure that Partnership which aims to support independent living across people can move off the streets. the BLMK Bedford, Luton & Milton Keynes Sustainability and Transformation Programme (STP) area. Sourcing appropriate Nationally, rates of schizophrenia are 5.6 times higher in black housing is a crucial part of this work stream and close working Caribbean people, 4.7 in black Africans and 2.4 times higher is therefore required to ensure a good outcome for individual in Asian groups. Black populations are most likely to service users with complex needs. The BLMK STP is working experience post traumatic stress disorder, suicide attempts, on a housing strategy specifically for the Transforming Care psychotic disorders and drug dependency. Programme and Luton will contribute to this work. A key cohort is young adults returning to Luton from out-of-borough Mental ill health is also a factor for other people such as school placements. victims of abuse, ex-offenders, care leavers and people with learning, sensory or physical disabilities. 8.1.6 Mental Health Isolation and loneliness is increasingly recognised as a major Good mental health underpins our physical health and factor in mental and physical wellbeing. Good housing, safe wellbeing and is fundamental to how we live our lives through neighbourhoods and a sense of community has a crucial role relationships, work, leisure, and in achieving our full potential. to play in keeping people connected and well. Mental health and wellbeing is influenced by many underlying factors, and there is evidence to connect poor and There are currently estimated to be between 3,000 and unaffordable housing with poor mental health31. 4,00032 people receiving mental health services in Luton. According to the PANSI estimates, between 22,872 and People in marginalised groups are at greater risk of mental 23,971 Luton people have some sort of mental health problem health issues, including black, Asian and minority ethnic (BME) people, and lesbian, gay, bisexual and transgender 32 Together for a Healthier Luton Mental Health Needs Assessment Shopna Amin, Feb 2018
31 The Impact of Housing Problems on Mental Health, Shelter, 2017 35
Page 73 of 478 and between 9,559 and 10,036 have two or more psychiatric Luton are thought to be destitute migrants with no recourse to disorders33. public funds, primarily from Eastern Europe.
Luton has a wealth of charity and third sector organisations Within Luton, a project run by NOAH Enterprises and funded with an interest in mental health whose strengths and via MHCLG, helps destitute migrants to access health care, specialisms should be harnessed to improve the wellbeing of reducing public health risks; to overcome barriers to people with specific mental health needs. employment; to access financial services via a credit union and to secure long term accommodation. The NOAH 8.1.7 Migrants Controlling Migration project also links with the NOAH Street Drinkers Outreach project to meet the needs of rough Migrant destitution in England is rising, and for migrants who sleeping migrants. find themselves destitute and with no recourse to public funds (NRPF) there are limited services available. Mainstream 8.1.8 Older People services struggle to provide effective support for those outside of the welfare state, yet destitute migrants remain extremely Although Luton has a lower than average population of older vulnerable. people, the number is growing and there is also evidence of people becoming frailer at an earlier age in the town34. Without accommodation, migrants exposed to rough sleeping are in danger of worsening physical and mental health, and an Luton Council commissioned research in 2017 to review the increased exposure to substance misuse. For destitute medium terms housing needs of older and frail people in migrants, the lack of accommodation is even more Luton. The research looked at current provision of specialist challenging as they do not have access to benefits. This accommodation and services, the pattern of demand and leaves them at greater risk of exploitation and/or trafficking. need in the town and options to remodel or develop existing Access to basic humanitarian and subsistence needs such as assets to meet arising need. toiletries, cash, travel, food and clothing is also a crucial support mechanism for ensuring destitute migrants are able to Most older people prefer to stay at home as long as possible survive day to day. Around two thirds of rough sleepers in but require better access to advice and support to enable
33 PANSI data 34 footnote from Public Health 36
Page 74 of 478 independent living. However, the provision of aspirational families especially need access to good advice on staying retirement living options can help to encourage moves to age- independent at home, adaptations, assistive technology and appropriate accommodation which frees up family housing financial advice. across tenure. All the council’s existing sheltered schemes were reviewed in Our research identified that Luton has a lower provision of order to identify potential development opportunities, as well older persons accommodation than comparable boroughs and as some additional sites which might be appropriate for there is a need for additional age-appropriate and sheltered targeted older persons’ accommodation. accommodation as follows35: We anticipate a doubling in the number of people in Luton Date Age exclusive Sheltered Extra Care Residential Care with dementia from about 1,800 in 2014 to 3,600 in 204036. Beds There is evidence that dementia is more prevalent in African 2020 30 104 24 55 Caribbean and UK South Asian communities. Luton’s 2025 81 282 66 148 Demential Strategy seeks to make Luton a Dementia Friendly 2030 134 468 109 245 Town.
The report notes, however, that these numbers would reduce 8.1.9 Physical Disabilities37 if more people were able to remain independent at home. Physical disabilities are also increasing in number. In 2017, The areas with greatest need for new accommodation are there were approximately 12,500 people with a physical Bramingham, Round Green, Leagrave, Challney and Crawley disability; by 2035 this will increase to 14.600. wards. Individuals with Physical difficulties faced difficulty There was a clear demand for improved information, advice when being rehoused and often spend time in and guidance services, including the potential for a community unsuitable accommodation. navigator model which identifies key members of a community to share knowledge and signposting. Older people and their
36 Luton Council, Joint Strategic Needs Assessment, 2015 35Housing Needs of Older and Frail People in Luton, Cordis Bright, 2018 37 PANSI figure 37
Page 75 of 478 There is need for developers to provide housing for 8.2 Priorities and Actions people in wheelchairs and built to mobility standards A summary of the types of services and accommodation (Cat 2 and 3 Building Regs). required are summarised in this table:
Client type Sign- Support to Access to New Low level Intensive Luton council has produced the Luton Housing Design Brief posting & stay in accommo specialist ongoing ongoing that incorporates accessible homes for all. Advice current dation accommo support at support at home dation home home Children, LAC & Care Leavers Luton Council supports households with disabilities through Domestic Violence Disabled Facilities Grants and adaptations funding within Ex-offenders HIV+ & Chronic council homes. conditions Learning disabilities Mental health There are small numbers of people with sensory disabilities, Migrants Older people known to the council services. There are 45 people known to Physical & having a visual impairment and 9 have a hearing impairment sensory disabilities and 4 people are deaf and 3 people are dual diagnosis. 8.2.1 Children, Looked After Children and Care Leavers People with visual and hearing impairments can benefit from support, sensitive housing design and assistive technology to We will reduce our use of hostels for young people leaving live independently. care. We will develop more suitable housing options for Looked After children and young asylum seekers. We will support foster carers in Luton through appropriate home extensions and access to larger homes to allow local fostering. We will work with partners to bring forward supported lodging and shared lives housing options.
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Page 76 of 478 We will continue to return children who are currently 8.2.3 Ex-Offenders placed outside of Luton back into the borough, developing specialist accommodation where necessary. We will work with partners to help people who are entering We will work with third sector partners to make move on the criminal justice system to retain their housing where accommodation available for young people. possible, including where they are a council tenant. We will work with third sector partners to seek funding to 8.2.2 Domestic Violence and Abuse provide proactive housing advice ahead of release to ensure an address when leaving prison. We will work with partners to support people, where We will work with NACRO and other partners to source appropriate, to stay safely in their homes rather than additional housing for ex-offenders. having to move due to violence, and to return home after a We will work in partnership to ensure that ex-offenders are refuge stay if possible. not excluded from pathways to housing and can access We will continue to develop referral networks between our appropriate housing and resettlement support to maintain Housing Needs team and support providers to improve the a stable and successful life. pathway into support for victims of domestic abuse. Information about refuge spaces will be shared to ensure 8.2.4 HIV+ and Chronic Conditions that people are helped wherever possible. We will review the need for supported temporary We will consider establishing a HIV+ champion to take an accommodation and make this available to victims of overview on our services to this cohort of people and domestic abuse where appropriate. especially in regard to supporting good mental health and We will review our tenancy management and encourage access to wider housing and support services. other landlords to do the same, to challenge perpetrators We will incorporate data from this cohort into our needs living in our homes and make both our permanent and assessment for accessible housing due to the increased temporary accommodation safe for residents. prevalence of mobility problems. We will develop a Domestic Violence and Housing We will incorporate people with conditions such as TB into Strategy with partners which will include an approach to our service planning for supported housing solutions and safe move on accommodation options. supported temporary accommodation.
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Page 77 of 478 8.2.5 Learning Disabilities & Autism 8.2.7 Migrants
We will help people stay close to family and community. We will continue to work with partners to address We will meet our commitments within the Transforming homeless migrants, and seek additional funding to Care Programme and facilitate access to appropriate address accommodation and support needs. housing for Transforming Care clients and other people We will encourage our staff and partners to train to with learning disabilities and autism as identified in the identify languages and offer appropriate housing advice. forthcoming Learning Disabilities Strategy. We will be an active partner in Learning Disabilites forums 8.2.8 Older People and groups to build working relationships. We will seek opportunities to meet the housing aspirations We will develop proactive services which support of people with learning disabilities and autism by independence such as rapid access to adaptations, supporting access to mainstream housing where relevant, assistive technology and financial advice. provision of shared accommodation options, shared lives We will promote age-appropriate accommodation, built to and provision of new accommodation as identified in the good design, care ready and in age-exclusive blocks. This forthcoming Learning Disabilities Strategy and will adopt may form part of a wider mixed use scheme. the Learning Disabilities Plan. We will remodel and relaunch our handyperson service to We will make 6 homes available at our Marsh Farm support independence at home. development for people with learning disabilities. We will work with partners including health partners to expand our advice offer and work with community 8.2.6 Mental Health gatekeepers to support older people making positive choices to stay well at home. We will participate in multi-agency approaches to support We will initiate conversations with developers about mental health through good quality housing and including age-exclusive accommodation within wider homelessness services. development schemes. We will incorporate consideration of mental health into our We will include age-appropriate homes within our HRA activities around vulnerable groups. development programme as part of our commissioning
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Page 78 of 478 priorities and identify sites which could deliver our own age-appropriate and extra care. 8.3 Risks and Mitigations We will identify a site for extra care provision and work with partners including health and social care Housing solutions which underpin wellbeing and health are organisations to commission a new scheme. highly personalised and related to many wider priorities. There are risks associated with a high dependence on 8.2.9 Physical and Sensory Disabilities partnership solutions for these client groups. Conversely this partnership working is also a strength as it maximises the We will increase the number of wheelchair standard capacity and resources of any individual organisation. dwellings which we build to 10% of our rolling HRA programme and build to minimum accessible standards across our programme. We will develop our assistive technology offer to help people live independently. Continue to take up all adaptations funding to provide adaptations for people with disabilities and align this programme with schemes to facilitate hospital discharge and avoid hospital admittance. Protect Housing Revenue Account funding for adaptations in council homes to support independent living. We will ensure that sensory disabilities are reflected in our approach to aids, adaptations and design for people with broader physical disabilities.
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Page 79 of 478 9.0 Equalities Statement 9.3: Brief description of strategy Housing Strategy 2019 – 2022 – Equality Analysis Introduction The council’s new housing strategy to 2020 is a cross-tenure 9.1: Equality analysis details housing strategy covering all forms of housing in the borough, Proposed policy Housing Strategy 2019 to 202 including private, housing association and council housing. It includes the provision of both new housing and existing
housing, and also the housing needs of the borough. The Equality analysis Claire Astbury Head of Housing housing strategy sets out our long-term ambitions for the Strategy & Development future of housing in the borough. We want our strategy to be Strategic Director Patrick Odling – Smee Service about more than just bricks and mortar; we want the strategy Director Housing to demonstrate the strong connections between housing and Department Customer and Commercial other services which are important to improving people’s day Date of review July 2020 to day lives. We want housing in Luton to contribute to
delivering jobs and growth, and helping to make the borough 9.2: Overview of service user and key stakeholders a healthier place. consulted
The strategy sets the vision, commitments and objectives Services users and stakeholders
Key users of the Internal departments of the To deliver its objectives, we will review progress on a regular department or service council, strategic partners basis. such as third sector
organisations , The purpose of the Equality Impact Analysis Key stakeholder involved Internal and external Housing issues affect all residents in Luton, the strategy in the Housing Strategy stakeholder including recognises there are certain groups who are less able to Tenants Panel , Service access housing of good quality, appropriate housing on the Users groups open market and/or groups who may struggle to sustain a successful tenancy. The strategy focusses on how to increase the general supply of housing and also how to help those 42
Page 80 of 478 groups unable to meet their needs on the open market by 9.5: Key Data targeting resources and services to create more affordable A summary of key population data for Luton is set out below: homes, make the best use of the stock available and . intervene before crisis. Table 1: Luton & UK Mid- Year Population Estimates 2013 – 2017 The strategy aims to have a positive impact on households/individuals from protected characteristic groups, especially those who may have particular issues accessing and maintaining tenancies/homes. This section therefore concentrates on identifying the particular issues different groups are more likely to experience.
Source: Office for National Statistics 9.4: Evidence base
In writing this impact assessment quantitative data from a range of sources has been considered, which forms part of the evidence base underpinning our Housing Strategy:
Business Intelligence Department, Luton Council – 2017 Mid-
Year Population Estimate July 2018
Luton & Central Bedfordshire Strategic Housing Market
Assessment Update – Report Findings Summer 2015 2011 Census The Growth and Changing Complexion of Luton’s Population, Mayhew Harper Associates 2011 Housing Allocations Policy Review 28th Dec 2017, Luton Council Cordis Bright Research 2018
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Page 81 of 478 Table 2: Luton Population by Age Group 2017
Source: Office for National Statistics
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Page 82 of 478 The table below show that Asian British households require larger sized accommodation in comparison to other ethnic households.
The table below shows the relationship between lettings to ethnic groupings vs property size
Studio & 1 bedroom lets – April 14 – March 17 – Total lets - Data Collection from Housing Needs Department Luton 732 Council:
Ethnic Group No of lets % of lets At Dec 2017 there were 12, 833 households as registered for Asian / British 70 10% housing register. Asian
Black / Black British 126 17% Ethnicity breakdown of the housing register vs 2011 White/ Other White 405 55% census data European / Eastern 28 4% Ethnicity of main % of applications 2011 census data Mixed 35 5% applicant for the population Arab/ Chinese/Other 15 2% of Luton (%) N/A 53 7% White British/ 45 47.6 other White Asian/ British 25 29.2 Asian Black/ Black 174 9.8 British Mixed 4.2
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Page 83 of 478 3, 4 &5 Bed lets – April 14 – March 17 – Total lets – 205 their own homes for as long as possible, and as an alternative to residential care. This will include increasing the supply of Ethnic Group No of lets % of lets extra care sheltered housing specialist sheltered housing Asian / British 76 37% which provides support and care in the same premises, while Asian enabling older people to retain their independence. We will Black / Black British 28 13% also develop more cross tenure housing options where there White/ Other White 68 33% is evidence of demand. European / Eastern 12 6% Mixed 7 3% We will also provide high quality homes and tailored support Arab/ Chinese/Other 8 4% to enable downsizers to move, many of whom will be older N/A 6 4% people. This will free up much needed larger homes for younger families, many of whom are experiencing overcrowding. 9.6: Summary of Impacts on Protected Characteristic Groups Many of the benefits of an Age Friendly housing strategy, such as more integrated Communities, better designed homes This section considers the potential impacts (positive and and neighbourhoods, benefit everyone, whatever their age negative) on groups with ‘protected characteristics’, the group, and not just older people. equality information on which this analysis is based and any mitigating actions to be taken. There is, however, a slight risk that focusing on age-friendly housing if solely looking at the needs of older people, may 9.6.1: Age - Where this is referred to, it refers to a person overlook some specific needs of younger populations, likely to belonging to a particular age (e.g. 32 year be young families with children, or vulnerable groups. olds) or range of ages (e.g. 18 - 30-year olds). The strategy acknowledges the needs of families specifically Potential impacts (positive and negative) of proposed strategy in ‘Improving housing quality’, through encouraging private landlords to offer greater security, certainty and stability for We will be seeking to increase the range of housing, housing their tenants, especially families with children, and we believe options and support for older people to enable them to stay in that our strategy overall will help people across all age bands. 46
Page 84 of 478 engagement and reports to Cabinet, which will include More detail is provided in Section 6: Priority Issues for equality assessments. Equalities 9.6.2: Disability Equality information on which above analysis is based A person has a disability if he or she has a physical or mental impairment which has a substantial and long-term adverse Luton is projected to experience an increase in the number of effect on that person's ability to carry out normal day-to-day people aged 65.and aged 85 +. Set against this Luton has a activities. below average supply of elderly-focussed accommodation sheltered or extra care sheltered housing Possible impacts (positive and negative) of proposed policy/decision/business plan Luton has one the highest populations of young people compared to London and nationally., Through the new housing strategy we will increase the supply of wheelchair housing and other specialist and adapted Mitigating actions to be taken housing for those with disabilities. We will also ensure that all new housing is built to Lifetime Homes standards, easily We will monitor the implementation of key actions in our adaptable as households’ needs change over time. housing strategy through the Council Plan alongside any relevant action plan. Poor quality housing is known to affect both physical and mental health. As well as building new homes to high quality During implementation, it will be key to balance the needs of standards we also have a programme of improvement works the ageing population against the demographic churn and to our own housing stock. While we have achieved the decent continued population growth across all age bands, and to home standard by the housing strategy is more ambitious for assess how younger groups and children will be impacted by the quality standards to be achieved for our housing in future, the individual new Housing developments and housing such as improvements in energy efficiency measures which projects that will derive from this strategy. will in turn help to combat fuel poverty. This will have positive health benefits for those with disabilities and chronic illnesses. Specific work programmes, such as the development of new homes, are subject to detailed programmes of resident 47
Page 85 of 478 Additionally through the new housing strategy we will develop our housing services to be ‘more than a landlord’. That will At this stage, we do not know how many disabled people include ‘going the extra mile’ for our residents including (physically, with learning disabilities, or both) and people with providing more individualised advice and support to our chronic illnesses will be affected by housing developments. vulnerable tenants and residents. However it is our belief that Implementation of the strategy will need to ensure a for most residents, the best route to health and wellbeing is consistent approach for these groups through employment, and the strategy is designed to strengthen links between housing and relevant services that We will monitor the implementation of key actions in our can assist in this goal. housing strategy ultimately through the Council Plan, alongside relevant action plans. Specific work streams, such There is a small risk that focus on age-friendly developments as the development of new homes, are subject to detailed may overlook the needs of particular groups, such as those programmes of resident engagement and reports to Cabinet, with learning disabilities. We have highlighted and addressed which will include equality assessments. this in the housing strategy and we will be including housing support for people with learning disabilities and other 9.6.3: Gender reassignment: vulnerable groups by connecting them to relevant services and contribute to helping them to live independent lives. Possible impacts (positive and negative) of proposed policy/decision/business plan Equality information on which above analysis is based People in the process of gender reassignment can face The number of older people with mobility difficulties is discrimination in local communities. Providing more, better projected to increase by 17% between 2012 and 2020. quality housing will benefit all communities in Luton, irrespective of their gender, which will be positive for this The number of working age people with serious physical group. The strategy can work towards linking with community disabilities is projected to increase by 23% over the same organisations that seek to support people undergoing gender period, from 3,620 to 4,446. Current unmet wheelchair reassignment, and towards reducing prejudice and stigma in housing need stands at 543 households. the community.
Mitigating actions to be taken 48
Page 86 of 478 Equality Information on which above analysis is based Mitigating Actions to be taken None at this stage We do not know at this stage how many people will be affected, as prevalence of gender dysphoria is uncertain. A 9.6.5: Families with children: Hate crime report by Galop (2013) shows only 50 recorded transphobic crimes in London, however, many will go Possible impacts (positive and negative) of proposed strategy unreported. The housing strategy seeks to support families, and this Mitigating actions to be taken includes support during paternity and maternity also supports this group by giving children the best start in life. We therefore The impact of the housing strategy on transgender people is expect there to be a positive impact on this group. likely to be low, the strategy encourages linked services, helping the affected group to access services. Therefore, we Equality information on which above analysis is based do not expect mitigating action to be required at this stage of research, however, the needs of an ageing LGBT population There is evidence that housing quality, including will need to be considered. overcrowding, can have detrimental impact on maternal and child health during pregnancy and the new-born. 9.6.4: Marriage and civil partnership: Mitigating actions to be taken Possible impacts (positive and negative) of proposed policy/decision/business plan None at this stage. Providing more, better quality housing will benefit all communities in Luton, irrespective of their relationship status. 9.6.6: Race - Refers to the protected characteristic of Race. It Same-sex couples may be discriminated against in the private refers to a group of people defined by their race, colour, and rented sector and in some local communities of the housing nationality (including citizenship) ethnic or national origins. strategy will work towards supporting all residents regardless of their marital status to access support and services, which Possible impacts (positive and negative) of proposed strategy can help to reduce discrimination in the community.
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Page 87 of 478 Policies to increase the supply of family sized homes and encourage downsizing by under-occupiers will benefit Possible impacts (positive and negative) of proposed strategy overcrowded households, amongst whom black and minority ethnic households (BME) are over-represented. We expect the housing strategy to have a positive impact on religion and belief, as providing more, better quality housing Luton has the one of highest number of overcrowded will benefit all communities in Luton, irrespective of their households in England and Wales (2011 census). religion or belief status.
Equality information on which above analysis is based Luton’s hate crime strategy seeks to address harassment and crime on religious or belief grounds and applies to all our There is evidence that overcrowding in the BME communities tenures in Luton with emphasis on our council tenants. can have a negative impact to family health and wellbeing. Equality information on which above analysis is based Mitigating Actions to be taken Luton has a very ethnically diverse population with variations Key actions include provision of larger home of all tenures, in tenure effective responses to hate crime through housing and neighbourhood management and review of equalities 9.6.8: Sex - A man or a woman. statements for specific housing services. Possible impacts (positive and negative) of proposed strategy More detail is provided in Section 6: Priority Issues for Equalities The housing strategy aims to increase the supply of housing across all tenures which will benefit both genders. 9.6.7:Religion and belief While women-headed households are likely to earn less over Religion has the meaning usually given to it but belief includes the duration of their life-times, the housing strategy includes religious and philosophical beliefs including lack of belief (e.g. measures for the provision of housing for those on a range of Atheism). Generally, a belief should affect your life choices or incomes. Women as the main predominant main carers of the way you live for it to be included in the definition. children and vulnerable adults tend to be over represented 50
Page 88 of 478 statistically as homeless and therefore owed ‘reasonable Equality information on which above analysis is based preference’ under the terms of s. 167 Housing Act 1996 and are protected by the homelessness legislation. For evidence on an ageing LGBT population and those living with HIV/AIDS, please see Luton Terrence Higgins Trust Homelessness single men are above the national average in Luton this will also be addressed through housing options and Mitigating actions to be taken pathways. The national average for individuals affected by HIV stands at Equality information on which above analysis is based 4.7 %, the national average being 2.4 %, this needs further investigation as appropriate adapted housing needs to be No specific data available developed to cater for the health needs for individuals in the future Mitigating actions to be taken 9.6.10: Human Rights None at this stage. There are 16 rights in the Human Rights Act. Each one is 9.6.9: Sexual orientation - Whether a person's sexual called an Article. They are all taken from the European attraction is towards their own sex, the opposite sex or to both Convention on Human Rights. The Articles are the right to life, sexes Freedom from torture, inhuman and degrading treatment, Freedom from forced labour, Right to Liberty, Fair trial, Possible impacts (positive and negative) of strategy Retrospective penalties, Privacy, Freedom of conscience, Freedom of expression, Freedom of assembly, Marriage and Providing more, better quality housing will benefit all family, Freedom from discrimination and the First Protocol communities in Luton, irrespective of their sexual orientation. There may be additional issues around the needs of the Possible impacts (positive and negative) of proposed ageing LGBT population, especially those living with HIV. As strategy the housing strategy is age-friendly, implementation will consider the needs of this population. We do not expect the housing strategy to have an impact on human rights. 51
Page 89 of 478 . that the number of multi-generational households are above the national average in Luton which stands at 4.2 % and the 9.7: Priority issues for Equalities considerations national average being 1.9 % (Cordis Bright 2018 ).
9.7.1 Age There is a current unmet need for wheelchair / adapted properties which will be addressed through Luton Housing Luton has a relatively young population compared to London Design Standards and the building of Life Time Homes and and nationally Luton is a young town with a high proportion of our Downsizing project. residents under 15. 9.7.2 Ethnicity However, population growth will also continue to increase demand for housing and support for older people. Luton has a very ethnically diverse population.
The analysis of demographic and demand data undertaken Luton has seen several waves of immigration. In the early part suggests that there are a number of wards in the borough with of the 20th century, there was internal migration of Irish and particularly high housing and support needs, particularly in the Scottish people to the town. These were followed by Afro- North West, North and South-Central wards of the Borough Caribbean and Asian immigrants. More recently immigrants (Bramingham, Leagrave, Challney, Round Green. and from other European Union countries have made Luton their Crawley). These areas would be priorities for the development home. As a result of this Luton has a diverse ethnic mix, with of housing and support services (Cordis Bright Research) a significant population of Asian descent, mainly Pakistani 29,353 (14.4%) and Bangladeshi 13,606 (6.7%) It is clear that older people’s priority is to be supported in their own homes, and this continues to be where the majority older people live, 78% of older people in Luton and 90% nationally (Cordis Bright Research).
The number of older people with mobility difficulties is projected to increase, majority of older people with mobility issues would like to stay in their homes. We also recognise 52
Page 90 of 478 Luton: Ethnicity: 2011 Census[ account; this reinforces the perception that Luton is now Ethnic group Population % becoming more diverse both culturally and ethnically.
White 111,079 54.6 The needs of these particular groups have been addressed Mixed 8,281 4.1 through a number of Joint Ambitions as illustrated in the Asian or Asian British 60,952 30.0 Housing Strategy. Black or Black British 19,909 9.8
Other Ethnic Group 2.980 1.5
Total 203,201 100
There is wide variation in household size amongst different ethnic groups – with Asian households being larger than average. There have been significant shifts in the ethnic composition of Luton since the last Census including: generally increases in the Asian population from 33,600 to 50,200; the Black population increasing from 11,700 to 19,800; a decline in the White and ‘other’ population from 139,000 to 132,000. There is evidence of high turnover of population with estimates that between 50% and 75% of the population in 2016 would not have lived in Luton or not have been born at the time of the 2011 Census.
In addition we have new communities from eastern and southern Europe and also people from various African countries. These populations’ changes need to be taken into
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Page 91 of 478 List of Appendices:
Appendix 1: Action Plan
Appendix 2: Commissioning Priorities
Appendix 3: Consultation Summary
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Page 92 of 478 Appendix 1: Action Plan
Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies Right Homes More Homes 1. We will continue to Liaise with developers and Housing Major 2225 Homes LIF, Local Economic press for delivery on all partners to support the build strategy & developers, by 2020 as Plan climate, market major sites identified in out of strategic sites Development registered identified in forces, the Luton Investment Team providers LIF Framework to support economic growth and 3500 Homes regeneration in the town. by 2022
2. We will be an active Establish pipeline of sites Housing £X budget for 230 Homes Foxhall Economic developer, delivering at strategy & Foxhall through Homes climate, market least 400 homes via our Bid for additional HRA Development investment Foxhall Business forces. housing company and headroom Team Homes by Plan, HRA, Government council house building £X budget for 2022 HIP, Local funding criteria programme as part of a Streamline development HRA Plan total delivery of 3500 processes. investment 170 Homes homes by 2022 through HRA by 2022 3. We will secure the Seek to achieve affordable Housing Housing Anticipated Housing Economic delivery of 700 affordable housing on development strategy & Associations housing Associations, climate, market homes by 2022. sites in accordance with Development Developers delivery by Private forces. Local Plan and support Team 2022: developers, Government them to start on site. HRA – 170 HRA, Foxhall funding criteria homes Homes, Local Purchase sites and land for Foxhall – 70 Plan future affordable homes development. Housing Associations – 460 homes
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Page 93 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies 4. We will strengthen Review council owned land Housing Finance, Land HRA Business Economic our wider partnerships to to support affordable strategy & Partners, purchasing Plan, Foxhall climate, market support access to land, housing delivery. Development housing programme Homes forces. development finance and Team associations, established by Business Government skills to maximise Seek opportunities for Property & 2020 Plan, Local funding criteria housebuilding in Luton partnership with investors Construction Plan. LIF and consider the potential and developers Services for specific joint ventures as appropriate.
5. We will work with Support planning Housing Planners, 10% of HRA HRA Business Economic developers and partners colleagues to influence the strategy & housing homes to be 4 Plan, Foxhall climate, market to support more of the house types of homes on Development associations, bedroom and Homes forces. larger homes that the new developments. Team Private larger Business Government town needs. Developers Private sites Plan, Local funding criteria to better Plan. LIF match SHMA requirements with year on year improvement 6. We will update our Draft and consult on a new Housing Planning SPD to be Local plan, Officer time supplementary planning SPD to secure on-site strategy & consulted on Planning guidance on affordable affordable housing and Development by December obligations housing to reflect our new establish a transparent Team, 2018 with local plan in order to policy for commuted sums Planning adoption by secure an appropriate mix Team September of homes on development 2019 sites. 7. We will advocate for We will include age Housing Planning, MPS drafted LIF, Local Market forces, and seek to provide age- appropriate accommodation strategy & Housing for Plan, officer time appropriate in our own programme Development Operations, consultation Allocations Availability of accommodation which Team, Housing by May 2019 Policy sites helps to free up family We will collaborate on a Needs and adopted sized homes of all market position statement by July 2019
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Page 94 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies tenures. to encourage private investment in age 2 sites to appropriate housing. include age appropriate accommodatio n by 2022 8. We will maximise all Bid for Homes England Housing Planning, Successful LIF, Local Officer time, funding opportunities and grants if possible and any strategy & finance multi-partner Plan HRA market forces, strategic growth other funding that becomes Development growth bid by Business economic discussions to deliver available to deliver our Team 2020 Plan, Foxhall opportunities homes which meet the housing needs Homes wider housing needs of the Luton housing market Collaborate with area. neighbouring authorities on growth bids in the Oxford- Cambridge Arc 9. We will refresh our Updated empty homes Private Sector Legal Empty Homes Empty Homes Officer time. Empty Homes strategy strategy to be developed Housing, Strategy to be strategy and continue to bring Empty Homes completd by homes into use at a rate Officer June 2019 of 20 per year
10. We will develop our Provide those on the self- Housing Planning Communicatio Local Plan, Officer time. offer to self-builders to build register with strategy & policy ns package in support these schemes. information about planning Development place by and sites Team, February 2019 planning with regular policy team updates in place Reducing Homelessness 11. We will support our Up to date / daily info on Housing Third sector Daily Homeless IT availability implementation of the refuge places available Needs organisations information Prevention and funding Homelessness Reduction through available by Strategy requirements Act with the introduction of Update info for supported Housing 2019 2016-2021
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Page 95 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies new software and focus housing spaces on daily Strategy on homelessness basis Forum Review of prevention. Mental Health homelessness Investigate the high number and Housing completed by of homeless applications Forum Panel 2019 from the Afro Caribbean meetings community. Action Against Equality Poverty, analysis Undertake Equality Analysis Business undertaken as of Prevention Service Intelligence part of IIA Team
12. We will reduce MHCLG funding stream Housing Third sector Panels Homeless Officer time, rough sleeping by 50% To closely monitor projects Needs organisations established by Prevention voluntary over 2 years and work and targets achieved on a through April 19/20 Strategy, No sector capacity with key partners to regular basis. Housing second night ensure that no-one new Strategy Rough out sleeps rough for a second Developing Single Persons Forum Sleeping night. Needs Panel Mental Health reduced by and Housing Nov 18 – 25% Developing a Complex Forum Panel April 19 – 25% Needs Panel meetings April 20 – 25% Action Against April 21 – 25% Poverty, funding from MHCLG
13. We will maintain Council lead audit. Housing NOAH Audit ongoing Homeless Dedicated and develop effective Identifying gaps so to Needs to April 2020 Prevention funds for reconnection services secure future funding Strategy reconnection back to home countries Protocols services, flights and cities for those Develop protocols and established and travel costs without a local connection. signposting for this cohort. with partners could diminish. via a forum by Develop a forum with 2019 partners for migrant support 58
Page 96 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies using the Homeless Link Tool Kit or access existing forums
14. We will review Undertake a piece of work Housing Housing Review Homeless Officer time, supported housing with providers around Needs Strategy supported Prevention Funding services to prevent repeat appropriate supported Forum housing by Strategy, No availability and homelessness and rough housing e.g. 2nd stage January 2020 second night risk of service sleeping amongst people hostels Luton CCG out closure with mental and complex Identify new health needs. Identify need/gaps for Temporary requirements cohort/vulnerable accommodatio by January individuals with supported n teams 2020 housing needs. Third sector Ongoing Identify funding streams to agencies review of fund the development of funding supported housing working LEX team streams and closely with stakeholders bids and bid writers
15. Ensuring that local Identify need and Housing Public Health, Liaison with Homeless Officer time, public and voluntary encourage joint project Needs Commissionin partners on Prevention meeting sector services prioritise working through Making g Team, quarterly basis Strategy, funding criteria homelessness prevention Every Adult Matter project procurement Housing First, when designing and or similar avenues Review Public Health, commissioning services services and commissionin for vulnerable individuals Identify and develop commissionin g team and families. services that are culturally g appropriate and accessible arrangements to all by 2020
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Page 97 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies
16. We will reduce Improved prevention activity Housing Finance team £1M saving by Homeless Officer time, homelessness costs by at to prevent homelessness Needs 2019 and £2M Prevention lack of least £2M between 2018 by 2020 Strategy resources and 2020 Faster processing of applications
Pathways out of temporary accommodation
17. We will expand our Seek opportunities to buy Housing Property & 10 additional Homeless Lack of Temporary appropriate homes and Needs Construction homes by Prevention Available Accommodation bring into temporary Services 2019 and 20 Strategy accommodatio Purchasing Scheme to accommodation by 2020 n provide an additional 20 Legal Homeless Prevention Services Strategy homes by 2020 to grow our portfolio to 80 homes. 18. We will improve the Build links with ethical Housing Luton Lets Attract 80 new Homeless Officer time, quality of temporary landlords Needs Rent Team, homes per Prevention lack of good accommodation by Private year each Strategy, quality working closely with our Set up a private lettings Landlords, year Private sector properties, private sector property agency Enforcement, Housing competition owners and leasehold New lettings Strategy locally or from providers. Investigate vacant agency other areas for properties in the town running by suitable homes. centre which could be used Dec 2019 for temporary accommodation Ongoing review of vacant property 19. We will support the Development of Complex Housing housing Protocol and Homeless Officer time,
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Page 98 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies introduction of supported Needs Protocol Needs associations Complex Prevention lack of temporary Supported needs index Strategy supported accommodation offering Development of Complex providers drafted by housing higher support for those Needs Index Sept 2019 providers, non- with complex needs. skilled Development of supported Priorities for supported temporary accommodation supported workers temporary providing accommodatio service. n identified by April 2019 20. We will eliminate Expand portfolio of leased Housing Property & 50 households Homeless Economic and our long term use of and owned accommodation Needs Construction in nightly lets Prevention market nightly lets by 2020. to reduce nightly lets Services at April 2019, Strategy conditions. zero use of nightly lets over 6 weeks from 2019/20. 21. We will reduce the Working with partners we Housing Third sector, 1300 Homelessnes Availability of number of households in will source appropriate Needs Housing maximum at s Prevention affordable temporary housing. Strategy & April 2019 Strategy, accommodatio accommodation by 100 Development, 1200 Housing n, increases in per year. We will build new council Housing maximum by Investment homelessness homes to create new providers, April 2020 Plan applications lettings Luton Lets, 1100 LIF Team maximum by Support skills and career April 2021 support in temporary accommodation to facilitate move on. 22. We will ensure that Skills assessment forms to Housing LIF, Assessment LIF Lack of residents of temporary be developed with LIF team Needs Community forms in use opportunities, accommodation are to create career pathways Development by April 2019 low skilled jobs. benefitting from the skills, for TA residents date and training support
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Page 99 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies available via the Luton Develop financial advice Financial Investment Framework surgeries for housing surgeries to and career pathfinder pathways trial by April team. 2019 date and Create volunteering and roll out across work experience TA by August opportunities 2019
Framework for volunteering and work experience in place by April 2020/21 with residents taking up opportunities by 2022 23. We will meet our Weekly monitoring of all Housing Housing 97% collection HRA Business Welfare reform income collection target of accounts to escalate Operations Needs by April 2019 Plan, changes, 93% for temporary outstanding benefit and Financial Plan staffing accommodation. asessments performance shortages sustained. 24. We will implement Establish a charging policy Housing Housing New policy in HRA Business Staff capacity an affordable charging which relates to LHA rates Operations Needs place by May Plan, policy for temporary and affordability for 2019 Financial Plan accommodation. individual households. 25. We will continue to Use liaison opportunities Director of Housing Ongoing, with Homelessnes Government lobby for increased LHA with government and Customer & Strategy & aim to achieve s Prevention Policy rates to reflect Luton influencers to make the Commercial Development, approval from Strategy housing market and limit case for a raised LHA level Business DWP within 1 the Council’s exposure to Intelligence year. temporary team accommodation costs. 26. We will reduce time Develop protocols and Housing Housing Protocols are Homeless Officer time,
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Page 100 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies in temporary housing pathways to assist Operations Needs, ongoing Prevention staffing accommodation by households to move on Hostels and Strategy capacity improving our processing voluntary Average access to time for homelessness Processing time for agencies processing better applications and homelessness applications time to reduce processes, supporting people to to reduce to be in line more “move move out into with statutory on” independent Seek funding with partners requirements accommodatio accommodation. for a housing pathway n options. service for temporary Ongoing accommodation residents funding opportunities to be explored 27. We will continue to Undertake research on the Housing Voluntary Research to Homeless Officer time, build on partnership needs of residents facing Needs Agencies, be completed Prevention adequate working to address homelessness Business by April 2020 Strategy funding for a homelessness challenges Intelligence date variety of and attract investment Identify gaps in services projects and through a variety of which can be the focus of starting new projects and initiatives, funding bids initiatives. taking up all opportunities to support sustainable prevention of homelessness and routes out of homelessness.
28. We will work with Develop and establish Housing Women’s Protocol in Homeless Lack of women’s organisations to domestic violence protocols Strategy & Agencies, place by June Prevention funding, poor improve emergency Development Community 2019 Strategy, coordination of housing and move on Establish safe places for out and Housing Safety, community voluntary options for victims of of hours services Needs Housing Safe house safety strategy agencies, violence and exploitation. Operations commissioned availability of Develop housing pathways by 2020 funding, for women experiencing changes to violence and their families Housing benefits Pathways 63
Page 101 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies Attract funding for specialist included in culturally sensitive housing wider projects services for women by Dec 2019 experiencing violence. date (refer to line 26) Hold/facilitate annual Luton Domestic Violence First conference conference to be held by April 2020 29. We will work with Audit existing panels and Housing Housing Review Homeless Lack of funding partners on a identify specific Needs Strategy & complete by Prevention for voluntary Homelessness Complex requirements eg MARAC, Development September Strategy, agencies Needs Panel to work with Mental Health & Housing Housing First, 2019 Housing First households that have Panel MARAC, JAP, project complex needs and seek Public Health, funding opportunities for Mental Health Housing First and other providers, projects. Resolutions 30. Develop jointly with Identify needs of cohorts Homeless Housing Draft Move on Homeless Lack of suitable third sector organisations and develop a move on Team, Operations, strategy Prevention move on a “Move On” strategy strategy based on individual housing Third Sector developed by Strategy accommodatio which will offer long term needs. associations, partners December n, officer time support Hostel 2019 Share protocols with providers homelessness partners 31. We will bid to be Develop co-ordinated Housing Housing Establish Making Every Not working part of the Making Every approach jointly with Strategy & Needs, Third MEAM Adult Matter, well or lack of Adult Matter network Homeless Link – enabling Development Sector membership understanding coordinated through better partnership working by July 2019. of their roles Homeless Link. with MEAM and Homeless Link. Quality Homes and Neighbourhoods 32. Commission an Identify funding for a Private Sector Enforcement Commission Luton Private Officer time,
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Page 102 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies updated housing condition survey. Housing Team, survey by Sector and lack of survey which specifically Scope the survey Enforcement revenue March 2020 Renewal funding identifies conditions in the Commission the survey funding, with results by Strategy private rented sector to September 2010-2015 improve the targeting of 2020 our work to improve housing quality.
33. Review the Update the discretionary Housing Staff time Redraft by Luton Private Officer time Council’s grants policy to grants policy to focus on Strategy & April 2021 Sector reflect the findings of our priority households and Development including Renewal stock condition research areas of disrepair team with appropriate Strategy and target the most Housing consultation 2010-2015. vulnerable households. Needs/Grants Improving and team moving forward. 34. Reduce levels of Provision of healthy heating Housing Third sector Year 1 reduce Poverty Capacity, fuel poverty by 25% over grants scheme Strategy & referral by 10% Needs resources and three years. Development agencies, Year 2 15% Assessment officer time, Roll out solar panel/battery team health Year 3 25% 2018. Public ability to attract storage scheme and create partners, Health external a framework for further energy Strategy, funding, projects companies, Energy Action monitoring installers, Plan arrangements Seek out and secure council and definitions external funding for energy funding efficiency work 35. Provide services to Identify clear budget and Housing Staff time, New scheme Afforable Maintaining vulnerable homeowners eligibility criteria by June Strategy & revenue launched by warmth sufficient who need help to maintain 2019 Development funding, third June 2019, 50 strategy, funding for the their own home by and Housing sector clients a year Energy Action scheme relaunching handyperson Needs team partners and supported Plan, Falls services and better contractors prevention targeted advice. plan 36. Establish the Scheme set up in 2018/19 Housing iBCF funding, 250 clients Afforable Resources,
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Page 103 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies Energy Doctor scheme and funding secured Strategy & other funding supported by warmth recruitment and support over 250 beyond 200 Development streams, 2020 strategy, delays clients by 2020 with Team referral Energy Action affordable warmth and partners Plan wellbeing initiatives. 37. Build strategic Build working relationship Housing Public Health, At least 1 Affordable Officer time, partnerships with health with Public Health for fuel Strategy & Health successful Warmth working with organisations, installers poverty action plan Development partners, funding bid Scheme/Strat partners, and funders to increase team Healthwatch, per year egy, Poverty access to our impact in tackling fuel Develop at least five active Social Care, focussed on strategy, funding for poverty, and improving partnerships to support Adult Care energy Energy Action EPC analysis housing conditions, vulnerable households with and Children improvements Plan demonstrated by referral arrangements Services. increases in EPC ratings Energy Average EPC across the town. Pursue funding providers. across Luton opportunities and make bids raised by one for funding rating by 2022
Monitor EPC scores across Luton 38. Seek all Funding bids submitted for Housing Energy At least 1 Affordable Insufficient opportunities to maximise all relevant bidding Strategy & providers and successful Warmth funding external investment in low opportunites Development installers funding bid Scheme/Strat opportunities, energy initiatives. Team per year egy, Poverty loss of EU focussed on Strategy, funding, Luton energy Energy Action ineligible for improvements Plan funding opportunities 39. Commission new Design Guide rolled out for Housing Planning, Design guide Local Plan. Departments homes built to good HRA homes Strategy & Legal, in place by Foxhall not working quality through both Development Property & April 2019 for Homes together to Foxhall Homes and new Incorporate affordable Team, Foxhall Construction all new HRA Business ensure good Council housing with a housing designs into Homes Services homes and Plan, HRA quality. minimum of 400 homes Foxhall Homes wherever incorporated Business Plan completed by 2022 possible into Foxhall
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Page 104 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies schemes by 2021 40. Invest in council Decent Homes investment BTS HRA capital All Council Affordable Officer time, homes to ensure that all as per HRA business plan, funding, homes at Warmth resources, homes reach EPC Band D particularly insulation works ERDF funding Band D by Scheme/Strat tenants by 2020 and Band C by 2020 and egy, Poverty, refusing certain 2025. Band C by Local Plan, works 2025 Housing Business Plan 41. Continue to improve Estate management Housing Contractors, Concierge Housing Resources, estate management for services reviewed to focus Operations BTS, service Business cost increases. Council homes, based on on quality of place Procurement. established by Plan, LIF feedback from our HRA funding 2019, tenants, including new Tenant contracts for cleaning and involvement in grounds maintenance. new contract arrangements New tenancy agreement rolled out in 2019/20 Improved tenant satisfaction score in 2019 42. Capture Review the Private Sector Enforcement Staff time, Refresh Private Sector Staff time and improvements in the Stock Condition survey and team legal survey in 2021 Housing sufficient private rented sector to keep refreshed annually to and 2022 Strategy resources to demonstrate effectiveness track progress tackle worst of our improvement conditions activities such as licensing. 43. Deliver tenancy Support services for Housing iBCF funding, Review of Tenancy Staff capacity sustainment initiatives vulnerable tenants set up Operations staff time, tenant audit Management which support vulnerable Police and priorities in Policies
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Page 105 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies tenants at risk of Improved targeting of tenant community 2019 hoarding, self-neglect and audits to identify vulnerable safety Proactive cuckooing, and minimise tenants partnerships housing the impacts on wider management neighbourhoods. for at least 5 vulnerable tenants per year Supporting Health & Wellbeing
44. We will reduce our Range of housing options 16+ Team, Housing Eliminate JSNA, Lack of use of hostels for young developed and made Adult Social Needs hostel use for Children and housing, people leaving care available to reduce hostel Care care leavers Young People funding use and under 19s Plan requirements by 2021 45. We will develop Range of appropriate Adult Social Housing Identify Sustainable Lack of housing more suitable housing housing options made Care and 16+ Needs, housing community options, lack of options for Looked After available with necessary Team Housing pathways with strategy, LIF, outreach Children and young support Operations support by JSNA support asylum seekers September 2019 46. We will support Review housing grants Housing Capital Policy Children and Staff capacity, foster carers in Luton policy to support local Needs, programme, reviewed by Young People Funding through appropriate home fostering options Childrens September Plan limitations, lack extensions and access to Services 2019 of takeup larger homes to allow local fostering. Up to 2 foster families supported per year 47. We will work with Supported lodging scheme Adult Housing Supported Children and Staff capacity, partners to bring forward established commissionin Strategy & lodging and Young People Lack of supported lodging and g, 16+ team Development Shared Lives Plan volunteers, lack shared lives housing Shared Lives scheme Team, set up by of suitable
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Page 106 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies options established Housing 2020 homes, lack of Operations funding 10 placements per year across schemes 48. We will continue to Identify need for specialist Childrens Housing 50% reduction JSNA, Health Staff capacity, return children who are accommodation services, 16+ Strategy & in out of & Wellbeing Lack of currently placed out of team Development borough Strategy appropriate Luton back into the Work with partners to e Team, placements by homes and borough, developing deliver appropriate housing Housing 2021 sites, Lack of specialist accommodation options providers, capital funding, where necessary Capital unable to funding source delivery partners 49. We will work with Tenancy Support Officers Housing Third sector Achieve as Homelessnes Lack of move third sector partners to deliver outreach to young Needs, partners part of Move s prevention on make move on tenants Housing on Strategy by strategy, accommodatio accommodation available Operations December Health & n, high housing for young people Move on strategy agreed 2019 Wellbeing costs with third sector partners Strategy 50. We will work with Review domestic abuse Housing Police, Policies and Homelessnes Staff capacity, partners to support policies and protocols with Operations Community protocols s Prevention joint working people, where partner agencies and Housing Safety, Third updated by Strategy, arrangements appropriate, to stay safely Needs sector June 2019 Stronger in their homes rather than partners Community having to move due to strategy violence, and to return home after a refuge stay if possible 51. We will continue to Develop and establish Housing Third sector Protocols in Homelessnes Staff capacity, develop referral networks protocols jointly with Needs and partners, place by June s Prevention funding and between our Housing partners Housing external 2019 Strategy accommodatio Needs team and support Operations funding n availability, providers to improve the Share information regularly Refuge Welfare
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Page 107 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies pathway into support for regarding refuge places availability changes victims of domestic abuse. information by impacting Information about refuge Establish safe temporary end 2019 supported spaces will be shared to accommodation for victims housing ensure that people are of domestic violence Safe house helped wherever possible commissioned in 2020 52. We will review the Locate appropriate Housing Housing Initial review Homelessnes Lack of staff need for supported properties for families Needs Operations completed by s Reduction capacity and temporary escaping domestic abuse December Strategy suitable accommodation and make 2019 accommodatio this available to victims of n domestic abuse where appropriate 53. We will review our Review housing Housing Housing Review Make A Stand Lack of support tenancy management and management policies Operations Strategy & completed by pledge from other encourage other landlords around domestic abuse in Development, June 2019 providers to do the same, to line with Make A Stand Housing challenge perpetrators pledge associations, Work with living in our homes and Health housing make both permanent and Promote a joint working Partners associations temporary approach to other landlords throughout accommodation safe for in the borough 2019 residents. 54. We will develop a New strategy drafted as Housing Community New strategy Make A Stand Competing Domestic Violence and part of Make A Stand Operations Safety Team, in place by pledge priorities Housing Strategy with pledges and Housing Police, Health June 2019 among partner partners which will include Strategy & partners agencies an approach to safe move Work with existing Development Review on accommodation partnerships to deliver partnership options approach by September 2019 55. We will work with Develop protocols to Housing Housing Protocol Homelessnes Lack of partners to help people sustain housing Operations Strategy & agreed by s Prevention engagement
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Page 108 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies who are entering the Development, December Strategy from partners criminal justice system to Probation, 2019 retain their housing where Customer possible, including where Services team they are a council tenant 56. We will work with Work with partners to Housing Third sector Identify and Homelessnes Unable to third sector partners to identify funding Needs partners, bid for funding s Reduction source funding, seek funding to provide opportunities for housing Advice by 2020 Strategy, lack of housing advice ahead of advice services partnerships, Community engagement release to ensure an external Establish Safety from partners address with leaving Co-ordinate a joint funding advice Strategy prison. approach with third sector approach by for prisoners leaving prison December 2019 57. We will work with Lease a number of homes Housing Public Health, Bid for funding Homelessnes Lack of NACRO and other as temporary Strategy & Probation, by 2021 with s Reduction external partners to source accommodation developing Development Third sector scheme Strategy funding additional housing for ex- a Housing First model for and Housing partners running by offenders. ex-offenders Needs 2022 58. We will work in Include in ex-offender Housing Third sector Protocols in Homelessnes Staff capacity partnership to ensure that protocols and complex case Needs partners, place by end s Reduction and ex-offenders are not homelessness protocols Health of 2019 Strategy engagement excluded from pathways partners, from partners to housing and can Probation, access appropriate Community housing and resettlement Safety team support to maintain a stable and successful life. 59. We will consider Establish a HIV+ champion Housing Terence HIV+ JSNA, Health Chaotic establishing a HIV+ who can understand Needs, Higgins Trust, Champion in & Wellbeing lifestyles can champion to take an specific requirements of Customer third sector place by April Strategy make situations overview on our services cases Services partners, 2019 difficult to deal to this cohort of people health with and especially in regard to Joint working established so partners Staff training supporting good mental that the council manage within council
71 Page 109 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies health and access to cases for people with by September wider housing and support chaotic lives 2019 services. 60. We will incorporate Encourage developers Housing Adult Care 5% target for JSNA, Health Developers do data from this cohort into including ourselves, to build Strategy & commissionin all homes to & Wellbeing not bring our needs assessment for more mobility standard and Development g, Developers, mobility or Strategy, homes forward, accessible housing due to stair free homes for people Planning stair free inappropriate the increased prevalence with HIV+ mobility problems standards build of mobility problems. standards. 61. We will incorporate Review need for specialist Housing Adult Care Review JSNA, Health Lack of funding people with conditions housing for people with Strategy & commissionin carried out by & Wellbeing for suitable such as TB into our illnesses such as TB to help Development, g, health July 2019 Strategy, accommodatio service planning for stabilise health condition Public Health partners Homelessnes n, lack of supported housing Any identified s Prevention partners to solutions and supported need followed Strategy deliver temporary up by July accommodation. 2020 62. We will help people Establish housing pathways Community Public Health, Advice JSNA, Health Staff capacity, with learning disabilities for this cohort to enable Learning Housing produced & Wellbeing availability of and autism stay close to independent living in Luton Disabilities Needs using some Strategy, partners and family and community. Borough Council Team, co-creation by Learning housing sites Housing December Disabilities for Produce advice and Strategy & 2019 Strategy 2019, development guidance for distribution Development Transforming Embedded Care with advice Programme and services by March 2020 63. We will meet our We will be an active partner Housing CCG, Public Identify scale JSNA, Health Appropriate commitments within the within Transforming Care Strategy & Health, of needs by & Wellbeing data becoming Transforming Care and support the housing Development, Housing June 2019 Strategy, available, lack Programme and facilitate pathways of specific clients. Adult Care Developers Learning of suitable access to appropriate commissionin Respond to Disabilities development housing for Transforming Develop a small number of g TCP clients on Strategy partners,
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Page 110 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies Care clients and other bespoke properties to assist an ongoing Transforming funding and people with learning with the housing needs of basis Care Housing land availability disabilities and autism as people with Learning Strategy for identified in the Disabilities and Autism, Work with BLMK forthcoming Learning based on information from partners to get Disabilities Strategy Learning Disability Strategy scheme in development by September 2020 64. We will be an active To attend and participate in Housing Community Regular JSNA, Lack of staff partner in Learning Learning Disability Forum Strategy & Learning attendance at Learning capacity Disabilities forums and and Housing Sub-group to Development Disabilities forum and Disabilities groups to build working establish needs and good Team, Adult sub-group Strategy relationships. working relationships Commissionin meetings g team 65. We will seek Build relationships with Housing Community Refresh JSNA, Health Lack of opportunities to meet the specialist providers for Strategy & Learning working & Wellbeing capacity, housing aspirations of learning disabilities housing. Development Disabiliities relationships Strategy, inability to people with learning Team, with two Learning identify delivery disabilities and autism by Support mainstream Housing specialist Disabilities partners, lack supporting access to housing solutions for Operations providers by Strategy of development mainstream housing learning disabilities. end of 2019 opportunities where relevant, provision of shared Respond to housing actions Liaise with accommodation options, as identified in forthcoming colleagues on shared lives and provision Learning Disabilities learning of new accommodation as Strategy disabilities identified in the strategy forthcoming Learning following Disabilities Strategy and publication will adopt the Learning Disabilities Plan. 66. We will make 6 Alllocate 6 homes on phase Housing Community 6 homes Learning Inability to homes available at our 3 of the scheme Needs Learning allocated by disabiliites identify suitable Marsh Farm development Disabiliites March 2020 strategy, incoming
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Page 111 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies for people with learning Team on completion Health & tenants disabilities. Wellbeing Strategy 67. We will participate in Establish need for and Housing Health Scale of Health & Lack of multi-agency approaches develop hostel style Needs and partners, project Wellbeing information, to support mental health accommodation with Housing ELFT, Third identified by Strategy, insufficient through good quality appropriate support Strategy & sector December Homelessnes sites/property, housing and Development partners, 2019 s Reduction lack of support homelessness services. Work closely with ELFT on housing strategy funding supporting individuals with providers mental health needs. 68. We will incorporate Mental health to be Housing Housing Complex Homelessnes Lack of funding consideration of mental incorporated into Complex Needs Strategy & needs panel s Reduction for voluntary health into our activities needs protocols Development established by Strategy, agencies around vulnerable groups. Housing First, December Health & MARAC, JAP, 2019 Wellbeing Public Health, Strategy Mental Health providers, Resolutions 69. We will continue to Using Homeless Link toolkit Housing Housing Promote Homelessnes Limited work with partners to to link to migrant support Needs Strategy & Homeless s Reduction availability of address homeless services Development, Link toolkit to Strategy, support for this migrants, and seek Third sector staff by July Town Centre group additional funding to Direct Rough Sleepers partners, 2019 strategy, address accommodation support towards migrants Customer Public Health and support needs. with no recourse to public Services, Rough strategy funds MHCLG Sleeper funding initiative delivering outcomes for migrants 70. We will encourage Develop equality based Housing Customer Review Homelessnes Lack of our staff and partners to service using existing Needs services, Third language s Reduction resources and train to identify languages resources and attracting sector provision by Strategy ability to
74 Page 112 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies and offer appropriate funding for new initiatives partners December monitor housing advice. 2019 services and language Bid for prevalence appropriate funding each year 71. We will develop Produce clear marketing for ATS Third sector Assistive CCG Falls Fragmented proactive services which assistive technology Housing partners, technology Prevention services, lack support independence for services Strategy & funding information Plan of resources, older people such as rapid Development, partners, available in inability to access to adaptations, Establish partnerships with Housing internal June 2019 reach assistive technology and third sector and health Needs revenue appropriate financial advice. providers for referral funding advice pathways pathways
Direct handyperson scheme to support for minor adaptations and independence at home 72. We will promote Encourage age appropriate Housing Planning, Ongoing Public Health Lack of age-appropriate provision on suitable sites in Strategy & developers, discussion Strategy, confidence in accommodation, built to discussion with developers Development social care with market, good design, care ready partners developers inappropriate and in age-exclusive Create a Market Position development blocks. This may form part Statement type document to MPS options, lack of of a wider mixed-use encourage investment in document sites and scheme. age-appropriate available from funding accommodation July 2019
73. We will remodel and Identify clear budget and Housing Staff time, New scheme Public Health Maintaining relaunch our handyperson eligibility criteria by June Strategy & revenue launched by strategy sufficient to support independence 2019 Development funding, third June 2019 funding for at home. and Housing sector and 50 clients scheme Needs partners and a year
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Page 113 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies contractors supported 74. We will work with Establish relationship with Housing Health Housing Public Health Maintaining partners including health community navigator Strategy & partners, information Strategy active partners to expand our service Development Luton Access, provided to relationships advice offer and work with Customer community with partners, community gatekeepers to Provide information and Services, navigators by staff capacity support older people updates for advice services Social Care September making positive choices to 2019 stay well at home. Ongoing updates to at least 5 advice providers/ networks 75. We will initiate All schemes with potential Housing Planning Ongoing with Public Health Lack of suitable conversations with for age appropriate Strategy & all appropriate strategy sites developers about accommodation to be Development developments including age-exclusive highlighted and discussed accommodation within as part of planning wider development negotiations schemes. 76. We will include age- All HRA sites assessed for Housing Property & All sites Health & Lack of suitable appropriate homes within age-appropriate homes Strategy & Construction assessed on Wellbeing sites our HRA development Development Services ongoing basis Strategy programme as part of our New homes brought commissioning priorities forward within programme Aim for 15 age and identify sites which appropriate could deliver our own age- homes by appropriate and extra 2022 care. 77. We will identify a Identify site appropriate for Housing Social Care Site identified Health & Lack of sites or site for extra-care extra care scheme Strategy & commissionin by 2020 Wellbeing funding provision and work with Development g, Strategy partners including health Set up joint working group Health Delivery and social care once a site identified partners, partner and
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Page 114 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies organisations to Capital funding commission a new programme, arrangements scheme. external in place by funding 2021 78. We will increase the Incorporate wheelchair Housing Property & Policy Health & Inappropriate number of wheelchair standard homes into HRA Strategy & Construction established in Wellbeing sites standard dwellings which programme Development Services, this strategy Strategy we build to 10% of our Planning, rolling HRA programme HRA capital Delivery of and build to minimum programme 10% accessible standards wheelchair across our programme. over 3 years 79. We will develop our Review ATS offer and ATS, Housing Health ATS Health & Commercial assistive technology offer compile public information Operations partners, information Wellbeing case to help people to live Social Care available by Strategy independently. commissionin June 2019 g 80. Continue to take up Seek opportunities for Housing Health Fully allocate Health & Lack of all adaptations funding to funding for adaptations and Needs, partners, iBCF council Wellbeing external provide adaptations for hospital discharge Housing funding, adaptations Strategy funding people with disabilities Strategy & external funding each and align this programme Development funding, year with schemes to facilitate capital hospital discharge and programme Win at least avoid hospital admittance. one additional funding bid each year. 81. We will protect HRA Budget for adaptations in Housing HRA capital No reduction HRA Business Financial funding for adaptations in council homes maintained Operations programme, in adaptations Plan pressures council homes to support throughout strategy period BTS, Housing spend to 2022 independent living. Needs 82. We will ensure that Review adaptations Housing Capital Review Housing Staff capacity sensory disabilities are approach to ensure Needs Programme system and Grants Policy reflected in our approach accessibility for sensory funding processes by to aids, adpatations and disabilities July 2019
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Page 115 of 478 Commitment Actions Lead person/ Resources/par Milestones/ Links to other Risks Dept. tners Targets strategies design for people with broader physical disabities.
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Page 116 of 478 Appendix 2: Commissioning Priorities Statement
Homeless Households Luton is facing very high demand for Council housing and high levels of homelessness. All the new homes we provide will be There are currently 1, 28539 homeless households occupying temporary valuable to meet these needs, but it is important to identify the accommodation. property types which can most meet needs which are not met Theses households are broken down as follows: elsewhere. Bedroom Requirement % The Housing Register is being reviewed but in June 2018 includes 1 bedroom 12 13,000 families and individuals. 2 bedrooms 52 3 bedrooms 29 The diversity of individuals on the Housing Register and their needs 4 bedrooms or larger 7 can vary considerably. There is a demand for larger and adapted properties which is not met by current supply. Supply versus Demand for Accessible Homes 40 Housing Register Data 2017/2018 Bedroom No. of No of No of No. Requirement applicants properties applicants properties requiring advertised with advertised 38 accessible wheelchair for Break down of Register homes user in wheelchair household user Bedroom Number of Number of (non- 1 bedroom 446 53 55 2 Requirement applicants sheltered) properties vacant 2 bedrooms 186 23 39 1 in previous 12 3 bedrooms 111 10 42 0 months 4 bedrooms 24 1 9 1 1 bedroom 4300 240 2 bedrooms 4723 234 3 bedrooms 2615 67 4 or more 579 10 bedrooms
39 Homelessness statistics, Luton Council, June 2018 38 LAHS data 2017/18, Luton Council 40 Housing Register data, Luton Council, March 2018 79
Page 117 of 478 Ambitions
We have an ambition to maximise the delivery of homes on sites Joint Ambitions available for council housing We will aim to reflect the housing needs of our diverse town We will develop a plan to make best use of our land through by incorporating larger family homes which respond to the for example assessing our Garage sites for potential house wishes of households to live together. building and developing of a Opportunistic sites identification We will use our Housing Network Partnership meetings to scheme working closely with our partners to identify potential discuss and promote adapted properties across all sites. We sites. will identify and raise awareness of the needs of individuals We will across our development programme seek to achieve and families on the Housing Register. a good mix of homes which meet a variety of needs. We will establish a specialist Housing Provider Network that Our disabled applicants that face ill health are to be specialise in adapted properties to identify our need and prioritised in the allocation of Council stock. We will build work to build and adapt their housing stock in the borough. properties specifically for this group of individuals focusing on We will build links to other departments of the Council to families with disabled children, the properties will be identify need and create pathways to accommodation for adaptable to the changing needs of the child. We will disabled people. continue to work with the Joint Adaptions Board and the Physical Disabilities Teams. A quota will be set aside dependent on units build on each site.
Our Development programme for the next three years, we will consider:
Each new site to identify the potential to incorporate wheelchair standard accommodation and if this is feasible we will be aiming for 10 % of the properties for this use across our programme. Age appropriate accommodation on suitable sites, particularly where this can free up currently family-sized council homes. The majority of our programme to comprise of family homes with two or three bedrooms We will aim to build 10 % of all homes to be four bedroom and above 80
Page 118 of 478 Appendix 3: Consultation Summary We attended Forums and Partnership events such as the Mental Health and Housing Forum, Older Persons Frailty Details of Engagement and Consultation Forum and Homeless Strategy Forum this enabled us to reach and engage and network with a number of agencies The aim of the Housing Strategy Engagement and Consultation was to find out, and understand better, the most As part of our engagement we visited and engaged with important housing issues for residents and other respondents, across section of Service User Groups in the borough such as as well seeking views on the relative importance of the Noah Enterprise Service Users group, Flying Start Stay and Council’s proposals for addressing those issues. We also Play and Young people user group at the YMCA. used the engagement to identify sources of information and data to inform the strategy. We met with a variety of statutory agencies such as the Police Commissioners Office, CCG and the Learning Disabilities All our engagement activity was aiming to ensure equality and teams. housing access for all as a positive outcome for Luton. In regards to the thirds sector we met with Women’s groups Our engagement and consultation falls into two main phases: such as Azalea , Stepping Stones and Luton Women’s Aid, Engagement from March to June 2018 and Consultation from Probation Support services such as Nacro and Housing August to October 2018. supports services such as Penrose, Signpost, NOAH and Mary Seacole HA. Engagement Phase We also undertook second stage engagement with women’s The first part of our consultation and engagement began groups and third sector housing support services March 2018 and closed in June 2018. We undertook three main forms of engagement: Attendance and networking; Staff Snapshot of engagement results surveys; and Councillor discussion. - Need for family sized houses Attendance and networking - Properties to be adapted to suit needs - The need for support around sustaining tenancies We engaged with the statutory sector, third sector and service - Providing appropriate support to women and families user groups in the borough. We engaged with 70 plus facing domestic violence agencies and individuals . - Enabling and supporting young people to sustain a tenancy - Assisting older people to remain at home 81
Page 119 of 478 In May 2018 we held a consultation meeting with Luton Councillors which was attended by 11 Councillors and the Staff Surveys summary was circulated to all Councillors.
At the Housing Staff Conference in March we distributed a Snapshot of engagement results questionnaire and received 198 responses. - Issues around the number of 1 bed flats granted Snapshot of engagement results planning permission - There was concern around Anti social behavior and - Concerns around Empty Homes and anti social safe places to live behavior in specific wards - Many recognised issues with affordability and the high - Issues around Land Banking and the effects on Luton - The shortage of family sized properties rents in Luton – need for more affordable housing - Quality of neighbourhoods and issues such as parking - Need to stop land banking and housing quality - Need for more family sized housing - More work to be undertaken around enforcement - Supporting tenants to sustain their tenancies - Need to build on brownfield sites Future Engagement and Consultation In May 2017 we went into internal consultation with all Council staff through the intranet, the consultation was live for two weeks which resulted in 70 responses The public consultation is yet to begin and will take for approximately 8 weeks between August and October. Snapshot of engagement results During this period we will be holding consultation networking - The need for more family sized housing events, encouraging involvement through Member Led - Affordable housing for working families Engagement, returning to people we spoke to at engagement - Priority given to families who are working with social phase and taking support from the Council’s consultation care to keep their family together and reduce the team to reach a wide audience. number of children in care
- Priority to be given to care leavers up to the age of 25
to support them in establishing independent lives.
Councillors Discussion
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Page 120 of 478 APPEDNIX B - Integrated Impact Assessment Form
(IIA)
The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement that
‘The needs of Luton’s people will be first in everything we do’.
Why do I need to do an IIA? The aim of this impact assessment process is to: • Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council. • Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens. • Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion. • Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified.
When do I need to do an IIA?
• An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.
• The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA. • If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA. • An IIA must at all times identify those who will be affected by the decision, policy or strategy. • At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens. • Your first early draft is to be sent to the Social Justice Unit for comments and guidance • Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit.
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If you need further guidance please contact the Social Justice Unit (SJU). Please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.
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Proposal Title: Luton Housing Strategy 2018 - 2020 Lead Officer Name: Claire Astbury – Head of Housing Strategy & Development Date of IIA: 27 July 2018
Date updated after consultation: Early draft Seen by: Maureen Drummond, Cohesion and (Please send an early draft of your IIA to the SJU to Equalities Adviser, 30 July 2018 ensure all impacts are being considered at the appropriate time)
Finalised IIA Signed and seen by SJU : Name: Date
Names of all other contributors and Claire Astbury – Head of Housing Strategy & stakeholders involved in the preparing of Development this proposal who have been consulted with Harvinder Parhar – Housing Strategy & and agreed this assessment: Development Officer (Please note the IIA must not be carried out by one person) If there is any potential impact on staffing None please include the name/s of the trade union representative/s involved in the preparation of this assessment or any supporting evidence of request to participate:
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Proposal Outline
Information supporting the proposal (who, what, where, how). Breakdown of present users by ethnicity, age, gender, disability, religion/belief, sexuality (if recorded). Show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered.
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(IIA)
The council’s new Housing Strategy 2019 to 2022 is a cross- tenure housing strategy covering all forms of housing in the borough, including private, housing association and council housing. It includes the provision of both new housing and existing housing, and also the housing needs of the borough. Our ambitions are to achieve positive outcomes in relation to equality and housing access for all.
To achieve this we will focus on the following themes
Themes: 1. Right Homes More Homes Vision: We work with a wide range of partners to secure the delivery of the right mix of homes to meet Luton’s needs and will achieve at least 3500 new homes by 2022. 2. Reducing Homelessness Vision: We actively prevent homelessness and provide pathways into appropriate housing and support for people who are homeless or at risk of homelessness. 3. Good Quality Homes and Places Vision: Luton residents are proud of their homes and neighbourhoods and improvement of poor quality homes is helping the most vulnerable households. 4. Supporting Wellbeing Vision: The right housing options are in place so that people in Luton can live well by feeling included and supported to live independent lives.
Luton has a very ethnically diverse population. Ethnicity Population of Luton Luton has seen several waves of immigration. In the early part of the 20th century, there was internal migration of Irish and Scottish people to the town. These were followed by Afro-Caribbean and Asian immigrants. More recently immigrants from other European Union countries have made Luton their home. As a result of this Luton has a diverse ethnic mix, with a significant population of Asian descent, mainly Pakistani 29,353 (14.4%) and Bangladeshi 13,606 (6.7%) Luton: Ethnicity: 2011 Census[ Ethnic group Population %
White 111,079 54.6
Mixed 8,281 4.1
Asian or Asian British 60,952 30.0
Black or Black British 19,909 9.8
Other Ethnic Group 2.980 1.5
Total 203,201 100
There is wide variation in household size amongst different ethnic groups – with Asian households being larger than average. There have been significant shifts in the ethnic composition of Luton since the last Census including: generally increasing ethnic diversity among the population growth in the Asian population from 33,600 to 50,200; the Black population increasing from 11,700 to 19,800; a decline in the White and ‘other’ population from 139,000 to 132,000. Between 50% and 75% of the population is new to Luton since 2001. 5
In addition we have new communitiesPage from 125 eastern of 478 and southern Europe and also people from various African countries. These populations’ changes need to be taken into account; this reinforces the perception that Luton is now becoming more diverse both culturally and h i ll APPEDNIX B - Integrated Impact Assessment Form
(IIA)
Impact Table The purpose of this table is to consider the potential impact of your proposal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.
Once you have completed this process you should have a clearer picture of any potential significant impacts1, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.
Staff (for HR related Citizens/Community Protected Groups issues) Positive Negative Neutral Positive Negative Neutral Race √ √ Gender √ √ Disability √ √ Sexual Orientation √ √ Age √ √ Religion/Belief √ √ Gender Reassignment √ √ Pregnancy/Maternity √ √ Marriage/Civil Partnership √ (HR issues only) Care Responsibilities2 √ (HR issues only) Social & Health3 Impact on community cohesion √ Impact on tackling poverty √ Impact on health and wellbeing √ Environment Impact on the quality of the natural √ and built environment Impact on the low carbon agenda √ Impact on the waste hierarchy √ Economic/Business Impact on Luton’s economy and/or √ businesses Impact on jobs √
1 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large. 2 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 3 Full definitions can be found in section 3
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Impact on skills √
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Please answer the following questions:
1. Research and Consultation
1.1. Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate. Click here for local demographics and information Some of the sources of background data for the housing strategy were: Dept for Communities and Local Government - Homeless figures 2017/ 2018 Luton Corporate Plan 2017/ 2018 Luton Investment Framework Luton Housing Standards 2018 Corporate Energy Strategy 2017/ 2020 Empty Home Strategy Heath and Wellbeing Board 2017 /2018 Penrose Annual Report Noah Enterprises Migrant Report 2017 / 2018 Luton Women’s Aid 2017/2018
1.2. Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate). Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.
Click here for the LBC Consultation Portal We have carried out specific consultation please see examples below:
Disabilities groups – Learning and Physical Disabilities Pathways meeting Older persons - CCG Networking meeting – Frailty and Housing Young persons – User group consultation YMCA Health Issues – meeting with Terence Higgins Trust 1.3. Have you carried out any specific consultation with citizens likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document. For advice and support from Consultation Team click here We have consulted tenants through the Tenants Participation Board we have incorporated their comments into the Good Quality Homes and Places theme We have consulted service users of the Noah Enterprise Homeless project on their needs in regards to their homelessness We have consulted with service users from the YMCA on the needs of younger people , discussed specific support needs for housing
Page 1288 of 478
APPEDNIX B - Integrated Impact Assessment Form
(IIA)
2. Impacts Identified
2.1. Where you have identified a positive impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. Guidance Notes: By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic? Race Our Housing Strategy has considered the different housing outcomes for different ethnic groups in Luton as well as the specific needs of migrants with no recourse to public funds. We set out ambitions for issues like the provision of larger homes which better meet the needs of larger families, which are more prevalent in our Asian communities. Homelessness prevention also has the potential to improve outcomes for Black residents as these are currently over-represented in homelessness. Where economic disadvantage overlays ethnic background, our targets for affordable homes support good quality of life through secure housing.
Gender Women are disproportionately affected by homelessness and our homelessness prevention actions will support them. In addition we consider the needs of women experiencing domestic violence and provide action points to address housing needs.
Disability Our strategy sets out actions to make more accessible housing available as well as appropriate adaptations to meet the needs of physically disabled people. The needs of people with learning disabilities and mental health problems are also specifically addressed.
Sexuality We do not directly address sexuality within the strategy but do have action points related to mental health support, homelessness and HIV services, which can provide positive outcomes to this cohort.
Age Our strategy addresses older people’s housing needs through building appropriate housing to meet their specific needs and supporting independence at home. Younger people and looked after children are also considered so that we can support better housing and secure homes for younger people in Luton, for example through greater priority in our allocations system
Religion/Belief Where this intersects with race and ethnicity such as the prevalence of larger families, we have set out targets for the delivery of larger homes.
Pregnancy/Maternity We do not address this directly but better access to more stable housing is an important area of support for pregnant women and new mothers.
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2.2. Where you have identified a negative impact please explain the nature of this impact and why you feel the proposal may be negative. Outline what the consequences will be against each group identified. You will need to identify whether mitigation is available, what it is and how it 2.3. could be implemented. Specific actions to be detailed in action plan below. Guidance Notes: By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic? None
2.4. 2.5. Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. Guidance Notes: By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic There will be no noticeable impact on people sharing a protected characteristic, i.e gender reassignment.
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3. Social & Health Impacts
3.1. If you have identified an impact on community cohesion4’, tackling poverty5 or health and wellbeing6, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children. Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.
For advice & support from the Social Justice Unit click here
For advice and support from the Public Health team click here We have identified the need for a increase in the Right homes More Homes for people in Luton , We want to create, with a mix of communities through building a wide range of housing this will meet our targets for social cohesion .
We will create safe environments and work closely with enforcement teams the Rough Sleepers Project has addressed the issues of begging in the Town Centre. Homelessness will be reduced and halved in two years. Housing First will provide homes to 20 individuals with complex needs and is designed for entrenched Rough Sleepers.
In Luton theirs a high percentage of individuals with HIV they are a highly excluded group in society and face long term chronic illness, We have factored this cohort into our House building programme and will built a quota of accessible housing designed for individuals with mobility issues.
In regards to young people leaving care we will work closely with our partners to provide the right supported housing environment so to ensure that young people leaving care are able to sustain their tenancies and improve their health and wellbeing.
4 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 5 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 6 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services?
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4. Environment Impacts
4.1. If you have identified any impacts related to the built and natural environment7, low carbon8 and waste minimisation please describe here what this may be and who or where you believe could be affected Guidance Notes: Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:
Waste Hierarchy
For advice and support from the Strategy & Sustainability Team click here We have identified a link to building design and tackling fuel poverty. - We will Regularly review every two year our buildings specifications these will include green / energy aspects costings - Exploring the potential to future proof homes and neighbourhoods - Seeking external funding for fuel poverty initiatives
7 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution. 8 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport.
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5. Economic Impacts
5.1. If you have identified any impacts related to Luton’s economy and businesses 9, creating jobs10 or improving skill levels 11, please describe here what this may be and who or where you believe could be affected Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below. Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below.
For advice and support on Economic Development click here We will use local builders and contractors , Building Technical Services at Luton Council where ever possible
9 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 10 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well-being and the reduction of poverty in the social box. 11 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships?
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Impact Enhancement and Mitigation Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:
Responsible Date Completed / Action Deadline Intended Outcome Officer Ongoing
We will Regularly review every two year our buildings specifications these will include green / energy aspects costings
Exploring the potential to future proof homes and neighbourhoods
Seeking external funding for fuel poverty initiatives
A review of the action plan will be prompted 6 months after the date of completion of this IIA.
Key Contacts Name Position Claire Astbury Head of Strategy and Development Harvinder Parhar Strategy and Development Officer
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Next Steps • All Executive Reports, where relevant, must have an IIA attached • All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment) • All reports are to be forwarded to the Social Justice Unit, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline • On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager
Completed and signed IIA’s will be published on the internet once the democratic process is complete
Useful Documents Corporate Plan Equality Charter Social Justice Framework Family Poverty Strategy Joint Strategic Needs Assessment (JSNA) Community Involvement Strategy
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Page 136 of 478 Report for: Executive Item No: Date: 20 August 2018 Report of: Service Director Adult Social Care 12 Report author: Helen Lambert
Subject: Review of Adult Social Care Scale of Charges for Non- Residential Services Lead Executive Member(s): Cllr Akbar Wards Affected: All Consultations: Councillors ☒ Scrutiny ☐ Stakeholders ☒ Others ☒
Recommendations 1. That the Executive is recommended to agree the consultation with stakeholders on the proposed increase to existing charges, the introduction of new charging options and to make amendments to the charging policy for the provision of non-residential care services.
Background 2. The Care Act 2014 provides the legal framework for charging. Charging should be fair and clearly understood by everyone. The overarching principle continues that people should only pay what they can afford based on a means test. Where a local authority arranges care and support to meet a person’s needs, it may charge the adult, except where it is required to arrange care and support free of charge.
3. Charges to service users provide significant income to support delivery of adult social care services. Policies on what should be charged for and decisions on the level of those charges are under continual review by the council, particularly as demand continues to increase and funding from the Government falls. A review of existing charges is an opportunity to look at the potential to increase the level of income received for Adult Care Services. The Council collects just over £3 million from non-residential fees and there is an additional income generation target of £79,000 to help contribute towards the council’s savings in 2019-20.
4. Adult Care is moving towards a strength based approach to delivery of services. Reviewing and changing the charging policy will give people an opportunity to review the type of services they receive and look to alternative ways of meeting their support needs from within local networks such as family, friends, neighbourhoods and communities through the Early Help Service.
The current position 5. A comparison of the range and amount charged by some other local authorities has been made. The Council’s charges are generally lower than the average for neighbouring and comparator councils. Details of current charges levied by Luton and other councils, as well as the level of subsidy provided by Luton Council are shown at Appendix A.
Page 137 of 478 6. The Council currently charges flat hourly, daily and overnight rates for Home Care, Day Care and Respite Care respectively. People in receipt of a direct payment are charged the same rates based on the number of care support hours/days their direct payment funds.
7. Day care rates are heavily subsidised by the council - in some cases by up to 80% of the actual cost of providing an in-house day care placement, more for private sector provision.
8. A significant proportion of the cost of day care provision is transport to and from the day centre (approximately 35%). This is provided as a door to door service, with specialist vehicles and escorts to ensure people are safely transported to and from their homes to the day centre. Many people are in receipt of DLA mobility benefits or attendance allowance. These benefits are paid to people with disabilities or physical impairments to help cover the cost of transport but transport is currently provided free of charge.
9. A recent home care retender has increased the average hourly rate paid to providers to £15.68. The current charge made to customers for home care is £14.75 per hour and this has not changed since 2015-16. The Council is currently subsidising home care clients by up to £1 per hour in some cases.
10. Standalone charges are currently made for meals at day centres. A person pays for their meal and the charge is not subject to a financial assessment. The current charge per meal is £3.40. The price has not changed since April 2011 and does not reflect the cost of providing meals which has risen considerably (approximately £8.80 per meal, which includes the cost of staff to prepare and heat meals)
11. The Council currently has a maximum charge for non-residential care charges of £465 per week. In some cases the maximum charge is much less than the actual cost of the care provided – there are several people being supported with care packages at home where the weekly cost far exceeds that of a standard residential care home. A person with assets of more than £23,250 would be expected to pay the full cost of their care in a residential home (upwards of £465 per week). Under the Care Act, a person should pay for their care and support if they have adequate finances. Having a cap on non-residential care charges is providing subsidised care for some people who have the means to pay for all of their care where it is above the current threshold.
Proposal 12. The proposal is to increase existing charges and broaden the scope of chargeable services by the following:
a. Increase the day care charge from £20 per day to £30 per day to bring the cost more in line with the average of other local authorities and the cost of providing the service. There are currently 446 people in receipt of day care services and 337 in receipt of a direct payment for social care activities.
b. Remove the £10 charge for people who attend day care for less than three hours and charge the same as full day attendance on the basis that the cost of a day care placement is much the same whether a person attends for half a day or a full day due to fixed costs. There are currently 51 people in receipt of half-day day care and 160 people who receive a similar service through direct payments.
c. Propose to change the charging for 1 to 1 ratio carer to client and 2 to 1 ratio carer to client for social activities provided through a direct payment to an hourly rate so that it is representative to the cost of providing the care. This will also ensure parity with the charging model for social care activities provided via a home care agency.
Page 138 of 478 d. Introduce a charge for transport at £4.00 per trip (£8 per return journey) which is based on the average price charged across the BLMK STP. Some council’s choose to apply a standalone charge or it may be subject to a financial assessment. Many people are in receipt of benefits that are to be used specifically to meet transport needs. The financial assessment makes allowances for transport related expenditure, so any chargeable expenditure to or from a day centre would be taken into account for those most in need of support. There are currently 370 people who are in receipt of transport to or from day care and 43 people who receive a direct payment to meet transport needs.
e. Increasing the hourly rate for home care from £14.75 to £15.68 commensurate with the average hourly rate paid to home care providers under the new contract.
f. Increase the cost per meal to £5.50 which is the current cost of the meal only (cost excludes preparation and heating up overheads). Although the price of meals will still be heavily subsidised it is recognised that nutrition is fundamental to a person’s health and well-being. The total number of people who purchase meals at centres is 202.
g. Depending on IT finance system adaptability, charge self-funders up to the full cost of care incurred by the council.
h. Remove the cap on charges for non-residential care fees. There are only 23 clients who have willingly declared savings above the £23,250 threshold. There are a further 210 clients who are treated as full fee payers because they choose not to disclose their financial circumstances. Of these, just 6 are in receipt of care that exceeds £465 per week that could be affected by the removal of the cap, however it would mean that clients in receipt of non-residential care would be treated the same as a person in residential or nursing care.
13. Appendix A shows a comparison of Luton’s current charges with other neighbouring and comparator authorities. Appendix B shows a summary of Luton’s current charges and the proposed charges.
Key risks 14. The financial effect of changing charges for non-residential care services is difficult to evaluate as it depends on a person’s ability to pay and the extent to which a new or increased charge may reduce demand for the service. Additional income generated may be minimal and the impact of any changes will need to be reviewed in terms of any long term impact to budgets.
15. There are approximately 2,000 Adult Social Care clients who are in receipt of chargeable non-residential care services. Currently 35% of those that have been assessed are not required to make any contribution towards the cost of their care because of their limited resources. 43% of clients are already paying the maximum that they can afford so any increase to the charges levied on those individuals is unlikely to generate additional revenue. It is estimated that approximately 12% of people in receipt of chargeable non-residential care services may be affected by any changes to how the services are charged for.
16. Increased charges may discourage people from using services – some people will refuse services following a financial assessment that determines they must pay towards their care. There could be a detrimental effect on someone’s health and wellbeing and that of their carer if a person chooses not to receive care and their assessed needs are not met. This could result in further costs to the Council or other services such as Health. Promotion of the Early
Page 139 of 478 Help Model will encourage people to consider alternatives that could prevent, delay or divert them away from Adult Social Care and becoming dependent on long term care support.
17. Meals at day centres are a standalone charge and are not subject to a financial assessment, as providing meals is not a requirement of Adult Social Care. It is recognised that day care meal provision may be the only opportunity for a person to have a warm dinner and if the cost became prohibitive, then there is a risk that people would decline meals and put themselves at risk. People who purchase meals at day centres can bring their own packed lunch and light snacks are also available to purchase at a lower cost.
18. The Council has a waiver’s policy and can choose to continue to provide services either free or at a lower cost if it is felt the person is putting themselves at risk by refusing care services due to increased charges.
19. There is a risk that the Council could suffer from reputational damage by proposing to increase charges to vulnerable people in the community. Informative, positive consultation with stakeholders and promotion of the early help model should help mitigate this.
Consultations 20. The Care Act Statutory Guidance expressly advises local authorities to consult people with needs for care and support in situations where the local authorities exercise their discretion in charging policies. The council last consulted with Adult Social Care clients and carers when it reviewed its charging policy back in December 2015. Given there are proposals which will significantly affect users in particular day care services and those that are currently full cost who may be affected by increased charges, consultation will be limited to this group of people as they are most likely to be adversely affected by the proposals. All other proposals do not require consultation as they are relatively minor changes.
Alternative options considered and rejected (please specify)
21. The Council’s existing charging policy based on hourly and unit cost rates is familiar with clients, having been in place since 2005. An alternative option, to charge based on the total cost of a person’s care package would require extensive consultation, thorough impact assessments and significant reconfiguration of existing IT charging systems.
Appendices attached Appendix A - Comparison of Charges
Appendix B - Proposed Charges
Appendix C - Integrated Impact Assessment
Background papers 22. There are no background papers to this report.
IMPLICATIONS
Page 140 of 478 For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated The legal basis for charging for non-residential care Vicky Sowah 1st August and support is provided within the Care Act 2014, Principal Solicitor – Social 2018 Regulations and Statutory Guidance. Services
The Care Act Statutory Guidance advises councils to consult when charging for care and support in non-residential settings.
The proposed consultation should be in line with the Care Act Statutory Guidance requirement, the Public Sector Equality Duty in the Equality Act 2010 and common law requirements including proper timeframe.
Finance Clearance Agreed By Dated Reviewing ASC charging policy and introduction of Atif Iqbal (Finance 31st July new charging options within the legal framework of Business Partner People & 2018 Care Act 2014 not only gives an opportunity to align PHCP Directorates) the Council charges with its neighbouring authorities but also provides a potential means of generating additional income by reducing the subsidised cost which will also help ASC to achieve it’s savings targets.
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated An IIA has been completed and has identified a Maureen Drummond, 1st August potential negative impact for White British Females Cohesion and Equalities 2018 over 60 who are currently making a contribution Adviser towards the service they use and would therefore be impacted by the increased charges Environment Clearance Agreed By Dated This report does not contain any direct environmental Katarzyna Wysocka, Team 1st August implications. Manager Sustainable 2018 Development and Transport
Health Clearance Agreed By Dated
Page 141 of 478 There could be a detrimental effect on someone’s Matthew Hudson 3rd August health and wellbeing (as well as their carer) if a Commissioning Support 2018 person chooses not to access appropriate care and Manager their assessed need is not met. This could result in Public Health, further costs to the council or other services such as Commissioning and health. Procurement Therefore it is important to ensure appropriate access and that the wavier policy is applied appropriately and in a timely manner. Community Safety Clearance Agreed By Dated
Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
Page 142 of 478 Appendix A
APPENDIX A - Comparison of Adult Social Care Charges 2018-19
Demographically similar Neighbouring Councils Luton Council Councils Luton Council Luton Council average/ Current Current standard cost Charge Subsidy Central Beds Bucks Bedford Milton Keynes Croydon Peterborough of providing Charged For Service service Day Centres (per day) - OP. £48.00 £20.00 £28.00 £33.40 £70.00 £57.70 £30.30 £57.84 £40.00 Day Centres (per day) - LD. £87.00 £20.00 £67.00 £57.30 £70.00 £28.85 £106.82 £57.84 £40.00 Day Centres (per half day) - OP. £48.00 £10.00 £38.00 Day Centres (per half day) - LD. £87.00 £10.00 £77.00 Home Care (per hour) £15.68 £14.75 £0.93 £21.00 £19.20 £15.90 £14.26 Variable - up to £14.00 cost of service
Home Care - two carers (per hour). £31.36 £29.50 £1.86 £42.00 £38.40 £31.80 £28.52 Variable - up to £28.00 cost of service
Transport to Day Care (return). £20.00 No charge £20.00 £3.50 £12.00 £12.80 £4.00 No data £2.20 Day Centre Meals £8.84 £3.40 £5.44 £5.00 £4.90 £5.20 £5.40 £4.12 £3.70
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Page 144 of 478 Appendix B APPENDIX B- Proposal for increased/new Adult Social Care Charges 2018-19
Average/ Option A Option B Standard Luton Item Cost of Council 2018-19 2018-19 No. Providing Current Charged For Service Service Charge 1 Day Centres (per day) - OP. £48.00 £20.00 £30.00 2 Day Centres (per day) - LD/PD £87.00 £20.00 £30.00 3 Day Centres (per half day) - OP. £48.00 £10.00 £30.00 4 Day Centres (per half day) - LD/PD £87.00 £10.00 £30.00 5 Transport to Day Care (per journey/trip) £10.00 No charge £4.00 6 Home Care (per hour) £15.68 £14.75 £15.68 7 Home Care - two carers (per hour). £31.36 No charge £31.36
8 Supported Living (per hour) £19.88 £14.75 £15.68 The lesser of Hourly DP i) the total 1 to 1 Support for Social Activities - Direct Payment Rate between cost of the 9 £10.56 Personal Assistant £10.56 - care service £11.41 provided or ii) the assessed £10 for up to Hourly DP contribution. 2 to 1 Support for Social Activities - Direct Payment 3 hours, £20 Rate between 10 £21.12 Personal Assistant for 3 hours £21.12 - or more per £22.82 day 1 to 1 Support for Social Activities - Home Care Agency £15.68 per 11 £15.68 (including Direct Payment Agency) hour
2 to 1 Support for Social Activities - Home Care Agency £31.36 per 12 £31.36 (including Direct Payment Agency) hour
13 Day Centre Meal £8.84 £3.40 £5.50 Page 145 of 478
Page 146 of 478 APPENDIX C - Integrated Impact Assessment Form (IIA)
The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement that
‘The needs of Luton’s people will be first in everything we do’.
Why do I need to do an IIA? The aim of this impact assessment process is to: • Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council. • Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens. • Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion. • Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified.
When do I need to do an IIA?
• An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.
• The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA. • If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA. • An IIA must at all times identify those who will be affected by the decision, policy or strategy. • At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens. • Your first early draft is to be sent to the Social Justice Unit for comments and guidance • Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit. If you need further guidance please contact the Social Justice Unit (SJU). Please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.
1
Page 147 of 478 APPENDIX C - Integrated Impact Assessment Form (IIA)
Proposal Title: Adult Social Care Scale of Charges Lead Officer Name: Helen Lambert Date of IIA: June 2018
Date updated after consultation: Early draft Seen by: (Please send an early draft of your IIA to the SJU to ensure all impacts are being considered at the appropriate time)
Finalised IIA Signed and seen by SJU : Name: Maureen Drummond, Cohesion and Equalities Adviser Date 1 August 2018
Names of all other contributors and Maud O’Leary – Service Director ASC stakeholders involved in the preparing of Vamsi Pelluri – Service Manager this proposal who have been consulted with Assessment and Care Management and agreed this assessment: Julie Smith – Financial Assessments Team (Please note the IIA must not be carried out by one person) If there is any potential impact on staffing None please include the name/s of the trade union representative/s involved in the preparation of this assessment or any supporting evidence of request to participate:
2
Page 148 of 478 APPENDIX C - Integrated Impact Assessment Form (IIA)
Proposal Outline
Information supporting the proposal (who, what, where, how). Breakdown of present users by ethnicity, age, gender, disability, religion/belief, sexuality (if recorded). Show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered. To increase existing charges for non-residential care provided to people in receipt of Adult Social Care services, so that the charge is more reflective of the actual cost of providing the service and bring in line with other local authority charging rates. This includes the removal of the cap on charges for non-residential care.
There are over 2,000 people in receipt of non-residential care services. The tables below show the current service users and their demographics for people who have been financially assessed or due to be assessed and are in receipt of non-residential care services:
Service Type No Some Full Awaiting Total Charge Charge Charge Assessment Clients Day Care Only 49 90 23 15 177 Home Care 262 312 151 116 841 Direct Payment 245 248 5 27 525 Mixed Package 157 211 65 39 472 Total 713 861 244 197 2,015
Ethnicity No Some Full Awaiting Total Charge Charge Charge Assessment Clients White/White British 383 553 196 110 1,242 Asian/Asian British 190 179 5 43 417 Black/Black British 84 79 24 16 203 Mixed/Other/Unknown 56 50 19 28 153 Total 713 861 244 197 2,015
Gender No Some Full Awaiting Total Charge Charge Charge Assessment Clients Female 418 447 151 99 1,115 Male 295 414 93 98 900 Total 713 861 244 197 2,015
Age No Some Full Awaiting Total Charge Charge Charge Assessment Clients 18-64 364 415 11 79 869 65 and over 349 446 233 118 1,146
Total 713 861 244 197 2,015
3
Page 149 of 478 APPENDIX C - Integrated Impact Assessment Form (IIA)
Impact Table The purpose of this table is to consider the potential impact of your proposal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.
Once you have completed this process you should have a clearer picture of any potential significant impacts1, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.
Citizens/Community Staff (for HR related issues) Protected Groups Positive Negative Neutral Positive Negative Neutral Race Gender Disability Sexual Orientation Age Religion/Belief Gender Reassignment Pregnancy/Maternity Marriage/Civil Partnership (HR issues only) Care Responsibilities2 (HR issues only) Social & Health3 Impact on community cohesion Impact on tackling poverty Impact on health and wellbeing Environment Impact on the quality of the natural and built environment Impact on the low carbon agenda Impact on the waste hierarchy Economic/Business Impact on Luton’s economy and/or businesses Impact on jobs Impact on skills
1 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large. 2 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 3 Full definitions can be found in section 3
4
Page 150 of 478 APPENDIX C - Integrated Impact Assessment Form (IIA)
Please answer the following questions:
1. Research and Consultation
1.1. Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate. Click here for local demographics and information Benchmarking exercise against other local authorities (see attached)
1.2. Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate). Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.
Click here for the LBC Consultation Portal No
1.3. Have you carried out any specific consultation with citizens likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document. For advice and support from Consultation Team click here No
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2. Impacts Identified
2.1. Where you have identified a positive impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. Guidance Notes: By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic? All people who are in receipt of adult care are subject to a financial assessment that determines how much they should pay towards their care. The financial assessment is not determined by someone’s sexuality, gender, age etc. Allowances are made for people with disability related expenses. The general principal is that no one will be left with less than the basic Income Support/Pension Credit plus 25% after paying for services. Any income they have above this threshold will be used towards paying for chargeable care services. A person would only be expected to pay the lesser of the charge for the service they receive or the available income they have. 2.2. Where you have identified a negative impact please explain the nature of this impact and why you feel the proposal may be negative. Outline what the consequences will be against each group identified. You will need to identify whether mitigation is available, what it is and how it could be implemented. Specific actions to be detailed in action plan below. Guidance Notes: By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic?
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APPENDIX C - Integrated Impact Assessment Form (IIA)
The proposals to change Adult Social Care fees and charges is likely to negatively impact White British, females over the age of 65, who have been assessed to pay the maximum charge. This represents approximately 6% of the total persons in receipt of chargeable non-residential services compared to just 1% of people who are over 65, female and from all other backgrounds. This is mainly because this is the predominant client group supported by Adult Social Care in Luton. They are also more affluent in comparison as a consequence of having other income sources such as occupational pensions and savings. Statistics also show that they live longer.
Charges for care services are based on someone’s ability to pay following a financial assessment. A person is charged the lesser of their available income or the charge for the service they are receiving. Nobody would be expected to pay more than they can afford for the services they receive.
The non-residential financial assessment is complicated and many factors are taken into consideration when assessing how much someone should pay. Income from benefits, pensions and savings above certain limits are some of the things taken into account when determining available income however the value of someone’s home is not. Income thresholds are determined by Government and are based on age and whether someone is single or part of a couple. Anyone with savings or assets above £23,250 is classed as a self-funder and would be expected to pay the full chargeable fee.
Under the Care Act, local authorities should charge the cost of the service to clients who can afford to pay for the service. We should not be subsiding people who have the means to pay the full cost of a service.
The table below gives examples of how much a single person aged over 60 would be expected to pay under the current and proposed changes to services dependent on the available income they have. The calculation is based on an assumed care package of the following - two ½ days of day care with transport and 5 hours of home care per week:
Person A Person B Person C Total weekly Income Total weekly Income Total weekly Income £189.00 £325.00 £189.00 Available Income Available Income Savings above above threshold above threshold £23,250 therefore full £0.00 £121.25 fee payer Current Charge Free £93.75 £93.75 Proposed Charge Free £121.25 £154.40
The current charge for these services is £93.75. This would rise to £154.40 under the proposed changes to charging - an increase of £60.65 per week resulting from £40 additional charge for day care less than 3 hours, an additional £16.00 for transport to and from day care and £4.65 increase in Home Care. Person A would continue to receive the service for free. Persons B & C would see an increase in their weekly charge, however person B would never pay more than £121.25 towards the cost of their care because this is the level of available income they have to contribute towards the cost of their care. There are approximately 6 clients who currently benefit from the cap on care charges and they will be affected if the full cost of their care exceeds the current cap of £465 per week.
The Council has a waiver’s policy and can choose to continue to provide services either free or at a lower cost if it is felt the person is putting themselves at risk by refusing care services due to increased charges
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APPENDIX C - Integrated Impact Assessment Form (IIA)
2.3. Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. Guidance Notes: By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic There is no evidence currently available to suggest that the Policy will have a noticeable impact, either positive or negative, on the groups identified above namely: Sexual Orientation, Religion/Belief, Gender Reassignment, Pregnancy/Maternity, Marriage/Civil Partnership, Care Responsibilities.
The provision of Adult Care is based on someone’s level of care needs irrespective of any of the above. The amount charged for Adult Care Services is based on someone’s available income following a financial assessment.
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APPENDIX C - Integrated Impact Assessment Form (IIA)
3. Social & Health Impacts
3.1. If you have identified an impact on community cohesion4’, tackling poverty5 or health and wellbeing6, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children. Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.
For advice & support from the Social Justice Unit click here
For advice and support from the Public Health team click here People are assessed on their ability to pay – they will only be expected to pay what they can afford for chargeable care services they receive.
The proposed changes to charging will ensure those who can afford to pay for their care are charged the cost of the care provided and it will also reduce the level of subsidy currently being offered to adult care clients.
The Council has a waiver’s policy and can choose to continue to provide services either free or at a lower cost if it is felt a person is putting themselves at risk by refusing care services due to increased charges.
4 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 5 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 6 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services?
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APPENDIX C - Integrated Impact Assessment Form (IIA)
4. Environment Impacts
4.1. If you have identified any impacts related to the built and natural environment7, low carbon8 and waste minimisation please describe here what this may be and who or where you believe could be affected Guidance Notes: Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:
Waste Hierarchy
For advice and support from the Strategy & Sustainability Team click here None
7 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution. 8 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport.
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APPENDIX C - Integrated Impact Assessment Form (IIA)
5. Economic Impacts
5.1. If you have identified any impacts related to Luton’s economy and businesses 9, creating jobs10 or improving skill levels 11, please describe here what this may be and who or where you believe could be affected Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below. Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below.
For advice and support on Economic Development click here None
9 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 10 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well-being and the reduction of poverty in the social box. 11 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships?
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APPENDIX C - Integrated Impact Assessment Form (IIA)
Impact Enhancement and Mitigation Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:
Responsible Date Completed / Action Deadline Intended Outcome Officer Ongoing Consultation with By October Maud O’Leary Seek approval from Stakeholders 2018 Executive to implement including service changes to charges users and carers following consultation with stakeholders
A review of the action plan will be prompted 6 months after the date of completion of this IIA.
Key Contacts Name Position Maud O’Leary Service Director Adult Social Care
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APPENDIX C - Integrated Impact Assessment Form (IIA)
Next Steps • All Executive Reports, where relevant, must have an IIA attached • All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment) • All reports are to be forwarded to the Social Justice Unit, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline • On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager
Completed and signed IIA’s will be published on the internet once the democratic process is complete
Useful Documents Corporate Plan Equality Charter Social Justice Framework Family Poverty Strategy Joint Strategic Needs Assessment (JSNA) Community Involvement Strategy
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Page 160 of 478 Report For: Executive Item No: Date: 20 August 2018 Report Of: Corporate Director - People 13 Report Author: Debbie Craig, Senior Education Officer
Subject: Surrey Street Primary School – Extension of Age Range Lead Executive Member(s): Cllr Hussain Wards Affected: South Consultations: Councillors ☐ Scrutiny ☐ Stakeholders ☒ Others ☐
Recommendations 1. Executive is recommended to approve the extension of the age range of Surrey Street Primary School, to include nursery provision for three and four year olds, as set out in the Statutory Proposals published on 21 June 2018 (Appendix A).
Background 2. Surrey Street Primary School currently caters for pupils aged 4-11 years. Children enter the Reception Year in the September following their fourth birthday. It is proposed to extend the School’s age range, by one year, to allow the School to provide nursery education for three and four year olds. 3. Statutory proposals are necessary when the age range of a community school is altered by one year or more and the Council must follow the statutory process summarised below:
• Stage 1: Statutory proposal published - this must contain sufficient information for interested parties to make a decision on whether to support or challenge the proposed change.
• Stage 2: Representation - once proposals are published there follows a four week statutory period during which representations (e.g. objections or comments) can be made. The representation period is the final opportunity for people and organisations to express their views about the proposals and ensure that the Council will take them into account.
• Stage 3: Decision – the Council must decide proposals within two months of the end of the representation period, otherwise the proposal will be referred to the Schools Adjudicator. Statutory guidance, relevant to the proposals, is set out at Appendix 2.
• Stage 4: Implementation – In general, proposals should be implemented within three years of their publication.
4. Prior to commencing Stage 1, the Governing Body of Surrey Street Primary School undertook a consultation exercise with key stakeholders. Details of the consultation are set out in paragraphs 17-21 below.
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5. Statutory Proposals (set out at Appendix A) were published in the newspaper and on the Consultation Portal of the Council’s website on 21 June. The closing date for comments/objections was 19 July; the Council did not receive any objections to the Proposal.
6. Stages 1-2 have now been completed and the Executive is asked to make a decision as per Stage 3 above.
The Current Position 7. Currently early years provision is not offered on the School site. The closest nurseries/pre- schools within a half mile radius have very limited vacancies and many have waiting lists.
8. The objective of the proposal is to increase the numbers of pupils entering Surrey Street Primary School with early years education (around 40% of children in Surrey Street Primary School’s Reception Year did not have an early years education; this figure was 50% for the School’s previous Reception Year intake). According to the Early Years Foundation Stage (EYFS) Baseline the majority of pupils join Surrey Street Primary School well below the expected level of development for their age. In addition to this, pupils with severe special needs enter Reception with very little formal assessment.
9. Although the School is rated by Ofsted as ‘Requires Improvement’, the Headteacher and staff are working towards significantly improving the outcomes for pupils through planned interventions and reduced class sizes to try and raise attainment, so that by the end of the Reception Year 70% of pupils reach national expectations. Ofsted have rated the Early Years Foundation Stage as consistently good at Surrey Street Primary School.
10. It is anticipated that the vast majority of children attending a nursery unit, attached to the School, will feed into the School’s Reception Year, via the admissions process, and help address the School’s high pupil mobility issues.
11. This proposed nursery provision will increase the range of early years options open to local parents. Given the small size of the nursery unit, it is not anticipated that this provision will have a significant adverse impact on other early years provision in the local area.
Goals and Objectives 12. To increase the number of pupils entering Surrey Street Primary School’s Reception Year with early years education and to help address the School’s high pupil mobility issues.
Financial Implications 13. Surrey Street Primary School would need to absorb the costs of operating the nursery unit from its delegated funding. Therefore there will be no financial implications to the Council as all the costs and risks will be contained within DSG.
14. Circa £50k of Basic Need Capital Funding (funding provided to Luton Council by the Department for Education) will facilitate adaptions/improvements to existing early years accommodation and external play areas and improve access arrangements for parents with buggies.
Proposal 15. Executive is recommended to approve the extension of the age range of Surrey Street Primary School, to include nursery provision for three and four year olds, as set out in the Statutory Proposals at Appendix A.
Page 162 of 478 Key Risks 16. The School is currently rated by Ofsted as ‘Requires Improvement’; it is envisaged that this proposal will assist with raising pupil attainment and help to provide a stable Reception Year intake.
Consultations 17. The following people/organisations were consulted before publication of statutory proposals:
Governors of Surrey Street Primary School Staff at Surrey Street Primary School Prospective parents Trade Union representatives Parents/carers of children attending Surrey Street Primary School Waiting list parents/carers of Surrey Street Primary School Local ward Councillors Luton MPs Local pre-schools, schools and nurseries Governing bodies of neighbouring schools Pre-School Learning Alliance
18. A copy of the consultation document and the feedback on the proposal are set out at Appendix A.
19. The School received two responses to their consultation. One from a parent, who supports the proposed nursery, and one from Rothesay Nursery School (RNS) which opposes the development of a nursery class at Surrey Street Primary School.
20. RNS are concerned that there is sufficient nursery provision in the local area and that additional early years provision would create unnecessary surplus capacity.
21. Governors were mindful that RNS is over a mile from Surrey Street Primary School and that a high percentage of children who enter the Reception Year at Surrey Street Primary School have not received a nursery education. It is anticipated that the majority of children attending a nursery unit, attached to the School, will feed into the School’s Reception Year, via the admissions process, and help address the School’s high pupil mobility issues. A number of parents have expressed an interest in a nursery place at the School.
22. No objections were received in response to the publication of statutory proposals to extend the School’s age range, published on 21 June 2018.
Page 163 of 478 Alternative options considered and rejected (please specify) 23. The Executive can decide to:
a. Approve the proposal without modification; b. Reject the proposal c. Approve the proposal with modifications, having consulted the Governing Body of Surrey Street Primary School.
Appendices 24. The following appendices are attached to this report:
• Appendix A – Statutory Proposals for Surrey Street Primary School. • Appendix B – Relevant Statutory Guidance on Age Range Alterations • Appendix C – Integrated Impact Assessment
Background Papers 25. There are no background papers to this report.
Page 164 of 478 IMPLICATIONS
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated The changes that are proposed form prescribed Raj Popat, Principal 31/7/2018 alterations under the Education and Solicitor Inspections Act 2006. The School Organisation (Prescribed Alterations to Maintained Schools) (England) Regulations 2013 and accompanying statutory guidance set out the process which must be followed when making such changes. The statutory process to make these changes varies according to the nature of the change and status of the school and the process followed in respect of these proposals is detailed in this report. The Council is the decision maker in relation to this proposal and must decide them within two months of the end of the representation period, otherwise the proposal will be referred to the Schools Adjudicator.
Finance Clearance Agreed By Dated Financial Implications are contained within the main Atif Iqbal (Finance 30/07/18 body of the report. Business Partner People & PHCP Directorates) Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated An IIA has been completed. The closest Maureen Drummond, 1 August Nurseries/Pre-Schools within a half mile radius have Cohesion and Equalities 2018 very limited vacancies and waiting lists, therefore this Adviser proposal will have a positive impact on age.
Environment Clearance Agreed By Dated There are no environmental implications to this Katarzyna Wysocka, 30/7/18 report. Strategy and Sustainability Service Health Clearance Agreed By Dated The proposal is in line with the PH strategic priority to Lucy Hubber MFPH 01/08/2018 support all children to realise their full potential Consultant in Public Health through the co-ordination of early years support. (Acting) Service Director – Healthy
Page 165 of 478 Lives and Children’s Joint Commissioning (Interim) Public Health, Commissioning and Procurement Community Safety Clearance Agreed By Dated
Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
Page 166 of 478 Appendix A
Prescribed Alteration to Surrey Street Primary School Notice is given that Luton Borough Council intends to make a prescribed alteration to Surrey Street Primary School (Community School), Cutenhoe Community Learning Park, Cutenhoe Road, Luton LU1 3NJ, from 1 September 2018, by extending the age range of the School to include nursery provision for three and four year olds. The current age range of the school is 4-11 years. The proposed age range will be 3-11 years. The current capacity of the school is 630 and the proposed capacity will be 630, plus 26 full time equivalent nursery places. The current number of pupils registered at the school is 488. This Notice is an extract from the complete proposal. Copies of the complete proposal can be obtained from Michelle Lilly-Hills, by telephoning 548041, or by writing to Mrs Michelle Lilly-Hills, Appeals Officer, Luton Borough Council, Town Hall, George Street Luton LU1 5BQ (email: [email protected]). Hard copies are also available from the office of Surrey Street Primary School. Alternatively, the complete proposal can be viewed at: www.luton.gov.uk/consult Any person may object to, make comments on, or express support for the proposal, no later than 19 July, by sending them to Mrs Michelle Lilly-Hills, Appeals Officer, Luton Borough Council, Town Hall, George Street Luton LU1 5BQ (email: [email protected]).
Signed: Amanda Lewis – Corporate Director, People Directorate
Publication Date: 21 June 2018
1 Page 167 of 478 These proposals have been published by Luton Borough Council, Town Hall, Luton LU1 2BQ and relate to Surrey Street Primary School, Cutenhoe Community Learning Park, Cutenhoe Road, Luton LU1 3NJ. Surrey Street Primary School is a Community School, maintained by Luton Borough Council.
Description of Alteration: It is proposed to extend the age range of the School to include nursery provision for three and four year olds. The current age range of the school is 4-11 years. The proposed age range will be 3-11 years.
Objectives:
The objective of the proposal is to increase the numbers of pupils entering Surrey Street Primary School with early years education (around 40% of children in Surrey Street Primary School’s Reception Year did not have an early years education; this figure was 50% for the School’s previous Reception Year intake). According to the Early Years Foundation Stage (EYFS) Baseline the majority of pupils join Surrey Street Primary School well below the expected level of development for their age. In addition to this, pupils with severe special needs enter Reception with very little formal assessment.
The Headteacher and staff are working towards significantly improving the outcomes for pupils through planned interventions and reduced class sizes to try and raise attainment, so that by the end of the Reception Year 70% of pupils reach national expectations. Ofsted have rated the Early Years Foundation Stage as consistently good at Surrey Street Primary School.
It is anticipated that the vast majority of children attending a nursery unit, attached to the School, will feed into the School’s Reception Year, via the admissions process, and help address the School’s high pupil mobility issues.
This proposed nursery provision will increase the range of early years options open to local parents. Given the small size of the nursery unit, it is not anticipated that this provision will have a significant adverse impact on other early years provision in the local area.
Evidence of Demand and the impact on other schools, academies and educational institutions in the area:
Whilst there is currently surplus capacity in the local area, it is anticipated that new housing developments will yield additional children. The nursery accommodation at Surrey Street Primary School will assist with meeting demand from families moving into new housing.
The Governing Body is keen for the nursery provision to cater for local children and younger siblings of pupils who are not accessing nursery provision at present. This will assist with raising standards at Key Stage 1.
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Project Costs
Circa £50k of Basic Need Capital Funding (funding provided to Luton Council by the Department for Education) will facilitate adaptions/improvements to existing early years accommodation and external play areas and improve access arrangements for parents with buggies.
Implementation:
It is proposed that the prescribed alteration will take effect from 1 September 2018.
Consultation:
The following people/organisations were consulted before publication of these proposals:
Governors of Surrey Street Primary School Staff at Surrey Street Primary School Prospective parents Trade Union representatives Parents/carers of children attending Surrey Street Primary School Waiting list parents/carers of Surrey Street Primary School Local ward Councillors Luton MPs Local pre-schools, schools and nurseries Governing bodies of neighbouring schools Pre-School Learning Alliance
A copy of the consultation document is attached at Appendix A.
The school received two responses to their consultation. One from a parent, who supports the proposed nursery, and one from Rothesay Nursery School (RNS) which opposes the development of a nursery class at Surrey Street Primary School.
RNS are concerned that there is sufficient nursery provision in the local area and that additional early years provision would create unnecessary surplus capacity.
Governors were mindful that RNS is over a mile from Surrey Street Primary School and that a high percentage of children who enter the Reception Year at Surrey Street Primary School have not received a nursery education. It is anticipated that the majority of children attending a nursery unit, attached to the School, will feed into the School’s Reception Year, via the admissions process, and help address the School’s high pupil mobility issues. A number of parents have expressed an interest in a nursery place at the School.
3 Page 169 of 478 Objections & Comments:
Any objections to, or support for/comments on, the proposals should be put in writing and addressed to:
Michelle Lilly-Hills Appeals Officer Luton Borough Council Town Hall George Street Luton LU1 5BQ
(email: [email protected])
The representation period for these proposals is four weeks. The closing date for comments and objections is 19 July 2018.
4 Page 170 of 478 Appendix A
SURREY STREET PRIMARY SCHOOL
Cutenhoe Learning Park, Cutenhoe Road, Luton, Beds LU1 3NJ www.surreystreetprimary.com Tel: 01582 748810
Headteacher: Mrs L Adams Chair of Governors: Mr R Cowan
CONSULTATION PAPER
ON THE PROPOSAL TO EXTEND THE AGE RANGE OF SURREY STREET PRIMARY SCHOOL TO INCLUDE A NURSERY PROVISION FOR THREE AND FOUR YEAR OLDS
MARCH 2018
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FOREWORD
This consultation paper has been produced by Surrey Street Primary School to seek the views of parents and other stakeholders on the proposed extension in age range to include 3 year old children. The proposed extension will create a single primary school for children aged 3-11 from 1st September 2018.
To find out further information parents/carers of children attending Surrey Street Primary School, prospective parents and other members of the local community can attend a drop in session, at Surrey Street Primary School, from 9.15 – 10.00am on Wednesday 25th April 2018
Parents and other stakeholders are asked to complete the attached consultation response form and return it to:
Surrey Street Primary School Cutenhoe Learning Park Cutenhoe Road Luton Beds LU1 3NJ
E-mail - [email protected]
If you would prefer to send your response directly to the Council, please address it to:
Mrs Michelle Lilly-Hills Appeals Officer Luton Council People’s Directorate Town Hall Luton LU1 2BQ
E-mail - [email protected]
The proposal to increase the age range of Surrey Street Primary School is an important issue. It is hoped that you can find time to read the remainder of this document and let us know what you think.
Your views are important and we value your opinions.
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INTRODUCTION/OBJECTIVES
1. Surrey Street Primary School currently provides education for children from 4- 11 years. We are a fully inclusive school, valuing and respecting everyone equally.
2. According to the Early Years Foundation Stage (EYFS) Baseline the majority of pupils join Surrey Street Primary School well below the expected age range for attainment. In addition to this, pupils with severe special needs enter Reception with very little formal assessment.
3. Surrey Street Primary School aims to provide an outstanding education and the best opportunities for pupils in line with our Mission Statement ‘Learning for Life’.
4. The Headteacher and staff are working towards significantly improving the outcomes for pupils through planned interventions and reduced class sizes to try and raise attainment, so that by the end of the Reception Year 70% of pupils reach national expectations. Ofsted have rated the Early Years Foundation Stage as consistently good.
5. In order to continuously improve the chances of our pupils and sustain the level of progress in the Early Years Foundation Stage, Surrey Street Primary School seeks to include a nursery provision to provide the best possible educational foundation for the community.
6. It is proposed to extend the age range of children admitted to Surrey Street Primary School from 4-11 years to 3-11 years old. This would mean that 52 nursery places would be available for 3 year old children from the term after their third birthday. Children would be able to attend am, pm or all day. This would be subject to places available. Government free entitlement regulations would apply. This is currently 15 free hours per week for all three and four year olds, and up to 30 hours entitlement for eligible families.
7. It is proposed this would be achieved by:
a) Surrey Street Primary School using part of the existing EYFS accommodation, which is situated on the school site. This would enable the children to be taught in a shared EYFS Unit, at the School, whilst taking advantage of the shared resourcing that the School could provide. b) Undertaking a prescribed alteration to extend the School’s current age range from 4-11 years old to 3-11 years old.
8. Advantages Nursery provision would be very similar to what is currently available to Reception pupils in school. Alongside specific phonics and mathematics programmes, there would be high quality play-based continuous provision including role play, sand, water, construction, reading, mark making, Welly Wednesdays, outdoor learning and outside play. Free flow between areas, including outside, would offer
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children the choice of activities and allow them to engage in learning which is relevant and appropriate to their stage of development. They would be supported by knowledgeable and appropriately trained adults; and led by an outstanding EYFS Manager.
The Nursery Unit will be accommodated in purpose-remodelled indoor and outdoor spaces
The Nursery Unit would be led by a full time specialist teacher, together with excellent, suitably qualified, support staff.
The children would benefit from experiencing innovative early educational activities to support their learning and development as part of a wider school curriculum; led by a qualified teacher.
There will be improved continuity of learning and development. A single teaching and learning policy supported by a common approach to assessment and the tracking of pupil’s progress will result in more consistent expectations.
Research has shown that, where schools provide nursery education, pupils make rapid progress as they move between the early stages of learning. School staff are able to share their expertise between Early Years and Key Stage 1: this is critical to consistent progress and the transition process.
Whilst there is no automatic transfer between nursery and the Reception Year (parents must apply to the Council for a place at the main school), for those pupils moving from the Nursery to Reception, the transition would be a smooth and effective process allowing the children to settle more quickly.
Creating a new integrated nursery unit offers better continuity to pupils in terms of curriculum and the school ethos. It would provide continuity of education and provision through a single leadership team and governing body.
Pupils would already have developed an understanding of the successful phonics and mathematics programmes which are run by the school. This would mean that pupils would arrive in the Reception Year with more advanced skills in these areas.
A wider range of resources and expertise could be shared across the age range of the school. This flexibility can be particularly useful for children with special needs or vulnerabilities.
It will provide the opportunity to enhance parental engagement across an extended age range.
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9. In order to progress matters further, a wider consultation is now being undertaken with all governors, staff, parents and the wider community to determine the level of support, or otherwise, for such a course of action. This is the first step of the consultation. Comments on this consultation will be considered by the Governing Body which will then decide whether to proceed with the proposal. If the Governing Body does decide to proceed with the proposals, it is envisaged the Nursery Unit will be operational from September 2018.
PUPIL NUMBERS, SCHOOL CAPACITIES AND ADMISSIONS
10. Surrey Street Primary School currently caters for children from the Reception Year, those who will have their 5th Birthday during the school year, until the age of 11 years old. The proposal would extend this age range to include children from the term after their 3rd birthday. The proposed nursery unit would provide up 52 places in two sessions, 26 in the morning and 26 in the afternoon. Parents may apply for an am and/or pm place for their child.
11. The Nursery’s session times will run as follows;
a) Morning session - 8.45 am until 11.45 am b) Afternoon session - 12.30 pm until 3.30 pm c) Additional childcare (including lunchtime) – will be available for eligible families.
12. The Nursery Unit’s Admission Policy will be in line with the existing admission policy for the Primary School. Should there be more interest in the Nursery than places available, then the waiting list will be held in the following categories;
a) Children with an Education Health Care Plan. b) Brothers and sisters of pupils attending the school or nursery unit when the pupil starts at the school. c) Pupils living in the catchment area of the school. d) On medical grounds supported by medical evidence. e) Children of staff who work at the school. f) On the shortest distance, measured in a straight line, between the main entrance of the school site and the pupil’s home address, those living closer to the school being accorded higher priority.
13. Where a tie-break is necessary within a category, priority will be given to date of birth, with older children having priority.
14. There will be three intakes per year, September, January and April depending on the child’s date of birth. If a child’s third birthday is between 1st April and 31st August they can apply to begin after 1st September. If a child’s birthday is between 1st September and 31st December a parent/carer can apply for their child to commence on or after 1st January. If a child’s third birthday is
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between 1st January and 31st March they can begin on or after 1st April. (Subject to availability.)
15. Please note admission into the nursery unit would not guarantee or give priority to a child for a place in Reception. Parents need to apply to the Council for a place in the main school in the Starting School Application Round, even if their child has secured a place in the Nursery. No priority is accorded to children having previously attended the Nursery Unit. Admission arrangements to the main School will not be affected by this proposal.
TEACHING & LEARNING
16. Teaching and learning opportunities within the nursery setting would follow the same, successful pathways which our Reception pupils experience at present. Bespoke phonics and mathematics programmes will be put in place to ensure that language and calculation skills are developed; and that pupils become familiar with the programmes at an earlier age. The School would broaden the curriculum through careful topic planning and there would be high quality play-based continuous provision including role play, sand, water, construction, reading, mark making, and outside play, Welly Wednesdays and outdoor learning. Free-flow between areas, including outside, would offer children the choice of activities and allow them to engage in learning which is relevant and appropriate to their stage of development. They would be supported by knowledgeable and appropriately trained adults; and led by an outstanding EYFS manager.
17. Children with special educational needs will be supported through:
• Early intervention • Evidence can be gathered from an early stage for children likely to require an Educational Health Care Plan. • Access and support from the Primary School’s SEN department • Access to the Primary School’s Speech and Language Therapist • Access to the Local Authority’s SEND Advisory Service • Access to a wide range of professionals
18. The Primary School’s SENCO is highly experienced and is currently working towards a national qualification for special educational needs.
GOVERNANCE/ADMINISTRATION AND STAFFING
19. The nursery provision would be overseen by a current EYFS Leader in education, with many years experience as a leader and manager.
20. A single set of policies and procedures will apply. Safeguarding and equal opportunities will be in accordance with Local Authority procedures.
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21. The primary school and nursery unit will be managed by the school’s leadership team and governing body, supported by a Headteacher who would have ‘whole school’ responsibility.
22. A governor with direct responsibility for nursery provision would be appointed.
23. It is anticipated that the staff of Surrey Street Primary School would be incorporated into the new primary / nursery structure.
FINANCIAL CONSIDERATIONS
24. Schools are given their own budget and have to manage within the money that is available. By incorporating a nursery unit, the school will also receive nursery funding for the number of children on roll. Parents will also be charged should they wish their child to remain for lunch and access the additional hours available.
25. The Governing Body would propose internal modification of the existing space, which would be included within the School’s planned and routine maintenance programme.
26. The Governing Body believe that value for money will be achieved by improving the baseline assessment and ultimately the pupil outcomes.
27. In order to raise attainment further, standards at the end of the reception year need to be much higher. Surrey Street Primary School aim to provide pupils with an outstanding nursery provision.
SITE CONSIDERATIONS
28. The proposed nursery unit would make use of the existing accommodation. The facilities will continue to be used for the purposes of delivering a broad range of educational activities to pupils. Governors will be implementing improvements and modifications to access to the school site.
CONSULTATIONS
29. It is important that all interested individuals and groups have the opportunity to comment on the proposed prescribed alteration to extend the existing age range to include a nursery provision for three and four year olds.
30. A drop-in session to discuss the proposed prescribed alteration has been arranged for parents, prospective parents and other members of the community on Wednesday 25th April 2018 at 9.15 am-10.am. The drop-in session will be held at Surrey Street Primary School.
31. Written comments on the proposal are invited and a consultation response form has been prepared to assist with this process. The deadline for
11 Page 177 of 478
submitting your comments is 4pm on 11th June 2018.
DISTRIBUTION OF CONSULTATIVE DOCUMENT
1. In order to ensure that this consultation document should be read as widely as possible, it is being distributed as follows: Governors of Surrey Street Primary School Staff at Surrey Street Primary School Prospective parents Trade Union representatives Parents/carers of children attending Surrey Street Primary School Waiting list parents/carers of Surrey Street Primary School Local ward Councillors Luton MPs Local pre-schools, schools and nurseries Governing bodies of neighbouring schools Pre-School Learning Alliance
Further copies are available on request at Surrey Street Primary School.
12 Page 178 of 478
CONSULTATION RESPONSE FORM ON THE PROPOSED ALTERATION TO INCREASE THE AGE RANGE AT SURREY STREET PRIMARY SCHOOL TO INCLUDE THREE YEAR OLDS.
You are invited to complete this consultation response form so that your valuable comments about the extension of the School’s age range can be considered carefully.
1. ARE YOU IN FAVOUR OF EXTENDING THE SCHOOL’S AGE RANGE TO INCLUDE 3 YEAR OLDS?
YES
NO
(please tick as appropriate)
2. ADDITIONAL COMMENTS
Please set out any additional comments you may wish to make. These could include specific comments related to your circumstances or general comments.
______
______
______
______
______
______
______
______
______
______
______
13 Page 179 of 478
3. I AM INTERESTED IN THIS ISSUE BECAUSE (please tick the appropriate box)
I am parent/carer of a child attending Surrey Street Primary School.
I am a parent/carer of a child who could attend on the school in the future.
I am a member of staff at Surrey Street Primary School
I am a resident in the area who is not likely to have children attending the school in the future.
Other (please specify) ......
Completed forms should be returned to:
All completed forms should be returned to Surrey Street Primary School by 4pm on 11th June 2018.
14 Page 180 of 478 Appendix B – Relevant Extracts from: DfE Guidance for decision makers (Statutory guidance for decision-makers deciding prescribed alteration and establishment and discontinuance proposals)
Main points The decision-maker will need to be satisfied that the appropriate fair and open local consultation and/or representation period has been carried out and that the proposer has given full consideration to all the responses received. The decision-maker must consider the views of those affected by a proposal or who have an interest in it, including cross-LA border interests. The decision-maker should not simply take account of the numbers of people expressing a particular view. Instead, they should give the greatest weight to responses from those stakeholders likely to be most directly affected by a proposal – especially parents of children at the affected school(s).
If the proposer has failed to meet the statutory requirements, a proposal may be deemed invalid and therefore should be rejected. The decision-maker must consider ALL the views submitted, including all support for, objections to and comments on the proposal.
Consideration of consultation and representation period The decision-maker will need to be satisfied that the appropriate fair and open local consultation and/or representation period has been carried out and that the proposer has given full consideration to all the responses received. If the proposer has failed to meet the statutory requirements, a proposal may be deemed invalid and therefore should be rejected. The decision-maker must consider ALL the views submitted, including all support for, objections to and comments on the proposal.
Education standards and diversity of provision Decision-makers should consider the quality and diversity of schools in the relevant area and whether the proposal will meet or affect the needs of parents; raise local standards and narrow attainment gaps. Under sections: 90, 91,92 and 93 of the of the Education Act 2002.
Equal opportunity issues The decision-maker must have regard to the Public Sector Equality Duty (PSED) of LAs/governing bodies, which requires them to have ‘due regard’ to the need to: • eliminate discrimination; • advance equality of opportunity; and • foster good relations.
The decision-maker should consider whether there are any sex, race or disability discrimination issues that arise from the changes being proposed, for example that where there is a proposed change to single sex provision in an area, there is equal access to single sex provision for the other sex to meet parental demand. Similarly there should be a commitment to provide access to a range of opportunities which reflect the ethnic and cultural mix of the area, while ensuring that such opportunities are open to all.
Community cohesion
Page 181 of 478 Schools have a key part to play in providing opportunities for young people from different backgrounds to learn with, from and about each other; by encouraging, through their teaching, an understanding of, and respect for, other cultures, faiths and communities. When considering a proposal, the decision- maker must consider its impact on community cohesion. This will need to be considered on a case-by- case basis, taking account of the community served by the school and the views of different sections within the community.
Travel and accessibility Decision-makers should satisfy themselves that accessibility planning has been properly taken into account and the proposed changes should not adversely impact on disadvantaged groups. The decision-maker should bear in mind that a proposal should not unreasonably extend journey times or increase transport costs, or result in too many children being prevented from travelling sustainably due to unsuitable walking or cycling routes. A proposal should also be considered on the basis of how it will support and contribute to the LA’s duty to promote the use of sustainable travel and transport to school. Further information is available in the statutory Home to school travel and transport guidance for LAs.
Page 182 of 478 APPENDIX C - Integrated Impact Assessment Form (IIA)
The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement that
‘The needs of Luton’s people will be first in everything we do’.
Why do I need to do an IIA? The aim of this impact assessment process is to: • Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council. • Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens. • Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion. • Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified.
When do I need to do an IIA?
• An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.
• The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA. • If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA. • An IIA must at all times identify those who will be affected by the decision, policy or strategy. • At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens. • Your first early draft is to be sent to the Social Justice Unit for comments and guidance • Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit. If you need further guidance please contact the Social Justice Unit (SJU). Please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.
1
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Proposal Title: Proposal to extend the age range of Surrey Street Primary School from 4-11 to 3-11 Lead Officer Name: Debbie Craig Date of IIA: July 2018
Date updated after consultation: Early draft Seen by: (Please send an early draft of your IIA to the SJU to ensure all impacts are being considered at the appropriate time)
Finalised IIA Signed and seen by SJU : Name: Maureen Drummond, Cohesion and Equalities Adviser Date 1 August 2018
Names of all other contributors and Michelle Lilly-Hills, Appeals Officer stakeholders involved in the preparing of this proposal who have been consulted with and agreed this assessment: (Please note the IIA must not be carried out by one person) If there is any potential impact on staffing n/a please include the name/s of the trade union representative/s involved in the preparation of this assessment or any supporting evidence of request to participate:
2
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Proposal Outline
Information supporting the proposal (who, what, where, how). Breakdown of present users by ethnicity, age, gender, disability, religion/belief, sexuality (if recorded). Show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered. The Council has published statutory proposals to extend the School’s age range as the Governing Body would like to operate a small nursery provision on the school site.
Full details of the proposal are set out in the Executive report (20 August) and its appendices.
The characteristics of children currently attending Surrey Street Primary School are set out below;
Gender: Girls – 220 / Boys – 241
Age: Year R (age 4-5) – 47 Year 1 (age 5-6) – 61 Year 2 (age 6-7) – 71 Year 3 (age 7-8) – 64 Year 4 (age 8-9) – 68 Year 5 (age 9-10) – 74 Year 6 (age 10-11) – 76
Religions: No Religion – 127 Christian – 98 Muslim – 90 Catholic – 62 Other Religion – 43 Hindu – 12 Buddhist – 2 Sikh – 1
Ethnicity: White Other – 140, White British – 95, Bangladeshi – 34, Pakistani – 32, Black African – 30, White & Black Caribbean – 21, Black Caribbean – 20, Indian – 14, White & Asian – 14, White & Black African – 11, Any other mixed background – 10, Roma – 9, Any other black background – 6, Other Asian – 6, Turkish/Turkish Cypriot – 4, Any other ethnic group – 3, Chinese – 3, Gypsy/Roma – 3, Kashmiri other – 2, Other Gypsy/Roma – 2, Traveller of Irish heritage – 2
Disability: 01
3
Page 185 of 478 APPENDIX C - Integrated Impact Assessment Form (IIA)
Impact Table The purpose of this table is to consider the potential impact of your proposal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.
Once you have completed this process you should have a clearer picture of any potential significant impacts1, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.
Citizens/Community Staff (for HR related issues) Protected Groups Positive Negative Neutral Positive Negative Neutral Race Gender Disability Sexual Orientation Age Religion/Belief Gender Reassignment Pregnancy/Maternity N/A Marriage/Civil Partnership N/A (HR issues only) Care Responsibilities2 N/A (HR issues only) Social & Health3 Impact on community cohesion Impact on tackling poverty Impact on health and wellbeing Environment Impact on the quality of the natural and built environment Impact on the low carbon agenda Impact on the waste hierarchy Economic/Business Impact on Luton’s economy and/or businesses Impact on jobs Impact on skills
1 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large. 2 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 3 Full definitions can be found in section 3
4
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Please answer the following questions:
1. Research and Consultation
1.1. Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate. Click here for local demographics and information See paragraphs 17-22 in the Executive report.
1.2. Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate). Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.
Click here for the LBC Consultation Portal Yes – paragraphs 17-22 in the Executive report.
1.3. Have you carried out any specific consultation with citizens likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document. For advice and support from Consultation Team click here Yes – paragraphs 17-22 in the Executive report
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APPENDIX C - Integrated Impact Assessment Form (IIA)
2. Impacts Identified
2.1. Where you have identified a positive impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. Guidance Notes: By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic? The closest Nurseries/Pre-Schools with a half mile radius have very limited vacancies and waiting lists, therefore this proposal will have a positive impact on age.
The children who attend Surrey Street Primary School come from 12 different areas and a high percentage of children do not attend any nursery setting. This academic year 40% of pupils entering Reception Year had no previous early years education. The year prior (2016-2017) 50% of pupils entering Year R had no previous early years education. 2.2. Where you have identified a negative impact please explain the nature of this impact and why you feel the proposal may be negative. Outline what the consequences will be against each group identified. You will need to identify whether mitigation is available, what it is and how it could be implemented. Specific actions to be detailed in action plan below. Guidance Notes: By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic? N/A
2.3. Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. Guidance Notes: By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic There will be no noticeable impact on people sharing a protected characteristic from the following groups – race, disability, sex, sexual orientation, religion/belief, gender reassignment, marriage/civil partnership, pregnancy maternity
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APPENDIX C - Integrated Impact Assessment Form (IIA)
3. Social & Health Impacts
3.1. If you have identified an impact on community cohesion4’, tackling poverty5 or health and wellbeing6, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children. Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.
For advice & support from the Social Justice Unit click here
For advice and support from the Public Health team click here The proposal is in line with the Public Health strategic priority to support all children to realise their full potential through the co-ordination of early years support. All children are entitled to 15 hours per week (term time – 38 weeks) free early years funding from the term after their third birthday.
4 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 5 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 6 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services?
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APPENDIX C - Integrated Impact Assessment Form (IIA)
4. Environment Impacts
4.1. If you have identified any impacts related to the built and natural environment7, low carbon8 and waste minimisation please describe here what this may be and who or where you believe could be affected Guidance Notes: Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:
Waste Hierarchy
For advice and support from the Strategy & Sustainability Team click here N/A
7 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution. 8 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport.
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APPENDIX C - Integrated Impact Assessment Form (IIA)
5. Economic Impacts
5.1. If you have identified any impacts related to Luton’s economy and businesses 9, creating jobs10 or improving skill levels 11, please describe here what this may be and who or where you believe could be affected Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below. Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below.
For advice and support on Economic Development click here N/A
9 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 10 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well-being and the reduction of poverty in the social box. 11 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships?
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APPENDIX C - Integrated Impact Assessment Form (IIA)
Impact Enhancement and Mitigation Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:
Responsible Date Completed / Action Deadline Intended Outcome Officer Ongoing Request Surrey Ongoing Debbie Craig Success of the nursery Street Primary provision School to monitor take up of nursery provision
A review of the action plan will be prompted 6 months after the date of completion of this IIA.
Key Contacts Name Position Debbie Craig Senior Education Officer Michelle Lilly-Hills Appeals Officer
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APPENDIX C - Integrated Impact Assessment Form (IIA)
Next Steps • All Executive Reports, where relevant, must have an IIA attached • All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment) • All reports are to be forwarded to the Social Justice Unit, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline • On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager
Completed and signed IIA’s will be published on the internet once the democratic process is complete
Useful Documents Corporate Plan Equality Charter Social Justice Framework Family Poverty Strategy Joint Strategic Needs Assessment (JSNA) Community Involvement Strategy
Page 19311 of 478
Page 194 of 478 Report For: Executive Item No: Date: 20 August 2018 Report Of: Service Director – Public Protection 14 Report Author: Tony Stefano – Parking Services Manager
Subject: Removal of Vehicles Illegally Parked Lead Executive Member(s): Councillor P. Castleman Wards Affected: All Consultations: Councillors ☒ Scrutiny ☒ Stakeholders ☐ Others ☐
Recommendations 1. The Executive is recommended to;
(i) Introduce a scheme to remove illegally parked vehicles in receipt of a Penalty Charge Notice.
(ii) Approve the vehicle removal criteria as set out in Appendix A to this report.
(iii) Authorise the Service Director, Public Protection following consultation with the Executive member with portfolio responsibility for Place and Infrastructure (Planning & Transport) to amend the removal criteria where operational requirements dictate it necessary.
Background 2. Decriminalised Parking Enforcement has operated in Luton since January 1999. The original parking schemes were introduced under the Road Traffic Act 1991 whereby the Council was granted Special Parking Area (SPA) status.
3. The Council currently undertake enforcement of parking regulations in accordance with the Traffic Management act 2004. This legislation came into effect from the 1st April 2008.
4. Powers to remove illegally parked vehicles are contained within the Road Traffic Regulation Act 1984 and associated legislation and regulations. These powers, if adopted, will permit the Council to remove illegally parked vehicles when certain criteria are met. These are set out in Appendix A to this report (Removal Criteria).
The Current Position 5. Enforcement is carried out by the Council’s in-house team of Civil Enforcement Officers who are deployed across Luton on a daily basis.
6. Luton currently has 26 residential parking schemes in operation which is a significant increase from the 8 that were in operation in 1999 when the Council took over responsibility for enforcement. A further 4 schemes are proposed subject to public consultation which if agreed would take the number of schemes to 30.
Page 195 of 478 7. In addition, the numbers of yellow line waiting and loading regulations have also increased significantly over the same period and continue to do so.
8. The team issue PCNs to vehicles which are observed parking in breach of the Council’s Traffic Regulation Orders by either affixing the notice to the vehicle or handing it to the driver of the vehicle at the time of the alleged contravention.
9. Once a vehicle has been issued with a PCN it will remain on the road until such times as the driver returns and removes it from the location. This can mean that vehicles can continue to cause blockages on the road network causing significant delays to other motorists and public transport providers with the service being unable to take any further action.
10. During 2017/18 the Council were unable to pursue 2876 PCNs which were issued to foreign registered vehicles. In addition, a further 6404 PCNs were unable to be pursued because of inaccuracies with the DVLA records or incorrect address information. These notices were written off and the Council unable to recover the potential income.
11. Vehicles with 3 or more unpaid PCNs can be considered as persistent evaders. Luton has a significant number of vehicles which have been issued with 3 or more notices and which also remain unpaid. In one case, a vehicle has 115 open unpaid notices with a balance outstanding of £12,269.
Goals and Objectives 12. The overall aim of the service is to help ensure a safe and efficient road network. This is achieved by monitoring parking regulations and ensuring that where regulations are in operation that they are adhered to by motorists.
13. The adoption of the powers to remove illegally parked vehicles is intended to further this objective by allowing the swift removal of vehicles which are either posing an obstruction to the road network or creating a hazard or safety risk to other road users.
14. In addition, It is envisaged that by having the ability to remove vehicles the Parking Enforcement team will be able to more effectively deal with vehicles which are persistent offenders/evaders or foreign registered and potentially be able to remove preventing such high numbers of PCNs.
Proposal 15. The proposal is to introduce a scheme which will allow the Parking Enforcement Team to remove vehicles issued with a PCN and which has remained parked in contravention parking restrictions.
16. Subject to agreement with this proposal the service will develop an operating protocol for the removal of vehicles. Times of operation will be agreed with the service provider.
17. The current fees set for removal of vehicles outside London are £105 and £12 per day for storage after the first 24 hours. Vehicle disposal fees are set at £50.
18. It will be necessary to carry out a tender process to appoint a removal contractor who it is hoped would also be able to provide a suitable car pound facility to securely hold vehicles removed as part of the tender process to be done in conjunction with colleagues with the procurement team.
Page 196 of 478 19. It is estimated that the cost of providing the service will be between £100,000 and £130,000 and it is anticipated that those costs will be recovered as part of the services normal operations.
Key Risks 20. It is anticipated that the introduction of this proposal will be cost neutral to the Council. However, it must be acknowledged that there is potential that operating this scheme may lead to additional cost to the Council. E.g. When vehicles which are removed but not recovered by the owner, the costs associated with the removal, storage and disposal of the vehicle may not be recovered.
Consultations 21. None
Alternative options considered and rejected (please specify) 22. The Executive could decide to not agree with the introduction of the scheme.
Appendices Attached 23. The following appendices are attached to this report:
Appendix A - Draft removal criteria
Appendix B - Integrated Impact Assessment
Background Papers 24. There are no background papers to this report.
Page 197 of 478 IMPLICATIONS
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated The Council has powers to introduce the scheme as Samantha Mckeeman 30 July 2018 outlined within this report.
Finance Clearance Agreed By Dated The estimated costs of the proposed scheme are Darren Lambert, Finance 1st August outlined in the body of the report. The charges that Business Partner 2018 the Council levy for removal, storage and disposal are set by legislation. All costs will be passed on to the vehicle owners and recovered before the vehicle is released. It is therefore anticipated that the scheme will be cost neutral to the Council. However, there are likely to be vehicles that will not be reclaimed and will therefore need to be disposed of at cost to the Council.
The proposed scheme will also result in a reduction in the issuance of PCN’s to vehicles where there are already a number of unpaid PCN’s. This will result in lower levels of PCN debt and fewer uncollectable debts.
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated An Integrated Impact Assessment has been Maureen Drummond, 27 July 2018 completed and the impact is neutral for all protected Cohesion and Equalities characteristics. However, for blue badge holders the Adviser introduction of this policy can be considered positive as it will enable the team to remove vehicles displaying blue badges which are being used to obtain free parking illegally, i.e. where the badge holder is deceased, stolen or where no badge displayed. There could potentially be a negative impact for those who cannot afford the fine, however, an internal payment plan procedure will be made available.
Page 198 of 478 Environment Clearance Agreed By Dated There do not appear to be any direct environmental Keith Dove, Strategic Policy 27th July issues as a result of this report. However Adviser 2018 inconsiderate parking can cause congestion on the highway network and the reduction in congestion could indirectly improve the movement of traffic resulting in reduced emissions and CO2. Health Clearance Agreed By Dated No issues as a result of this report. Lucy Hubber MFPH 30/07/2018 Consultant in Public Health (Acting) Service Director – Healthy Lives and Children’s Joint Commissioning (Interim) Public Health, Commissioning and Procurement Community Safety Clearance Agreed By Dated
Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
Page 199 of 478
Page 200 of 478
APPENDIX A
Vehicle Removal Criteria
Vehicles can be removed in line with this
Category One:
• Parked in contravention in a position or location which is prohibited and is causing danger, & serious health and safety implications for other road users or pedestrians. E.g. on yellow lines or close to a junction. • Illegally parked in a formal disabled bay (30 minutes waiting time or 15 minutes if persistent evader • A persistent offender or evader (parked in prohibited location or permitted parking place • A foreign registered vehicle with 3 or more unpaid PCNs or parked in such a manner to cause an obstruction to other road users or pedestrians.
Category Two:
• Parked in an operational Bus Lane or at a Bus Stop • Parked obstructing a dropped footway (on a resident’s request) • Parked on a footway where yellow lines are in operation or where a TRO banning the parking of footways exists • Parked on school Keep Clear Markings • Parked in a Doctors Bay • Taxi Ranks
Category Three:
• A foreign registered vehicles with no outstanding unpaid PCNs. • A vehicle which is parked in a parking place reserved for specific users without displaying a valid permit e.g. residential or shared use parking place (subject to restrictions within the regulations)
Category Four:
• All other contraventions
In the case of vehicles being requested for removal under Category three or four, these requests must be approved by the Senior Civil Enforcement Officer before the vehicle is removed.
Page 201 of 478
Page 202 of 478 APPENDIX B - Integrated Impact Assessment Form (IIA)
The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement that
‘The needs of Luton’s people will be first in everything we do’.
Why do I need to do an IIA? The aim of this impact assessment process is to: • Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council. • Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens. • Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion. • Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified.
When do I need to do an IIA?
• An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.
• The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA. • If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA. • An IIA must at all times identify those who will be affected by the decision, policy or strategy. • At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens. • Your first early draft is to be sent to the Social Justice Unit for comments and guidance • Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit. If you need further guidance please contact the Social Justice Unit (SJU). Please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.
1
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Proposal Title: Removal of vehicles for parking contraventions Lead Officer Name: Tony Stefano – Parking Service Manager Date of IIA:
Date updated after consultation: Early draft Seen by: Maureen Drummond, Cohesion and (Please send an early draft of your IIA to the SJU to Equalities Adviser, 25 June 2018 ensure all impacts are being considered at the appropriate time)
Finalised IIA Signed and seen by SJU : Name: Date
Names of all other contributors and Tony Stefano stakeholders involved in the preparing of Vicky Hawkes this proposal who have been consulted with and agreed this assessment: (Please note the IIA must not be carried out by one person) If there is any potential impact on staffing None please include the name/s of the trade union representative/s involved in the preparation of this assessment or any supporting evidence of request to participate:
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Proposal Outline
Information supporting the proposal (who, what, where, how). Breakdown of present users by ethnicity, age, gender, disability, religion/belief, sexuality (if recorded). Show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered. It is proposed to introduce a policy which will allow the Council’s parking service to remove vehicles which are issued with a Penalty Charge Notice (PCN) where they remain in contravention of parking regulation in accordance with the Traffic Management Act 2004 and regulations introduced by the Secretary of State.
The attached report for policy group sets out the processes for how the vehicle removal operation will work but in practical terms, vehicles will be removed in accordance with an agreed local removal criteria which places the emphasis on how vehicles are removed and in what order. For example,
Category one: • vehicles which is parked on yellow lines and causing an danger for other road users or pedestrians • a vehicle which is a persistent evader or; • a foreign registered vehicle with 3 or more unpaid PCNs.
Category two: • Parked in an operational Bus Lane or at a Bus Stop • Parked obstructing a dropped footway (without residents permission) • Parked on a footway • Parked on school Keep Clear Markings • Parked in a Doctors Bay
Vehicles may be removed from anywhere within Luton so long as they are parked in contravention of existing parking regulations and will only be removed following the issuance of a PCN for the contravention. Vehicles which are parked within a parking place cannot be removed for the first 30 minutes after the issue of a PCN or 15 minutes in the case of a ‘persistent evader’. In addition a 10 minute grace period would also need to be provided where a vehicle is removed from a parking place after the expiry of the period for which an appropriate charge was paid.
The fees paid to recover a vehicle once removed are set by regulation, which currently stand at £105 outside London with a £12 fee applied per day after the first 24 hours to cover storage fees.
Once a vehicle has been recovered by the owner, they will be notified of their right to make formal representations to the Council should they wish to contest the decision to remove the vehicle with 28-days of its release. They will also be informed of their right to appeal to an independent adjudicator in the event that the Council refuse their representations.
Vehicles which are either diplomatic or displaying a valid disabled parking badge will not be removed (except where the badge is being abused) so the introduction of this policy will have no impact on those individuals.
The policy will apply across the whole of Luton but it is expected that the number of vehicles removed will be from those areas where the concentration of parking regulations is greater so it is likely will be in and around the immediate area of the town centre.
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Page 205 of 478 APPENDIX B - Integrated Impact Assessment Form (IIA)
Impact Table The purpose of this table is to consider the potential impact of your proposal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.
Once you have completed this process you should have a clearer picture of any potential significant impacts1, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.
Citizens/Community Staff (for HR related issues) Protected Groups Positive Negative Neutral Positive Negative Neutral Race X Gender X Disability X Sexual Orientation X Age X Religion/Belief X Gender Reassignment X Pregnancy/Maternity X Marriage/Civil Partnership X (HR issues only) Care Responsibilities2
(HR issues only) Social & Health3 Impact on community cohesion X Impact on tackling poverty X Impact on health and wellbeing X Environment Impact on the quality of the natural X and built environment Impact on the low carbon agenda X Impact on the waste hierarchy X Economic/Business Impact on Luton’s economy and/or X businesses Impact on jobs X Impact on skills X
1 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large. 2 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 3 Full definitions can be found in section 3
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Please answer the following questions:
1. Research and Consultation
1.1. Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate. Click here for local demographics and information
1.2. Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate). Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.
Click here for the LBC Consultation Portal No. Should the introduction of this policy be agreed then communications will be released in conjunction with the communications team.
1.3. Have you carried out any specific consultation with citizens likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document. For advice and support from Consultation Team click here No
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APPENDIX B - Integrated Impact Assessment Form (IIA)
2. Impacts Identified
2.1. Where you have identified a positive impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. Guidance Notes: By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic? In the case of people with disabilities the introduction of this policy can be considered positive as it will enable the team to remove vehicles displaying blue badges which are being used to obtain free parking illegally, i.e. where the badge holder is deceased, stolen or where no badge displayed. Therefore this policy will enhance the credibility of the blue badge scheme for people with disabilities and ensure parking places reserved for those users remain free from misuse or abuse.
2.2. Where you have identified a negative impact please explain the nature of this impact and why you feel the proposal may be negative. Outline what the consequences will be against each group identified. You will need to identify whether mitigation is available, what it is and how it could be implemented. Specific actions to be detailed in action plan below. Guidance Notes: By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic? None
2.3. Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. Guidance Notes: By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic The policy will have no noticeable impact on people sharing a protected characteristic
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APPENDIX B - Integrated Impact Assessment Form (IIA)
3. Social & Health Impacts
3.1. If you have identified an impact on community cohesion4’, tackling poverty5 or health and wellbeing6, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children. Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.
For advice & support from the Social Justice Unit click here
For advice and support from the Public Health team click here
We already have in place an internal payment plan procedure which deals with those people that have financial difficulties. This procedure would be amended to include circumstances where a vehicle is removed and financial hardship is declared and evidenced, using a number of debt resolution agencies that re available to provide assistance.
4 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 5 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 6 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services?
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4. Environment Impacts
4.1. If you have identified any impacts related to the built and natural environment7, low carbon8 and waste minimisation please describe here what this may be and who or where you believe could be affected Guidance Notes: Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:
Waste Hierarchy
For advice and support from the Strategy & Sustainability Team click here
7 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution. 8 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport.
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5. Economic Impacts
5.1. If you have identified any impacts related to Luton’s economy and businesses 9, creating jobs10 or improving skill levels 11, please describe here what this may be and who or where you believe could be affected Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below. Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below.
For advice and support on Economic Development click here The aim would be to appoint a contractor following a tender process and so it may or may not be a local provider. We would however seek as best we can to have the facilities to store removed vehicles as close to Luton as possible with reasonably good transport links.
9 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 10 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well-being and the reduction of poverty in the social box. 11 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships?
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APPENDIX B - Integrated Impact Assessment Form (IIA)
Impact Enhancement and Mitigation Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:
Responsible Date Completed / Action Deadline Intended Outcome Officer Ongoing Set up a financial Tony Stefano hardship procedure Monitoring blue Tony Stefano badge usage
A review of the action plan will be prompted 6 months after the date of completion of this IIA.
Key Contacts Name Position
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Next Steps • All Executive Reports, where relevant, must have an IIA attached • All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment) • All reports are to be forwarded to the Social Justice Unit, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline • On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager
Completed and signed IIA’s will be published on the internet once the democratic process is complete
Useful Documents Corporate Plan Equality Charter Social Justice Framework Family Poverty Strategy Joint Strategic Needs Assessment (JSNA) Community Involvement Strategy
Page 21311 of 478
Page 214 of 478 Report For: Executive Item No: Date: 20 August 2018 Report Of: Service Director, Public Realm 15 Report Author: Laurence Pratt
Subject: Red Routes – Consultation Report Lead Executive Member(s): Councillor Castleman Wards Affected: Biscot, Dallow, Saints, Limbury. South, Crawley and Wigmore Consultations: Councillors ☒ Scrutiny ☒ Stakeholders ☒ Others ☒
Recommendations 1. The Executive is recommended to :-
(i) Implement the Town Centre pilot scheme with minor modifications by introducing No stopping “Red Route Restrictions” on New Bedford Road (Telford Way to Manchester Street), Gordon Street, Upper George Street, Wellington Street, Alma Link, Inkerman Street (Alma Link to Dunstable Road) and Dunstable Road (Inkerman Street to Telford Way) based on the comments received by introducing an Experimental Traffic Regulation Order (ETRO).
(ii) Implement No stopping “Red Route Restrictions” on Airport Way by introducing an ETRO.
(iii) Not to progress the following proposals at this stage:
• Dunstable Road • Leagrave Road • Marsh Road • Windmill Road/Kimpton Road).
(iv) Agree that the ETRO referred to at (i) above is monitored during the objection period of six months and that a further report be submitted to the Executive outlining the results and whether or not the ETRO should be made permanent.
Background 2. The Council as Highway Authority has a duty under the Traffic Management Act 2004 to ensure expeditious movement of traffic (including pedestrians).
3. As part of this duty it has been proposed that a network of Red Routes is considered for implementation in Luton to reduce the amount of parking and stopping on strategic routes in Luton and thereby improve the movement of traffic.
4. Red Routes will prohibit stopping to park, load/unload or to board and alight from a vehicle except in marked bays.
5. On 05 March 2018 Executive agreed to take forward three trial routes to (informal) public consultation. These were
Page 215 of 478 a. Windmill Road, Kimpton Road and Airport Way to reduce the inconsiderate parking on the route to London Luton airport from the Town Centre.
b. Dunstable Road (from Telford Way) to Birch Link, Leagrave Road and Marsh Road (to Three Horseshoes roundabout) to reduce the inconsiderate parking at these locations and improve bus punctuality on a key route from the north of Luton.
c. New Bedford Road, Wellington Street, Gordon Street, Upper George Street, Alma Link, Inkerman Street, Dunstable Road (to Telford Way) to reduce inconsiderate parking, reduce congestion and improve bus punctuality around the Town Centre.
The Current Position 6. The public consultation was held between 11 May and 08 June 2018.
a. Almost 1800 leaflets were delivered to residents and business directly affected by the proposals. b. 50 posters were sent to various organisations, including libraries, community centres, churches and mosques, to erect to advertise the consultation and exhibitions. c. More than 800 e-mail alerts where sent out to people and organisation registered on the councils consultation portal for ‘community and business safety’, ‘engineering and transport’, ‘environment’ and ‘street services’ consultations.
d. E-mails were sent to Emergency Services, Bus Companies, Utility Companies, Freight Transport Association, Sustrans, Luton Airport and Road Haulage Association
e. Drop in sessions were held between 22 May and 05 June at St Georges Square (moved from library), The Mall (2No.), Bury Park Community Centre and Denbigh High School
f. Dedicated e-mail and telephone line was also set up.
The consultation was also advertised on the council’s Facebook page and a news release was issued and published on the council’s website.
Consultation 7. The consultation results are summarised below and a report is at Appendix A.
Town Centre
8. 228 responses were received (208 online and 20 hard copies).
9. 141 (62%) agreed with the proposal (Figure 1). Figure 2 shows the breakdown of the responses by audience. This shows that 64% of business respondents do not agree with the proposal.
Page 216 of 478 13, 6%
73, 32%
141, 62%
Yes No Don't know
Figure 1 Do you agree with the proposal to implement a red route in the town centre?
Other 4 3 0
Resident/business outside of Luton 6 1 0
Community/Volunteer organisation in 1 0 1 Luton
Businesses 5 11 1
Residents 117 46 9
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 2 Do you agree with the proposals to implement a red route in the town centre by audience
10. Consultees were asked if they had any alternative options to ease congestion, increase traffic flow and make the roads safer in Luton Town Centre. 137 comments were received. Table 1 shows the most common themes. The most common theme was better enforcement including with CCTV. Improved public transport and parking were also frequently mentioned.
Theme Number of mentions in comments Better enforcement of current restrictions / 38 implement and utilise more CCTV Improve public transport 24 Provide better parking 22 Answered ‘no’ to the question 17 Introduce traffic calming solutions 9 Pedestrianise the area 7
Page 217 of 478 Too many traffic lights 7 Table 1: Themes for alternative options
11. 93 other comments were also received. Table 2 shows the comment themes. Better parking and enforcement were again high in the number of comments. There was also concern that local businesses would be affected because people could not park outside to visit or make deliveries to their premises.
Theme Number of mentions in comments Provide better parking options/tackle current 31 parking issues Proper enforcement needed 17 This will affect local businesses 13 Better public transport needed 9 Waste of money/money earning scheme 8 Plans don't go far enough 8 Table 2: Additional comments
12. A petition containing 65 signatories was received against the Wellington Street red route trial. The petitioners stated that they required more parking and a business friendly approach with the issues regarding theft, anti-social behaviour, littering and loitering especially after dark addressed along with more warden/police patrols in the area.
Windmill Road, Kimpton Road, Airport Way
13. 730 responses were received (724 online and 6 hard copies).
14. 594 (79%) do not agree with the proposal (Figure 3). Figure 4 shows the breakdown of the responses by audience. This shows that the majority of all types of audience were against the proposals however, the comments associated with responses and the feelings expressed at the drop in-sessions were mainly concerned with Kimpton Road. Furthermore the Bus Company and an affected Business MD have both submitted objective evidence to the consultation process regarding the continuing, inconsiderate parking along Airport Way.
Page 218 of 478 31, 4% 102, 14%
594, 82%
Yes No Don't know
Figure 3 Do you agree with the proposal to implement a red route in Windmill Road, Kimpton Road and Airport Way?
Other 2 31 1
Resident/business outside of Luton 2 55 2
Community/Volunteer organisation in 1 6 0 Luton
Businesses 10 50 4
Residents 82 449 25
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 4 Do you agree with the proposals to implement a red route in Windmill Road, Kimpton Road and Airport Way by audience
15. Consultees were asked if they had any alternative options to ease congestion, increase traffic flow and make the roads safer in Windmill Road, Kimpton Road and Airport Way. 377 comments were received. Table 3 shows the most common themes. The most common theme was that there was not a problem followed by more parking provision and traffic calming.
Theme Number of mentions in comments There isn't a problem 130 More parking provision is needed 57 Traffic calming needs to be looked at incl. 46 traffic lights, 20mph limit zones, cameras
Page 219 of 478 Local business will suffer from these proposals 36 Better enforcement is needed of current 33 restrictions Answered ‘no’ to the question asked 17 Table 3: Themes for alternative options
16. 333 other comments were also received. Table 4 shows the comment themes. Better parking and enforcement were again high in the number of comments. There was also concern that local businesses would be affected because people could not park outside their businesses to visit or deliver goods to them.
Theme Number of mentions in comments Local businesses will suffer 174 More parking provision is needed 36 There isn’t a problem 35 There should be better enforcement of the 19 current restrictions Table 4: Additional comments
Marsh Road, Leagrave Road, Dunstable Road
17. Due to the nature of this route the questions were asked for the individual roads. 1201 responses were received (1144 online and 57 hard copies).
Marsh Road
18. 792 (66%) do not agree with the proposal (Figure 5) for a red route in Marsh Road. Figure 6 shows the breakdown of the responses by audience.
78, 7%
323, 27%
792, 66%
Yes No Don't know
Figure 5 Do you agree with the proposal to implement a red route in Marsh Road?
Page 220 of 478 Other 3 2 0
Resident/business outside of Luton 7 7 1
Community/Volunteer organisation in 2 6 0 Luton
Businesses 13 97 11
Residents 277 646 63
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 6 Do you agree with the proposals to implement a red route in Marsh Road by audience
Leagrave Road
19. 843 (71%) do not agree with the proposal (Figure 7) for a red route in Leagrave Road. Figure 8 shows the breakdown of the responses by audience.
50, 4%
300, 25%
843, 71%
Yes No Don't know
Figure 7 Do you agree with the proposal to implement a red route in Leagrave Road
Page 221 of 478 Other 3 1 1
Resident/business outside of Luton 7 8 0
Community/Volunteer organisation in 2 6 0 Luton
Businesses 15 99 7
Residents 251 700 35
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 8 Do you agree with the proposals to implement a red route in Leagrave Road by audience
Dunstable Road
20. 802 (67%) do not agree with the proposal (Figure 9) for a red route in Dunstable Road, Bury Park. Figure 10 shows the breakdown of the responses by audience.
56, 5%
335, 28%
802, 67%
Yes No Don't know
Figure 9 Do you agree with the proposal to implement a red route in Dunstable Road?
Page 222 of 478 Other 3 2 0
Resident/business outside of Luton 7 8 0
Community/Volunteer organisation in 2 6 0 Luton
Businesses 17 97 7
Residents 284 660 42
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 10 Do you agree with the proposals to implement a red route in Dunstable Road by audience
21. Consultees were asked if they had any alternative options to ease congestion, increase traffic flow and make the roads safer in Dunstable Road, Leagrave Road and Marsh Road. 730 comments were received. Table 5 shows the most common themes. The most common theme was that more parking was required to alleviate the issues. Better enforcement and bus stop placement was also mentioned.
Theme Number of mentions in comments More parking needs to be provided to alleviate 100 parking issues Red routes will be bad for businesses in the area 63 generally Better enforcement of current restrictions are 57 needed This is a waste of time and money 47 Bus stop placements need to be looked at and 44 amended Answered ‘no’ to the question 43 The proposed red routes are a good idea 29 Bad for business - specifically regarding 17 customer parking Bad for business - specifically regarding 14 deliveries Table 5: Themes for alternative options
22. A petition containing 1791 signatures was received against the Dunstable Road, Leagrave Road and Marsh Farm red route as it will have a detrimental impact on local businesses and will not relieve congestion.
23. 392 other comments were also received. Table 6 shows the comment themes. Parking provision and enforcement was again high in the number of comments. There was also a lot
Page 223 of 478 of concern that local businesses would be affected because people could not park outside to visit or delivery them.
Theme Number of mentions in comments More parking needs to be provided to alleviate 96 parking issues Red routes will be bad for businesses in the area 69 generally Bad for business - specifically regarding customer 17 parking Bad for business - specifically regarding deliveries 14 Better enforcement of current restrictions are needed 50 This is a waste of time and money 45 Bus stop placements need to be looked at and 37 amended The proposed red routes are a good idea 31 Table 6: Additional comments
Goals and Objectives 24. To report the outcome of the informal public consultation and to seek approval to proceed as per the recommendations of this report.
Proposal 25. It is proposed to
a. Implement the Town Centre pilot scheme with minor modifications based on the comments received. The estimated cost is £165,000 including CCTV enforcement cameras purchase and setup costs.
b. Implement Airport Way only part of the pilot scheme. This would assist with the enforcement of the illegal and inconsiderate parking in the area and assist bus punctuality. The estimated cost is £40,000 (includes the purchase of CCTV enforcement cameras)
c. Put the other schemes on hold while the issues brought up in the consultation are considered (see paragraph 26) and implemented (as appropriate).
26. Further to proposal (c) above consideration of the following concerns:-
i) Kimpton Road - additional, short and mid-term parking near the shops, drop off area near Parkway Station, loading bay for deliveries to the shops and car hire/hotel. The estimated cost of the design works is £20,000.
ii) Marsh Road, Leagrave Road*,Dunstable Road - review of bus stops and consideration of installing bus stop lay-bys and additional parking/ drop off/loading bays. The estimated cost of the design works is £10,000.
iii) *Biscot Area – implementation of parking review. The estimated implementation costs is £35,000.
Page 224 of 478 27. The timescale for implementation should Executive approve the recommendations
• Completion of design, preparation of ETRO – August 2018 – November 2018 • Implementation of Airport Way red route – November 2019 • Implementation of Town Centre red route – January 2019 • Experimental TRO objection period and monitoring – 6 months from the date of Making the ETRO. • It is expected that design works described in paragraph 26 (i) and (ii) should be completed by January 2019. • Implementation of the Biscot Area parking review (once agreed) should be implemented by the end of March 2019.
Key Risks 28. The key risks of implementing red routes are:
• Red routes could be seen as draconian as they prevent stopping while the red line is operable other than for vehicles/drivers that have been specifically exempted in the Traffic Regulation Order. • The additional restrictions will require enforcement. If there is insufficient enforcement, drivers may continue to park illegally reducing the effectiveness of the red routes in improving traffic flow, bus punctuality and reducing injury road traffic collisions. • Parking is likely to be displaced into adjacent areas. 29. The key risks of not implementing red routes are:
• Continued congestion due to illegal and inconsiderate stopping and parking. • Continued issues with carrying out enforcement on foot to the extent that would be required to ensure a reduction in congestion. 30. If either no red route was introduced or all three pilot schemes were introduced there would be a risk to the Council’s reputation as these options would go against the wishes of the responders to the consultation.
Human Rights Implications 31. A public authority can interfere with such rights where interference is lawful and proportionate which, if engaged, is considered to be the case here due to the wider public interest in improving the highway network.
Crime and Disorder 32. In considering the Council’s duties under Section 17 of the Crime and Disorder Act there are no crime and disorder implications associated with the proposals.
Consultations 33. As detailed above.
Alternative options considered and rejected (please specify) 34. The following alternative options have also been considered but not recommended:-
Page 225 of 478 a. Not to proceed with the implementation of red routes. This would mean the status quo remains and would not alleviate any of the issues.
b. Progress with implementation of all proposed pilot schemes. This would mean ignoring the comments made by the public.
Appendices Attached Appendix A – Luton red route trial - consultation summary report (Enclosed for Members Only)
Appendix B - Integrated Impact Assessment
Background Papers Executive report dated 5 March 2018
Page 226 of 478 IMPLICATIONS
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated An ETRO is similar to a permanent TRO in that it Steven Sparshott 31st July imposes traffic and parking restrictions. An 2018 experimental order can only stay in force for a Solicitor maximum of 18 months while the effects of the traffic and parking restrictions are monitored and assessed (and changes made if necessary), before the traffic authority decides whether or not to continue the ETRO on a permanent basis.
Finance Clearance Agreed By Dated The estimated costs, as detailed in paragraphs 25- Darren Lambert, Finance 1st August 26, total £270,000. An additional £6,000 will be Business Partner 2018 required to monitor and review the pilot scheme.
£285,000 is available in the capital programme for 2018/19 for these works.
If the Executive decide not to support the Town Centre scheme, the overall cost would only reduce by £135,000 as a back office will still need to be set up at a cost of £30,000.
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated A integrated Impact assessment has been completed Maureen Drummond, 27th July and because drivers will not be able to stop or park Cohesion and Equalities 2018 on the roads involved except in designated areas the Adviser following groups will be disproportionately affected a) disability, b) age and c) pregnancy/maternity Environment Clearance Agreed By Dated The implementation and enforcement of Red Routes Keith Dove, Strategic Policy 27th July will improve traffic movement and reduce congestion/ Adviser 2018 vehicle idling in these areas, resulting in less vehicle pollution and CO2 emissions . It should improve the
Page 227 of 478 punctuality of public buses which indirectly could encourage more people to use buses and result in reduction in the use of the private car and contribute to further reductions in emissions. Health Clearance Agreed By Dated The implementation and enforcement of red routes Patsy Richards 3rd August should reduce obstructive parking on footways, Senior PH Manager 2018 which will positively impact on health through the encouragement of walking, cycling and public transport. Equally, the reduction in congestion and vehicle idling should result in less pollution and improve air quality. As a consequence of improvements the speed of traffic may increase; consideration should be given to the potential changes to road safety. Community Safety Clearance Agreed By Dated
Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
Page 228 of 478 APPENDIX A
Luton red route trials
Consultation summary report
Luton Borough Council Created by Document Reference: 4037 Sally Irving Date 18/06 [email protected] 0330 0080 855
Page 229 of 478
CONTENTS PAGE PAGE NO.
1. EXECUTIVE SUMMARY 2
Overview 2
Recommendations 2
2. INTRODUCTION 4
3. METHODOLOGY OF CONSULTATION 5
3.1 Respondent comments 5
3.2 Leaflet delivery 5
3.3 Drop-in sessions 8
3.4 Emails 8
3.5 Promotion of the consultation 8
3.6 Phone calls 8
4. CONSULTATION RESULTS 9
4.1 Town centre 9
4.2 Windmill Road, Kimpton Road, Airport Way 16
4.3 Marsh Road, Leagrave Road, Dunstable Road 23
Drop-in sessions 34
2 June, Bury Park 35
Emails 36
Phone calls 36
APPENDIX A – LUTON TOWN CENTRE COMMENTS 38
APPENDIX B – WINDMILL ROAD, KIMPTON ROAD, AIRPORT WAY COMMENTS 50
APPENDIX C – MARSH ROAD, LEAGRAVE ROAD, DUNSTABLE ROAD COMMENTS 80
APPENDIX D - EMAILS 126
APPENDIX E – EXTERNAL COMMUNICATIONS 137
QUALITY 140
© Project Centre Luton red route trials Page 230 of 478 1
1. EXECUTIVE SUMMARY Overview Residents, businesses and visitors to the local area were asked to give their views on proposed red route trials in response to illegal and inconsiderate parking on Luton’s main routes causing significant delays to traffic flow.
The consultation ran for four weeks between 11 May and 8 June 2018. In total, we received 2,159 responses to the consultation; these can be broken down by area:
228 Luton Town Centre responses
o 208 online responses
o 20 hard copy responses 730 Windmill Road, Kimpton Road, Airport Way responses
o 724 online responses
o Six hard copy responses 1,201 Marsh Road, Leagrave Road, Dunstable Road responses
o 1,144 online responses
o 57 hard copy responses Of the 2,159 responses, 10.6% were received for the Town Centre proposals, 33.8% were for Windmill Road, Kimpton Road and Airport Way and the majority (55.6%) were received for Marsh Road, Leagrave Road and Dunstable Road.
Recommendations Results summary
The results of this consultation are analysed in detail in section 4 of this report and all comments supplied by consultees can be found in the appendices. To summarise the main findings were:
Town centre – Over 60% of residents support the proposal to implement a red route trial in the town centre however over 50% of businesses disagree with the proposal.
Windmill Road, Kimpton Road and Airport Way - Over 80% of respondents do not agree with the proposal to implement a red route trial in this area.
Marsh Road, Dunstable Road and Leagrave Road – Over two-thirds (66%-71%) do not agree to trial a red route in this area.
Taking into consideration the responses received from the consultation and the conversations at the drop-in sessions we have listed below recommendations for each area.
Any schemes going forward should be implemented on an experimental order for 12 – 18 month trial which will allow comments between 6 – 18 months.
Town Centre
© Project Centre Luton red route trials Page 231 of 478 2
Go ahead with the scheme as proposed and include the following additions:
To ensure that businesses continue to function, they mentioned they required a short stay bay for quick drop offs of cash and deliveries. Therefore, we recommend that in addition to the proposal we will add two loading bays of ten minutes on Upper George Street which will not impact on the flow of traffic and allow businesses to function.
Stop the red lines before the day centre at 49-53 Alma Street, to allow them to load and unload disabled passengers outside their centre.
Marsh Road, Leagrave Road and Dunstable Road
Due to the amount of negative responses this trial should not go ahead yet. Looking at the distribution of the responses, the respondents near Dunstable Road agree with the proposal, however this is not reflected across the other areas. We suggest this is not taken forward until the other areas have been implemented and the benefits seen. This can be part of phase 2.
Windmill Road, Kimpton Road and Airport Way
There was a large number of comments from businesses regarding vehicles stopping/parking on Kimpton Road to access the local businesses and drop-off/pickup at the station. The current design does not reduce the parking levels in this area. However it is clear that the current level of parking is not working for the users. It is recommended that consideration is given to short stay bays on Kimpton Road. Further engagement is required with businesses on the plans. The trial of red routes can be implemented once this has been undertaken.
Implement Airport Way as proposed. Due to the narrow width of the road we are unable to provide any additional parking or loading bays.
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2. INTRODUCTION Luton Council (the council) has commissioned Project Centre to design, consult and implement three pilot red routes in Luton, followed by a review.
The council is seeking to reduce congestion on key roads. Red routes provide an unambiguous, clear and informative set of regulations that reduce stopping, waiting and parking either all day or at peak times.
As a strategic network tool to improve traffic management, red routes are to be implemented in three areas as a pilot scheme with a view for further rollout in the future on the strategic road network. The three routes are:
Town Centre
Windmill Road, Kimpton Road and Airport Way
Marsh Road, Leagrave Road and Dunstable Road
The project comprises of three phases:
Phase 1 – Scheme design and consultation
This includes design of the scheme, informal public consultation on the concept of the red route network and a report on consultation results
Phase 2 – Legal Traffic orders, implementation (subject to council approval)
This includes drafting Traffic Regulation Orders, Stage 1/2, implementation and Stage 3 safety audit.
Phase 3 – Review
This report documents all the responses received as part of the consultation in Phase 1.
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3. METHODOLOGY OF CONSULTATION 3.1 Respondent comments Over the three areas 2,062 comments were submitted either online or via hard copy responses filled out at the drop-in sessions in Luton or sent in by post.
3.2 Leaflet delivery 451 leaflets were delivered to households and businesses in the immediate area of the town centre proposal by council staff. 893 leaflets were delivered to households and businesses surrounding the proposals for Dunstable Road, Leagrave Road, Kimpton Road and Airport Way, and 315 for Marsh Road. Leaflets were delivered by council staff. Maps below.
Town Centre delivery area
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Kimpton Road delivery area
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Marsh Road, Leagrave Road and Dunstable Road delivery areas
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3.3 Drop-in sessions Five drop-in sessions were organised, advertised and attended between 22 May and 5 June in Luton as an opportunity for stakeholders to discuss the proposals with a member of the project team and ask any questions.
The locations of these sessions were St George’s Square, The Mall (x2), Bury Park Community Centre and Denbigh High School. Over 300 leaflets were given out at the sessions.
3.4 Emails An email address was provided on the leaflet and website. 28 emails were received via the PCL Luton consultation mailbox and to council staff regarding the scheme both supporting and opposing the trials. These emails can be found in Appendix D.
One email contains a petition from residents and businesses opposing the scheme, this can also be found in Appendix D.
3.5 Promotion of the consultation The council promoted the consultation and drop-in sessions twice on their Facebook page, resulting in 34 ‘shares’ and engagement via the comments section from stakeholders.
The consultation was linked to/from the council’s consultation portal and a news release was published on www.luton.gov.uk.
An article was featured in Luton Today on 4 June 2018 about local business owners being against the red route trials as they are worried they will go out-of-business from the proposals. https://www.lutontoday.co.uk/news/business-owners-on-kimpton-road-fear-red-routes-will-kill-our- shops-1-8520168. Similar articles also appeared in The Herald and The Post.
The council also sent posters to various community facilities including libraries, community centres and places of worship. Targeted emails were sent to the emergency services, transport providers and key businesses, as well as an email alert to 805 addresses. A full list is available in Appendix E.
3.6 Phone calls A dedicated phoneline was setup during the consultation. Two calls were received. Callers spoke about their concerns for a local business on Marsh Road/Icknield Road and the day centre on Alma Street.
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4. CONSULTATION RESULTS The following results section has been split into the three trial routes:
Town centre
Windmill Road, Kimpton Road and Airport Way
Marsh Road, Dunstable Road and Leagrave Road
Responses have been analysed for each section. It should be noted that not all respondents have answered all questions, where this is the case 100% equals the number of people who responded to the question.
4.1 Town centre Proposals for the town centre (within the area bounded by New Bedford Road, Telford Way, Dunstable Road and Wellington Street include all double and single yellow lines replaced by the equivalent red lines, existing loading, disabled and parking bay restrictions are to be retained. Although, a slight increase in the length of the parking bay in Wellington Street and new loading bays in Wellington Street and Peel Street are proposed.
The following section looks at the results from the consultation. There were 228 responses:
208 online responses
20 hard copy responses
Q1. In what capacity are you responding to this survey?
2, 1% 7, 3% 7, 3% 5, 2%
[VALUE], [PERCENTAGE]
181, 81%
Luton resident Luton business Luton resident & business Community/volunteer organisation in Luton Resident/business outside of Luton Other
Figure 1: In what capacity are you responding to this survey?
Figure 1 shows us that the majority of respondents were Luton residents (181), followed by 22 Luton businesses, seven people answered as an out-of-Luton resident/business and ‘other’ respectively, five
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(from hard copy responses) said they were a resident and a business within Luton and two responded as a community/volunteer organisation from Luton.
Q.2 What is your postcode? The maps below (figure 2) shows the spread of responses for the town centre red route consultation. The majority of responses have come from within Luton and the surrounding area with one response from a person living in Ipswich.
Figure 2: The location of respondents
Of the respondents who provided a postcode, 101 were from inside Luton and four were outside Luton.
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Q3. What mode of transport do you mainly use?
7, 3% 6, 3%
2, 1% 18, 8% 8, 4% 4, 2%
19, 8%
159, 71%
Car Bus Train Bicycle Taxi Walking Other Combination
Figure 3: What mode of transport do you mainly use?
From figure 3 we can see that the majority (159) of respondents’ main transport mode is a car, followed by 19 people who use the bus, 18 walk, eight cycle, four get the train, two said taxi and a further seven chose ‘other’. Other modes included lorry, minibus and work van.
Q4. Do you think implementing red routes in this area will help to: reduce congestion and increase traffic flow
make the roads safer
buses to run on time
The following three charts show the different responses for each question. Overall respondents agree that implementing red routes will help to reduce congestion, increase traffic flow, make the roads safer and help buses to run on time.
15, 7%
74, 33%
135, 60%
Yes No Don't know
Figure 4: Reduce congestion and increase traffic flow
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Figure 4 shows that 60% of respondents think that introducing red routes will reduce congestion and increase traffic flow, 33% did not agree with this statement and 7% did not know.
12, 5%
83, 37%
129, 58%
Yes No Don't know
Figure 5: Make the roads safer
The results in figure 5 show that 58% of respondents agreed that introducing red routes will make the roads safer, 37% disagreed and 5% stated they didn’t know.
38, 17%
112, 50%
74, 33%
Yes No Don't know
Figure 6: Buses to run on time
50% of respondents (112) think that introducing red routes will help buses to run on time, 33% (74) did not think this would be the case and 17% did not know (figure 6).
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Q5. Do you agree with the proposal to implement a red route in the town centre?
13, 6%
73, 32%
141, 62%
Yes No Don't know
Figure 7: Do you agree with the proposal to implement a red route in the town centre?
Figure 7 shows that the majority (62%) of respondents agreed with the plans to implement a red route in Luton Town Centre. 32% of respondents did not agree and 6% did not know.
Other 4 3 0
Resident/business outside of Luton 6 1 0
Community/Volunteer organisation in 1 0 1 Luton
Businesses 5 11 1
Residents 117 46 9
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 8: Do you agree with the proposal to implement a red route in the town centre by audience
Figure 8 breaks down the results to look at the responses by audience type. Most residents (68%) agree with trialling a red route in the town centre compared to 27% who disagree and 5% who are unsure.
The majority of businesses who responded do not agree with the proposal. Respondents from outside of Luton agree with the proposal, as do the ‘others’. The community and voluntary organisations are split.
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Figure 9: The location of respondents and if they agreed or disagreed with the proposal
The map above (figure 9) shows the respondents who provided a postcode and their response to if they agreed with the trial red route in the town centre. There is no specific location that is for or
against the scheme.
Q6. Do you think there is an alternative option to ease congestion, increase traffic flow and make the roads safer in Luton town centre?
Theme Number of mentions in comments Better enforcement of current restrictions / 38 implement and utilise more CCTV Improve public transport 24 Provide better parking 22 Answered ‘no’ to the question 17 Introduce traffic calming solutions 9 Pedestrianise the area 7 Too many traffic lights 7
Table 1: Themes for alternative options
For this question respondents submitted 137 comments through the online consultation (121) and hard copies (16). Full comments can be found in Appendix A.
Table 1 shows the most common themes in response to this question. The top theme (raised by 38 respondents, 27.7%) requested better enforcement of current restrictions, and six respondents asked for CCTV to be introduced to help with enforcement and discourage illegal practice. However, regulations do not allow yellow line waiting restrictions to be enforced by CCTV.
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The second most common theme (24 respondents - 17.5%) called for better parking provision in the area, improvements included building multi-storey car parks, creating more pay and display bays, and reducing/amending fees to encourage people to spend in the town centre.
22 respondents (16%) commented on the need for improvements to be made to the public transport system, including introducing trams, lowering fares and improving the bus priority network.
There were 17 comments (12.4%) in which respondents stated ‘no’ to this question ‘Do you think there is an alternative option to ease congestion, increase traffic flow and make the roads safer in Luton town centre?’.
Nine comments (6.6%) called for traffic calming solutions to be implemented.
Seven comments (5%) were received calling for areas along the route to be pedestrianised, a further seven comments felt that there are too many traffic lights and junctions which is causing the congestion mentioned in the consultation.
There were a number of comments which highlighted very specific views/ideas for how to achieve the aims of the scheme and as such these do not fall within the common themes. Other comments gave views on parts of Luton outside of the consultation area or said ‘probably not’/’yes, absolutely’ but did not offer anything more and as such these have also not been identified within the common themes.
Q7. Please use the space below to provide any additional comments on the proposals for Luton town centre.
Theme Number of mentions in comments Provide better parking options/tackle current parking 31 issues Proper enforcement needed 17 This will affect local businesses 13 Better public transport needed 9 Waste of money/money earning scheme 8 Plans don't go far enough 8
Table 2: Additional comments and themes
Respondents provided 93 comments, 81 via the online consultation and 12 through hard copy responses. Full comments can be found in Appendix A.
As shown in table 2, the area of most concern to respondents is parking in the town centre and that more parking is needed. 33.3% (31) of the comments received highlighted this issue. A number of these comments said the lack of parking will damage the local economy.
18.3% (17) of comments said the current parking restrictions are not enforced, and they should be. Respondents also said that drivers would continue to flout the rules as they do at the moment because they can get away with it (no enforcement).
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13 comments (14%) say that introducing red routes will negatively affect local business, some believe they will lose custom and have to close due to the lack of parking available for potential customers.
The need for better public transport provision appeared in nine comments (9.7%).
Eight respondents said that the scheme is a money-making exercise and a waste of public funds, and that the plans do not go far enough to combat the issue.
There were several comments in this section which cover one specific idea or nothing so are not captured within common themes, these include ‘that’s all’, ‘add Peel Street to plans’, and ‘try and get some better shops(…)’ etc.
4.2 Windmill Road, Kimpton Road, Airport Way Proposals for this area include all double and single yellow lines to be replaced by the equivalent red lines, parking bays will not be affected as a result of the proposed red route scheme however, there are changes being made as a result of the Eaton Green Heights development. There are currently no existing loading bays and none were proposed for this area. Existing disabled and taxi bays will remain.
The following section looks at the results from the consultation. 730 responses were received for Windmill Road, Kimpton Road and Airport Way:
724 online responses
Six hard copy responses
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Q1. In what capacity are you responding to this survey?
34, 5% 59, 8% 7, 1%
66, 9%
558, 77%
Luton resident Luton business Community/volunteer organisation in Luton Resident/business outside of Luton Other
Figure 10: In what capacity are you responding to this survey?
We can see from figure 10 that the vast majority (77%) of respondents identified themselves as Luton residents, followed by Luton businesses (9%), 8% were residents/businesses outside of Luton, 5% selected ‘other’ and 1% were a community/volunteer organisation in Luton.
Q2. What is your postcode?
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Figure 11: Responses by location
Figure 11 shows that of the respondents who provided a postcode 320 were from inside the Luton boundary and 38 outside.
Q3. What mode of transport do you mainly use?
6, 1% 8, 1% 7, 1% 17, 2% 2, 0% 6, 1% 25, 4%
653, 90%
Car Bus Train Bicycle Taxi Walking Other Combination
Figure 12: What mode of transport do you mainly use?
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The majority of respondents (90%) selected a car as their main mode of transport, as seen in figure 12. This was followed by bus (4%), ‘other’ 2% and train, bicycle, taxi and walking accounted for between 0-1% each. Two respondents who sent in a hard copy chose more than one type of transport, labelled as “combination” in Figure 12.
Q4. Do you think implementing red routes in this area will help to: reduce congestion and increase traffic flow
make the roads safer
buses to run on time
The following three charts show the different responses for each question. Overall respondents disagree that implementing red routes will help to reduce congestion, increase traffic flow, make the roads safer and help buses to run on time.
31, 4% 125, 17%
568, 79%
Yes No Don't know
Figure 13: Reduce congestion and increase traffic flow
Figure 13 shows that the majority of respondents (79%) disagreed that introducing red routes would reduce congestion and increase traffic flow, 17% agreed with this and 4% of people did not know.
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41, 6% 102, 14%
581, 80%
Yes No Don't know
Figure 14: Make the roads safer
80% of respondents believed that introducing red routes would not make the roads safer, 14% of people agreed and 6% didn’t know (figure 14).
92, 13% 98, 13%
534, 74%
Yes No Don't know
Figure 15: Buses to run on time
Figure 15 shows that 74% of respondents disagreed that introducing red routes would allow buses to run on time, 13% agreed and 13% were unsure.
Q5. Do you agree with the proposals to implement a red route along Windmill Road, Kimpton Road and Airport Way?
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31, 4% 102, 14%
594, 82%
Yes No Don't know
Figure 16: Do you agree with the proposals to implement a red route along Windmill Road, Kimpton Road and Airport Way?
The majority of respondents (82%) did not agree with the proposals to implement a red route along Windmill Road, Kimpton Road and Airport Way. 14% agreed with proposals and 4% of respondents weren’t sure (figure 16).
Other 2 31 1
Resident/business outside of Luton 2 55 2
Community/Volunteer organisation in 1 6 0 Luton
Businesses 10 50 4
Residents 82 449 25
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 17: Type of respondents and their opinion on the scheme
Figure 17 shows that the majority of all types of respondents disagree with the proposal for this area, this included 81% of residents.
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Figure 18: Location of respondents and their opinion on the proposal
Figure 18 looks at the results within Luton and those closest to it and shows the spread of those that agree and disagree with the proposal. There is a blanket opinion of disagreement with the proposal.
Q6. Do you think there is an alternative option to ease congestion, increase traffic flow and make the roads safer in this area?
Theme Number of mentions in comments There isn't a problem 130 More parking provision is needed 57 Traffic calming needs to be looked at incl. traffic lights, 46 20mph limit zones, cameras Local business will suffer from these proposals 36 Better enforcement is needed of current restrictions 33 Answered ‘no’ to the question asked 17
Table 3: Alternative options
Respondents provided 377 comments for the above question, these were received via the online consultation (375) and a further two were from hard copy responses.
Table 3 shows that of the 377 comments; 130 (34.5%) stated they did not believe there was congestion in the area as stated in the leaflet.
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The second most common theme was that more parking is needed in the area, 57 comments referenced this (15.1% of the comments in this section). 12.2% of the comments called for more traffic calming options to be implemented in the area, such as traffic lights, lower speed zones, enforcement cameras.
The view that local businesses will suffer came up in 9.5% of the comments for this question (36 comments). In 33 comments (8.6% of comments) respondents expressed their view that the current restrictions should be enforced better.
17 comments (4.5%) answered ‘no’ directly to the question being asked, ‘Do you think there is an alternative option to ease congestion, increase traffic flow and make the roads safer in this area?’.
There were a number of individual, unique comments that were not captured under the common themes, some relative to the scheme, some not such as “people don’t know how to drive”.
Q7. Please use the space below to provide any additional comments on the proposals for this area.
Theme Number of mentions in comments Local businesses will suffer 174 More parking provision is needed 36 There isn't a problem 35 There should be better enforcement of the current 19 restrictions Table 4: Additional comments
This section of the consultation received 333 comments, most from the online consultation (330) and three via hard copy responses.
Table 4 shows that the most common theme for this question was that local businesses will suffer if these plans are implemented, over half (52.3%) of the comments.
Similarly, to table 3, 10.8% of respondents (36 comments) said that more parking is needed in the area and approximately the same said there isn’t a problem with congestion in the area (10.5%, 35 comments). 19 comments said that the respondent felt there should be better enforcement of the current restrictions.
A number of comments were specific and the idea was only held by one or a few comments, other comments were not about the consultation area and some offered no view, these comments are not captured by common themes. These comments include ‘no comment’, ‘why try and cut off a new community?’, ‘I agree’ etc.
4.3 Marsh Road, Leagrave Road, Dunstable Road Proposals for this area include all double and single yellow lines to be replaced by the relevant red lines, existing parking bays and restrictions will be kept in this area and additional parking bays will
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be provided. Existing loading bays will also be kept. We received 1,201 responses for Marsh Road, Leagrave Road and Dunstable Road responses:
1,144 online responses
57 hard copy responses
Q1. In what capacity are you responding to this survey?
8, 1% 8, 1% 16, 1% 6, 0%
133, 11%
1018, 86%
Luton resident Luton business Luton resident & business Community/volunteer organisation in Luton Resident/business outside of Luton Other
Figure 19: In what capacity are you responding to this survey?
Figure 19 shows that the majority of respondents (86%) identified as Luton residents, followed by Luton businesses (11%), with the remaining respondents (Luton resident and business, community/volunteer organisation in Luton, resident/business outside of Luton and other) accounting for 0-1% in each category.
Q2. What is your postcode?
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Figure 20: Location of responses
Figure 20 shows that of the respondents who provided a postcode, 302 were from inside Luton and seven outside. Q3. What mode of transport do you mainly use?
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14, 1% 12, 1% 16, 1% 9, 1% 58, 5% 5, 0% 65, 6%
1010, 85%
Car Bus Train Bicycle Taxi Walking Other Combination
Figure 21: What mode of transport do you mainly use?
Figure 21 shows the main mode of transport respondents used was a car (85%), the second most popular choice was bus (6% of respondents), 5% chose walking and between 0-1% accounted for each of the following: train, bicycle, taxi and other. 16 respondents chose a combination of transport types on their hard copy response.
Q4. Do you think implementing red routes in this area will help to: reduce congestion and increase traffic flow
make the roads safer
buses to run on time
31, 3%
321, 27%
837, 70%
Yes No Don't know
Figure 22: Reduce congestion and increase traffic flow
70% of respondents disagreed that introducing red routes would help reduce congestion, as seen in figure 22, 27% agreed and 3% were not sure.
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71, 6%
287, 24%
831, 70%
Yes No Don't know
Figure 23: Make the roads safer
Figure 23 shows that 70% of respondents also disagreed that introducing red routes would make the roads safer, 24% agreed and 6% weren’t sure.
124, 10%
291, 25%
774, 65%
Yes No Don't know
Figure 24: Buses to run on time
Of the respondents, 65% disagreed that introducing red routes would enable buses to run on time, 25% of people agreed and 10% were unsure (figure 24).
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Q5. Do you agree with the proposals to implement a red route along Marsh Road?
78, 7%
323, 27%
792, 66%
Yes No Don't know
Figure 25: Do you agree with the proposals to implement a red route along Marsh Road?
Figure 25 shows that 66% of respondents disagreed with the proposals to implement a red route along March Road, 27% agreed and 7% said they didn’t know if they agreed.
Other 3 2 0
Resident/business outside of Luton 7 7 1
Community/Volunteer organisation in 2 6 0 Luton
Businesses 13 97 11
Residents 277 646 63
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 26: Opinion on proposal broken down by audience
Figure 26 shows that the majority of residents, business and community/voluntary groups within Luton disagree with the proposal. There is a 50/50 split from residents/businesses outside of Luton and the ‘other’ category marginally agree with the proposal.
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Figure 27: Responses by location for Marsh Road
Figure 27 shows the response type by location, from those that provided a postcode. This shows that location doesn’t have an effect on the response, there is blanket negativity towards this proposal.
Q6. Do you agree with the proposals to implement a red route along Leagrave Road?
50, 4%
300, 25%
843, 71%
Yes No Don't know
Figure 28: Do you agree with the proposals to implement a red route along Leagrave Road?
Figure 28 shows that 71% of respondents do not agree with the proposal to implements a red route along Leagrave Road, 25% agree and 4% did not know.
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Other 3 1 1
Resident/business outside of Luton 7 8 0
Community/Volunteer organisation in 2 6 0 Luton
Businesses 15 99 7
Residents 251 700 35
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 29: Opinion on proposal based on audience response
Figure 29 shows that the majority of all respondent types disagree with the proposal. However, the ‘other’ category agree with the proposal.
Figure 30: Location of responses for Leagrave Road
Figure 30 shows that location does not have a bearing on the response. There is blanket coverage against the proposal.
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Q7. Do you agree with the proposals to implement a red route along Dunstable Road?
56, 5%
335, 28%
802, 67%
Yes No Don't know
Figure 31: Do you agree with the proposals to implement a red route along Dunstable Road?
Figure 31 shows that 67% of respondents do not agree with the proposals to implements a red route along Dunstable Road, 28% agree and 5% did not know.
Other 3 2 0
Resident/business outside of Luton 7 8 0
Community/Volunteer organisation in 2 6 0 Luton
Businesses 17 97 7
Residents 284 660 42
0% 20% 40% 60% 80% 100%
Yes No Don't know
Figure 32: Audience type and response
Figure 32 shows that all audience types, apart from ‘other’ respondents, disagree with the proposed trial red route.
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Figure 33: Locational response to the proposal for Dunstable Road
Figure 33 shows that a respondent’s location does not have a bearing on their response. Overall, respondents across Luton do not agree with the proposal.
Q8. Do you think there is an alternative option to ease congestion, increase traffic flow and make the roads safer in this area?
Theme Number of mentions in comments More parking needs to be provided to alleviate parking 100 issues Red routes will be bad for businesses in the area generally 63 Better enforcement of current restrictions are needed 57 This is a waste of time and money 47 Bus stop placements need to be looked at and amended 44 Answered ‘no’ to the question 43 The proposed red routes are a good idea 29 Bad for business - specifically regarding customer parking 17 Bad for business - specifically regarding deliveries 14
Table 5: Alternative options
The above question received 730 comment responses, 703 of these were via the online consultation and a further 27 were from hard copy responses.
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Table 5 shows that the most common recurring theme is that the Council should provide more parking, 100 comments referenced this (13.7% of the total comments in this section).
63 comments (8.6%) said that implementing red routes would be bad for local businesses in general, there were 17 responses that (2.3%) specifically mentioned loss of business would be caused by a lack of parking for customers, 14 (1.9%) said that business would suffer with receiving deliveries.
7.8% of respondents (57 comments) felt that better enforcement was needed of the current restrictions along the routes. 6.4% felt the red routes scheme would be a waste of time/money (47 comments). Bus stops and their placement should be reviewed/amended was mentioned by 44 respondents (6%).
43 comments (5.9%) gave the answer ‘no’ to the question asked of ‘Do you think there is an alternative option to ease congestion, increase traffic flow and make the roads safer in this area?’.
However, there were 29 comments (4%) in support of the scheme.
There were comments in this section which have not been captured in these themes for reasons such as they are the only one or one of very few to express a view, the response is not related to the consultation or the response does not make sense. These comments include ‘yes’, ‘Lots of options’, ‘traffic will just go elsewhere’, a comment of just emojis etc.
Q9. Please use the space below to provide any additional comments on the proposals.
Theme Number of mentions in comments More parking needs to be provided to alleviate parking issues 96 Red routes will be bad for businesses in the area generally 69 Bad for business - specifically regarding customer parking 17 Bad for business - specifically regarding deliveries 14 Better enforcement of current restrictions are needed 50 This is a waste of time and money 45 Bus stop placements need to be looked at and amended 37 The proposed red routes are a good idea 31
Table 6: Additional comments
We received 392 comments on this question, 369 were from the online consultation and 23 via hard copy responses.
Table 6 shows that similarly the most common theme (24,5%, 96 comments) was that more parking is needed in the area and that there are parking issues throughout the consultation area.
The affect introducing red routes will have on businesses was another common recurring theme with 69 comments (17.6%), 17 comments (4.3%) specifically mentioned the lack of customer parking and 14 (3.5%) mentioned that red routes would affect their business’ deliveries.
12.8% of comments (50 comments) referenced the current restrictions which are in place need better enforcement, which could target the issues currently being experienced. 45 respondents (11.5%) expressed their opinion that the scheme was a waste of time and money.
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Bus stop placements and movement which has occurred in recent years was commented on by 37 consultees (9.4%), with people expressing that bays are needed for buses to pull into rather than stopping in the road.
7.9% of comments (31 comments) expressed views that they thought implementing the red routes was a good idea.
A number of comments are not captured in the common themes for various reasons such as they offer very specific ideas/views which have not been included by many/any others, the comment does not relate to the proposals. Comments include ‘no’, ‘who ever came up with the idea of red routes does not actually live in Luton’, ‘this proposal is 20yrs too late’ etc.
Drop-in sessions There were five drop-in sessions held across the borough throughout the consultation period. Attendees to the sessions brought up the following topics/concerns:
May 22, Central Library
Town Centre
o Businesses are concerned about contractors dropping off keys, money deliveries etc. on Upper George Street
o Residents and businesses said there is no congestion on these roads, so red routes are not needed
Marsh Road, Leagrave Road, Dunstable Road
o Local residents and businesses are quite upset regarding a previous scheme that was implemented by the council regarding paving, parking bays, lighting etc. which was a big investment
o The local community recognise that there is congestion in the area but feel that the scheme would reduce parking
o Near the Biscot area there is a venue that hosts weddings every weekend with 300 guests, there are concerns that they will park on the side streets
Kimpton Road, Windmill Road, Airport Way
o Local businesses feel the red route will kill businesses in the area and are campaigning against it
o There is a walkway between Kimpton Road and Luton Airport Train Station and locals drop off and pick up on Kimpton Road, near this walkway
30 May, The Mall
This session was heavily attended and was mentioned on local radio the morning of the event.
The Pickle and Sandwich shop, a business on Kimpton Road, stated that people pop in for a minute, grab sandwich and drive off and they want their customers to be able to carry on as
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such. They do not think that bays are used by customers but by those who are parked there all day
The business ‘Creams’ (near Wellington Street) would like more pay and display parking for customers as business is already suffering. They open after lunch and believe the area needs to be more attractive to increase footfall
Red routes are needed more on Dunstable Road than Marsh and Leagrave Roads
Road users queried the enforcement or red routes vs current restrictions
2 June, Bury Park This event was well attended and had the maximum turnout across all the sessions. There was a mixed responses from attendees, with residents generally being in favour and businesses against.
A number of businesses said that buses stopping are the cause of congestion
It was voiced by residents that businesses were the cause of congestion, giving an example of an emergency vehicle taking 20/30 mins to pass through and they had photos to prove cars park on single and double yellow lines blocking traffic
‘No to red route in Luton’ social media group
Attendees said a petition against Marsh, Leagrave, Dunstable red routes and wanted to extend the deadline for the consultation as Luton has a high proportion of Muslim’s many of which do not have access to the internet. There was also a language barrier and the consultation was being held during the period of Ramadan.
o https://www.change.org/p/luton-borough-council-petition-to-stop-the-proposed-luton- red-routes-in-marsh-rd-leagrave-rd-dunstable-rd
The tragic incident where a toddler was killed in a bus incident in 2014 in Bury Park was brought up attendees, who said that the police decribed the area at the time as ‘very busy’
Businesses made numerous references to a previous scheme where Dunstable Road had three lanes lessened to two and laybys removed
4 June, The Mall
This session relied on footfall in the Mall. Attendees were interested in the proposals and the majority were in support of the proposals. Residents were in support of the proposals and businesses against.
Many consultees were elderly and pensioners who relied on public transport day-to-day and were happy to hear that the red route would likely increase efficiency in public transport service. Suggestions to consider a drop-off area at the Luton Station entrance for vehicles dropping off commuters/passengers.
Quite a few people unaware of the proposals, although many lived outside the consultation areas such as High Town.
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Councillor mentioned of businesses in the Kimpton Road area campaigning against the red route due to the adverse effect of proposals on businesses in this area.
Business owner said businesses would struggle and requested for lay-bys for bus stops.
5 June, Denbigh High School
This was a quiet session with few attendees. A mix of people for and against the scheme.
A few people suggested there had not been enough advertising of the consultations
Requests for consultation period to be extended
Local business owners, including from the Post Office, expressed their concerns
It was put forward that the “gyratory” on Leagrave/Dunstable Road has a car park (and shops in it) that should be looked into to prevent queuing out onto the road
Emails We received 28 emails during the consultation (Appendix D). The following sets out the interest in each area:
Town Centre – a petition has been received by the businesses on Wellington Street objecting to the red route with 66 signatures with the reasoning behind this being ‘businesses will suffer and require more parking’. There is a voluntary organisation operating at 49-53 Alma Street and the proposals currently stop outside their centre. Other reasons cited against was businesses would struggle and that it is not required.
Windmill Road, Kimpton Road and Airport Way – reply was strongly against; cited that it was not needed and businesses would struggle with a red route. An article was published in the local newspaper against the red routes, this was driven by local businesses. A letter against Airport Way has been received by one business.
Dunstable Road, Leagrave Road and Marsh Road – mixed response for/against slightly leaning more towards FOR. Reasons FOR has been cited as parking congestion on the main roads holding up traffic and creating hazards and parking leaving HGV’s no option but to reverse on to the main roads; main reason was cited to irresponsible parking in the area. Reasons against cited as the red routes would encourage speeding and affect businesses. A resident at 310 Leagrave Road has asked for a bus stop relocation from outside their property to further down.
The Council received two petitions against the trial red routes; one was against the Wellington Street red route trial which has 65 signatories, and one was for the Buy Park area (Dunstable red route trial) which had 1,791 signatories.
Phone calls Two phone calls – one for Leagrave Road area from a car dealership at the junction of Marsh Road/Icknield Road who would be unable to take deliveries of vehicles with the current red route proposals. The other call was related to a day centre on 49-53 Alma Street which has been addressed below under ‘Town Centre’.
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Appendix A – Luton Town Centre comments
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Do you think there is an alternative option to ease congestion, increase traffic flow and make the roads safer in Luton town centre? Please use the space below to tell us what you think.
Unedited responses below. Upper George does not suffer from congestion or decrease in traffic flow. However some roads may need better parking management. YES - if you actually enforced parking controls that are already available. I am utterly sick to death of trying to drive up cumberland street with everyone parked on the double yellow lines (you try drive up they give you evils - i work up there so have to drive it every day) people parked fully on the pavement in cutenhoe, at the corner of junctions, one of the worst is people parking in the road right by the roundabout on whipperly way (they park in the left lane so you have to swing round them to go left). If we enforced the rules as in the highway code - not parking over peoples drop kerbs, not parking on corners, not parking on double yellow lines - not fully parking on the pavement - then the traffic would run better EVERYWHERE. If we can’t enforce the measures we already have what difference will red routes make? Allow cars use the useless pointless buslane from luton to Dunstable You would need a warden on Wellington Strreet all the time to stop people parking on the pavement on the double yellow side hopefully people would be less likely to park on red lines if not then tow them I support the red route per se, however, I KNOW you don’t have the resource to police it, nor will you have. The areas are covered by double yellows at present and you can’t keep control, certainly not of Wellington St, as you don’t have the resource. While a warden is at the top of Wellington St, they are needed at the bottom. You could station someone there all day and still not stop it. Put bollards up. Or police it with cameras. The proposal goes too far. Red routes are suitable for main arterial roads to keep traffic flowing. There are small businesses on a lot of these routes that will need to be serviced with deliveries which do not seem to have been considered. By reducing public service rates No cars allowed in the town centre more expensive parking ticket fines and cctv to send tickets via post NO Increase of control, clamping illegally parked vehicle’s, increasing parking charges to encourage people to use public transport. Increased number of loading bays in sensible spots to prevent people using wherever for loading. Either a good park and ride site or increased bus priority measures only better enforcement or completely pedesrianise wellington st Only to pedestrianise Wellington Street Only have loading bays and some disabled bays in town centre- re/ move all on street parking out of town centre. Review traffic flow and make certain streets one way. Place bollards / block vehicular access to certain roads in town centre to reduce parking/ people stopping to get takeaway food. Heavily enforce people driving onto square area Better public transport No Get rid of the one way system,open up more of the access roads, remove traffic lights from roundabouts. Remove the pedestrian walkways around the town centre. Remove the one way streets. Make the roads wider. no Having red routes is not the answer . maybe more traffic wardens would help. U get people sitting in cars waiting for people to arrive. Having a drop off point in the town center would be helpful. This to be used for people that are collecting people from work. Reduce the number of traffic lights in the one way system in town. There’s too many traffic lights if you go around the one way system which reduces the flow of traffic. Reduce bus fares to try and encourage people to use public transport. Clamp down on
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illegal parking, (taxi drivers have been parking on yellow lines in Mill Street for years and getting away with it) More traffic wardens and make them more prominent, if possible (and legal) clamp offending vehicles. No. Drivers ignore virtually all other restrictions. introduce a park and ride system Cameras on road to ticket those who double park Please can you ban parking all four wheels on the pavements Increase use of public transport Yes definitely Need more parking and more of the town centre pedestrianised. Bollard to stop cars parking on already pedestrianised area, which are currently being used by cars. Block the bottom end of Wellington street off to the public. Further enforce parking tickets, clamping, etc. to sanction drivers that illegally park or make roads more dangerous to cross or drive on. No more traffic wardens ,CCTV Cameras and new technology No No alternative.
REDUCE BUS FARE, QUALITY/CONDITION OF BUS, MAKE ROAD MORE PEDESTRAIN AND CYCLE FRIENDLY, PARK AND RIDE, BETTER SINAGE, MORE CCTV IN ROAD TO MAKE IT SAFE FOR PEOPLE TO WALK We have reported illegal parking in Alma Street (usually visiting the dentist opposite our building) and also speeding round the corner of Upper George Street into Alma Street (sometimes racing and going round several times) I think these issues also need enforcing as well as Red Routes. Change the school run time. If schools opened at different times this would allow more freedom off traffic.Rather than having the whole town commuting at the same time.I.S schools open earlier this would parents to drop of kids on the way to work. Or have schools open later once the work commute has dissipated . A congestion charge can help keep the town free of traffic. No congestion charge after 10.00 am till 3pm. More enforcement against inconsiderate drivers Yes the planning of traffic flow is very poor around Luton - larger one way systems should be considered e.g. stockingstone road and Hitching road, plus the bus route should be opened to traffic. There should be more targeted prevention by street wardens and potentially higher charges for repeat offenders. Police should take action over wild drivers More visible traffic wardens who should not be afraid to confront certain businesses who constantly ignore the rules/laws Abolish the one way system as roadworks and/or accidents bring the route to gridlock I think that the council should be really radical and that we should have a car free zone (with shuttle buses for those who cant walk) around the town centre – more people would fill this space if we did this and it would therefore make it safer (less crime, less antisocial behaviour) for everyone as well as encouraging people to walk more. I know that this isn’t going to happen, but design and planning decisions can make a very real difference to people’s lives – “designing community in”. There is some evidence around Luton that supports my view: • When it snows and people have to walk, the sense of community is amazing – everyone seems to want to have a chat or at least say hello or comment on the weather. I know the unusualness of the weather is a factor in this case, but so is the fact that people are out of their cars and in the same space as each other. • The cycleway that runs along the busway – it is always full of people. They put it there, it is easily accessible to a large amount of Luton residents and it is a safe, off-road space …… and the people came – cyclists, dog walkers, joggers, people walking to work, families out for a walk, people using disability scooters (not many of the latter, perhaps it should be marked –
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and marketed - as being disability friendly?). A less radical alternative would be park and ride! More buses Yellow box junction Hatters way / Dunstable Road junction and Dunstable Road / Telford way roundabout similar to Telford Way New Bedford Road ‘Roundabout’ Having to come right into the centre of town - and only from the right direction - to park is ludicrous. Luton is now big enough that a park and ride could be considered. Simply enforce the existing restrictions Introduce more box junctions at busy junctions and roundabouts to allow better traffic flow. Some of the roads proposed for the red route are not bus routes, and are not particularly busy. It may be useful to increase restrictions on the main roads: Stuart, Guildford, etc., but not on the side streets between these. Temporary stopping to load/unload, pick up/leave people (not only by taxis), etc., doesn’t cause obstruction these. Clearing the main streets would also mean that traffic would preferentially use these. Increase and reduce the cost of parking at the existing sites therefore reducing the need to park in inconsiderate ways Stop putting in all the one way areas. More car parks....multi storey. The congestion zone is always there in Luton town centre , it’s all the stationary traffic. Impose a charge for cars coming into town centre, say before 10.30 Make more free or cheaper parking spaces available. Maybe reduce carpark fees to 50p for the first hour then normal fees after that. That way the ‘pop in’ shopper can park in a safe area. I think it’s a good idea. The congestion is almost entirely caused by unnecessary and badly-sequenced traffic lights. Many could be replaced by mini-roundabouts. The rest must be simplified to a simple 2-way cycle, banning right turns if necessary. Also, re-open as many closed Town Centre roads as possible. Enforcement of no stopping, no parking. more vigilant policing of area Whats the worst that can happen A better permit parking system for residents In relation to Dunstable road and the area of bury park rather then implementing a red route it would be more beneficial to redesign that section. The need for a metre wide central area is not required. Removing this would create a wider space for the cars. Also the many shops are using space outside their permitted area. I understand there are fines where there is a contravention but it is rarely enforced. Some say there is a private agreement between the shops and the enforcers here. Enforcing this with camera evidence would together with removing the central reservation will buy a lot of space and reduce traffic. Raised kerbs to stop the parking on pavements employ more enforcement and get more wardens on the street. Engage real street police with powers as many problems happen through selfish drivers too lazy to think of others that get away with it through no enforcement. You should look carefully at existing routes and the daft junctions you have constructed. No, I don’t reduce the number of cars on the road Increase cycling, walking and using buses. This reduces the number of cars and the number of cars parked on road, Enforce the existing parking restrictions; there is no need for red routes. Probably not More traffic wardens Reason for proposal is given as ‘illegal and inconsiderate parking on Luton’s main routes is causing delays...’. But many of the roads included (for example Grove,Liverpool, Cardigan) are not main roads. I use some regularly, and have never been obstructed by parking. They are not bus routes. There is no illegal parking along the dual carriage way section of Dunstable Road, which is a bus route, so the proposal has nothing to do with the problem. The problem is on the single carriage way section of the Dunstable Road.
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Luton road planing is not good and your traffic lights timing make traffic worst Re assess the traffic light phases. Put a ‘right filter’ from Crescent Rd into Hitchin Road. Synchronise the busway lights with Hucklesby Way/Crescent Rd lights. No Tram Also there should be bus bays in Bury Park and all over the town More roads from selbourne road joining onto leagrace road. That will refuce traffic into bury park. Automatic ticket for vehicle parked restricting traffic infront of Aa carpets.
No less cars You need to stop the shops in bury park area from taking deliveries with massive lorries They should have storage away from this area and bring deliveries in small compact vans Shops like Haji & Sons also always storing their cardboard rubbish rotten fruit and bins on public pavement and road Blocking parking and ease of getting in and out of ivy road etc Council Is to blame Also make ivy road only residents parking Remove the pay&display option Make a bus lay by Provide drop off and pick up zones The pedestrianised area next to St George’s Square is also a problem for unauthorised parking late at night - as is Bute Street. Enforcement. Most of the proposed Red Routes for the town centre already have parking restrictions. These are often ignored and are rarely enforced. Nothing will change in this area if enforcement does not improve. Yes the buses block my way of riding a bike and are the real reason why there is so much traffic. The red route will not do anything. There needs to be less bus stops and better locations for them to park rather than in the middle of the road Introducing red routes is not likely to make the roads safer. “Opening up” routes in this way will only give carte blanche to the pre-existing petrol heads to go even faster than they already do around the town centre circuit. Witness their behaviour of an evening after about 21.00 hours.. Yes there is congestion but there is also a lack of enforcement of current restrictions, witness all the cars parked on lines in Wellington Street. Better Traffic Light control at the junction of Hitchin Road and Crescent Road More parking bays Stop Eastern Europeans without GB licence plates taking advantage and flouting parking laws. Tow their cars away. Opening bus way for normal traffic Congestion is only a factor during rush hour. and Saturday morning. Public transport is the answer but there is no incentive to use it. I have rarely seen congestion resulting from poor parking. The only effective modern way to reduce congestion is to reduce the amount of cars. less cars more buses Try implementing the traffic restrictions that are in place already. Fixed penalties for entering the yellow boxes in the town would encourage compliance. The traffic signals are not properly co-ordinated. A frequent occurrence is cars blocking roads because they have a green light, but no exit to the junction, so they cause chaos. A red route won’t help that, it will make it worse. More carpeting will help No Minimise pedestrian and vehicle conflict. Close the Wellington Street for a car traffic except for loading and taxis. enforcement of present restrictions is what is needed and a better traffic management eg All traffic coming down hitchin road and crawley green road have to go through town or
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around the ring road to the bottleneck at telford way.new Bedford road . Who bright idea was that? Create more parking spaces on the side roads, have better visible parking signs. Cheaper parking options An enforced yellow box junction at Hitchin / Midland road with better phased traffic lights to smooth out traffic flow. It’s very congested around the station area being a major cross town route, stop cars from illegal and dangerous parking causing serious issues for buses and cars. Look at introducing lower car parking charges for short term parking. At the moment town centre parking is expensive for shoppers who only want to park for 10-30 minutes. Lower cost (maybe 50p / 30 mins) might encourage people to park and shop Properly monitor and enforce the yellow cross-hatch junction at New Bedford Road/ Telford Way (near the railway bridge) Stop people parking on double yellow lines as it blocks roads and creates congestion Add speed bumps and pay and display for visitors Wheel clamping and tow truck on site/on call - camera for visual and to notify tow truck/clampers 3 points : to use a “lollipop” style road sign for the give way after the zebra crossing giving way to traffic on Gordon St. there are near misses on this junction EVERY day because Upper George St think they have right of way (strait road, no signage apart from on floor on an already busy rad layout) 2nd point : limit the size of vehicular that can come down Dunstable Place as we often have huge removal vans etc trying to turn left on to Upper George St and having to mount the pavement to get round. 3rd Point . Some form of traffic calming to stop the town center being used as race circuit for super car/ bike “celebration show offs” ( cars hired for the day and then driven at speed in build up areas) INCREASE CAR PARK SPACES AND TIME ALLOWANCE Improve local transport options There is no problem along the proposed route in the Town Centre. Wellington Street causes problems because of irresponsible parking, which is where the the problem should be solved. I do not see a congestion problem in this area More traffic wardens to enforce current yellow lines Think about road users and cater for their needs; provide loading bays 4 all to use, affordable parking in close proximity to amenities/shops, enforce traffic regulation breaches. I think you need to have better parking facilities around luton and cheaper Luton is not as congested as London we have double yellow lines implemented enough in Luton including road humps etc Better public transport So far council road improvements are a mess , example Crawley green road and round about say no more Need More parking spaces and loading bays provided. Free car parking and bus bays 20 mph speed limits on some roads Stop traffic parking on the curb Ban all traffic from entering the centre from 8am till 6pm No, we are a business on Gordon St, bend too tight for buses to turn and always pedestians on bend so bus has to stop and because taxis stop in Middle Street to pick up and if red lines all business will close More hump on Wellington Street to reduce the speed traffic and it will help run smoothly. Cars, buses and lorries go too fast here and needs spped humps or traffic lights near the church as it is hard to cross the road for public to get to the other side, as other wise one has to walk up to where the lights for traffic and the cross the road when traffic light changes Fix the buses I don’t see any congestions on Upper George street or the surrounding area
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Use a 'lollipop' style give way sign on Upper George St. Just before junction with Gordon St not just mark the road. Or speed bump before zebra crossing Move the taxi tank because they don't use after 6pm but people can't park because off been a taxi rank Pay and display should kept as it is. Red route should only be implemented on Wellington Street (right side). In order to tacklet the issue of parking Council should look at making/creating more pay & display i.e. Upper George Street should become pay & display No There is no congestion in the town centre Tackle bus parking issue where busses just stop hence the reason the traffic stops. This will solve 90% of the problem Bus stop is a need to space for all passegers to the access. Shelter would be covered on all climates. Brighter announcers on the shelter stand. Stand still be reflection the driver's conditions Build an eastern by-pass Implement/enforce existing regulations - eg. No parking on double yellow lines throughout the town Don't Know No No
Please use the space below to provide any additional comments on the proposals for Luton town centre. If there was a park and ride or free parking spaces, maybe people wouldn’t park so badly in and around town. Since the introduction or resident parking in parts of new town the other roads are now totally blocked (the end of park st towards luton hoo back gate classic example - no one used to park down there - resident parking introduced now that road is utterly crammed) there are too many cars in the town centre and new town, resident parking (although I know it is needed in many places) has just moved the problems. We need more car parking - as lets face it no on is going to stop driving (for many reasons). Red routes etc... will just ease it for a bit - the problem is too many cars for the area. Stop looking for ways to make money you blady bunch of theifs Clearly some racial element behind this! Targeting areas with high ethnic minorities predominantly bangladeshi and pakistani. This will affect business in the area really bad and put off other people from neighbouring counties to visit bury park for shopping. Majority of business is from asian background in luton. I have no idea what the chief executives of luton is thinking! This aint norwhich where he is from! None of the directors in the council have any idea on how business is important for a lutonian, as none of these guys live in luton. This is ridiculous stop trying to force your opinions on how this town should be managed. This will litterally kill off business. So think before you even think about making a red route on Dunstable road. Need to ensure people who park in town centre, park in the bays provided and those people who don’t should get fined straightaway using CCTV to capture licence plates. The roads around the town hall including weekends are the worse. Why can church goers on Sunday park anywhere but people who go to Mosque in Friday cannot. Parking rules should apply 24/7, not just during work hours! More red routes especially the entire one way system including mill st Use cameras to police this, put bollards all the way down the side of Wellington St that is used for pavement parking at present. I am totally for Red routes on main arterial roads. This will not help luton in long run as will disturb local business, it is ready is in bury park. The main problem on these roads are parked/waiting taxi’s, please ensure that these
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vehicles are NOT granted any exemption. when visiting town centre side of wellington st there are too many cars parking on footways and I have to walk past in middle narrow road Exemptions for Taxi and Private Hire should be limited to local licensed vehicles only to give benefit to the local trades and to stop out of district licensed vehicles blocking up the road network Need a rethink for whole of Borough including resident parking and park and ride. Dedicated bus routes that take buses right through- ie- not shared with general traffic. Automatic plate recognition for fining. Strict enforcement 24/7. Get rid of the one way system,open up more of the access roads, remove traffic lights from roundabouts. I am a disabled badge holder. It is difficult enough parking in town when u need to go into town for a few items.There is not enough parking for non disabled badge holders either. We have lost the big library car park. It was replaced with a ground level one. The Bute Street Car Park had been sold and can go at any time. Workers in the town find it difficult to get parking if their shift patterns vary week to week. I don’t think this will work and is another way just to target the motorist with a fine of some sort. Instead the council should work with its taxi drivers and public transport drivers who spend the most time on the roads in Luton. Please try and get some better shops in the centre instead of all the charity shops, fast food and pound shops, try and give the town a better and more positive image. I do not think that the issue of inconsiderate and sometimes illegal parking is something that should be a matter of democratic ‘vote’ (been looking at the results to date on the Airport Way, etc. consultation). It is patently clear that there is a problem despite the numbers voting against the proposal, which to me reeks of self-interested Uber drivers and others. It needs to be dealt with regardless. why not enforce current parking regulations instead of introducing even more (which you will no doubt fail to enforce!) New red routes must be strictly monitored and anyone ignoring restrictions must receive the due fine without exception Likely only to be effective with a high degree of enforcement There are so many cars in this area, either parked on the pavement or waiting to collect family members (a large majority are council staff) that it is becoming dangerous to even walk through the town - especially by the Town Hall coming around the corner from Wellington Street. This needs to be managed though otherwise people will just ignore it. We are based at 49-53 Alma Street, Luton, LU1 2PL and operate a Day Centre for adults with an acquired brain injury on a daily basis. Many of our clients have physical disabilities including wheelchair users. We utilise Luton Borough Council disabled transport to bring our clients to and from the Day Centre and can have between 3 and 4 minibuses attending twice a day. From your map all of our property now falls within the Red Route and we will need to use the dropped kerb that also falls within the Red Route. You have said that Dial a Ride are not able to stop on a Red Route who also bring in some of our clients and I am unsure if your own transport will be allowed to stop (I assume they are deemed the same as a Dial a ride bus). This is going to cause us extreme difficulty in accessing the building safely with our clients with mobility problems. Is it possible that someone could come and discuss this issue with me? the additional residential building, expansion of airport and lack of infrastructure investment and traffic planning i fear will cause more congestion and traffic in luton. its poor now it will be dire in 5 years time. see above There is hardly any parking facilities as it is for small businesses and you will end up driving them away for chicken shops and such like which there are too many already It is good that something is being done to address these problems. As a cyclist I welcome anything that makes me feel safer and that perhaps will encourage more people to cycle. There seems to be an increasing problem with cars parking in cycle lanes and on pavements, presumably the red routes will help with this
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I totally support the Power Court and Newlands Park projects I suspect that the intended red route measures are simply to allow the Council to be able lawfully to enforce compliance using cameras will only work if “policed”. many existing road regulations are ignored - so will red routes if not comprehensively controlled Red routes are essential for our busier roads but they will need to be effectively managed and enforced going forward. Red routes do not add anything except a different colour to existing rules forbidding parking and loading on most of the principal streets which are proposed, and the large range of possible restrictions and time periods will just increase confusion. Enforce the existing rules See above Taxis are among the worst offenders. Concentrate on them..they do what they want anx will continue to do so. Ask a woman a to help design the next road change!! This is plane and simply another cash cow for the council, Luton is not a city so don’t try to fool the residents , we pay enough to the council and it’s appalling the state of the roads, on my road I have to dodge bloody pothole after pothole and broken down speed humps , why does that council not use the money we’re it is needed and stop taking the residents for fools. Council tax rise year on year and services reduced year on year. Maybe the council should stop paying the fat cats stupidly inflated salaries for sitting on there backside. The public are being pushed to the limit and sooner or later there will be a revolt. Don’t push your luck cos it will run out believe me! No easy answer OK as a pilot but needs to be town-wide Please could Peel Street be added to the red route They do not go far enough. Mill Street is often an issue Ashburnham Road should also be made into a red line route on the side of the road that doesn’t have parking. People park on the pavement making congestion every morning and afternoon. This is dangerous apart from anything else. There are seldom parking attendants in the area. Shorter permitted stop times would help. Red routes are totally impractical for Luton. They will cause severe disruption and force people away from shops and businesses, It does not take much imagination to enforce laws that are already in existence. The proposal is unclear. I am very unhappy that you are apparently not developing cycle routes (near Telford Way is a nightmare) and that you may be downgrading some existing cycle ways. I only found out about this today! I work in a local school! Improve your publicity! I would also suggest you enforce the other parking restrictions around Luton Red routes have nothing to do with road safety and are an unnecessary cost. There are existing regulations to deal with parking problems. Proper and correct enforcement of these should reduce congestion and deal with any potential safety issue. What about chapel st That is packed every day !! There needs to be provision for short stops for collection, for example from the sorting office, or the cleaners or newsagent along the dual carriage way. The side roads are fine for this, and 3-5 minute parking does not cause obstruction. The area in front of the sorting office is frequently full, so it is not sufficient, and it does not allow this type of very short term parking (no one will pay to park every day to go to the newsagent). No Whilst I support the red route, a lot of congestion can be attributed to poorly implemented traffic management. All the resident sare sick of dumb drivers parking at the mouth of roads like ivy road And grocery shops just treating all areas as their back garden I notice small bays but with big tucks delivering in shops in bury. There should be bus bays
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Too much space has been given to the shops Too many cars parked by the corners AA carpets shop has a van there all the time Thats all Luton has a major problem with cars while I hope these measures will help we need to become less car friendly Bottom of Ivy road customers of haji and sons always park on the mouth of the road this causes obstruction when turning into ivy road Tram
Bad idea and waste of money, the money should be spent on the pot holes and the bad condition of the towns roads This will, I assume, help solve the parking on pavement problem. Please stop parking on Wellington Street How will traffic flow and congestion be monitored before and after any introduction of Red Routes? If there is no robust evaluation the Council cannot know if the measures make the improvements claimed. In London Red Routes are enforced by many cameras, including on buses, with a 24/7 staffed observation and control centre. Drivers know they will be sanctioned if they stop on a Red Route. Where will the funding come from for enough cameras in Luton town centre? stop cars parking on the pavement on Wellington Street. Bute Street should also be included as cars park all over the new square £300,000 can be better spent on other projects more beneficial to the look of the town centre. I suspect increasing numbers of people continue to shop and entertain themselves at other local town centres such as Hitchin and St Albans as Luton’s continues to detioriate. Parking on roads such as wellington street means people have to walk in the road as cars frequently park on both sides of the road despite it being narrow. people should use the car parks rather than just park wherever they please. One of the few good ideas that the council has come up with so far. except for disabled drivers, there should be NO parking during red route operation hours I strongly agree with red route in all area’s of Luton u have proposed You need to work with businesses. Did anyone talk to these people ahead of a proposal? Red routes work in London as there was issues with poor parking on arterial roads. I don’t see that in Luton from my experience of driving here for 25 years. enforcement I thought the busway would improve the bus times, so if that is the case, why do we need a segregated bus lane? Enforcement is key. Consideration of junctions when placing crossings etc. A whole light phase could be missed with a poorly spaced crossing phase. Increase the parking fines by 5-10 times to discourage people from ignoring the double yellow marking. Fully support the red route on Wellington Street. There are always cars parked on the pavement on the right hand side (towards the Town centre) which makes travelling down the road difficult and dangerous. There should be other options considered before introducing red routes, for example having more parking bays, parking being more cheap or free like other towns. Trying to travel across town is very difficult, no route with free flowing traffic, better link roads around town needed to remove commuting traffic I fully support the red route on Wellington Street, where there is significant and dangerous conflict between pedestrians and car users who drive on the pavements. The red route should also extend the full length of Alma Street because buses using the stops outside the Galaxy need to use Alma Street to head back up the A6. This is a bit of a strange proposal as many of the areas where the red route is proposed do not suffer from people parking inappropriately, e.g. the sections on Dunstable Road. I fully agree with the proposals for Wellington Street as it can be a nightmare with vehicles
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obstructing pavements but none of the rest of the planned scheme. I would also suggest the scheme is amended to include the tail end of Chapel Street from B4540 headed NE towards the dead-end as that area is an absolute nightmare at times and it puts pedestrians at risk. Red routes and cameras will not solve the issue. There are too many foreign cars who park illegally on Wellington Street, who have been issued parking fines, and who have no consideration for their actions or parking. Their vehicles are obviously not registered as I have seen countless parking fines on cars and in gutters (ie thrown away) and which they have no intention of paying. This will be an absolute waste of tax payers money. Clamp the vehicles on the spot or either tow them away on site with police support/backup As a local business on Upper George Street we would be unable to run our business on a day to day basis if we have red lines outside 9- 11a and urgently request a 10 min loading bay between 9 & 11a . We have contractors picking up keys and or equipment at all times during the day that require a short stop outside the office. The businesses in Upper George Steret will be forced to shut down as there are no provisions made foe deliveries. My business relies on safe cash deliveries, and this cannot be made if the secured vehicle cannot stop outside my premises. You need to look at the space around and allocate parking you got rid of a storey parking behind the library and placed it with a very small one our town is growing but our council in Luton our not thinking a head for the future and the residents and business are paying for what ?!! Can’t event sort out power court , football stadium would bring town tragic to a standstill’ Create more parking spaces for shoppers. this is all just to make money that’s all Too many foreign EU plates taking advantage of breaking driving and parking laws in Luton especially on Bute Street and Wellington Street. Speed racers from John Street along the back of Silver Street to Bute Street then along Guildford Street reaching excessive speeds. Needs a night monitor with equipment at weekends to see scale of problem first hand Buses would have more room going up Alma Street as wider rd. Stop taxis picking up and stopping middle of Grodon Street and they take ALL bays so NO parking for customers or unloading stock at our premises will only be chicken and one pound shops left!! Change the highway management, they are useless Hire more traffic warden, it will help unemployment/more people will have job Why you want to make Wellington Street as a red route Congestion charge needed as there is too much traffic on the main road (Dunstable Road) here. Fix the buses If red route is implemented on Upper George Street, I will lose my job Implement some sort of speed restriction to stop the 'racing circuit' around the Alma, Gordon and Upper George Streets. We need to raise issue about parking for contractors picking up keys! increase the parking payment hours and charge more and Luton council can make more money The proposed will adversely effect business in the potential red route area. What council shouild be is create more pay and display units. This will allow more disciplined parking plus generate more revenue. Considering business need support from the council in this hard time I would strongly urge the council to reconsider their plans for red route. The whole set of three red route proposals in entirely welcome and well-received. This is the best way to destroy our town centre We as bury park businesses pay the most amount of business rates yet you have not even provided ample parking. The more businesses do better the more business
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rates you will get Wellington Street will be proposal planning first than other street. Luton Town Hall can be upgraded to the top conversion overall the shopfront by the space office. Brighter the civil office directions towards all civilisations.
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Appendix B – Windmill Road, Kimpton Road, Airport Way comments
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Do you think there is an alternative option to ease congestion, increase traffic flow and make the roads safer in this area? Please use the space below to tell us what you think. Put parking spaces in this very wide road that have a restricted time on them , so that residents of Luton can use the small businesses that are along here. Start implenting yellow box cameras on roundabout and junctions and enforce them. The Red Route along Kimpton road must only be allowed providing that sufficient parking can be given to allow the small business along Kimpton Road to continue. I am a customer of both Plumbs Diy and the Cafe. Roads are perfectly fine how they are in that area. It's a wide enough road anyway. That currently only has congestion because of the building that is currently being undertaken What congestion? Shouldn’t have given permission to build houses there. Also I use this route along kimpton road and I never see any congestion in this area only at the minute it’s large lorries going to the new housing estate Facilitate spaces for the shops , stop taxis and airport parkers thats where the problem is namely on airport hill There is no congestion. The road is very wide plus the houses/flats that are being built will have had adequate parking allocated through planning. Stop building appartments/flats on Kimpton Road - this increases people/m² and so much more traffic will be created... Or create an alternative route away from the new development so it isnt all directed to the same road. There has never been a build up of traffic on this road. Not needed. Only a free bus service,paid in with your council tax. We are based on Kimpton Road and it is always quite quiet and never any delays to Buses. How can you actually know what the congestion will be like there? There is currently construction traffic littered on both sides of the road and temporary traffic lights constantly in use. I would suggest that the safety of the area will greatly improve once this changes and perhaps then an informed decision can actually be made. The fact I have to point this out can only mean decisions are being taken by non-lutonian residents, people that don't drive, pen pushers justifying a job or the same **** that thought the busway was a good idea...probably the same twat that enjoys the derelict views of Power Court too. Asking local residents and local businesses is only a fantastic thing to do if you happen to listen to what they say... Make 20 minute parking bays for the shops, businesses and station pick up. Providing allocated spaces for loading (of which there are currently none) in sensible spots instead of banning it throughout the whole entire area Employ traffic calming measures to ensure a steady flow of vehicles. Replace the mini roundabout at the bottom of Windmill road with traffic lights or create a one way system around windmill road/airport way/ gypsy lane. The road is wide enough to accomadate traffic as it is Not really as people use the area to wait to go to airport Providing a car park for people wishing to use the small business on kimpton road (sandwhich shop and cafe ect) I would need evidence to support the need to consider a Red Route in the whole of this area. I have seen none that suggest that this should be introduced in Kimpton Road. It is a wide fairly straight road with extremely good visibility. Such restrictions would possibly be beneficial in Windmill Road and Airport Way. However parking isn't the issue - the volume of vehicles is. less dars more buses only problem is the building contractors Alternatives would be free time limited bay say 30 minutes so the business are not deprived of trade, and included pay and display machines for longer stays helping to increase the flow of users. Due to poor enforcement of the current regulations the bays are being used
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for extended periods as no deterrent is in place, this means genuine users of the shops are parking in locations outside of the bays. Free parking at Luton Airport. Allow more taxi firms to service Luton airport. Install berries restricting possibility to park on the pavement. Bus fares should be subsidised. There is no price incentive to use public transport in Luton. I agree that a red route along should be implemented on Windmill Road and Airport Way, but not on Kimpton Road as this will disrupt the local business which have been there for a number of years more use of other alternate routes as this will affect smaller businesses smaller businesses need local parking otherwise you will kill they're trade and this should not happen not building a school opposite the retail park I have never ever experience any traffic congestion on that road. If anything this is one of the easier traffic free road around the area. How has this conclusion come to fruition is beyond comprehension? Give local taxi drivers a designated area to park and wait for next jobs. Allow the Hilton to increase its onsite parking. Speed camera Have a drop off zone for Luton airport parkway train station on or just off of Kimpton road Reduce traffic lights within these areas, as this is the main cause of congestion. No congestion There is no congestion there only at the minute because of building work Get rid of that silly roundabout and put a proper set of traffic lights in Yes traffic lights, extend the road on gypsy lane Perhaps look at the reason why people feel the need to park inconsiderately! The airport have imposed extortionate charges in their pick up areas, there is not enough parking on Kimpton Road - which as a massively wide road could accommodate additional parking if not for the building work - which is temporary! There has been no issues regarding traffic in that area and people use this as a short cut into town or to get tie the motorway quicker by making this into a red zone you will be closing down business in the area that have family that need this to survive. There isn't any, never seen any lived in Luton for 40 years No The roads are not currently an issue as traffic is minimul the only congestion comes from the road works being done so this is an irrelevant solution Until the building work is completed and the road is back to normal it is difficult to say. Can the waste ground by the side of the hotel be used as a drop off for parkway and the hotel so they don’t park on the road. Enter a traffic light at the roundabouts on eithe end of the road to help flow of traffic Kimpton road doesn’t have congestion any worse than any other road in the town No need for any restriction as there us very little congestion in this area I just wonder how Vauxhall coped when 15000 workers came out at the same time. Buses waiting for us all.....we didn’t gave traffic lights there in those days. Haven’t had any problem with traffic going that way leave parking bays outside kimpton road shops but put 20 mins max time. agree with other proposals. bury park needs to be a red route. More free short term car parks What congestion ? Designated parking near the local businesses No need for red routes on Kimpton rd as the road is very wide. Actually you need to provide more parking to help the local businesses on that road Stop airport taxis and meet/ greet from occupying valuable parking spaces Re open all the side roads around town to ease the traffic on ring rd There is no need in Kimpton Road where the road is wide enough, particularly where there are businesses open to public, for parking spaces to be provided. Open up the busway to all traffic therefore taking some traffic off Windmill Road and letting
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people get to Kimpton Road quicker and easing congestion for Gipsy Lane traffic. Yes better traffic light control etc No red route get to the airport this road is no busy road The only route here where vehicles may park out of necessity is kimpton Road. This is generally to visit businesses on the kimpton road. However kimpton road is a wide road and can easily absorb this. To inflict a red route In this area would destroy all the small local businesses in this area forcing them to close. This would be a big mistake by Luton council. no need red route Kimpton road is not busy road No need ret route No no red route The options are fine as they were prior to the building works. Everyone expects delays at the moment due to the new houses that are being built, but putting local business's at risk along Kimpton Road, is not a good idea by making it a red route. The worst bit of Kimpton Road is opposite the Vauxhall plant, when people keep stopping to use the cash point and the small layby outside the offices as it blocks the gate into the rear car park for people that work in the buildings and makes the foot path unusable. Keep it the same...If it isn't broke.... Roads have always been fine only. Once the construction works are complete, Roads will go back to being fine. Red route will destroy local business. And that is disgraceful this option is even being floated about. A red route on airport way makes sense but there is absolutely no reason for this on the other roads. No There is no congestion along that road, it’s very wide easily takes all sorts of traffic. It’s not as if there is a bus every 2 mins. That road is easily 5 car widths. no need red route for airport easy to get to the airport may ways to get to the air port we don't have to implement red route in Kimpton road no traffic on this road so many way people can get to the airport. why ? council thinking to do this no need red route in this aria waste of time and money this road no busy road only traffic warden can control. traffic is backing up due to lights on airport and train station, this should be made a slip road to join, making the flow of traffic move for airport user can use 4 route one from M1 for outsider. and locally 3 route can be use to get to the airport Why ? red route this is not London we understand red route in London but no need red route in Luton No problems in kimpton rd I am using this road to go the work but on the way to go and come back we can do shopping from the shop if we are late. i never seen any traffic on Kimpton road. Moreover we can use other routes to get to the airport. AS long as I know about the other routes there are other different routes from town centre and locally Gipsey Lane, Crawley green road , Kimpton road and also M1 from outsider to get the airport. So there is no need to do the red route on the kimpton road. No need to implement red rout because no traffic congestion on the Kimpton road. for airport user have 3 route can be use to get to the airport from locally and Luton town + M1 .I believe your implementation can be affected to all the business holders who are here from long times. There is no congestion. You need worry about bury park causing all congestion. Also the timing of traffic lights to. Airport way makes sense. But not Kimpton or windmill road. STOP BUILDING AT THE AIRPORT I feel a red route in kimpton Rd would affect businesses in this area and isn’t necessary as the road is so wide. I do think however red routes in other others where the roads get blocked as they are too narrow is a good idea. Kimpton Road is wide. Businesses on Kimpton Road suffer from lack of parking already
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Unsure Must be an alternative somehow Most of the congestion on Windmill Road is caused by the traffic lights at the Gypsy Lane retail park and Kimpton Road was wide enough to have parking along at least one side of it until the road was narrowed. Given that the no loading restriction brought in on Airport Way early in 2018 is ignored by many motorists, no. The businesses in kimpton road need parking to stay alive the nearest at present is up near the war memorial Traffic lights on windmill road and Kempton road Provide time-restricted parking bays so local businesses can still function. Use these roads as normal but not red routes, totally unnecessary. No I use Kimpton Road on a regular basis and the only congestion I have encountered is due to all the construction work being carried out,once that is finished things should improve There was no problem with traffic in Kimpton Road until the works began. The road is plenty wide enough to have the restricted parking that has always been there. There should be parking restrictions on kimpton road to stop cars being parked in the bays all day. There is never any parking available when trying to visit the local shops in kimpton road, this is the main issue for traffic flow, illegal parking or stopping due to lack of available parking in the area Short stay parking bays to enable people to stop at the shops or pick up someone from the train station. No everywhere you go in Luton it is gridlocked The parking at the shops is NOT the cause of the congestion, it's the building work that's going on that's causing it. No need for a red route as the shops near places for people to park but then theses people do park like idiots and you can’t get round them especially when they park on the bend in the yellow lines Maybe introduce it but put a bay where people can park on the road somewhere Provide parking for businesses/customers in that area It will be when the Redrow homes site is complete Congestion is caused by two main roads meeting at an indequate roundabout at junction of Kimpton Road and Vauxhall Way. A flyover is needed As usual these details weren’t thought about until after the building works started Kempton rd - wide enough to accommodate parking - road rarely congested Kington Road is never congested when I drive along it. I don’t remember any accidents on it either. It’s a wide road and I prefer to drive in it rather than Crawley Green Road. Ban lorries during peak hours Have time limited parking bays (2 hours?) outside shops in Kimpton Road and police them properly What analysis has been undertaken thus far around the type of vehicles, times of day, etc to come to a conclusion that a red route would benefit or be useful? No need for restrictions road is wide enough to have parking bays Don't fix what isn't broken. Businesses struggle enough. Stop playing god The roads are currently wide enough to easily deal with a few parked cars using the shops I don’t see a reason to change Remove some the stupidly timed lights and street furniture. Open up bus way between Hitchens Rd and kimpton Rd Use cameras to ticket those who stop or park there No, the current plan is good Congestion is not a problem on this road. Speed cameras THIS ROAD IS NOT THAT BUSY Time limited parking bays in Kimpton road as this is wide enough to take 2 lanes for traffic and park. Pay and display with 20mins free will help local businesses
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another road not a red zone Allocate parking dedicated to the shops on Kimpton road. Kimpton road is already very wide and easily supports parked cars to the side and traffic flows past with no trouble , I’ve been partner to this for over 15 years . I have never experienced congestion in the first place and think by doing this you will kill off all local businesses that I rely on and use on a daily basis and if I cannot park or any one else for that matter you are putting the kiss of death on the owners Kimpton road is wide enough I have not encountered any congestion caused by parking Please can you ban parking all four wheels on the pavements Maybe implement a congestion charge. Traffic flow on Kimpton road is never an issue. Implementing a red route along this road will be detrimental to the local businesses here. There is only ever congestion when there is construction in place and temp traffic lights. Traffic is no problem on this road Current traffic congestion in Kimptom Road is caused by construction vehicles and temporary traffic control. So no need for a red route. Stop trying to screw small business in the area Road is too wide. Condense it down and create parking bays. The congestion in the area is not due to parked cars, but due to the amount of traffic through these roads. Introduce park and ride, car sharing zone, reduce speed limits. Put road calming in place Encourage alternative transport by ensuring public transport routes are just as convenient as using cars. It currently takes over 5 times as long to travel by bus from leagrave into town as it does by car. No wonder so many use cars when time is so precious. Penalising car users and restricting access to small businesses is short sighted and destructive. Yes, speed cameras, or speed humps Stop building houses on those roads I regularly use the bus to get to work on Vauxhall way. I never notice an issue with congestion or delayed buses. Waste of time trying to implement something that isn't needed 20 mph limit , road humps , speed cameras Enforce current road markings. No point making it a red route if not enforced. Sometimes you have to stop for reasons other than parking. Unfair to be penalised There only seems a problem when vauxhall turn out. These roads flow OK as they are, but implementing red routes on these roads would result in the business's having to close and result in job loses. I lived in Luton for many years and still visit regularly. Instead of spending good money on surveys, brochures and consultations Please fill in the horrendous pot holes in the roads (there's a particularly nasty one on Ashcroft road). Don't spend tax payers money on stupid and totally unnecessary red routes. I don't see any issue with the road as it is. I see there has been 2 sets of traffic lights added to Kempton road, they are not turned on yet but I'm sure they will ease the safety issue though not the congestion Shame on you LBC - I've shopped at the little sandwich bar for 10 years, they work so hard - they are devastated that you even suggest this all because the airport is king !!! You should hang your heads in shame - go and rub your noses around the bigger shops - grab a mac Donald's while your at it- you are a waste of space !!!! Kimpton rd is never congested park and ride for schools causing a huge amount of congestion twice daily. Improving roundabout on windmill road. It causes congestion coming from Kimpton Road. Add off-road parking, or widen and add bays to park in Paid parking Yeah, if you fix the pot holes in the roads, that will have a major impact on reducing traffic congestion. Make permanent parking spaces so people dont need to park in road
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I believe the road is wide enough and suitable for the traffic that goes down there as it stands. I often visit the business' along that road such as the Café, and I struggle to park there as it is. this would be detrimental to the businesses and the customers that frequent these shops. NO alternative. Use the other road Leave Kimpton road alone. There's no congestion. We've known Kimpton road for 33 years. Even when 20,000 people worked at vauxhall this road could take the traffic of workers clocking on and off. The road was much narrower back then too. There's no disabled parking bays in place so where will these customers park? What do we do with deliveries, bin collections etc? It's a ridiculous idea! There's absolutely no need for red routes - we are not in the city of London! Since when have these roads been congested or unsafe? Unnecessary waste Of council money trying to fix a problem that doesn’t exist Some of these roads are highly congested and despite wardens patrolling them people still continue to park up. Bollards on the path on Airport Way are also necessary as current issue is cars/minibusses parking off road on paths/verges. Red lining will not work without enforcement every day. Payed parking, with a parking tefund if spend money in local business, loading and unloading g restrictions Open up current bus route at park way to the public Stop pulling up the roads and bannning parking just so you can profit from a new load of flats Not while there is building work going on around this area There is no congestion on this road anyway Having red lines by shops n business is a no go as they will get no customers or deliveries Stop making the whole town centre one way and not everyone will be forced down one route Put up traffic cameras. Out parking bays in for customers only visiting the shops. There is always other options, but to target local businesses who have done nothing wrong apart from serve the public, and build good relations with the local community, I believe is wrong in every aspect. The solution should be in helping these local businesses not try putting them out of business. Part time Lights at the main roundabout would defo be better traffic wardens ,CCTV Cameras and technology There should be short stay parking bays, you have put development in place with no thought of the impact on the existing businesses better parking facilities something else! Stop building flats in every space possible with no car parking spaces. Build more roads to spread out traffic flow more cameras As long as there are parking bays next to plumbs the diy shop srea The traffic flow already is good. Use space on road for parking I don’t think an alternative option is needed. This road is rarely ever congested. the road is safe as it is. If you check the road collision on Kimpton over the last years there will be next to none. Kimpton road and windmill road are not congested, I work in the area (Osborne road) and have never had a problem. Apart from rush hour the traffic moves pretty well on these roads. Red routes will not speed up traffic in the rush hour Build less houses! No in kipton road , we need to park to pick up drop off people from trainstation ....
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you are causeing the problem there by building hundreds of homes , but you don't want anyone to stop or park or go into the shops in that area .. you cant have it both ways Increase local parking to stop inconsiderate parking due to lack of alternative I did not realise that there was such a problem with congestion in this area - I have never experienced anything except the tailback of traffic in the morning waiting to get out at the Gypsy Road end. Why is it you think there is s high amount of congestion on kimpton road? Do you really think the majority of people who use the airport use this route? Enforcement Speed limit make it safer. The problem is it is a through road from the M1 and when anything happens on the motorway the traffic diverts along Windmill Road. Painting red lines won't make a difference, as parking on the road is not the problem. If the lorries and all buses could use the busway it would help. As the airport expands a one way system around in/out of airport must be considered, to ease the short cuts that become congested, equally sheer amount of traffic on the roads - because the bus services are not great means too many local people use cars for short journeys instead of buses. the cost of luton buses is expensive compared to TFL. More buses Never experienced any congestion within the public road network More consideration needs to be given to the purpose people currently do - and once the new development is complete - will use Kimpton Road. Plastering a red route along it doesn't solve any problems as far as I can see - what provision can and should be made for the residents, people dropping off at the station etc.. this seems to be attempting to solve a problem that doesn't (yet?) exist..? Airport Way to and from jct 10;needs widening. The bottle neck of capability green is conjested everyday. Tales ages to get to stopsley on way home Airport expansion and new housing and school gypsy lane will cause more congestion. The roads cannot cope. No capacity for increased traffic Enforce the existing regulations. Eliminate long stay parking in the parking area nby the shops in Windmill Road Take the traffic lights off of the big roundabout at the bottom of Crawley green road Increase parking at existing sites and reduce parking costs therefore reducing the need to have people park in the way they are...... many people do this that are heading for the Airport, why? Because of the greed of the parking agents and the council in charging extortionate amounts to park a car and be dropped off, crazy! Increase enforcement. At present this is very weak so it is worth taking the risk and parking thoughtlessly/stupidly. The congestion is almost entirely caused by unnecessary and badly-sequenced traffic lights. Many could be replaced by mini-roundabouts, especially outside Gypsy Lane retail park. The rest must be simplified to a simple 2-way cycle, banning right turns if necessary. more fines for illegal parking Implement a limited stay time and no return within a hour for example. A red route will not benefit anyone in the area. employ more enforcement and get more wardens on the street. Engage real street police with powers as many problems happen through selfish drivers too lazy to think of others that get away with it through no enforcement. More traffic wardens ticketing illegally parking around the airport including removal, but the Kimpton road has the parade of shops that are used by the workers at Vauxhall and the hotels around at this moment in the future the new houses that are being built their will also need them. Think of the future. All the years iv lived in Luton iv never seen congestion on Kimpton Rd unless ut has temp traffic lights I would like to see a cycle route between the airport and the town centre, both areas employ a large amount of the local population and although there are good cycle routes through Luton to the town there are none from the town to the airport. reduce the number of cars on the road
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The congestion isn’t generally caused by inappropriate parking except along Wigmore Lane by Someries School in the mornings. The main cause is the sheer weight of traffic which turns the roads leading to the M1 into long lines of stationary vehicles and the proposed. Red Routing will not solve this problem. The existing parking restrictions are sufficient to deal with any parking problems if properly enforced. Yes stop building new properties without having the infrastructure in place to facilitate the increase of people and subsequent traffic. Create parking spaces so any changes do not effect local business. Enough space along the road to make pull in bays to reduce any issues Kimpton road is not a congested road. Roads if they are ‘unsafe’ could have traffic cams installed if necessary. Kimpton road is not blocked by parking, and provides an essential level access to Luton Airport Parkway station. It is the only completely level access, and the lifts and escalators on the station side are frequently out of order. There is no provision in the proposal for allowing cars to stop to let out passengers. Wider roads? The roundabout at windmill road is too small. Kimpton road is a mess only since the building works started but it was fine before. It’s probably the widest road in Luton now. Enforce parking, a red route is total overkill No congestion less cars Working traffic lights 40mph speed limit Congestion on Windmill road, especially between 7am and 8h30 am, is due to 2 factors and not by cars stopping along this road (which doesnt happen anyway): 1. the traffic light on gipsy lane to go to the luton retail park, a roundabout could be better. 2. it is the only road for Luton residents to access Luton parkway rail station car park as only buses and taxis coming from the airport via the A1081 can turn right at the traffic light on the dual carriage way A1081. There is no congestion on Kimpton road or airport way. There is no need however what you will do is put a number of small local businesses that have been there for years out of trade Never any congestion Never any conjestion Build houses instead of flats on Kimpton Road. Yes you need to focus your energy and time on the roads that haven’t been finished and are causing problems for around luton. There is no congestion when I’m passing through Stop building houses near businesses ... The roads in this area are wide enough already and i have no ever experienced conjestion (apart from when roadworks are ongoing). If you want to stop “illegal” parking then why dont you introduce ‘Legal Parking’. Provide spaces, even pay and display (hey it will generate an income for the council) instead of banishing all parking, therefore dissipating local businesses which will then shut down and bring down the aesthetics of a town and area which we are trying to improve. The congestion has been caused by the development, we have never had lorries having to park in the middle of the road. Never seen congestion Red Route I go along these roads by car or bus or taxi fairly often and never see significant congestion caused by car parking on any of these routes. I think the proposals are completely over the top and a waste of money. A red route would make no difference in this area. Traffic flow is generally pretty good. Even at peak times when it is pretty busy, the red route wouldn’t change anything. This is not an area blighted by inconsiderate parking.
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Red routes won’t help with traffic. There’s never any traffic along Kimpton road until you get to the little roundabout at the windmill pub. Red routes will kill off the businesses and shops along these roads. Since the redevelopment started I have had a real problem parking legally as all the parking bays were taken away. I went to the café the other day and there was nowhere to park. I thought the cafe must be packed out. But when I finally went in there was noone in there! So, if its not customers of these businesses it must be the workers parking illegally and inconsiderately. Once they go I think it will all calm down. No Its absolutely safe , you would make all the local business suffer ans the workers to, is no parkings spaces for anyone apart from badge holders, this is nonsense!!! Parking in these roads do not cause congestion I don’t understand why you wish to make kimpto n road a red route , the only people i see causing congestion are the builders who take up all available parking spaces which means i have to park illegally to make my deliveries, the road has been made in to a right mess, who ever changed the road layout a few years ago needs their head testing Widen the roads improve the infesteucture NO CONGESTION on Kimpton Rd There is no traffic flow problems in this area I don’t believe with the exception of peak times that there is evident congestion in this route. Who is lobbying for this? More traffic wardens No make the road a little wider, allow for spaces on the side of the road. OR put a bus lane in Stop building over priced housing estates for London commuters Appreciate for some roads not Kimpton toad
No - unless improve the road capacity Yes put it back as it used to be free parking for half an hour and lots of space to park . The road is wide enough and that has been apparent just during the recent roadworks The airport causes major traffic and has the resources to have alternative routes from the M1 etc installed this easing the traffic locally in Luton, keep the airport traffic out of the city. Airport way needs to a one way lane from the airport due to the high volume of taxi’s; persons waiting in vehicles; unnecessary double parking opposite Holiday Inn Express for individuals waiting to be collected/picked up from airport. Pick up area “complimentary” needs better signage & taxis should be issued with permits to operate at airport. People dont know how to drive, thats why there is traffic there at all time Stop parking No Kimpton Road must be one of the widest roads in the towncannot see the advantage of making it a red route Not sure Provide suitable parking for people wishing to use the businesses on Kimpton Road. Implementing a red route will not allow for deliveries. Perhaps consider loading bays. Provide increased parking bays, roadside parking that doesn’t block traffic I don’t think there is a traffic problem here at all Improve the traffic flow on crawley green roundabout , as the lights on the roundabout causes the traffic to back up onto kimpton road ! Also the timings on the ;lights on gypsy lane also causes the traffic to back up towards the town centre only standing along the roads shooting people that stop.
The road only becomes congested when traffic lights for road works are in action, other wise the traffic is able to travel at a very good rate Proposals for Kimpton Road dont seem approprate as this is the route to the airport from the town centre whereas dominant flows to the airport likely to be from M1 ie doesnt warrant status of a red route. Use of Windmill Road (with development / imrovement) would provide a better link serving
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the airport, M1 and Parkway railway station. Red route proposals need to be better integrated with traffic demands. Provide a drop off point for the station on both sides of the road and parking for shops By working with the airport and looking at their parking and drop off and pick up facility this will reduce the number of cars waiting on the local roads and will ease congestion. Congestion happens everywhere on roads. People have to deal with it. Would prefer more to be done to take dangerous drivers off road and uninsured. Yes I think you need to look at other areas in Luton. Areas that have been implemented and not been successful. Why disrupt a road that is working perfectly well. It will cause utter disruption. Best thing to do is fix the problems on the Luton roads before causing anymore problems to your residents. I enjoy using this road don’t make it a problem for me and my family.
There never seam to be any problems along Kimpton Road. It just needs a limited parking time on the bays to stop airport parking and residents parking long term. YES- employ MORE civil enforcement officers because LBC cannot enforce single or double yellow lines currently so it does not matter what colour the line is... ENFORCEMENT IS REQUIRED, NOT WASTING OUR MONEY If possible people can walk instead of taking their own personal transport Wind mill road gets busy but with traffic going to the motorway. But Kimpton road I have never seen it congested and businesses along there will be badly affected. What will happen to vehicles dropping off and picking up at the train station entrance in Kimpton road? Put speed cameras on kimpto n road _ will help safety Inconsiderate parking is a perennial problem on Luton’s streets. The roads targeted in this route are not the worst. parking fully on the pavement seems to have become the norm & there is no penalty applied. Employ more traffic officers & give them powers to remove repeat offenders. This route has very busy period, mostly when the shifts for airport workers change. You could consult companies to ask them to stagger shift patterns. If this went ahead, you would also need the same ‘red zone’ for the holiday inn roundabout & along Percival Way. Just doing Airport Way will not help with the congestion on this main roundabout & will just encourage people to stop/ drop people off here instead. Stop the current contractors/builders contesting the roads. No There is no congestion in Kempton Rd there is no need to implement a red zone its very sad for all the business that will go under because of this. There is no congestion in Kimpton rd Kimpton rd has no congestion All this will do is move the problem to residential streets in the area. The streets around Cutenhoe Road are already used as a ‘car park’ for commuters and holiday makers. Osborne Road is positively dangerous at peak times despite having yellow lines, any attempt to complain only results in a parking warden for one day who does nothing. The problem needs to be reviewed holistically with a range of measures which includes parking permits, traffic enforcement, additional reasonably priced parking and even the implementation of new local bye laws. Never seen congestion till the development started. Agree there needs to be some enforcement The main congestion on this route is the roundabout going to the airport in the morning and evening. I have only seen cars parked at the shops at kimpton road. If traffic flow is a problem why is there no other way in and our of the new housing estate being built on the Vauxhall site Kimpton Road is wide enough to put in proper time limits parking bays to sort local businesses and provide drop offareas. Ditto Windmill Lane. Yes more roads Yes many cities have started banning diesels and high polluting vehicles. Why diesnt luton
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become the UK first? A parked car doesnt use any fiel a red route will not help at all on kimpton road. Soeed cameras and 20mph zones There is no problem with these roads -just sheer weight of traffic. I commute to work and it’s bumper to bumper for most of my journey until I get to Kimpton road. That’s always plain sailing. I don’t see any reasons to enforce these changes. No Kimpton road needs better parking for the smaller businesses.
There is no congestion What congestion? Even during peak hours this is one of the clearer roads in Luton Stop building hundreds of flats you idiots More cut in parking bays are what is required not a red route where no one can park because this would harm residents and local business...
There’s never any congestion along Kimpton road. Why are you looking for a solution when there’s no problem? I don’t think traffic flow in this area is a problem. If you want the traffic to flow why have you put so many traffic lights along Kimpton Rd. Also Red routes would kill the businesses along there who are already struggling Increase patrols of traffic enforcers for inconsiderate motorists who feel they can park where they wish. Yeah to many traffic lights on gipsy lane and the round about going to A505 Dosent need it in windmill road and Kimpton Road, I have never been stuck in traffic there. I think the businesses in Kimpton Road need some allocated packing outside...it is really difficult to find space now but a red route is only going to make things worse. I am sure congestion in Kimpton Road is only exacerbated by IBC workers and the new housing planned so don’t penalise the businesses for other causes No need for alternative option . see below Parking on one side of the road only with a one hour time limit Better Junction at the end of Kimpton Road/Windmill Road There is no issue with congestion or safety in this area. In fact more parking bays should be provided The traffic seems to flow easily enough along Kimpton Road and Airport Way - only the frequent roadworks and vehicles entering the old Vauxhall site cause traffic hold ups. I do not consider parked vehicles on Kimpton Road have any effect on traffic flow or safety. I do not see the need for an alternative option Reduce the charges imposed at the Airport or extend the free waiting time for people to drop off or collect passengers. Congestion on Airport Way & Kimpton road partially caused by drivers waiting for airport passengers and avoiding the extortionate parking charges at the Airport. 30 minuets free parking only, no return for 2 hours. That’s your job to figure out. There is never congestion on kimpton road- I’ve been here 12 years and only see congestion when it’s time to dig up the roads for what ever reason No - apart from actual enforcement of the law (more police patrols/traffic wardens) The problem that is not being addressed is the non-standard mini-roundabout junction with Kimpton Road and Windmill Road. This is the feature that causes all the queues backing up Kimpton Road from Windmill Road. A red route won’t help the buses go up and down the road if there are vehicles waiting in a queue ahead of them. The mini-roundabout needs to be changed into a signalled junction - either that or buy the Windmill pub (which has now closed down again) so it can be demolished and allow for a proper junction to be installed. On-road parking is a major cause of delays and reduced safety. Something must be done about it, this proposal seems a reasonable approach
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Increase parking, lower current parking charges, remove drop off charge at luton airport (therefore cars leading up to the airport won’t stop sooner to avoid this and it negates the need for barriers which slow more cars down) There’s never congestion on Kimpton Road and by introducing a red route, it will drastically effect the local business I use along this road. To be honest as these are small businesses I think they could go out of business very quickly. Windmill Road and Kimpton Road dont flow because people drive through luton to get to Junction 10. We have put traffic lights up on roundabouts through out the town and Crawley Green roundabout gets backed up, as there are too many lights on it. Enforce existing laws Windmill road has a mini roundabout by the windmill pub , (ajoining kimpton road). Traffic light their would ease congestion in all directions. With the secondry school being built in gypsy street the mini roundabout will only get worse No alternative option is necessary. Stop placing traffic lights on roundabouts that are self feeding! I do not agree with the red route along Kimpton Road. Better enforcement of current restrictions would improve all of the above. Why is a red route necessary. Kimpton Road works perfectly well with the current layout. The issue is the council has not finalised the TRO for the current road layout therefore it can’t enforce any orders. Enforcement is the issue here. Local businesses should not have to be penalised for the Councils lack of enforcement. A Red route on Kimpton Road will not effect on bus services, this is a non issue. Introduce parking bays in safe areas and red lining where not. Small businesses down this road will suffer if parking is cut off altogether No congestion in front of these shops etc The road is wide enough and there will be traffic lights in place, plus double yellow lines where needed I travel down Kimpton road daily and parking has never been an issue to the flow of traffic as it is a wide road. It is only an issue while the building works are being carried out. Once these are completed I can’t see there being any issues again Keep parking bays for the shops - how will they survive if no one can park to use them - kimpton toad is wide enough to accommodate parking - otherwise you are wasting the road width Stop poor designed new builds. Have a tram network in Luton to run like London’s tube system. Better public transport Make a road off motorway straight to airport avoiding Vauxhall roundabout which will release congestion in town roads Yes, stop building. Put proper parking bays outside the shops like plumbs. Don’t build hundreds of houses!!! Kimpton Rd was ok when Vauxhall was in full flow. No consideration given to local businesses. Red route or not the infrastructure will not cope!!! Put signs up leading commuter traffic another direction. Free car parking and bus bay Ease congestion on hitchin road first by building a bypass and problem solved simples!!! with no parking how do people get the things they require from shops like PLUMBS that have been there years we need shops like that, you are trying to put another small business out, its about time the council remembered who put them were they are you should be supporting small buisnesse’s not putting them on the rubbish heap, and can you please tell me where the disabled bays are on kimpton road. Widen the roads ans install pedestrian crossings near to homes ans workplaces. Parking drop off bays for the back end of the train station . Parking bays for the lovely shops there. Yes - stop trying to force more traffic to the airport on Luton roads. If you need to put a back entrance in via Hertfordshire do that! Stop approving big ugly housing projects Fix the roads and build a better road way
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I’d start by removing the new traffic lights on Kimpton Road as an arterial route. Effectively connected directly to the M1 Junction I can forsee this causing chaos. Doesn’t apply to this area. Small businesses will suffer and they will close down. Leave it as it is If it is illegal and inconsiderate parking it would be cheaper to have wardens dishing out heavy fines. Then the legal parking bays,would be adequate for servicing local shops etc. I guess most of the parking is not local but commuters using the back entrance to the station Build an underpass for people to get from the station/shops to the new residential area Stop building large housing estates with limited access Yellow Lines and more Traffic Enfocement Officers Only needed on Airport Way to keep cars off the verges. Yes, provide free access waiting areas for people picking up passengers from the airport. I don’t know how to ease it, but putting local independent business out of business by not allowing their customers to park is not the answer! There is never any congestion along this road as a result of parking, only due to the roundabouts at either end. A red route will not stop that - there is nothing that needs to be changed here. have more than one exit from housing deveopment Fill the potholes & get rid of traffic lights on the roundabout at the bottom of Crawley Green Rd. A flyover If you didn’t build so many flats in that area there wouldn’t be a problem with extra traffic and safety I am unable to comment about Airport Way or Windmill Road, however I do use the businesses on Kimpton Road. There is also a cash point on this road that I utilise. If the existing lay-bys could remain outside the businesses and something done to enable motorists to enable them to use the cash point to offset the red route. Please work with the local the local business as well as increase the flow of traffic as Kimpton Road becomes a hub of activity in terms of housing and schools. I don’t find Kimpton Road busy or dangerous, the only issue is the very limited parking Speed cameras Please leave as they are. do the same as you have done to all the rest of Luton slow the speed to 20MPH thus congesting the whole area. It will help that area but make it very difficult for residents and visitors to have easy access to ADA and Iceland. A necessity for those on a limited budget Make Kimpton Road one way, allowing traffic flow, parking for the shops plus a bus lane. The main flyover roundabout traffic light system is ridiculous and causes backed up traffic in all directions There is no alternative. Roads are ok until core times when a large volume of people need to be at work or leaving work. It doesn’t last for long. Amend the flow on the traffic lights at Gypsy Lane retail park, especially at morning and afternoon peaks Help the businesses that are there and provide adequate and safe parking . Great shops and they need our support Open up the right turn at the traffic lights on the A1081 so cars can get to parkway station & gypsy lane. There is no need for a red route along Kimpton Road, it is wide enough to cater for cars parking, as they do now. Alternative suggested routes along the roads leading to Airport Way Make it one way new bus lane is aforce out car flow outs. The red route is a better for all access to the aiport and railways. Faster ways on the bus linked to major stations. No If the double red lines fails to prevent cars parking on the pavement, can the council fit a row of pavement bollards either side of the entry exit to the vauxhall
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car park on airport way.
Please use the space below to provide any additional comments on the proposals for this area. I use the small DIY store on Kimpton Road. A red route past their store will make loading/unloading outside their store impossible. They sell bulky items such as kitchen units so parking further away is impractical. The café and plumbs that we use frequently will loose business if vehicles cant park outside There are very established businesss here that need cards to stop and park Is this just to prepare for when the redrow housing estate is completed ? I travel to work at the airport along this road, don’t see why it needs changing The small businesses along kimpton road will suffer and I thought the council like small businesses or is it because u want these to go under so the council can make use of that area for something else!!!!! Kimpton road business will be unfairly affected here when the real problem is caused by airport pick up drop off people waiting and taxis on airport runs who park in the area , I work at vauxhall motors but use the busines's before and after work , I have seen first hand how dangerous the people parking on airport hill are , this i would agree with I feel for the shops in this road. Especially Plumbs DIY a traditional family run business. They are very convenient and the lack of parking currently is not fair also. This zone will destroy them like a knife in the back. A controlled (camera) drop off zone for the Parkway station back entrance should be provided There needs to be a pick up/drop off bay for the Kimpton Road entrance to the train station. It's very difficult to be dropped off and picked up now and will become even more so. The only issue I have is, whilst we need to get rid of the illegal parking which this proposal will help. Then the illegal parkers will find other spots affecting local street parking. It is bad enough now where the pavements are used more than rhe roads to park on A red route is a good option on the key roads in this area. There is a huge amount of development happening and it should be well prepared for. My only concern is for the small businesses on Kimpton Road. They stand to do quite well with increased residential property in the area but there needs to be adequate parking to prevent them becoming isolated from their current customers. Parking at Napier Park for the retail, leisure and residential development should be sufficient to prevent overspill into Kimpton Road despite the intended red route. For the existing business in this area to survive , they must be adequate free parking , especially to Plumbs DIY-Timber Shop . Customers MUST be able to park to be able to collect heavy materials. Plumbs is a unique shop for Luton , providing a one-off specialised services to all its local customers. Due to the current building works in this area and the reduction of Parking Spaces , this company has seen a drop in its customer footfall and hence business . All business in this area require more parking spaces, not less spaces. The road width in front of these premises is actually wider than normal , and hence , even allowing for parking on both sides of the carriageways , there is still adequate widths for two way traffic flow. There is already only minimal parking on Kimpton Road and a red route is going to really negatively affect the shop holders in the road and make it impossible for the public to make use of their services. As a Kimpton Rd business user for the last 6 years and a Kimpton Rd business owner for 9 years before that, please leave the people alone! You have allowed 5 car parking spaces which always have the same cars in (residents presumably) and the bays towards the Hilton are miles away. If you want to drive people out of their business, at least offer them some compulsory purchase or alternative premises. Parking is not an issue on Kimpton Road because the road is very wide
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If this is put forward, there need to be some loading bays. This measure is another example of the council impacting small, local businesses. A red route means no parking and no passing trade ofr the businesses located in the area. Please enforce this, particularly along airport way at all times of the day. The cars parked along airport way during will eventually cause an accident and without heavy enforcement they'll just continue to do so. It will cause more congestion and will put pressure on the shops as there will be now were for the people to park I suspect that you want the shops to close so more flats and house can be built there in the shops place The alternative is to remove the ridiculous parking costs at the airport, esepcially for the 10 minute drop off I regularly use the bus and have done for many years. I have not noticed issues with traffic on this road and my bus is very rarely delayed. The only problem on this route at the moment is the building work taking place by redrow on Kimpton road. Once this building wok is completed I believe the issue will be resolved. Our money can be put to much better uses. There are some small local businesses on Kimpton road. We should be supporting small local businesses but by putting a red route on kimpton road you would be signing their death warrant, some of which have been there for years! There is a well established DIY business inKimoton Road. A purpose built layby has recently been installed. Restructuring parking would severely impacted this business. The volume of trades vehicles in the area have not caused any real safety or traffic flow issues so why the need to introduce restrictions in the future. I use the road daily and Kimpton Road us not the issue it's the other two being used as routes in and out if town. This would force the closure of and cause financial disaster for the families of the local business owners in Kimpton Road.cerainky Windmill Road and Airport Way nee to be the key routes with restrictions about not Kimpton Road. i frequently use plumbs diy shop in kimpton road and have done for 40 years.surely you could give the shops there some alternative parking an area on the building maybe.not everybody wants to shop in large impersonal stores.we won't have any small shops at this rate.give the small man a chance for a change Needs a major rethink. Red routes would have a real impact on the businesses in that area Make more bays available for local businesses, such as the cafe. Making these roads red routes would kill the local shops here. I use the food operators here, you have already reduced the parking and taking it away completely would be a disaster ! The biggest cause of traffic is the fact that they have never been able to get the access to and from the airport correct, I worked at the airport 10 years ago and since then they keep changing the layout claiming that this will improve but it never does your red route would not work as well as filling the pot holes all over Luton the roads are terrible and you should be liaising with local businesses to asses the impact rather than just forcing this change. THE BUSINESSES WILL SEVERELY BE AFFECTED IF YOU IMPLEMENT THIS AS CUSTOMERS WILL NOT BE ABLE TO PARK, THEREFORE I OPPOSE THIS RED ROUTE SCHEME please leave the parking bays opposite the shops in Kimpton road, they need support not making it so difficult that they close, or is this another plan to built more houses that locals can not afford !!!! There is a number of small businesses that would suffer greatly should you implement this unnecessary measure. This road is busy, but not congested. I have never experienced a traffic jam here. The road is wide, and free flowing majority of the time. By implementing a red route it will destroy independent businesses. Something you are meant to be supporting This will make it hard for any business along routes to trade. This is just an excuse to push out small businesses and to get money from the public unnecessarily. Try fixing the potholes
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Customers frequenting the area drive down, the restriction will restrict customers. There are only a few parking spaces near Vauxhall’s the rest of the area is double yellow lines anyway, get rid of the mini roundabouts towards the retail park and put traffic lights in which is much safer Rediculous. Small businesses fo fed to shut down for a “red route” The businesses on kimpton road and windmill road need parking for their customers - who will compensate them for loss of business? The very expensive busway has done nothing to ease congestion in town. Stop changing things that don’t need to be changed ensure that you have spoken to the people that use the roads and the business in the area before making decisions that will make them loses there business This will destroy local businesses. One shop there has been trading for more than 40 years. Why don't you leave things alone.In busy times there is congestion all over Luton.Spend the money on something more worthwhile. The shops on Kimpton Road will all suffer trade I utilise the parking bays to use the shops and cafe. This red route would mean I am unable to do this and therefore would mean me bein unable to frequent these businesses. There are business' on this road that will suffer. What happened to helping local small business' to survive. There is also a cash machine on kimpton road that is free of charge not to mention an entrance to ibc where people are dropped and picked up from work due to limited parking. With all the housing and the extra traffic I don’t think having a red route will help. Businesses along there rely on people being able to park. There are small businesses in this area that are not being considered in your proposal. This will cause them to suffer opposing to your ideas of supporting small businesses in Luton. Well established Local businesses will be badly affected if people can’t park Not enough parking. You can’t even get dropped off safely at the train station entrance in Kimpton Road and they are promoting public transport...... Needs bays for the shops that are on that road so you can stop otherwise these shops will go out of business What will happen to the businesses in kimpton road if you prevent parking outside. It appears that parking is over the road. How is this safe? Also will it be free. Businesses will suffer if people cannot park and visit easily. They will lose out to the big names on the retail parks just as the burger van did in gypsy lane when McDonald's was allowed to build there. These businesses deserve their own parking bays to be able to survive and thrive. Cars are parking on the pavement causing safety problem as pedestrians have to walk on the road with children and luggage. Needs to avoid parking by airport travelers Probably not wise to allow an estate to be built If Kimpton Rd is made a red route it will KILL the businesses along there, specifically Plumbs diy store. Why is parking allowed all over the pavements in Luton? Isn’t is illegal? Why not ban pavement parking like London and Exeter? Small family business's will suffer these people have served the community for many years It is important to protect the businesses, some of whom are long established and to protect employment. The proposed red route will make it difficult to find a parking space in this area for the shops such as PLUMBS. I am all for these roads being made red routes as I think it will ease congestion , the only thing that concerns is will it be strictly policed. Airport Approach Road is yellow lines but that doesn't seem to bother some drivers, especially HGV ones who regularly park on the road oblivious to other motorists and not concerning themselves with the traffic chaos they are causing. I also think that some sort of fencing or bollards should be placed on the pavement as it seems to be fair game now just to park on it or the verges regardless of the damage being caused. The area is also covered with litter and on occasions I have seen
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people urinating in the bushes. As a delivery driver and resident of luton , i use the areas proposed daily , the width of kimpton road and windmill means even with parking both sides traffic flow should not be a problem. I also believe a red route will cause businesses in those areas to be effected and in some cases even close down please don't put down our business thank we have lost many parking bay this road is not busy road we use shop in Kimpton road There are local businesses in the area which will be negatively impacted with the suggested changes I love joes...joes is life Have you given any thought to the businesses in the area that will be going into receivership Extend parking along kimpton road. To help local business. And will help with traffic along it. Will stop people parking on the side of the road and impeding traffic flow I often use the businesses on kimoton rd and windmill road. I will not be able to if it is a red route. The lay-by is always full now. You will be condemning those businesses to closure which would be a massive loss. this will have a severe impact on all businesses within the area due to deliveries and customers not being able to stop. To turn the existing 2 hour free parking into 30 min paid parking is no good to anyone. You’re deciding how long people are allowed to use these shops for. We want our customers to spend a decent bit of time there, the allowance of 30 mins will drive them elsewhere. , control by traffic warden or parking machine to be implement controlled by time or by camera the road will be no traffic more safer road Kimpton road parking bay misused by airport parking company and holiday makers who parking their car going for holiday traffic warden never come to this road Why ? if traffic warden do regular visit Kimpton read will be safe and no traffic please do thanks we use Kimpton road shop and sandwich bar quick pick on my way to work council making more difficult for shop user and road user look at the crawley green round about, the lanes and the lights do not work, and the whole traffic round the town is being held by the lights going up london road. the council is making more difficult to move around please consider the business holders on the Kimpton road who are here from long time. we are here from long time so it will effect our business too. I want to say please consider all the other things like the business holders and road users. Moreover you have to consider all the other routes which I already describe as above. Hope someone has traffic plan for when building work is complete. Not just more traffic lights. yes I think red routs would be good but the shops need short stay parking for their customers Currently having to walk in the road daily on airport way on my way to work, due to in considerate drivers parking on the pathway , only A matter of time before there is a serious accident, also the mess these people make is a disgrace some peoples first views of Luton our airport way and all the mess that is thrown along the hedge rows down the road this doesn’t create a good impression of our lovely town, buses constantly held up due to people stopping in airport way and the knock on effect it has other roads The Peking bays on Kimpton Road need to be of a sufficient size to ensure the businesses along there do not lose trade. what congestion on kimpton road its one of the widest roads in the town, what is going to not helped is the 3 sets of lights that have been added which are not turned on yet.And how is my wife meant to pick me up when i finish work as i work in vauxhall and she would not be able to stop outside the plant or should i just drive to work and add to the congestion through the town. currently l walk to work and get picked up in the evenings I use the shops in Kimpton Road regularly and they have decreased the amount of parking
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available, the road at this point is wide enough to have parking on both sides of the road and still have flowing traffic in both directions. As a pedestrian who is often inconvenienced by cars park wholly or partially on the pavement, I totally support the concept to red routes. However, they are only going to be effective if vigorously enforced 24/7 unlike the current situations where the restrictions are completely ignored when drives know that there are now enforcement officers on duty. Need a supermarket here as only Asda and look what happened when that was closed for 3 months or so last year. I regularly use the small business s on this route as do others some have been there many years what will happen to them Restrictions for Airport Way make sense as that road is extremely busy most of the time No to red route on Kimpton Rd Whilst red routes may be beneficial fir the Airport and its users it will decimste the LOCAL Businesses!!! I think the buildings proposals are good and will bring prosperity to the area Local business will suffer as they will be no where to park No stopping along this road will kill the small row of shops and mean more traffic going along Gypsy Lane to collect people from the train station and that road is already far too busy, even before the new school opens No abolish this scheme it’s does not work Don't destroy these businesses unneccesarliy, they are people's living you are messing with. Parking bays needed to keep locals businesses going If you put red route need to have parking outside businesses Parking for local businesses should stay and there should be a place for station drop off. It will kill small local businesses and besides building and road works will finish (hopefully soon) A Red Route on Airport Way and Windmill Road would be good but Kimpton Road traders need parking for their customers. The perceived view that there is too much traffic is probably down to the construction work of flats and houses. Red route will prohibit parking and ruin businesses in the area Clamp down on untaxed cars and private sellers selling cars occupying road space The airport doesn't do enough for Luton area Local businesses cannot suffer anymore! You need to make arrangements for us to park, even 30 minute bays, so we can gain access to the shops, or the small businesses will continue to suffer. Whst about the poor shop owners NO! The road is very wide and free flowing, can’t see problems with congestion. Parking bays for 30 mins and red routes will seriously effect business. Has the impact upon local business based in the area been thoroughly considered? By stopping access to the local businesses in this area you will, in turn, destroy the community shops. I WILL HAVE TO TRAVEL INTO THE TOWN CENTRE FOR SHOPS red zone will ruin local, small businesses which are a key component to a successful community. Why would you implement a red route on Kimpton road when there are business that have been there for years? Parking bays along either side of Kimpton road , even if pay bays , will raise needed revenue, but , stopping people going to any of the businesses will , inevitably , see the demise of customers thus leading to the closure of said businesses and no more payments of rates , taxes or any other government charges they owe , this is tentermount suicidal , not to mention putting more people out of business and out of work!! Rediculois and unnecessary!!! Save our local businesses Local businesses such as the shops and cafes opposite the new Redrow development will
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suffer due to customers being unable to park. Please can you ban parking all four wheels on the pavements Small businesses in the areas suggested for the red routes currently rely on passing trade and on the ability of people being able to stop outside their business. To introduce red routes and stop the accessibility of these areas will send the small businesses mentioned under and destroy the lives of those who run them. All of the business on the road will be killed off Also why restrict local businesses ability to attract trade and with it your ability to collect rates from them? I think you need to think of the impact in which it will have on businesses. Where will customers park and deliveries etc. As above - aim to help people continue their business in a positive way, rather than make life more difficult. Introducing a red route will impact negatively on the small businesses in kimpton road. i use the shops in kimpton road and parking is a disaster as it is, how am i supposed to stop on a red line! There are small local businesses along Kimpton Road who rely on face to face custom. If there is limited or no parking along this road their businesses will suffer. Surely we should be supporting our small local businesses that already have enough to contend with. No loading bays will also have a detrimental effect as deliveries will be harder to accept. Use our money on things that are worthwhile instead of wasting it. How does the council expect local businesses to to exist and give employment to local residents whilst continuously putting barriers up to stop trade with sky high rates and lunatic ideas like this Businesses will lose out if no parking. Great idea something needs to be done about the inconsiderate parking along many of the routes this should be done around schools also I drive through this road nearly everyday, i frequently stop and use the shops situated opposite the new houseing development. It is a struggle to park there as it is never mind making it a red zone! if anything, more parking should be available to help local business down this street continue to prosper and also to make sure that people do not start parking along the road in the estate causing problems for actual residents. I don't think this has been thought through. What will happen to the small businesses in this area. These red routes are totally unnecessary. We need the pot holes in the roads filled and more adequate, affordable parking in Luton. I've never witnessed congestion along these roads which I travel every day. Please consider the businesses and customers that go to those businesses on that road. I often visit the café and the DIY shop on that road, if I wasn't able to park there it would cause great difficulty. There is no need to do this as the buses have been on the same route for years with no difficulty. the only issue that occurs on that road is when there are temporary lights due to the works going on. A red route will badly affect local businesses which are already struggling. I am concerned about the welfare of the shops on Kempton road, how are they going to survive without customer parking, I don't mind parking up near the shop but I don't have the time of energy to walk from the parking bays opposite the hotel. I am interested if you will go ahead with this project regardless of the outcome of the survey, we have discussed this in our office ( quite a few use this parade of shops for its convenience) the general opinion is that you are going to do it anyway and the questionnaire is just a way to go through the motions😡😡 We should be looking at ways to support and promote local businesses! Not making it impossible for people to access them. The following comments are made from the point of view of the management of the Hart House Business Centre. The disabled bay outside Hart House should be removed. It does not serve a useful or necessary purpose, and is frequently abused. The footpath at this point is extremely narrow, making it dangerous for pedestrians. Removing the disabled bay will
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enable to footpath to be widened. The bay is used as a general parking space and this will increase if the red route is implemented. We have had experience of people parking in this bay blocking the driveway to the Hart House car park. Disabled visitors to Hart House are able to park in the car park at the rear of the building. I work at the airport so use these roads daily, and they don't even have high levels of traffic. Unless you're anticipating a massive traffic increase from the development on Kimpton road. Which you probably are.
Fed up with the council ruining this town, more fines, more cameras. Just stop it. No consideration for the small businesses operationing, this would shut them down This scheme is not before time. Especially in Dunstable Road and Leagrave & Marsh Road. Leave it alone- you've already taken nearly all the parking away We have a businesses in leagrave and Dunstable road and red route will make our business shut down What thought have u given to the poor small businesses trying hard to earn a living (absolutely nothing) all u r interested in is killing off the small shops, as a council u should be helping Will effect local business If you are using Red routes along Kimpton Road, you should have more parking adjacent to the Sicilian Cafe and adjacent area for shoppers using those facilities with a 30 Minuit Max stay to stop all day parking. There are local businesses on Kimpton Road. All removing parking spaces will do is facilitate the closing of these. With the new development across the road this would be perfect for the businesses. Your going to ruin local businesses getting rid of the parking You will be cutting of local business in this area. You should take all this into account as this could result in more shop closures and less likely the public can assess this area without a car ! Apart from the potholes, the Kimpton road is the best part of my journey. Its easy and quick as well. So I feel making the Kimpton road a red route is not necessary. Spend the money on fixing the road condition i.e. the pot holes!! I drive through kimpton road every day to commute to work in St albans and never have any issue with congestion on that road. I believe the money could be better spent in other areas, crawley green road is the worst road for congestion in the mornings. the potholes along kimpton road need attention. I feel this proposal is just a waste of the councils time and money, where there are more pressing matters to see to. we use a few of the amenities on that road -if you apply a red route we will not be able to park and use them - you will destroy the local community Fix the potholes!! We feel we are fighting a constant fight to survive. Please leave Kimpton Road alone. We've had battle after battle with road alterations and proposed plans to change what has always worked perfectly well all these years. Our businesses will not survive red routes and it's certainly not needed. We are not in London! Introduce more pay and display areas and extra loading bays As mentioned above bollards on the path on Airport Way are also necessary as current issue is cars/minibusses parking off road on paths/verges. Red lining will not work without enforcement every day. Additionally, redlining Kimpton Road near gate 2 of Vauxhall will create a big issue at shift changeover times (0600; 1300-1400; 2100-2200). This will kill the small business in this area You will close down many small businesses if you implement this. Local businesses need on this route need parking spaces. If anything we need more parking bays Implementing red routes is a terrible idea and will destroy the small businesses on Kimpton road.
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If the council built affordable parking then people would pay
I fully understand the need for traffic flow. However has any consideration been taken in mind as to how these business’s that are fundamental to local people will continue to trade. These business’s rely on foot traffic and passing cars to survive. Give them designated parking bays for customers If this is implemented a whole row of businesses that have been there for years will die , you did not consider the impact on those. It’s unfair to wipe out local businesses by creating no parking for their customers , look at that first ! how are businesses supposed to operate if customers cannot access them? Small viable businesses on Kimpton Road will suffer. There are businesses along this road that rely on people being able to visit. This is a disgusting proposition! The roads proposed for the red routes do not suffer with congestion. I regularly use some of the small business on Kimpton Road and to stop parking outside these shop would be a real shame. This will basically shut down the business on that road!! customers can't access shops, deliveries cannot do their jobs either. This is has clearly not been thought through and the money and time invested could put to a better cause. See above. Businesses in kimpton road will be badly affected. There are problems sometimes during peak hours. Your proposals are a sledgehammer to crack a nut and will inevitably lead to penalties for Luton residents for no good reason. Get some proper traffic consultants in to work out a integrated solution to the problem. Not a piecemeal solution that you currently propose put in parking areas so kimpton road can be used , and the shops and café can be used or you will put them out of business Business would dramatically decrease for cafes etc along this route as customers already struggling to park would simply be unable to use the services any more. Small business has been impacted with every change for the car industry so closely linked to this area and further restrictions would impede new custom. This red zone will surely have a detrimental affect on the small parade of shops - there is not enough parking in the bays for this and if people can't park they will go elsewhere. Thanks very much Luton council, you have over the years gone out of your way to destroy the parade of shops on kimpton road, you have removed parking so the development on the Vauxhall site can begin, the rest of the parking you in your wisdom move the parking down the road that is convenient for the hotel but not convenient for customers who quite frankly won't walk that far. But you know this - how many letters and signatures have I presented to you since you started to destroy my business? Thanks very much LBC - you lot try a real job, let's see how you get on with your own business where the very money you take home at the end of the day is relevant to how many walk through the door. If you carry on with this plan i am going out of business There's loads of room on kimpto n road,congestion has never been a problem but recently parking has, Why should we be penalised and not be able to have deliveries, just because the road is busy. The problem is the factory over the road BWI which has lorries build up onto the major road and the roofing place down the road trying to get lorries into their yard, both of which we were told when the council gave them permission, wouldn't happen. We had no problems before. We have no problem with cars parking on the yellow lines. It won't ease congestion, improve air quality or help with noise. Waste of council tax money. 1/2 the people along Windmill Road are only here for 6 months and then move elsewhere as most houses are bedsits or HMOs. We have been here for over 30 years and it is only since the trading estates and factories have opened up that the road traffic has got busier. Airport users and employees often park on the pavement and disused car park entrances(old Vauxhall car park) on Kimpton Rd. Would the red lines mean vehicles can not cross over them to park on the pavement old car park entrances.
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You need to clear the gullies and verges along this stretch. It is an eye sore of rubbish and litter Hard to tell about Windmill Road because of the new developments at an early stage. Luton should join London in banning all parking on pavements. This will harm small local businesses and potentially the new estate that is being built. It does not take much imagination to improve traffic flow by enforcing laws that already exist. Thoughtless people block roads because they know they can get away with it. Get more wardens and police out on the streets with real powers and the project will be self funding Think of the small businesses trying hard to survive and earn a living on that rd I both drive and cycle this road frequently on my commute to the airport and the number of inconsiderately parked vehicles is dangerous and adds time to the commute (which has the added side effect of adding more pollution from vehicles). I have seen many complaints that the proposed red route will harm local business by taking away parking from potential customers, but in my experience these customers are currently illegally parking on the double yellow lines in the area and are the prime cause of the traffic problems at the town end of Kimpton road. Further towards the Airport people continually park their cars on the footpath or block the road. This denies use of the footpath to pedestrians, slows traffic into and out of the airport and generally gives a very bad impression to those visiting the town. Another concern I have is that as an Airport worker we a constantly told to report any suspicious behaviour of people/vehicles in locations they should not be, the number of illegally parked vehicles on the roads to the airport and around the airport itself makes this very difficult the new housing development where vauxhalls used to be will add to the congestion due to the traffic lights. what is the purpose of creating a red route at this stage - was not the impact of congestion considered before the go ahead was given to housing development? Better policing of the parking restrictions along Wigmore Lane. A new road round to link the A505 above Luton to the new Airport Way. It is ridiculous to even consider red routes for these roads. The existing parking restrictions are sufficient to deal with any parking problems if properly enforced. Furthermore red routes have nothing to do with road safety; unsafe parking can be dealt with by use and enforcement of yellow lines. I use this route to and from work daily and stop along the way in the parking bays to visit the sandwich shop, cafe or shop. Making these routes red routes will stop this and these businesses will not survive! Kimpton road is not a road that suffers from heavy congestion. It only has heavy traffic at rush hour, which is no different or lighter than elsewhere in Luton. The parking is essential for anyone visiting local businesses on that road. I visited the consultation outside the Library on 22 May. The people there not only failed to provide information in the library that the consultation had been moved, but were clearly unfamiliar with any of the roads affected. When I asked questions about specific places, they did not know what I meant, and did not know, for example, about the access to the station. There is no point in providing consultation points if the people there cannot answer questions. The Council have given permission to build new homes so they should ensure there is adequate parking for the new residents and visitors and not try to destroy existing businesses by removing the availability to park outside for the customers. I think red routes will not help down Kimpton road. There are businesses and residents that will suffer greatly if this goes ahead! I believe that the businesses on all these roads would be ruined as nobody will be able to park near them Give more parking to the small businesses. Luton has a major problem with cars we need to become less car friendly Windmill Road certainly does not need a red route, particularly where the very few small
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businesses are. There is a parking bay there, and this serves that small area very well. It will be disastrous for the small business in that area and it’s ridiculous that you are even considering Give shops more free parking Give the shops more free parking If you close this road, you have to take into account the business that “YOU” alone with be closing. If you close this road of people that have been using it for years with “ease” will not be able to. They will not be able to. You are in turn making shop close due to a road closure that doesn’t make sense for the residents of Luton. The welfare of your residents should be your priority and the business that are there. Why make more shops close and have less foot fall in Luton?! You shouldn’t make this happen and rethink all the other options that need addressing in Luton . Seriously these businesses need customers if you take away the parking how are they meant to survive... As above I personally think you will ensure the survey goes in your favour, the red route will go ahead regardless of what we do, if this does happen I will insist on total transparency on how the votes have been collected, hopefully honestly and not by doing your survey while sitting in your offices repeatedly filling out the survey! More free parking outside shops There is no proposed drop off for the Kimpton Road entrance to Parkway station. With the future DART terminal also being in this area, both will be detrimentally effected by the red route. No Comment It is particularly obnoxious that you propose to prevent cars stopping along the Kimpton Road by the pathway leading to Luton Airport Parkway station. I have dropped off passengers at that point many times as it leads directly to platform 1 for trains to London without requiring stairs/lifts/escalators. With this proposal there is no gap at all on the red line along the road making such drop-offs, which seem entirely harmless, against the law. As a result those who do this will have to drive a lot further, causing further congestion, to reach the main entrance of the station.
The shops on Kimpton Road would suffer from this, and nobody would gain. Once the Redrow development is finished, I could possibly see the need to revisit this in the future. But at the moment, it’s just not required in this area. I truly believe these red routes will have a dreadful impact on small businesses and shops. Why not put parking spaces in place just for the customers. It is good idea Its a greedy idea , who would think this would do any good ? Ensuring that there is a safe drop off zone for Luton Airport Parkway is more important than implementing a red route. It is dangerous at the moment as there is no safe drop off zone. I’m very concerned for the small business’ along Kimpton Rd, who are already struggling to survive. Strongly disagree with this idea!!!! give the shops more parking spaces free for 15 mins I don’t have a problem with congestion in this area, just a bit busier with the new building work going on, just will cause a problem to the businesses in this area, how r we to visit them?? Waste of money that can be better employed elsewhere. The shopping parade in Kington Road relies on trade from customers who have to travel there by car, allowing no parking for customers and deliveries will destroy there businesses. Given the width of the road at this area, I have never experienced any traffic holdup at this point. There does appear to be large amount of apparent long term parking by the builders etc working in the area. This can be dealt with by restricted time parking rather than Red route. It should have been done long ago
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Improving the road networks by upgrading single carriageways to double would be a start Kimpton road is very wide It has an entrance to parkway station I drope off and pick from there If red route you cannot use that entrance to station unless you walk there Not having parking or loading bays is going to make local businesses especially smaller ones suffer or have to close... A similar system operates internationally - with tighter taxi control. It was not welcomed initially. However, the results have proven to be effective for all parties. No further comments Stop the parking !! You will be ruining small business’s Great idea With the development of Napier Park making parking restrictions over and above what is now restrictive . l would think would not help occupancy I used to live in Bournemouth, they used parking attendants on mopeds to capture illegals parked cars, and the amount of tickets one attendant could issue in a day, outweighed the cost hugely. Inconsiderate Parker’s in the airport and Vauxhall area is a real probed, it’s the main reason we moved last year away from eaton valley road. But it seems nobody really cares, the perking on double yellows on the airport road, the parking on banks at the old Vauxhall car park entrance on the 505, is really infuriating. It’s the same in stopsley high street. My friend owns a business without parking nearby they will go out of business, I think some enforcement is required, to be honest allowing free parking for two hours is asking for the system to be abused hence all the people parking up all day,however I think some free initial parking close to the shops is needed, 15 - 20 minutes just so the shops can make some money This will totally ruin businesses in this area as there is very little footfall, most people come by care & there are very few parking places. Make sure there are enough parking spaces outside the shops on kimpton road. the local businesses need customers to be able to stop. the road overall has enough space to create more parking bays. make the bays free but put time restrictions on them a certain cultural group in this town have no regard when it comes to parking. this is a good step in the right direction I use the shops on a regular basis and would like to see an improvement to the spaces outside the shop, & I don’t want to have to pay for the 10 mins I will spend parked there. Proposals for A1081 and A505 seem approprate but same results could be achieved with loading/unloading restrictions with enforcement. Red route would be superfluous Total lack of thought for train users and the local shops with this red route proposal. We are the property managers for the Landlords at Barratt Industrial Park, Airport Way, Luton, LU2 9NH. The tenants at the industrial estate have seen a growing issue with the parking on the estate and on the road onto the estate. This is both cars parking on the estate road and on the estate and on some occasions leaving their cars park on the estate while they are away on holiday. This is used by taxis, private hire vehicles plus general public vehicles - which is not only causing access obstructions and parking issues on our estate but the litter that is thrown out of vehicle windows and more recently the re occurrence of human excrement on our property is a total disgust. With the implementation on airport way of this red route this will only make the situation worse as they will no longer be able to park on airport way which will mean more cars will be waiting and parking on the estate causing a huge issue for the tenants. We do not endorse the red route on airport way and feel this will only detriment local businesses. Existing businesses are struggling already without implementing this proposed scheme No parking on red route during operational hours Red routes will affect the businesses currently on this road. Which is unfair as they have been here along time. Time to protect our smaller independent businesses It would really help if we could have minimum stoppage outside the shops on kimpton
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road, 15 minutes would be good - ideally free, this would enable those customers wanting a paper or a sandwich the opportunity to stop off and then be on their way. Whilst in principal red routes are a good idea, they will not be enforced- FACT! Local businesses in Kimpton Rd will close at a time when their business should boom due to the housing estate opposite - FACT More taxpayers money will be wasted - FACT LBC don’t listen to the people so why bother asking for a survey - FACT I agree with Luton borough council red route proposal Please see above. The family who run the Sicilian cafe have put years and years to build up their business. stop people parking on footway in airport way I hope the proposed parking bays will be sufficient to allow the business to continue to thrive. As a long standing customer of the Sicilian cafe and other local business on the proposed “red route” I strongly believe imposing such a thing would have a very detrimental effect on the businesses that operate on this route. These roads aren’t actually too bad. Kimpton Road is a wide road with good visibility. Though there is a lot of development meaning it will be used more in the coming years. If you want to sort congestion in luton put a red route in bury park where there is congestion every day I travel through Luton regularly for business and do not find an issue with travelling on these roads. In particular I regularly visit the Sicilian Cafe on Kimpton Road and if I can no longer park I will not be able to visit. The building of a new high school on Gypsy lane will only increase the problem parking in this area, particularly when you consider that its catchment does not include the area in which it is built. Thus all the pupils will be commuting to school! The main hold up in the area is the additional sets of traffic lights being installed at the new entrance to the new housing estate As a person who uses the shops regularly on Kimpton road I feel this will be very detrimental to the lively hoods, please use traffic wardens instead to patrol the area on a more frequent basis. No opinion on Airport Way, didn’t think you were allowed to stop there anyway. But provide Airport drop off somewhere that doesn’t cost!!! There’s nothing wrong with Kimpton Road. Traffic flows through there with no problem whatsoever, so much so that the traffic lights aren’t even turned on. By implementing a red route through Kimpton Road LBC is single handedly determining the fate of those small businesses who have been there for years. There’s no point with a red route. Especially on Kimpton Road. It’s one of the widest roads in Luton and the parking there does not cause congestion. In fact I have never been seen congestion on that road in my 30 years in the town. Removing the spaces on this road will only put the local businesses on that road under which does not help the community. A red route on kinpton riad will not help reduce congestion. The road is fine. The money should be spent on better infrastructure solutions where there is an actual problem. I dont see why kimpton road has been chosen as a problem area? I do not think there is a problem in Windmill and Kimpton Road with parked vehicles causing congestion.Airport Way is chaotic with parked cars and lorries and needs attention. Kimpton road does not have a traffic issue. Hundreds of homes about to be left as a non red route. In some places its 16m wide. The issue is bury park and in town. This red route is totally and utterly unnecessary. Don’t waste money on something that’s not needed. This will only cause misery for the local businesses and residents. There already isn’t enough parking for the shops on kimpton road, removing what little is left will be a death sentence for these businesses which have managed to get through the previous changes made to the parking. I don’t believe there is significant traffic disruption to warrant placing red routes in this area. It would also cause issues for the local businesses as there would be no parking for
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customers. I regularly go to the cafe on Kimpton road, therefore my perspective is as a customer who would be affected by these changes. No The red lines will make small business in the area suffer as people cannot park close to the shops It would be nice to see parking closer to the shops, I’m finding it impractical to park all the way Down the road just so I have to walk to get a sandwich A patrolling traffic warden would be a better option as they can use some discretion which cameras cannot. Makes no sense whatsoever when there are still business on Kimpton Road - where on earth do you want their customers to park? As a regular user of this route I have never found that people parking their cars were causing delays or obstruction. There fore the use and implication of a red route would be a serious waste of tax payer monies . In kimpton road congestion is intermittent and is caused by roadworks. The parking is not a problem and is essential along this road. Provide more free time limited parking spaces like there was before. Why don’t you put a Red route in Bury Park which is a nightmare.It gets so congested that emergency vehicles couldn’t pass along there. Implimenting this will affect people from using the local shops causing more small businesses to close This will ruin the the shops business that have been there for years I go through this area, and have never witnessed any traffic issues . Whether the development in the area will make a difference , is yet to be seen. The new airport way has taken traffic out of the area, I can see no point in a red route Leave parking bays in on Kimpton road to allow use of shops by passing trade possibility of 15 min free parking them Pay and Display We have seen previously the chaos caused by L. B .Council trying to improve traffic flow. I.e. Traffic lights at the roundabout in Vauxhall way. There are other examples sell over the town. Leave well alone and do something constructive! It is important to have sufficient parking bays along Kimpton Road for vehicles waiting to pick up at the airport. Rather than a redway, more attention needs to be paid to preventing vehicles from illegally parking on the pavement in Airport Way, especially on the hill. As a pedestrian walking from the airport at night, I have had to walk in the road because the whole stretch from the food factory to the roundabout opposite the Vauxhall van factory has had vehicles parked with four wheels on the pavement. Further, consideration needs to be given to the shops in KImpton Road. As the Redrow estate is completed on the old Vauxhall site, even more people will be likely to use the shops. Therefore, any plan should consider sufficient parking for their customers. Any parked cars on Kimpton Road do not obstruct the existing traffic flow lanes. Ensure that the road infrastructure is in place and established before any development on the Airport business park takes place This is only designed to ease the flow of traffic for people making their way to the airport in line with LBC and LLA’s desire to double the number of passengers using the airport - this is nothing but corporate greed. The red route should also be extended to Archway Road off of Marsh Road, this road is very unsafe for crossing especially near the Archway bridge and Sarum Road. Sarum Road should also be considered as this road always has cars parked on the pavement between 8am-6pm, even though there are double yellow lines. There are never any traffic wardens checking, and I think there should be cameras to deter people parking on this road. There is a public car park off of Archway Road that is always empty. This needs to be looked at because as you are aware the volume of traffic in this area is already too high and there will be accidents caused if nothing is done about it. Stop making it harder for us car drivers! The luton busway is a disaster, you could have created a new road instead only barely full buses can use it, and at what cost?? Do your road planners
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even drive??? Stop making parking so difficult, small businesses rely on through traffic and the ability to easily park We need closer parking to the shops, the provided parking is too far for our customers. I would like to suggest that any extra parking that may happen only have a 15-30 mins waiting, my business requires a high turnover so a 2 hour waiting is going to do me no favours. The parking right out side the shops should be the same and preferably the residence park down the road and come back at say 5pm as none of their cars move through the day, one of them catches the bus and leaves his car. This plan could also be the death knell for the small businesses located on Kimpton Road. People will no longer be able to park and pop into the shop / cafe / DIY store. If a red route is introduced there MUST be short-stay bays (15 mins maybe?) to allow this to continue. Something must also be done to stop on-road and on-kerb parking related to the airport. It is becoming a real nuisance over an increasingly wide area around the airport
Have the traffic light timings for the whole town reviewed so they work with the traffic rather than against it (i.e. not showing green lights at junctions with no traffic) If you can’t park at Kimpton Road you will destroy local businesses. I use the kimpton road entrance to the train station and get dropped off there every morning, because the bus does not go from my area to Luton Airport Parkway. If a red route was installed, i would not be able to get to get dropped off at the station, which would impact my life a lot, seeing as i am dropped off at 7 and picked up at 5. This has not been though through and should not be implemented. Windmill road from 43 to no 61 has a small parking bay which is meant for residents. But is used by the 2 factories and the industrial unit employees and vistors even though they have their own ample parking in their factories and units. Also it has now started being used for Luton airport parkway.the residents in street have knows here to park during day. And sometimes have no option to double park on windmill road. With the red route going through windmill road this would not be possible It is not now time to make this part of windmill road resident parking only as well This area does not have a congestion problem cause be parked vehicles. A better traffic management system, to keep the traffic flowing is necessary. Congestion has been caused by roadworks, and expansion of the airport. When work is completed, all will be good. Enforce double yellow lines on street corners. This suggestion fo a Red Route is trying to fix something which isn’t broken. The way Kimpton Road is laid out currently is fine apart from the layby outside the shops. The construction site is causing issues on the road at the moment, this is not being monitored by the Council. Lorries are being off loaded in the carriageway by tower cranes, this is dangerous and a hazard to other road users. We need small businesses in this. Area The small businesses along Kimpton road could suffer due to the proposed red route. There is a parade of shops that will not get any business if there is no parking in the area. The only parking problem is people parking at the cash machine further up the road Allow parking bays and then put your red route in too keep the local shops open the new residents on the estate will need them and so do I . They provide great service There needs to be parking bays on Kimpton Rd for the businesses to survive. I use a plumbing shop along there & without the parking bays outside it will be impossible. Bays with 1hr parking will be best there. Over development of unaffordable housing, putting local people and business last. Putting parking restrictions will affect small businesses which need parking in these areas. Congestion is a flow issue, redirect traffic around these areas, parking restrictions affect the locals as much as businesses, change the viaduct roundabout light sequence so one load of traffic can go around in one go, a ten second extension can make a huge difference to the current timings rather than clearing 2 sets of lights only to get stuck on the 3rd it can be achieved in one pass. Batters way needs more attention I’m my opinion, try turning right in traffic on chaul end lane when everyone is turning right round the roundabout only to get
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locked out of joining unless you become an obstruction to oncoming traffic. Absolutely stupid idea loads of small businesses there that need to councils support bin this ridiculous idea on kimpton road a very cross council tax payer get the works traffic to park were they work, so people like me DISABLED can park and go to the shop that has served me and many others for years.
Kimpton road has a short parade of small businesses along it that it is not possible to get to on foot. A red route would not only prevent passing trade but mean they were not able to load and unload goods. There is currently building work opposite side of the road, so if congestion is such a big problem maybe use that as an opportunity to widen the road there to allow parking as well as traffic. The road is plenty wide enough for you to sort something out The current Luton council seems determined to ride rough shod over well established and necessary establishments. If you don’t leave the availability to park at Plumbs then the new residents of the new estate opposite will be forced to get in cars to venture further to buy a packet of screws, tiles, wood etc Please explain how this helps reduce traffic. Most of the parking along Kimpton road is down to site development. Your planning department are rubbish! These shops on Kimpton Road would lose their livelihoods. People depend on them. Allow small businesses to thrive and stop trying to impede there abilities make a living by adding a red route these Small businesses won’t get passing trade and as there is noparking close enough it will become a derelict piece of land with businesses unable to make a living. Probably another council ploy to clear the business and build something new that will fit with their plans of redevelopment What consideration have YOU made to support the small businesses located upon Kimpton Road? These guys rely on parking outside their businesses which is inadequate as it is. The development of new homes adjacent to this has placed even more pressure on this due to delivery and builders vehicles. The answer is not to further restrict this location. I would have thought LBC would promote small business, not take actions to destroy them. Several small local businesses are on Lipton road and implementing this red route will be severly detrimental to them. I have never experienced any issues with parked of stopped cars on Kimpton Road and Windmill Road. Also you should be supporting small business on Kimpton Road by keeping free parking. By introducing a red route around these areas, it means that people who usually park there to wait for passengers arriving at the airport will move further along ending up parking in our roads, which they already do. So in theory you aren’t fixing the problem but instead moving it elsewhere. A waste of time and money to solve a “problem” that does not exist! This will also destroy the local businesses along the road. another way of making money Too many people living here. Roads & parking are dreadful. If there’s an accident it’s gridlocked. Build a flyover I see the progress to this area daily as it’s part of my route to work and I’m excited by what’s to come. However local businesses need local support and driving and parking are 2 essentials when accessing services. I understand and appreciate the transformation that the town is undergoing but let local businesses be a part of that as well. this will kill business in the whole area including any new business that may want to start Family run businesss rely on the people to come there shops, you wil put them out of business. It will effect the family run business on the parade of shops that rely on costumers Why try and cut off a new community? It is not fair to penalise the shops in this area, they need parking to keep trading. This proposal has not taken into consideration small businesses trying to support and service the area. How are we to get to these places on Kempton rd with restrictions in place? It is
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not right to be pushing more business out of the community without looking into the impact this will cause. I can’t believe in a country where we go on about saving our local businesses the council is even thinking about this. Putting the red route in will kill small businesses that have thrived in the area for decades. These people provide jobs for others. Loss of these jobs will make owners and workers suffer financially Making a red route on Kimpton rd would be a death blow to the businesses there & traffic on that road would be alleviated by allowing anoth route to the train station & gypsy lane A red route will bankrupt the businesses that operate near the recently built layby, such as Plumbs diy, the paper shop, cafe, sandwich shop etc. I use these shops, and with nowhere for customers to park they will die. Whats the point of having a red route when there are 3 new sets of traffic lights that have been just put in Adds on monorail and Thameslink between airport and railway station to the town centre. Now proposal plans for the Transportation Authority The whole set of three red route proposals is entirely welcome and well-received I use the vauxhall van plant, north car park where the entry and exit loans to airport way. Most weekday evenings at 22:30 pm there are cars parked up on the pavement waiting for their airport passengers restrictingthe vauxhall employee drivers view down the road, makingit difficult to then right into the road. This is also made more difficult and dangerous if the _ parked car is sitting there with their head lights on, oblivious and ignorant to the dangers they are creating whilst on their moblie phone. I feel the proposed double red lines is to be marked along airport way, which I hope will prevent cars mounting the pavement and parking there, before on of our vauxhall collegues ends in a serious accident.
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Appendix C – Marsh Road, Leagrave Road, Dunstable Road comments
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Do you think there is an alternative option to ease congestion, increase traffic flow and make the roads safer in this area? Please use the space below to tell us what you think. Have buses stopping in bays rather than in the middle of the road and more pay and display parking available Yes relocating the bus stop outside 310/312 leagrave road. Congestion in bury park is caused mainly by buses having to stop on the roads and not having an indent in the massive pathway to stop at. Also there is always cars/vans outside AA carpets that leads to a build up of traffic right down leagrave road, AA carpets needs a loading bay indented into the massive pathway. Use time restrictions Make a bridge between leagrave road and selbourne road.
Bus bays Speed humps. Create appropriate stopping spaces for buses. Remove excessive pavement size on both marsh road and bury park routes. Provide more appropriate parking especially considering the council’s liberal granting of commercial licences and permissions for flats/HMOs. There probably is another option, but the red route is not the answer, as it would effect hundreds of people’s lives and livelihoods, and it’s the buses that cause the congestion as they have to stop for the passenger. If there were busy passages by the road side it would be lot better. Yes reduced pavements and bus lay bus as well as parking lay bys Get rid of wide foot paths and out back the roads back to what they were 10 years ago. Maybe have parking times Yes, remove the bus stop outside 310/312 leagrave road and relocate it in between holland road and norman road. There is no problem so why do I need to give an alternative? Create bus bays in the main busy areas like it used to be, especially bury park area.. we do not need large footpaths to cater for the busses, take them away and create a bus bay it will ease traffic flow Re introduce bus lay-bys Limit the amount of cars per household. Yes there is a easy way and it’s so simple and I hope you agree with this and maybe carry out a survey about it as well. I believe that on Marsh Road there should be a change of Road Layout to ease the traffic. The areas where the pavements are wide and can be amended to accommodate cars to park inwards in to the parking bays and this would also allow a bus stop in this new area where originally there was a large pavement area. The same goes for Bury Park area. There is so much pavement area which could be used to have inward parking bays and again it would accomadate a bus parking stop away from the road and allow the traffic to flow. There are other areas of Luton where the shopping parade has this sort of parking and it helps. Having a red route in a small congested town like Luton really isn’t a good idea. I think the aim should be to create more car parking spaces so people don’t have to double park and this can be done by widening the pavements.
Make more legal parking available. Make some pavements smaller add more parking and loading bays especially in bury park and marsh road More parking spaces needed I Bury Park Keep everything as it is but add double yellow lines and more patrols. Make Dunstable road one way. More loading bays on Dunstable road so no congestion anywhere.
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Make more parking for local businesses if implementing red route Bus stops should be move or allocate them space off the road Not sure yes, bring back the bus lay by to allow traffic to pass the buses no Double yellow lines More patrols. This problem is of the councils making - it has never enforced the current controls adequately; hence the problem. It will be the same with red routes unless it is properly enforced. I think this will make the road a more dangerous also parking will become ridiculous and dangerous in many places Need more parking in the areas. Proposal has very limited number of parking spaces. Providing adequate parking would avoid vehicles stopping in affected areas. Cameras More patrols to enforce no parking Sort out the timings of the traffic lights along Leagrave Road crossroad at Blundell Road towards town, they stay red too long. Have more parking spaces near willow way and the army place. There is nowhere to park to go to the local takeaways and shops near there. This also applies when visiting the surgery on Gardenia Avenue and nearby chemist More offstreet parking Speed cameras More patrols Urban clearway Kindly please follow what Hackney borough council did in past. Put parking cameras in Burry park. Please Stop people parking on double yellow lies. More enforcement officers patrolling the area. Speed cameras. Parking bays on one side on the road Spread out the bus routes. To make the roads safer you could try and keep the traffic at a minimal. Radical increase of control and clamping illegally parked vehicle’s No No Make bury park a oneway system to ease the flow of traffic through leagrave road leading to Dunstable road, there should be designated area’s for buses to park when picking / dropping passengers off...loading bays need to be ingressed into the footpath to allow the flow of vehicles... There should be traffic cameras along with traffic wardens to issues fines for illegal parking Double yellow lines More patrols I think the red route will work providing it is enforced at the moment warden only come down at random time once and thats it for the rest of the day. As a bus driver it can be very difficult to get through these areas with cars parked both sides. The little road outside nadeem plaza the allows you to turn back should also be closed off as it diverts traffic back on it self. The only alternative is to have real enforcement that does not walk past offenders and allow them to park on the road. marsh road is very bad for loading and unloading but no when is ever given a PCN so red routes should work More traffic wardens/ cameras Urban clearway Double yellow lines More enforcement officers patrolling this area especially when weddings are taking place. So weekends between 12pm-4pm and 7pm-11pm and during half terms between 12pm-4pm and 7pm-11pm Speed cameras Double yellow lines
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More patrols by ticket officers Only more enforcement on the inconsiderate parking both sides of road Greater efforts to prevent inconsiderate parking of delivery vehicles particularly in Bury Park area. Build a bus stop using pedestrian crossing so that bus can slide off the main road and its safer for everyone. Pedestrianisation of bury park- 1 way, only allowing buses, deliveries and taxis. Even trial pedestrianisation on certain days to see effects and benefits / have certain days car free. Needs to be ring road/ link road to skirt round bury park/ have parking at one end. Not really The buses stop in the middle of the road in Bury park - this causes the most congestion. This needs to be stopped. Up in Milton Keynes, the council employs teams of traffic warden who patrol in numbers and are a visible deterrent. There should be 24/7 teams of traffic wardens in the key areas of Luton.. IN BURY PARK PART OF DUNSTABLE ROAD TEAR UP THE SILLY BLOCK WORKIN MIDDLE OF THE ROAD INSTALL PROPER PARKIG BAYS WITH LIMITED TIME ALLOWANCE IN THE BAYS AND START FINING PEOPLE IGNORING THE RULES... MORE PARK WARDENS ARE NEEDED TO WORK IN PAIRS IF NEEDS BE TO COMBAT AND BRING ORDER TO CHAOS THAT RESDIENTS BRING TO ThE AREA CURRENTLY. Actually police the area. Years ago, PCSO’s were regularly seen in these areas, ticketing cars parked illegally, even in the surrounding residential streets. Removing these patrols has lead to an increase in inconsiderate and illegal parking Parking cars on pay parking. Speeding cameras Double yellow lines Yes. First of all this big long busses are not designed for roads in this area, and all the businesses will be affected and people will not come to the shops due to not able to park. Why you can’t use the new busway more? Where you have already spent millions? To make the traffic flow better, make the traffic lights system better which is around the Nadeem plaza and make red route only the bury park between Nadeem plaza and Sainsbury’s. Leave alone as it is leagrave road between traffic lights near Nadeem plaza to sellbourne road mini roundabout. Our roads are small so instead of killing our small businesses by making red routes invest in smaller busses. Make the most of the busway or let the car users use that road so there will be less traffic in Burypark. Also traffic heading towards town from Burypark will be better if you make the roandabout near Sainsburys’s better as currently because of this round about traffic is held back in Burypark. Also put metal barriers all over Burypark between Nadeem plaza to Cycle king/moor Street so shopper will not run in the middle of the road to get across whenever they want as this disturbs traffic a lot and not safe and have designated traffic lights to cross the road. Also all the shop in Burypark they uses the vast majority of the pavement so where public suppose to walk? This consolation is only good for council’s Pocket to rip off people by giving pcn and it will kill the local businesses in leagrave road which is already affected by Burypark so as a local resident I do not support it and I request council to find alternative solutions. Put limits on venue central. Also units 1 and 3 as all congestion comes from these units. Parents dropping off and picking up kids and stopping in middle of road. Venue central having too many customers then the private parking it can provide. Only 30 spaces More patrols by enforcement officers. Speed cameras Road humps Allow buses to use other roads. Speed cameras More enforcement officers on a permanent basis. Only implement in worst area of road Make some road one way
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No because a lot of drivers think they can park just where they like Leagrave road dose not have a problem with cars parked it due to loads of cars in luton on hole Review and revise the traffic lights sequence at the juntion with Waller avenue. Traffic in the area has worsened since the last change. time restriction Speed cameras. Road humps
Make the main road one way. Make parts of it one way Make biscot road one way too. Make the road one way Urban clearway Traffic lights Speed cameras No (other than enforce existing restrictions) no alternative You need to ensure its enforced as parking on double yellows occurs frequently yet nothing is done Make it one way More cycle lanes and provisions for pedestrians More traffic wardens to enforce parking restrictions and a zero tolerance parking policy. Ban pavement parking fully or partially in the whole of the borough. I produce one way system Remove cycle lane as it’s not used often enough More parking bays for residents. stop making changes to routes put more parking in Double yellow lines. Another zebra crossing More patrols when weddings are being held by venue central Please can you ban parking all four wheels on the pavements Urban clearway Double yellow lines Allow buses to stop in road just like on Dunstable road. A vehicle to remove badly or illegally parked vehicles. This will be necessary to enforce Red Route regulations anyway. Urban clearway More enforcement officer patrols especially when events are taking place at venue central. Just patrols whenever an event takes place at venue central will fix the issue Along some of these routes there are already parking restrictions in place which are regularly ignored and not consistently enforced. Perhaps proper enforcement of the current restrictions with some amendments would serve the same purpose. No You tell us but not a red route Speeding cameras. Make road one way more designated parking bays One way system Road humps Speed cameras traffic wardens , CCTV Cameras , Technology cctv camereas or the use of other technology No No as people don’t even pay attention to no parking outside schools these areas area
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nightmare to drive down and dangerous as people are crossing between parked cars Time and time again we have told you the buses need to stop in a proper bus stop and not in the middle of bury park on dunstable road. This than causes a hazard and risk to life when cars try to over take the bus and go into the other lane. Please watch your cctv Stop making excuses and Fix this problem. 1 or 2 of The parking bays in bury park need to turn into bus stops and the traffics lights have made this situation even more worse in bury park.
Red route will cause more issues and more complaints from residents and at the end you will have to go back to yellow lines. Make the road one way More enforcement officers required to stop the parking which at times is very bad and dangerous to see on coming traffic especially Marsh Road and Leagrave Road A greater push for people to use buses, which in my view can be done by subsidising the cost of tickets, investing grants to increase frequency and making the customer experience better i.e. spreading real time bus information to all bus stops on the route. No Make roads on way. Add speed cameras More police patrols More parking bays so we dont need to park on main road As far as Marsh Road And Leagrave Road is concerned I do not feel that there is congestions on these roads. To make roads safer introduce speed cameras and humps. In increase traffic flow make it one way so we don’t have to stop behind buses. To ease congestion putting limits on the wedding hall the garage the college will only achieve this Make roads one way Speed cameras Restrictions on venue central as they have private parking for 30 vehicles but take on 500 guests Red route is not the correct way. Moving bus stops is a good idea. Extra bays are a good idea. Making it a one way or parts one way is a good idea. More traffic lights. Make the road one way Introduce a zebra crossing. You can make leagrave road one way or parts one way You need to look at parking issues for residents 1st implement a ban of vehicles from schools up to 500 meters during hours of 8am and 9am.No deliveries between the hours of 8am and 9 am. All deliveries to use the loading bays and delivery bays provided.Too many deliveries are happening outside the shop.Parking on double yellow lines and blocking the flow of traffic.Fine the outlets for having deliveries during red route prohibition times.It is the outlet that encourage the deliveries.They need to manage the deliveries better.
Yes there is. Another pelican crossing Make bury park wider or one way as traffic stems from there. One way traffic Removal of cycle lane Speed cameras Make it one way and also make bury park one way. This way more parking bays and cars cab drive past buses as they can have designated bus bays. Important that where appropriate more parking spacs provided Widening of roads
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Remove cycle lane. Less buses using route Road humps. One way traffic flow Limit wedding customers parking as it’s already hitting pur business as our customers and delivery drivers can’t find anywhere to park. Introduce limits on how long non residents can park. Introduce a ONE way system similar to connaught road. Leagrave Road must be wide enough to allow parking bays as I think biscot road is worse but you’re not red routing that road which is alot tighter. Pr9babbly because the mayor lives on that road. Speeding cameras. More parking bays. Making parts of leagrave road and marsh road one way. You can make leagrave road one way. Introduce speed humps. Remove cycle lanes this will give space for parking bays. Biscuit road is more cramped so that should have red route not leagrave road. Double yellow lines Urban clearway Speed cameras Make it double yellow lines Make the road one way Buses will always be delayed because of weddings that take place here Increase traffic warden patrols but they have not really done anything in the past. Red routes + traffic wardens/towing cars is the best approach Double yellow lines and allow to drop off and pick. Allow residents to park. Inforce speeding cameras and one way system. Make it an urban clearway so we can still drop off and pick up but we can’t stop for long duration. Double yellow lines. Making leagrave road one way similar to connaught road. Adding speed cameras. Parking and stopping for only residents. Make leagrave road and marsh road one way Cars parked on leagrave road don’t cause issues. Buses stopping in middle of road cause issues. Limit how long non residents can stop to 20 minutes. Speed humps. Zebra crossing or traffic lights. Limit amount of bus stops.
We need more parking bays. Limit what times unit 1 and unit 3 operate. Limits venue central. Speeding cameras. More patrols by parking attendants. Make leagrave road one way so we can park on either side of road and no issues for buses and traffic. No one can stop on red route how will they park on side roads? You have had many complaints about no parking because of venue central and so on and you want to implement red route and youre telling delivery drivers or carers to park on side road?where ?on the pavement ? On this road because it’s double red lines no one can park or drop off or pick up at anytime of the day. Make it one way road or make parts one way Add road humps to catch anyone driving fast. Don’t allow venue central and unit 3 to park as they cause all the problems. A Total ban on vehicles parking on all Luton pavements would help Traffic lights Speed cameras Make it one way Make roads wider
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Road humps Traffic crossings
Make the roads all one way. Restrict non residents from parking on these roads Speed cameras. More zebra crossings. Speed cameras Allow only residents to park Speed cameras Don’t allow venue central customers park on residents bays and main roads Yes there is. Make leagrave road one way Add speed cameras Put restrictions on venue central as all congestion derives from there. Speed cameras Closing down of venue central and units 1 and 3 as all congestion and traffic and safety issues arise from these establishments Make parts of leagrave road one way Roads humps Speeding cameras Speed cameras Road humps remove cycle lanes make parts of Leagrave road one way so cars can pass buses Marsh Road traffic is appalling, mostly due to illegal parking, particularly outside the banks and Iceland shop, causing major holdups in traffic flow. no i dont believe there is at present Bury park is just a no go area. This road needs to be widen as there is no where for the buses to pull in to at bus stops, as when the buses are at stops it brings all traffic to a halt. This road needs to be rethought out as it will cause grid lock in central Luton if nothing is done. Red route can be implemented 7am - 7pm. But needs policing properly. If not red route then at least no waiting or parking on double yellow lines or on pavement. More Buses Double Yellow Lines with a “no waiting / no unloading” at rushing hour times. Enforce more effectively existing traffic/parking regulations. No Another scheme for some big contracts money being wasted all the time by the council. Stop creating more schemes and concentrate on the existing service improvement. How many time has bury park been changed and what has it done to better the traffic? It’s just another thing to make the rich richer work on things like getting appointment at doctors have to wait over 4 weeks for appointment people r dieing no one cares I don’t agree with the red riouts sceem Marsh road has very wide pavements. The area needs parking lay-bys to keep the shppping area alive. None that I can think of at present. Open your eyes , there is no bloody congestion other then due to rush hour traffic in this area. No parking in Dunstable Rd particularly in the Bury Park area. As parking is often abused with no apparent action taken. This causes difficulty for traffic flow, the only solution is to make part of it Buses only or have a Bus only route in Crawley Rd. No Stop mc Donald drive through at 3 horseshoe roundabout The congestion is almost entirely caused by unnecessary and badly-sequenced traffic lights. Many could be replaced by mini-roundabouts. The rest must be simplified to a simple 2-way cycle, banning right turns if necessary. On Dunstable Road, remove the bus lane from the M1 to Currys, buses can use the Busway. Convert the traffic lights at Chaul End Lane retail park to
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a roundabout to eliminate tailback. Increase enforcement Enforce stopping / parking laws.Red route Make sure people that park illegally on the main road and on roundabouts and on yellow lines are fined you just seem to let people off no good enough more vigilant traffic wardens in the bury park area. cars always parked on pavements and part in road yes. add bus laybys where you can. put red route only in key areas Reduce the stupid size of the pavements in bury park and develop thr bus layby where they pull in to load and unload passengers. Its the buses which cause the greatest amount of traffic More enforcement. CCTV By fixing potholes and loose drains Bring back the bus stop lay bys Create bus stop bays Make dunstable road and bury park road one way More speed cameras,Road humps for safety,more parking bays on side roads think about one way system instead. As the cause of most traffic is the busses stoping on the bus stop. And large have vehicles unloading perhaps have traffic wardens patrol the routes and ticket immediately. Make bus lay by in bury park by cutting into pavement traffic wardens to enforce the current permit scheme. Always see cars parked on double yellow lines and zebra crossings. Venue central, the garage and vernal ignorant parking at this part of lea grave road means coming out of side roads is extremely difficult, Often don’t have a clear view of the road. Need constant enforcement - no parking illegally. Parking down side streets to be permit only, anyone without permit get a ticket. No parking on pavement. Why don’t you change bury park by making the road bigger and make sure the shops do not put too many things on the footpath Reduce pavement size on dubstable rd and increase a lane on the middle that can be used as one way to town centre in the morning and opposite direction in the afternoon Change the bus stops so they have bays to park in instead of parking in The middle of the road. Sometimes there a queue of buses blocking the road waiting to load and unload passengers. Which idiot decided to make the buses to stop in the middle of the road. No Make leagrave road some parts one way with speed humps Simple.... Provide more parking bays for cars. Make parking bat’s for buses. Y on earth they stop in middle of the road for passengers is beyond me Yes, you need speed cameras and speed humps on leagrave road especially in front of britannia building. Venue central is a serious cause of congestion due to events guests park all over the place.
MORE PARKING BAYS FOR RESIDENTS (Permits holder only) Use the speed camera Force business in the area to provide more private parking space for their clients. Getting venue central to provide adequate parking for its customers will ease congestion Make bus bays and narrow the pavements on Dunstable rd One way systems etc broader rooad don’t know why you increased footpaths that much when you did it years ago Make a parking lot or buy some space and give free parking to public in first come first serve basis. employ more enforcement and get more wardens on the street. Engage real street police with powers as many problems happen through selfish drivers too lazy to think of others that get away with it through no enforcement. No Actually punish the people who repeatedly cause congestion by parking in the cycle lane
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unless they are loading a passenger. By-pass Also putting traffic where nobody lives , Putting Busses where people live. I.e Busway No reduce the number of card on the road. reduce the size of the pavements in bury park and use the extra space as bus lane as the buses cause congestion Proper enforcement of the existing parking regulations, which is clearly not being done at present at least in Leagrave and Marsh Roads. Make a space for bus stops where buses can pull over for drop/pick up, so the traffic flows smoothly and doesn’t held the traffic. Build more roads and off street parking No REDUCE BUSES REDUCE BUS STOPS MAYBE CONSIDER RED ROUTE AT CORNERS OF THE CONGESTED ROADS We need Bus Bays Buses stopping on the road makes the problem Yes increase traffic warden patrol, install speed cameras along Leagrave Road Just make round abouts with wide lanes .I think this will help to clear the congestion. U don’t nknow how too plan ok.we don’t want red rout ok Don’t know In burypark along oak rd ash rd beech rd kneworth rd their shoyld be one of free parking to encorage people to park their. Also 30 min on dunstable rd and leagrave rd and burypark rd would help control traffic. Bus should be routed round bury park rd Make bus lane As it was back in 80s Not sure, either way there will probably still be people stopping there. Make the pavements smaller and make parking bays Make the parking bays in Dunstable Road back into bus stops Cut down number of cars per household More bus stops baya on Dunstable road rather than the buses stopping in the road which causes the congestion Make the roads bigger and paths smaller Yes bus bays and loading bays, get cameras to stop inconsiderate parking Yes more traffic enforcement Restrictions on heavy load lorries. Taxis to use bus way More parking bays in bury park and marsh road No More parking spaces and need proper bus stops not in the middle of the road Bus bays so they don’t hold up traffic while passenger get on or off No Enforcement of current yellow lines. Re-route buses is create a bus parking zone which does not interfere with traffic less cars leave roads as they are except for marsh rd introduction of a congestion charge Make a bus lay by I cannot see any other solution given the areas considered are all in a congested built up mode. Definitely don’t need red route on Leagrave Road from junction of selbourne rd upto woodland ave because never get any congestion on that section and road is safer as it is. The only way to deal with congestion in
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Bury park is to deal with the buses which are causing standstill traffic and also consider changing Dunstable Rd back to how it was before liberal government changed it No. THe red route, enforced with cameras, should ensure ensure that the buses are not held up, Other than bollarding the route and installing pedestrian guard rails everywhere...no! Fix the road surfaces and remove trafic lights with crossover roundabouts, trafic will improve No loading Bays Make bus bays or remove bus stops in congested areas such as Bury Park. Almost all traffic is caused by buses blocking the roads Parking facilities need increasing in Bury Park Area Storey Car park in burypark Increase road width. Furthermore request Tesco Express on Dunstable Rd delivery vehicles hours are prescribed. Tesco delivery lorries cause congestion. Enforce double yellow lines 24 hrs a day. Yes, introduce bus and van parking. Creating car parks for cars and vehicles Yeah give more parking space A bus lane, loading bays for vans, traffic wardens to enforce parking restrictions,wardens to keep footpath clear as shops displays over their boundaries, Yes Bus bay loading bays for businesses. Council decided to get rid of the old bus lane and now they see it did not help with congestion at all. Council realy need to get local ppl from the area on their committees if they plan to do anything in that particular area. Please make more of an effort to listen to the people who live in that area as they have a much better understanding of what is needed. Make bury park all red routs to improve traffic flow in the area Have a bus stop where buses can park with holding all the traffic. I.e to narrow footpath. Remove one bus top outside cake box pointless as there’s one past Oak Rd and traffic can pass through get the buses out of luton Before implementing this you should provide parking in these areas so that people say Bt park on the road. Yes it will probably improve traffic flow but at the cost of unhappy public who uses bury park and Leagrave road for shopping Bus lane and bus bays Better parking facilities for the proposed roads will help with congestion flow. At the moment because due to lack of parking spaces people just park up. Local people should not be punished by having red line routes. I believe dropped curbs to properties is a long term solution. Young families and elderly rely on easy access to protect vulnerable family members by being able to pick and drop from close to homes. Improve bus routes, increase alternative parking Yes Bus bays Yes enforce the current parking restrictions especially in Bury Park Bus stop bays , loading bays Take out parking bays and make bus stop Remove van loading bays, bus stops & have more Parking Bays (Dunstable Rd - Bury Park). Create parking options If you have taken the time to survey Dunstable road through Bury Park, you will note that the only reason traffic gets delayed is due to the buses blocking the road when stopping at different locations on the route. The initial changes made to Dunstable road back in the 2002 or 2004 was a total disaster, the bus bays were taken away, roads were narrowed and footpaths widened. Increased parking, fewer bus stops and improved traffic signals. Provide more parking off road, implement large goods vehicle ban during certain periods, bus stop layby’s on Dunstable toad through Bury Park.
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Sort out bus lane I don’t use these roads all that often, but very much doubt if the cost is justified. A similar amount of money spent on additional parking wardens to enforce existing restrictions would be more sensible. Your proposals do not seek to cost alternatives, and it is very hard for the public to assess the cost-benefits if these proposals. No doubt this is deliberate because you think you know better than all of us. More traffic wardens in all areas. Amended restriction of parking times in allocated bays. No parking on junctions as it seems to be the norm and stops visibility in every direction theres lots of alternitives but the council needs to consult and engage with me my alternatives are much better then red route that will kill all the businesses in the area More parking space and off road bus stop Yea buses cause the main congestion they should av bus stops then where they pull off the main rod like a bus pit stop they cause main delay to traffic Bus bays There should be only 2 bus stop in burypark and leagrave road. Instead of four. One Sainsbury’s and the other one on leagrave road ( selbourne road) The council deliberately changed our road so they can introduce the red route. The old system had good flow of traffic except road corners. Create bus bays. The buses are the main cause of traffic. Loading bay stop vans from stopping Give buses their bays back to allow them not to stop in the middle of the road causing tail back traffic. Traffic wardens to enforce bad parking practices in key spots. Improve parking availability in shopping areas and improve public signs to available parking spaces and areas. Lomg term encourage walking cycling and travel by bus with subsidised cheap fares and educational programmes. Bus bays need to be introduced on Dunstable Road. As it is the busses that cause most of the traffic. Find alternative routes for busses that do not need to go thru bury park. Additional loading bays. More parking, this also needs to be advertised to make people aware.
Wardon on duty will be good Extra Traffic Wardens issuing parking tickets to cars parked illegally. More traffic wardens to put tickets on cars parked on yellow lines No. They have tried and tested everything butnthere is so many businesses on leagrave road and dunstable road. People park all over the pavements and double yellow lines making it very unsafe for children crossing from the major local schools which are just off leagrave road. Denbigh. Also children are always at risk of being hidden between wrongly parked cars. There have been accidents due to this in the past leading to fatalities. Also I believe that so many accidents on leagrave road have been caused because of cars parked wrongly. Children that travel to school on busses also get very late and this effects the community as a whole. We cannot allow this just for the sake of local businesses. They have been thriving ignorantly of our misery for too long. They argue and fight if anyone asks them to move their vehicles. Such as garages. They park all over the place. There is a wedding hall which has big events and cars park everywhere at the time of any events taking place in it. Which us just appealing. Make bus bays so they don’t stop on road stopping traffic from behind to stop and cause congestion.Put red lines on birch link area so that no vans are parked there which they do for hours on end and reduce traffic flow to one lane or less as traffic fights to converge into one lane from two Refuce amount if crossings to two in bury park and out pedestrian crossings instead of free crossings where both the pedestrian and public don’t know who has the right of way so both stop and cause more congestion. 1. have bus bays, buses shouldn’t be allowed to stop in the road 2. Loading bays for vans 3. Traffic wardens to enforce yellow lines
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No Dunstable road could be made one way,and bury park road. Or dual carriageway putting red routes in those areas just gonna cause traffic else where Make more loading bays. Bus stop laybys. The buses hold up traffic. Not parked cars. Yes. Make bus bays so that buses do not block the road when stopping at bus stop Make loading and unloading bays for the vans to keep them off road Better monitoring of yellow lines by traffic wardens and make hefty fines to those who park illegally.
I welcome the prposals for Marsh Rd, Leagrave Rd and Dunstable Rd. Enforcement is the biggest issue for both existing and proposed measures. There will need to be extensive camera enforcement. This consultation gives no details of any proposed enforcement. Changes from single yellow lines to double red are good in this area. There may not be enough additional loading bays along Leagrave Rd between Woodland and Rondini Ave - there are a number of small businesses on both sides of the road. In addition there is a huge problem of illegal pavement parking the length of Marsh Rd in particular. If drivers who currently park illegally outside banks and shops in Marsh Rd feel enforcement is enough they will simply drive up onto and along the pavement (as they do now) and park on the pavement. This infringement has not been enforced for years. A mobility scooter, child’s buggy and even a single pedestrian can sometimes not get by on the pavement. The tree tubs on the pavement have helped but some of the bollards have been knocked down by drivers and not replaced. More needs to be done to protect pedestrians along Marsh Rd pavements. If the Red Routes are successfully introduced in this area there is a danger that traffic flow will allow traffic speeds to increase. This too would cause additional risks to pedestrians outside of the existing 20 miles per hour area. Better parking and better cyle routes Bus bays Take bus stops off the actual road! Remove bus stops and stop loading on these roads causing congestion Create a car park without a red route. Bus bays More enforcement Bus bays in areas of congestion. Clear, extra visable parking. Yes widen the road and shorten the footpath and make a separate lane for busses . Yes sort out the mess you’ve made in Bury Park and double the lanes or put bus lanes in. Because it seems you have made it a nightmare to drive thru Once the football club has relocated, create a through road up Hazelbury Crescent connecting with Ash Road. The roads in between (Ivy, Beech, Oak) will be one way going up the other direction. Bury Park can then become pedestrianized only allowing for buses and loading vehicles. On the other side all traffic can be routed down Bury park Road heading into town. Reduce pavements to allow car parking - free for short periods up to 30 mins. Much congestion is cars going round and round try to park for a pick up or a short errand. Buses are also blocking the road at bus stops which need to be indented into the pavement. Put busses in bays along these roads put traffic coming into bury park from leagrave Rd via bury park road move bus stop between becch/oak rd and community centre and place in between with a designated bay introduce no parking at all times on street corners which will increase public safety, reduce the no of injuries an individual may face. remove traffic lights from Barclays and change to pedestrian crossing or zebra extra loading bay with timing restrictions outside Sandersons and KFC. bus lay by opposite KFC
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vertical parking bays opposite Waldeck road replacing existing one with time restrictions. a bus lay by opposite ivy road no parking grids at end of beech/ivy/Kenilworth/oak and Waldeck rd. extra loading bay outside AA Carpets and Nirala with time restrictions. loading bay on right hand side of oak road with time restrictions. bus lay by on the left of oak road No parking on leagrave rd between 8am - 6pm except for permit & disabled badge holders. a multi storey car park at the old football ground with clear signage..
Yes provide more parking If hard working businesses are paying tax vat it’s the least council should do Fewer bus stops and less crossing will make the traffic flow smoother The buses are the main cause of the issue. Stopping in the road to pick and drop passengers instead of bus bays causes traffic. Sometimes even multiple buses waiting to park. Yes there is improve bus stops Yes but it involves finally relocating the football stadium. Traffic is manageable but bus lay-bys must be brought back to keep traffic flowing. The red route simply penalises toad users instead of dealing with the problem of congestion Yes spending a Little on bus stop the way buses do not block the flow of traffic when stop to pick passengers Buses should have a alternative route We need bus bays This will decrease our house values as more people from Leagrave will park on my road because they will not be able to park outside their property The red route will not ease congestion as it will not REDUCE the number of cars on the road which is main cause of congestion. The red route is designed to increase traffic flow without stopping which could result in increased speed and thus will not make it safer. A red route in a busy shopping precinct such as Nursery Parade on March Road and Bury Park on Dunstable Road will make it more dangerous by making the cars flow faster. This will make more people choose this as a rat run and will become a bypass for cars on other roads. The alternative is to have bus bays to allow the buses to move out of the way of the traffic while boarding and alighting passengers. More and effective enforcement of the existing restrictions and addressing the lack of parking with a long term strategic plan in consultation with the public and the business in the area Introduce pay & display parking on side road like (mount pleasant Road , river way , extra ) Actually having traffic wardens operate in Bury Park. On a bus journey I once saw someone abandon their car, blocking in a car in a disabled bay, and actually leave the car in the middle of the road so they could do some shopping. The bus I was on was then unable to get through. traffic wardens needed to fien those who do not comply. Red routes good idea to stop people parking wherever they fell like parking. Yes the buses block bury park when they stop in the middle of the road. Why are there like 6 bus stops right in bury park. The buses are the root cause of this problem on leagrave road. Bus stops need to be reduced and they need to park on the side. Just imagine a bus stooping for 3 minutes in the middle of bury park, it causes havoc and traffic get stuck all the way back onto leagrave road Making proper bus stops and arrange parking for bury park can reduce the traffic in Bury park, Leagrave road and Dunstable road area YES YES YES! ENFORCE current restrictions instead of letting people get away with it. London has these red routes you want to implement and the roads of London are no less busier or safer than ours in Luton. I think the council want to make money of citizens, as if their expenses are not high enough already. We think that instead of creating a red route. The council car park at Luton Town Football club should be opened up in Oak Rd, because it stands empty most days, apart from on football match days. Opening the car park would be a lot of help to ease parking problems in the area. Creating a red route in the area will make the sideroads busier. As it is a busy shopping
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area, the residents already have a lot of parking problems in their own roads and have to go round and round their road to find parking, It is very hard to park in any side road. Making a red route Will only pass the problems onto already congested side roads. We (the residents) are paying a lot of money to park, even though it is impossible to park at most times of day. No No you can install enforcement camera that can fine drivers 24 hours for parking where they not supposed to park There is already an influx in the increase of cars on the roads and we already are suffering from lacking from adequate parking slots in Luton and placing red route will not reduce traffic or congestion , but will rather divert more traffic and increase heavy traffic and impact greatly in other parts surrounding those areas. Make the road wider with more parking facilities. And make pavements smaller No No No red route Introduce proper bus bays that will assist traffic flow, buses stop middle of the road forcing long tail backs whilst passengers disembark. Yes more bays Yes ban the buses On Lewsey Road the visitor car park should be at least double decker because there are lots of visitors and this causes extreme congestion, especially at 5-7pm. Bus bays off road traffic wardens Dunstable Road (Bury Park) is the main area causing congestion. Red routes without strict enforcement wont achieve objective. Strict enforcement of existing or new loading /unloading restrictions would achieve same objective. Implementation of a red route in an area with traffic calming and pedestrian friendly design is not appropriate and will devalue concept of red route. more parking bays and laybys for buses could be added on wide pavements in the marsh road shopping area and bury park. this would allow parking and busses to stop without causing congestion The alternative is to implement bus parking bays to enable busses to park whilst boarding or dropping off passengers. Most of the delays in the dunstable road and leagrave road area is due to the busses. Yes, make public transport free! The knock on effect of having free public transport is huge, less congestion, less pollution, less accidents etc etc. The negative of free public transport is only cost, but I believe the positive outweigh the negatives. Yes fix the bus stops which cause the main delays.they need to be able to pull into a designated stop such as the bus stops by chaul end and by halfway avenue.This design of bus stop does not restrict the flow of traffic,A bus waiting for a few mins causes major traffic I don’t see a problem with the traffic flow things are working fine as they are. If the red route was to go into place it won’t help at all but just cause further congestion If the red route was to go into place it would do anything but increase traffic flood, would cause further congestion in my opinion.
Making actual bus lay-by along with creating more parking spaces i dont know Parking on a red route except for parking laybys should not be allowed. This will increase road capacity and keep traffic moving. in time parking narrows the width of the road. Make more parking space Yes there plenty of different avenues that can be looked into. Firstly would be getting the tram system working so that would take buses off the road & i have used the local transport service and found appauling as buses had never come on time. Make a seperate bus lane on Dunstable Road as it was before. Bury Park road should be 2 way traffic to unburden the main road traffic. Don’t apply red zone and not provide another solution.
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1 speed cameras 2 make parts of Leagrave Road one way so cars can pass buses and we can have more parking bays on Leagrave Road 3 remove cycle lane 4 more parking bays (permit holders only) 5 make all bays Residents parking only Mon-Sun 24 hours (A&B) (exceptions for family and friends visiting) 6 require Venue Central to provide more private parking for their customers and put restrictions on them Cars that break traffic rules should be punished Yes No, I think Red route is only option Bay bus stop Use flyover people drive safe Separate bus lanes and loading and unloading times Yes more one way streets Bury park is already congested with previous amendments by council. Although it need a proper car park. It will effect the local business and for taxi drivers and local people it will be difficult to pick and drop. The bus way made was a waste of space and time which could be an alternative route. The bus stops in bury park would be made on side not in the middle of road. Same on legrave rd and marsh road. Yes. Having no separate bus lanes through Bury Park has made matters worse. The council need to put the bus lanes back in More car parks bos stops in the Dunstable road and stops traffic The 4 way junction in bury park road and biscot road have terrible light signals traffic loads up from biscot road to rv food and wine. Also traffic lights on dunstable Road dont help at all Finish the bus lanes? They are main course of congestion!! No. I feel they will block traffic. What needs to be done is to create a couple of multi storey car parks at convenient locations to the shopping areas so you can get the parked traffic off the road to enable more space for traffic to flow. Seems like a no brainier. Bus laybys to keep other vehicles moving This is the only set of proposals that are needed among those offered. It has been a parking nightmare for over 30 years. Pavement parking here has been systematically ignored, especially by the small car businesses in Leagrave road. Once again, enforcement would have solved the problem. Bus bays need to return back. More parking n loading offloading bays required. Why have 2 bus stops within 10 seconds distance. Have purpose built lay by areas for buses so traffic can pass without congestion Make roads wider Provision of additional parking in strategic areas to allow support for businesses to the old bays for bus stops Don’t need to do anything it’s fine i think this is a very stupid idea. No need to waste money. Make bus bays Traffic wardens to enforce the penalties and take pay parking and make separate bus stop No Traffic lights, traffic wardens, traffic cameras, no lorries runni g through Leagrave Road. No parked cars on curb. We need bus bays Yes No Bus bays
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There is no other option here; no room for bus lanes, no room for bays. These roads are the worse roads around the town, they can be narrow, full of pedestrians, congestion and too much chance for conflict. Have bus bays don’t let busses stop on roads loading and unloading vans and trucks should not be allowed on roads get them off roads Divert traffic into burypark road. Have smaller buses. They cause the most congestion. Bus lay-bys alongside red route Please don’t red zone it will make life more difficult for luton people’s many thanks. The way burypark has been redeveloped to allow parking outside shops and reduceing the width of the road has made driving along this road difficult .You have to have your wits about you as you don’t know who or what will appear in front of you. Bus bays so buses don’t stop on the road
Make the footpath smaller Bus bays and traffic wardens When busses drive through bury park they should have proper bus bays to pull into to drop off pick up. They should not be allowed to stop in the middle of the road. Remove and clear shops fronts which encroched And clear the footpaths for push chairs and disabled wheel chairs Make a seperate route for buses or totally remove them from this route. More parking Bus bay and loading bay I think the council has too much money than sense and is wasting money on unnecessary things. Firstly the narrowing of the roads of bury park has been an absolute disaster. That is the reason for traffic flow problems. And I am saying this as a pedestrian who walks everywhere. Car park More car parking If you make the pedestrian area smaller in Dunstable road/ bury park area and make the bus stop as it used to be curved inside that will make the traffic flow better Set time outside business hours where parking will not be allowed, or create large area for Just parking.free for the first 30 min Provide bus lay bys so traffic can flow freely just common sense Also provide multi story car park to bury park No I would suggest bus bays so traffic passes while bus load and unload and extra parking to cover everyone’s needs. Extra traffic warden Sort out B&Q roundabout, Oakley Rd roundabout (Dunstable Rd side), hatters way roundabout bury park end. The amount of congestion you get in these areas is unbelievable. Red route area is just for this greedy council to make extra money. If the council wants to make money put in yellow boxes in the areas I suggested and if any one blocks these roundabouts they get fined. Over head road Add Zebra crossing instead of lights by Nadeem Plaza. AA carpets not to park vans all day outside the shop on double yellow lines. I’m not sure Overfly bus route Over fly bus route No Make bus bays so the damn things don’t cause the traffic in the first place Yeah create proper bus bays and leave the rest alone There will be more congestion Yes there is an alternative option as 1) make bus bays to collect passengers as they end up stopping in the middle of the lane. The person who proposed and passed the previous layout of bury park made it more congested by making the footpath wider and decreasing the size of the lanes.
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This will decrease the buses from causing traffic 2) re route the buses as I have been made aware that the bus route is controlled and planned by the local council authority I think traffic flow in Luton is not to bad at all. Stop cars being parked on double yellow, increase paid parking bays, STOP the use of pavements being used by business to sell goods...this reduces space for public to walk and forces them to walk on BUSY roads increasing risk of collsion. Parking area to reduce any unnecessary parked cars To put cameras and send people tickets The bus stops are the main problem in the bury park area. When bus stop. Then the traffic staying behind making along quiue. And there is no time showing for loading bays which cause big delay and cogestion. And need to use force for the double yellow lines increase traffic wardan in the area. Bus bays Loading bays More traffic wardens and parking spaces Yes, traffic used to flow great in dunstable road before the road and foot paths were alldered, when buses stopped to pick or drop you were able to overtake them, now bus stopes at bus stop and traffic builds up behind, because your not able to over take them safely???? Remember the good old days when we had separate bus lane. Instead of giving the shopkeepers more footpath to put more on display bring back what we had 30 years ago it will work batter. Build a multi-storey car parks to reduce cars left on pavement people don’t mind paying car park as long it’s available Make Dunstable road one way Traffic wardens and issue tickets on spot Preventing right turn out of Archway Rd onto Marsh Rd Yes, I do feel this is a need for more parking rather then less parking which the red route will do. It will make it harder for residents. Yes create more parking bays and car parks Make the Bus bays and reduce extra wider foot paths and make more parking available Yes. The bus route should be directed around bury park instead. They can go on bury park road. No Reintroducing bays for buses and enforcement of ticket officers in areas where it is not permissible to park Get bus stops off road side don’t let the buses stop in the middle or of road Or strictly penalise improper parking, double parking, waiting in roads Make bus lanes yes add bus laybys at bus stops The no right turn sign on waldeck rd to come down and allow traffic to turn in to waldeck to go up to biscot rd and Cromwell road Buses stopping and delivery vans cause the congestion. Bus bays and loading bays More traffic wardens or fined by cctv The turning point outside nadeem plaza Bury Park needs to be blocked. If there is no right turn the traffic will keep flowing. Cars turning right here hold up traffic causing heavy congestion. Also need more traffic inforcement officers on roads. Just the sight of them deter drivers from parking anywhere. At the moment there is no traffic warden presence and drivers are aware of this and take advantage parking anywhere they can. Traffic enforcement by wardens and stop buses from picking up passengers while they parked in the road Encourage cycling. The problem of congestion will never disappear in Bury Park unless you have a new underground multi-storey car park underneath the football ground before it gets redeveloped. Traffic Wardens
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On Dunstable road we need bus bay as there stopping is what causes traffic. Also If proper parking is provided then people do not need to park illegally and inconveniently. Also rather then investing in red routes the council needs to look at easing congestion throughout Luton . Especially the traffic caused at chaul end on a daily basis . This is because of the traffic lights at kfc . We need a roundabout there instead Bus Bays and Loading Bays More car park More traffic wardens The issue is the lanes in Bury Park are singular and the psth ways are too big. The shops should not be allowed to put their fruit etc on the pavements this all then create space for an extra bus lane. Enforce current traffic and parking laws More Roundabouts bus lanes only lane traffic lights not to change so quick and more traffic light signals right or left turn lights so cars can stop for drivers that want to turn off a main road on to the side roads Traffic wardens why do you pay them?
Create more affordable and practical parking spaces Having bus bays My particular concern and daily experience is Bury Park. The red will not change any thing until two issues are addressed. The main reason the traffic does not flow is the when the buses stop in the middle of the, this causing the traffic to halt. The second reason is when AA carpets have their delivery. I propose that they are allocated specific times to load/unload. They being at not busy times of the day i.e very early morning, midday and after 7.30pm Bus bays and loading bays. Make bus bays at bus stops Build more car parks Create more car parking spaces. It’s limited. Bury park has been destroyed by the council Change school timing, there should be more carparks in bury park area, more traffic lights. As demand grows so does supply basic principles of Economic, everyone need a car, families are growing and number of cars within house holds are increasing year on year. Not Much you can do to ease traffic. Change bus routes which is one of the main causes, stop them from going into bury park, and use Bury Park road for alternative routes. Foot paths in some areas are far too large cut them down and use that as a bus lane or an additional lane for cars (perfect example is Dunstable Road) You speak of making roads safer, take a look at Birmingham, they have introduced average speak cameras on their dual carriage ways and long roads do the same on Dunstable road and hatters way, this will; 1. Stop drivers from going over the speed limit 2. Generate extra revenue for the council if anyone does and imply heavier fines which will discipline the public. You definitely need to get rid of the traffic lights that you stuck in the heart of Bury park, (in front of Nadeem Plaza) if the council have done this to allow pedestrians to cross then why couldn’t you just lay zebra crossings, traffic lights just cause too much congestion. Make things simple for the public, you have Luton Towns Car park on Ash Road, make that accessible for the public on weekend or even weekday and charge at affordable prices, this will decrease congestion. I am more than happy to give consultation on how to make things better and easier for Luton residents. Feel free to contact me via email [email protected] Bring back bus top lay by Provide multi story parking facilities dunstable road IncreSe traffic wardens to enforce parking should be in appropriate bays even for a shorter stay Make bus bay so can traffic go easy More traffic wardens, less traffic lights, more bus bays along busy routes
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Redesign it Lay by for buses and traffic wardens to enforce yellow lines There are other ways When a bus stop it blocks everything use traffic wardens the council made one lane to couse problems so when bus stops it blocks everything for parking you need a multi-storey car park not pay and diss play Bays for busses Need to make proper busy stops where a bus can park in and not stop on the road Buses bay will reduce traffic Main problem for congestion is the buses and not the parking. Congestion on Dunstable Road will reduce massively if the following measures are taken: 1. Implement Red zone 2. Change existing parking spaces to allow cars to allow cars to park at an angle. This will avoid cars attempting parallel parking on main road. Cars used to approach parking space at angle in the past. 3. Don’t allow buses to stop on main road. Some of the parking spaces should be converted to bus stops. 4. Install cameras on junctions of Kenilworth Road, Ivy Road and Beech Road. Too many commercial and passenger vehicles abusing double yellow lines. More parking spaces required including disabled spaces. Bus bays To make bus lanes which are the only obstruction to cause traffic to stop and make it congested Pavements are too big. Reduce them to make use for bus stops. Have a seperate bus lane. The footpaths on dunstable road are too big. Have a multi storey car park There should be a law for having only 2 cara per household as there are too many drivers now. People should be forced to see the importance of bad traffic. Make better public transport To wider the road in bury park to make space for a bus to stop. Make the pavements in bury park smaller Making bus lay-bys,where buses can pull in and not hold up traffic behind them Yes. Just take in the curbs for buses to park and that’ll fix everything. There is not that much traffic on comparison to London for you to have red routes! Plus limited availability for parking I believe keeping bury park road one way so traffic flows that way and disperses out on to Telford way, which possibly be connected better to Crawley road, Dunstable road should become 1 way from Sainsbury’s, the other space should be utilised for more parking and pedestrian walk way, possibly a bus lane could be introduced Reduce the footpath along Dunstable road in bury park,and make bus stop on the side of the road,and push back the shop excess stall , Bus bays would do a better job, Yes make the pavements normal size shops on dunstable road to trade only within there shop grounds not take over pavements forcing pedestrians into the roaf Provide bays for bus stops so they don’t obstruct other traffic. Not at present Have an increase in traffic wardens Make layby bus lanes More bus bays needed and more traffic wardens to patrol at busy times Yes ofcorse, make bays for busses to collect passengers especially in bury park as the pavements are too large and don’t need to be that large The design that was passed and implemented in bury park last time was jus a total waste of money as that’s the reason to the busses causes traffic to slow down Change the system to gyratory one way for leagrave road in Burypark provide street parking all the way down. Add road bumps. and pass traffic from bury park through Conway road and 5 roads down the tour
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Discourage more cars on the roads and encourage public transport . Don’t buses stop on Road . Separate loading bays . They should hsve dedicated bus stops and also a possibility to create a one way system N/A Better parking facilities in bury park Bus stop bays Yes but this is he only one presented Yes The footways in bury park are way too big. There was no need for such size. Make the footway smaller to standard size and introduce bus lay by where the buses can park and onload offload passengers. Also 3 bus stops. 1 near the bridge near selbourne road. 1 near beech road and abother further up. I do however agree with red lanes from leagrave road until the split in the road just after nadeem plaza. Yes more policing Make more parking available Yes, eradicate loading bays. Create more parking in the area. I regularly walk to bury park and despite double yellow lines cars are parked not just on the road but sometimes the whole of the footpath. I suggest you enforce the existing laws to discourage people from parking irresponsibly. I have even seen cars parked at zebra crossing and done so everyday. Surely we don’t need red lines to implement something like this. More bus bays so buses do not congest the road. More loading bays to get vans off the road. More traffic wardens Double yellow lines cameras.. as they did worked successfully on Leagrave road in past and make buses bay to park at bus stops thats the main reason of traffic on Dunstable road bury park Make a decent size car park in bury park so we can park I visit the area regular to get shopping other staff It’s not about diverting traffic it’s about no one stopping on the route Make parking bays for the buses and vans , allow diagonal parking as previously used to be Yes provide designated carparking spaces. In bury park the pavement widening scheme increased traffic congestion as the road area was decreased. Bus bays and loading bays off the road so they dont stop on the road and hold traffic I believe that if you somehow reduce the footpath and make it into a bus stop that also will help the traffic flow nicely. Yes. We should create bus bays so that busses don’t hold up traffic on the road and create more loading bays as the pedestrian footpath takes more space than necessary. We can also create a car parking facility which will automatically prevent people from parking inconsiderately and illegally. Furthermore, traffic signals need to be better place so as to prevent almost a stop/start routine. These are better suggestion than a red route as red route will only cause more issues and inconvenience as it is effecting traffic day and night. Majority of the times the proposed red routes don’t have traffic, so why implement a solution that imposes restriction 24/7, create bays and ease traffic automatically. Widen the roads bus bays through bury park area - the main cause of congestion is the road was narrowed and the bus bays removed this causing tailbacks because cars can’t pass Make more parking facility for cars You need to create bus bays so buses don’t stop on the road which is the main case of congestion. Creat a parking areas which are cheap and easy access to the shop I think there should be bus bays to stop the busses from blocking the roads. That causes a lot of congestion. Loading bays should be used for businesses to load/unload their goods instead of them parking in the streets. Traffic wardens should be more visible and active in implementing the double yellow line parking restriction on them and other road users. The flow of traffic would
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have been much better if people got fines for parking on double lines-no red route is needed here. Change the bus routes or bring back the bus bays in burypark Create bus bays and do not allow them to stop on the road Bus bays...loading bans...... Proper bus stops - not in the middle of the road. Bring back bus bays so buses don’t stop in the road. Increase loading bays to get deliveries off the road. Council to enforce parking regulations. Bud bays/ loading bays We need a big new road around this area Bays for Buses reduce shop fronts space, enforce parking rules, increase parking for customers they should make building for car parking Don’t allow busses to go through bury park. reviewing the controlled parking zone times and extra enforcement teams Creating bus bays and loading bays outside aa carpets and Sanderson removing bus stop outside Ambala sweet Centre Busbay, car parks. With particular focus on the bury park area re-introducing the lay-bys for buses and reducing the pavement size for more parking would ease congestion. yes red route through Bury Park as terrible congestion in this area due to inconsiderate parking There is a lack of bus stop bays which are the route cause of the congestion in Luton I believe we must deal with that issue first Just think how many proper bus stop hardly any that’s the problem Deal with this first Get rid of wide pavements in Bury Park and make two lines on both side ie how it used to be Don’t Traffic enforcement officers, additional parking availability Put in bus bays for all stops.this will reduce traffic Yes enforce the current system of illegal parking and introduce a bye law making it illegal to park on pavements and then enforce that Bus bays won’t help at all, it has to be made into a red route. It is ridiculous to traffic through there. More parking enforcement. No Provide Bus bays instead, reduced pavement to allow parking, traffic wardens to enforce yellow lines Have most of the narrow roads used as one way roads open up alternative no right left turn roads I. To right left turn roads as the traffic that needs to flow in these directions will take away additional traffic to other routes clearing the roads a little. Congestion charge
in congusted areas more patrol of traffic warden ..should be increases. issue PCN to illegal parkings.. add two lanes and more parking - especially in bury park! Perhaps you could spend the money building a multi story car park. Bury park is often as busy as the mall! Not sure More parking available in bury park Buses Build fly overs Alternatives given by Shahid Rashid are more acceptable Raise taxes get proper transport systems into town and not just waste money on stupid bus lanes. People dont like buses trams are nice and do the job. Free parking sites Limit the number of cars per household Change footpaths to how they were before to increase roadside parking, and to stop people
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parking where they shouldn’t, putting in bus bays in bury park where the pavement is easily wide enough and surround with railings for safety, and introducing a loading bay on leagrave road near AA carpets because that side of the road needs it as it is always blocked by loading trucks, and which could double as evening parking. Purposed built car parks Bus bays clearly marked and indented into the pavement so cars can pass. Buses having to stop in the middle of the road is one of the major causes of congestion. Increase pay and display parking bays and double yellow lines. BUS BAYS, REDUCED PAVEMENTS TO ALLOW PARKING, TRAFFIC WARDENS TO ENFORCE THE YELLOW LINES...these are plausable and justifiable changes that can be made to ease congestion. NOT THE RED ROUTE. Number of buses should be reduced due to tail backs it can cause in bury park drivers should be able to use bus lanes from 5am and after 5pm due to that is rush hour time so that should move traffic flow drivers should be given equal rights because we also pay road tax,
Maybe have a actually bus stoonfor buses instead of the bus stopping in the road and not allowing traffic to pass. Yes make proper bus stops on the side of the road where the bus can pull in to without effecting the flow of the traffic To have proper bus stops and lay bys so busses dont have to stop in the road for 5 to 10 minutes causing traffic and for shops loading bays No BUS BAYS - this will alone solve the congestion and traffic flow crisis that luton borough council say there is. Bus Bays can be allocated along the routes allocated on dunstable, leagrave and marsh road. REDUCED PAVEMENTS TO ALLOW PARKING - there is excessive pavements that are not being utilised. Parking is key. The council have not provided sufficent parking facilities for a shopping district as busy as bury park. TRAFFIC WARDENS TO ENFORCE THE YELLOW LINES - this is a plausable alternative and sufficent to ease congestion and improve traffic flow in the designated areas. Red routes is not a good idea as it does not seem effective Make dunstable Rd as it was, lanes for buses to stop without stopping traffic flow and more wardens to implement fines for those that park illegally no we just have to deal with the level of traffic No red routes No There is no other option no no No. The red route plan is the best way forward. Sort out illegal parking and supply more parking spaces Try reducing congestion by sorting out B&Q roundabout, Oakley Rd roundabout (Dunstable Rd side) by the Range. Also hatters way roundabout bury park side. The amount of pollution, congestion these areas cause is unbelievable. Why waste money on red routes when these are the most congested areas in Luton. Increase parking Build a multi storey car park in Bury Park Enforce more strictly the parking regulations already there and make it an offence for a vehicle to park on the pavement. Pay and display bays for visitors Speed humps should be put in Apply speed bumps and pay and display bays on leagrave road for visitors. Putting in speed bumps and pay and display for vistors 👎👎�😡😡😡😡👎👎� Need additional rail crossings No luton is congested too many cars on the road it is what it is
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No Get the buses to stop in bus stops not in the traffic flow Have buses to not stop on the road and into the payment, it creates a lot of congestion up to the entrance into bury park especially from the stop outside lifestyles shop. Maybe a sign for drivers to give way to buses to get out of bays to allow busses to run on time. Red route will have a dramatic effect on shops as bury park is not seen as a high street. There is also no car park in the area and it is not ideal to use Sainsbury’s or Lidl car park as that will create more congestion there. Marsh road is a issue due to loading vehicles as no vehicles can go around it especially around the supermarket area. Maybe allow only loading at certain times or create a bay for loading vehicles only Bus layby Some red routes are required in key places, other ideas would be to open up waldeck road to both sides That is the best red route Block hgv lorry’s Instead of paying unqualified people £100,000 a year who have caused the traffic due to poor design in previous planning make proper bus bays and better parking bays no need for red route at all. Red route is a money making ploy. Use bus bays in bury park so when the buses stop they don’t block a whole lane of traffic, you could do the same on marsh road too Introduce more loading bays Separate bus route No Sort out parking in Bury Park. This area is the main cause of congestion in Luton. The previous work done to widen the pavements and narrow the road have made the area worse not better. Wide the road create more parking bays introduce, double yellow lines- increase traffic wardens patrol- install speed cameras. Yes, provide better, and affordable parking. No, BuryPark and Marsh road have plenty of pay and display parking spaces but drivers refuse to use them and prefer to park Inconsiderately wherever they like. All alternatives have been tried and failed- the only viable option is the red route. Give bus stop bays. It’s the buses that are causing the issue of traffic. Everytime the buses stop to drop or pick up passengers they cause an unnecessary queue Fix the pot holes Only one bus stop in leagrave road to Sainsbury’s enough. Right now there too is 3 stop. Make a parking bay next to AA carpet for loading and unloading the pavement there is too big it can be make smaller or half size. Create more parking places and Camera control traffic during peak hours when necessary. No Yes make a separate bus lane and also make a seperate lane for emergency vehicles in doing so the pavements will have to be smaller . The pavement is far too big . Bus layby for buses to stop, more parking (not extortionate amount) Make bus service more efficient Bus stop should be in bay not on road Town centre should be all red routs. Traffic will just go elsewhere. waste of energy and tax payers money ...the way traffic is going its fine Make three lanes in bury park One for the buses Push all bussiness to get off pavement And to there shop.so every thing inside shop nothing outside From the shop wall leave 6 foot pavement rest for road
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Make bridge’s for pedestrians to get Across the road Bury park, take out middle brick section, expand road. Build a car park in Bury Park so shoppers have somewhere to park Bus stop bays should be made. So buses do not stop in the middle of the road. More Parking facilities should be made.i.e multi storey car parking, Move football stadium and build a paying carpark for bury park shoppers Create bays for buses to pull in and pick up / drop off passengers and allow traffic to pass things are running fine....so why complicate things by putting in silly schemes... We need bus bays to allow traffic to pass. Red route will send traffic elsewhere CCTV VERY IMPORTANT ON THIS ROADS Bus bays Leave it as it is we don’t have any problems unless you want to make money of it Better traffic light management Put bus bays Cameras and fines Provide parking spaces Bus bays You need to create bus bays. The traffic issue is caused mainly by buses on leagrave road Loading only bays No, Red routes is best idea No red routes The main problem of congestion on leagrave road are the buses and bus stops. Lay-bys have to be created. Bus bays the way it use to be. I think camera to monitor speed should be put on as we have had several accidents on leagrave Rd Yes. One way systems. Bus stops not actually ON the road.
Dont know Use bus ways Entry into Dunstable Road from Telford way should be made into 2 lines the pavements need to be decreased in width leaving 2 metre minimum where possible,buses should have laybays spaces beside the 2 lanes ,so as currently the buses stop in the middle of the road which build up traffic,.with this new proposal traffics can flow freely Bus bays Bus bays More parking put red line all alone leagrave rd no stopping or parking, than traffic will flow swiftly, same with dunstable rd There should be an enforcement camera facing the traffic light junction and “yellow box” outside Cycle King/Sabba Furniture on Dunstable Road - Bury Park, as a lot of cars go into the restricted yellow zone therefore creating a build up of traffic and not allowing traffic with right of way to enter Dunstable road due to cars blocking off the entry onto Dunstable Road. Leave it how it is it’s safe always has been Provide for parking and loading. Loading not just for customers, but buses/taxis picking/dropping passengers. Bus lanes There is no issues with the flow. Think about parking in bury park and make a large storey car park in bury park so people can park and shop Reduce pavement and install loading bays, to help traffic flow. there is no congestion in this area Better public transport. I dont know Have lay by in Bury park for buses and moreLoading unloading bays make pavements
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narrower. Bury park,Dunstable road needs a bus lane. It’s the bus that holds up traffic. SAXON ROAD DEFINITELY NEED TO MAKE ONE WAY AND ONLY FOR RESIDENT. Because every day has fight with different groups which embarrassing the resident and there is not any authority to look after this issues. More traffic lights Homes and buliders must plan for the future by having at least parking for 2 cars if not 3. Make separate bus lane or pull over bus stops to make sure buses don’t end up holding traffic behind them Make bus stops off the road or just change their routes so they don’t stop and mess traffic up. We need to open bus way for normal traffic to ease congestion RED ROUTE Will Bring more problems and issues in Luton. Yes, plan road improvements work that will improve roads and not make them worse, eg bury park. Allow bus lane to be used at non buzy times It has nothing to do with cars being parked. I drive every day and its just a lot of traffic. Ditch the busway. And put more lanes in on hatters way BUS bay Yes u need better car parks - pref multi storey car parking in marsh Rd and bury park rebuild bus lay by’s in bury park to stop congestion behind bus stops. bus bays with enforcement cameras issuing immediate fines. Yes more cheaper car parks in area. Bus bays Yes. Need red route on Leagrave Rd. Too much cars parked on both sides of road. On zigzags. On yellow lines. Drivers don’t care. Parked close to bus stops or on bus stops. Buses get late and can’t park safely in bus stop because of cars near Saxon Rd on Leagrave Rd. Need improved bus stop Fix the roads and of all the pot holes then the roads will be safer First provide sufficient low cost parking then put restrictions in place No Yes.lots of options Red route would be perfect, specially where I live on spencer Rd. My wife is disabled and takes a long time to get home when even at the bottom of my Rd on Leagrave Rd. Lot of cars park by the garage between spencer Rd and Saxon Rd. Sometimes my wife wets herself as she is disabled because of this uncontrollable traffic. No one cares, they even park on zigzag lines to go into the Leagrave Rd garage. Iv has enough of this. Then the garage parks there costumers cars on our road. Make parking bays insted if trying to make a red route to rob the locals if there money’s Yes. More traffic wardens that are active. Bays for buses. Need Bus bays Make bus bays!!! Seperate bus lanes or different route for buses. Stop parking on corners Yes, change it to how it was before. You made wider pavements however only to benefit the grocery shop owners. They got the shop out right to the pavement which has hardly any space for two people walking and this is very dangerous. I believe if u get the bus lane back on dunstable road it will ease the traffic. When a bus stops on the road rhe whole road becomes standstill. Having bus bays will resolve all the problems as its the busses that hold up traffic and cause problems. More signs Lot of traffic always be held on Leagrave Rd between Spenser Rd and Dane Rd. Need a red route on all of Leagrave Rd. No you guys are making it hard for every 1 wake up who is in chargrg off this Yes create small multi storey carparks in some of the larger areas - ie marsh road rather than building more and more flats which are unaffordable anyway for some anyway. Cars which park on roads to stop for shopping will use carparks if available and congestion will reduce.
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The council can come up with something but no red route I think make a bus stop without road not on the road Stop the busses going through bury park they cause the traffic Speed humps or speed cameras I drive my own car for transport and I think the only option is the red route implementation in suggested areas. In my opinion the main reason for congestion is inconsiderate parking/waiting. It is about time the council take measures as the town becomes stand still at times specially dunstable and leagrave road areas where i am a resident. The only alternative I can see would be to introduce a one-way system between Stuart Street and Birch Link, with the introduction of barriers to prevent illegal u-turns that frequently happen in that stretch of road. Additionally, railings could be added between the road and walkway where there is no legal off-street parking provision from Birch Link to the intersection of Leagrave Rd and Blundell Rd/Waller Ave. if the road markings “ as is “ were enforced!! the problem would not occur this is only best way forward but when you allow VC on Leagrave Rd on busy day when wedding gos on sorrounding Roads Like Dane Rd,Sexon Rd,Norman Rd all these roads pack with people as guests they parks their cars on these roads Widening the road , take away the speed bumps this will make the traffic flow through quickly and increase good air quality at the moment the air quality is bad for people with breathing problems. Stop pavement parking No
Please use the space below to provide any additional comments on the proposals. This bus stop is a nuisance for the home owners because it is restricting their parking and removing it further down in between holland road and norman road would be an ideal solution because that is where most of the speeding happens and most accidents. Sitting a bus stop there will slow down the fast cars and will keep the traffic flowing. The present bus stop is a major hazard for the road users as cars are constantly overtaking the buses whilst at the stop. The owners have difficulties on a daily basis entering and exiting their properties due to the big green bus stop and blocks all vision when mostly exiting hence why it is dangerous for the road users and present owners. Double red lines will not help congestion in anyway it will only cause all businesses to lose customers and eventually shutting them down. These areas are business areas and all businesses will be affected, both with losing customers and not being able to load/unload or receive deliveries. Our business relies heavily on customers coming to order and pick up goods but also on us making deliveries all throughout the day. The red routes is unfair and congestion can be sorted by making indents into the pavements for buses and AA carpets loading bay. You can't provide parking, you don't give permissions, simple solution. This current issue is one of bad decisions being made over the years, not one of inconsiderate stopping. Please get it right and do not further inconvenience local council tax payers with further enforcement. It's purely a vehicle to generate more revenue and we won't stand for it. Get rid of the current senior mgt of Luton council to start with for making such disastrous decisions to date. The current layout of roads has affected our business in bad shape and if the red routes will be introduced it will take a huge toil for the worst to our business Bus stops are being relocated so its a good idea to relocate the bus stop outside 310/312 leagrave road to give residents full access to their parking outside their own houses Think of the businesses that would be affected by this new proposal, do not waste our money on these silly plans. increase parking and reduce the footpath sizes on some areas. There is a lack of parking on leagrave road end coming into bury park,,, there is no choice but to park on the road. More parking is required Residents of leagrave road who have permits should be allowed to stop for 20 mins and load of offload pick up or drop off as long as they have residents permit A&B on leagrave road. You
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can't expect them to have to park miles away to drop off and pick up or drop off shopping and kids and so on. once the red lines are down people will park on the pavements, will this be stopped? The roads and traffic congestion in these areas are a total disgrace brought about by council inactivity. Like many others we now rarely use the town centre (we did yesterday and traffic was a mess) and choose to use places like Hitchin, Milton Keynes etc which is taking huge amounts of money out of the local economy. Luton council is totally incompetent in managing the town and I doubt these measure will help that much - they will just paint red lines and leave it at that - people will not have to change their behaviour. WHY IS THIS DOCUMENT SPELL CHECK ON USA ENGLISH - we spell centre NOT center. Typical of the rubbish that comes out of the town hall. I hav a disabled mother who lives in marsh road and has limited mobility how is it fair to decrease her mobility further Solution to alleviate the problem is to provide available parking before bringing in any red route system. The proposal would severely negatively affect local independent business, consequently exacerbate unemployment locally as customers would avoid the area. Think you should extend it to school markings too. Making them red instead of yellow. And actually enforcing existing restrictions, eg the no vehicles on mown verges along leagrave high street and poynters road. All of the roads mentioned are wide enough for cars to pass. It is the volume of traffic that causes delays My concern in Marsh Road is it will push parking into other areas. People already park behind the double yellow lines in Archway Road, on the wide Pavement outside the old Sorting Office. The bottom end of Limbury Road will become clogged so cars will still clog the roads that drain Marsh Road. There really needs to be more disabled parking. So many of these problems are caused not only because there are so many cars but also because when LBC gives planning permission for new accommodation they allow 50 flats and only 10 parking spaces so the roads become clogged with 40 cars of people who can't park where they live. It's unrealistic to expect people will use public transport when it is so bad. To get the bus into town now means and hours journey through each and every housing estate along the way. It's ridiculous. Public transport just isn't an option. The car is king. The habit in Luton is to park on the pavement. I push a wheelchair user and my best friend a pram. We often have to put vulnerable people into the road so we can continue our journey because cars block the pavements. This problem is so much bigger than creating red routes. I am not sure that red routes will really change anything in general. They will open up one road but cause parking issues in other places. Nobody seems to be looking at the bigger picture. Public transport is not the way forward. More parking needs to be created. I live in the area of Marsh Road and at school run times it is often the least clogged road. Stop lorries to come in the burry park and offload haji chicken while parked on main road. Lorries should be allowed after 9 pm. This red route should be extended to the north luton boundary to the far extent of sundon park, junction sundon park rd/camford way. Reason there is heavy congestion in sundon park road, especially since the new motorway junction opened. Cars parked on sundon park road create obstructions for heavy traffic. The cost of revising the scheme for the length of sundon park road must be less now than extending it in future years when congestion is worse and houses are built to the north of luton by central beds council. How will it be enforced because the the Traffic Wardens are too frightened to issue parking tickets in some of these areas ! Business name. A&k motorist centre Implementing a red route on leagrave road will affect my business and affect my deliveries and If implemented LBC must enforce the red route either with wardens or preferrably cameras, otherwise bad/inconsiderate parking will continue to happen. Parking in River Way & Willow Way is currently very difficult for residents due to increasing numbers of Leagrave Station parkers. Implementation of the red route in Marsh Road will inevitably push day parkers into side roads such as ours. If implemented can yellow line
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restrictions please be introduced in our residential roads. Move bus stop from leagrave road opposite Britannia estate. I have 2 cars and can only park 1 because of the bus stop with the red route i have no other parking. More speeding cameras and Cameras on bus lanes are important as people do not respect the law at all, as luton is worse compare to any other town and cities. These changes will keep people safe and safer luton also make peoples life easier for everyday commuting Close venue central More patrols when there are weddings taking place Move the bus stop that is between tudor road and Cavendish road. At school times it is impossible to park a bus at that stop and dangerous at times aswel.move the bus stop to the car park near holland road its a much saver place. Along marsh road there is enough pavement space to potentially put more loading bays for the lorries that come everyday to pizza hut the carpet shop the polish shop and the road can also be made wider to create more pay and display parking that needs to be enforced. Should use the meters which require a reg plate and enforced by cctv for compliance All red route proposals are very good but will require real enforcement to be succussful I think the red route should be day and time controlled- on Marsh Rd some business open out of hours and if a red route is 24hrs , it may impact on their business'. Concerned how this will be enforced. On Dunstable road, you have one lane for private vehicles whereas dedicating one lane for buses and taxis which I rarely see being used. If you let both lanes used I believe you will have less congestion on Dunstable road. There is a house along Marsh rd who runs a business from her home doing house clearances. She has a slip on the drive and then parks about 3 vehicles on the road. Constant issues. Lawlesness parking all the time in Bury Park- needs strict enforcemwnt. Maybe work qoth likea of Sainsburys etc for park and walk facility to stop people driving into Bury Park. Ban pwoplw from.parking in front of their shops- evwn though it may technically be private land. Remove on street parking bays either side of dunstable road in bury park area- otherwise this will not enable amooth red route. Pedestrianisation would improve the area, encourage more browsing and shopping and footfall. Would be a more pleasant place and would encorage shops to clean up thus enhancing the area. Implementing red routes won't be effective unless there is effective and regular enforcement. MAKE RESIDENTS DO AWAY WITH THEIR FRONT GARDENS AND PUT IN DROP KERBS FOR DRIVE ACCESS .... it is unfair for those of us being affected not to have been informed about this, I only heard as my neighbor mentioned it!! absolutely annoyed Please don't punish residents anymore then you already are venue central and units 1 and 3 are a nightmare. Red lights will impact residents more then the venue and units 1 and 3. Where will my visitors park if this is implemented! On Leagrave Road just just get rid of the bays at the bottom If you don't do all of the suggested area please please do Marsh Road especially outside Barclays Bank How about fix the roads pot holes and bad surfaces The changes MUST be reviewed after a period of no less than 3 months to confirm what improvements have been achieved. If there is no improvement or it has been detrimental, it should be reverted Need 10 mins loading time. As most business would suffer. This is a must as i have to load and offload the small van/car with tools Residents need more parking and venue needs to be closed down. Add more parking bays Only for residents In the Bury Park section of Dunstable Road cars park completely on the public part of the pavement. I hope the Red Route proposals will deal firmly with this issue. Red routes would be unnecessary if enforcement of existing parking rules is enforced. I think the red route would just encourage people to park on the actual pavements, which they actually do now.
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Please can you ban parking all four wheels on the pavements Following on from my comment above. The area outside the shops and garage on Dunstable Road near the top of Kingsway has a double yellow line. There are often up to 10 cars parked here. Along these roads there are many small businesses and homes with no parking space. What provision would be made for them in a red route scheme? More parking for residents. Because you've made a mistake with venue central who's customers park on he main road and cause these issues. Now you're punishing the residents by doing a red route when you should have nipped it in the bud by putting restrictions on venue central. Close down venue central and NO to red route offer residents drop kerb at no cost Will need education and strict enforcemrnt to be effective I think it's a great idea people should use the correct parking, loading bays etc I think often it is pure laziness, they don't want to walk two minutes from the car to the shop It will damage small local businesses I rum a Post Office and it will have detrimental effect on my business and the to the business next door to me. It may be ideal to move the bus stop outside the Post Office towards the Library on Marsh Road and provide free controlled parking bays outside my Business to support the business if the proposal goes ahead. We need more parking. An excellent idea. Something definitely needs to be done about vehicles parking on the main road. My main concern is that drivers will look for free parking places elsewhere which in turn will move the problem to residential streets nearby. Where do leagrave road residents park there cars ? Where will they drop off and pick up? How will shopping brought in ? Asda and Amazon etc will not deliver anymore so will we have to park miles away and carry 2 bags in at a time ? Parking will become an even bigger issue. Just look at the complaints about parking. Better enforcement as this area along Leagrave Road is terrible for parking on double yellow road marking. Residents just abusing system Things will only improve if you close down venue central. Parking issues raised since they have been holding weddings. Parking is limited introducing this policy will restrict side parking even more as they will all use the side roads. Parking bays just be made mon-sun 0000-23:59 residents only There's not enough parking and red route will make it worse. If it was a residential only area it might work as only residebtscwould fight for parking spaces. But we have wedding venue shops mosques colleges garage so it's not correct option. Not to allow wedding customers to osrl on residents bays they must have own parking. This policy will cause harm to residents. People will start parking on side roads so they will take up residents bays even though we pay to park. They will stop middle of side roads to pick up kids from Islamic school and college Where will my deliveries deliver ? As they will now find no where to stop and drop off. Parking bays will.not be enough This is one of the worst ideas. We have limited parking and now residents bays will be taken up by shop customers garage customers venue central customers school and mosque customers college customers Make leagrave road or parts one way so we domy need a red route By closing venue central all the issues will vanish. Signs need to be put up telling drivers NOT to park on pavements Venue central users garage and ship users school and college users will all park on side roads now which means even less or no space for residents. This is not a good idea, especially on Leagrave road as people have to stop to park in front of there houses which will just cause penalty fines for no reason and a waste of money one when trying to appeal. Also is this really to benefit traffic flow or is this another way of getting the government more money through penalty fines!? Will be a burden on elderly and kids.
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Will be a burden to go out as we know we will never find any parking. You council are wasting your time you need to sort out other issues but are worried about red routes which will disrupt local businesses and cause headaches for the residents and businesses The leaflet doesn't give any details around enforcement. Speed camera is another thing missing from proposals, especially on the strength of leagrave road between juntions with Waller Avenue and Montrose Avenue. There has been numerous accidents over last 3-4 years and near misses happen on daily basis due to a combunation of overspeeding and high number of garages along this stretch. None Residents who live on leagrave road and have no off road parking will have to park a long distance away. Anyone with elderly parents and kids will suffer. You expect me to drop my elderly parents and my kids miles away from my house ? How will i drop off shopping as the parking bays you are proposing will always be in use no one will delivery to my address parking will be even more congested as no one will be able to park on leagrave road i am against this policy of yours. I am 100% in favour of the proposal, but it will have to be rigorously enforced. Drivers have total disregard for the yellow/double yellow lines there now. I am also concerned that residential side streets will be used for parking more than they are now. In Leagrave more use should be made of the Mostyn Rd car park for instance. River Way & Willow Way is used by drivers parking all day (for free) & working in Leagrave or using the train. It is very irritating. Mark buss have cheap fares The parking of vehicles in the short section of Leagrave Road from bottom of Selbourne Road through continually to Bury Park Park needs to be addressed by making Red Route at all time speaking as a business owner on marsh road there does not seem to be any loading facilities on both sides of marsh rd. we are world of carpets who have full rolls of carpet delivered from the front you have put 2 unloading bays on the opposite side of the road. this would add to the congestion on marsh rd with us trying to cross the road with full rolls of carpets.the rolls are delivered in 40ft lorries. Remove the parking bays along the routes. Remove the disabled parking bays that are so often abused EXCEPT outside driver/owner property. Leave bus stops alone. In London buses stop on red routes so what would be the problem, if the measures are supposed in part to improve bus time keeping. Pay the police more money from what you have. Not by taking more from the layman. Have looked at the crimes rates? Parking provision needs to be increased on marsh road. All through the shopping area parking lay-bys could be added. If these were in place there wouldn’t actually be any need for a red route anyway. Concerned it will result in serious parking probs in side roads Seems to me it will make traffic run with not so any delays or hold ups therefore a faster journey. Your going to move the parking problem we already have from one area to another so don’t even think about it, the council Is supposed to work for the people and the only thing LBC is doing is making life more difficult for residents . As far as Q8 is concerned the changes made last year to traffic lights etc. in Dunstable Road have had little or no effect, people still cross over the road, ignoring the lights, cars stop and let people cross again ignoring the lights if they are green or not, Dunstable Road , traffic and people will always be a problem, there is no easy solution. The side roads off of Dunstable Rd are also full, so trying to push more parking into them, to get traffic out of the main road would be a waste of time because there would be no where for them to go. In general they are a good idea and in the other roads they may well work, but not in Dunstable Road. Change traffic light sequences to improve traffic flow This survey should have maps of the areas Do it, but enforce it please. Otherwise just a waste of money It will just end up a money making scheme and not really help with traffic We already have no parking on our roads. With the introduction of red route it will be impossible to have parking. This will be a kick in the teeth considering we already have to pay
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for parking permits to stop cars parking on the routes maybe provide parking spaces at a lower cost Bottom of leagrave rd junction is a nightmare so very much welcome this Agree, should have been done a long time ago. Need to be enforced to let people know if they park on the routes they will get tickets. If no argument about additional parking. Bury park has parking which people just don't want to pay for. Any other high street there would be constant enforcement. Why not this one ? So lbc planned this a long time ago that is why they put in so many cameras. Lbc should not persecute the driver after giving so many shop licenses Roads around here are totally congested. Despite the current double yellow lines there appears to be minimal enforcement If u make leagrave road red route you will force everyone to park on saxon dane spencer norman roads. As we are so close to venue central all the visitots will congest up our roads. Make leagrave road one way and put pay and display in some bays. More parking bays/car parks for cars. Buses to get their bus stops or stop buses coming along these roads altogether If you do red route on leagrave road u will force all non residents to patk on out side roads like saxon and spencer and we already struggle with parking. Why not introduce pay and display bays on leagrave rd giving visitors somewhere to park safely without congestion on streets no Even if this proposal is put in place how will it be implemented as many drivers disobey the general road laws? Putting red routes down on Legrave road will cause further misery for people who live on the side roads as this will further increase congestion on side roads. Saxon road should become one way to reduce congestion Red routes are of no benefit to this town not only will they kill of the businesses it will also make Luton a no go zone for outsiders and locals who wish to come and visit here or even shop. How will shops get deliveries from parcel companies during the day on kimpton road windmill road bury park etc if they can’t stop and they also will lose business from customers too Red routes are a disgrace Thoughtless people block roads because they know they can get away with it. Get more wardens and real police on the streets with real powers and the project will fund itself and prevent many dangerous driving incidents plus improve road safety. Red routes are not the answer go back to common sense. This will only be beneficial if council enforcese the new regulations How would you enforce the red route effectively? How would you ensure that the elderly or those on need who live upon these roads do not become isolated? Luton has a massive traffic problem, although the Ted route will help, it’s putting a plaster on a gaping wound The ad-hoc parking of cars upon marsh road makes the cycle lanes unusable and very slow when driving. I live very close to marsh road but will take long detours to avoid using it during the day as busses frequently get stuck waiting to overtake an illegally parked car. The funny thing about this proposed red route sceme is that most of these roads people should not be parking on anyways as they are either double yellow or single yellow. Years of weak parking enforcement have given the impression that it is socially acceptable to abandon your car anywhere you choose, and sadly there are many inconsiderate drivers that are capitalising on this.
this is just another way of penalizing and taxing people increase cycling, walking and buses The existing parking restrictions should, if properly enforced, deal with any problems of congestion and safety in the above roads. However, it is very evident that these restrictions are not properly enforced at present. If they were to be, red routes would be unnecessary. Red routes also have nothing to do with road safety. I use Dunstable road 4/5 times a day and the traffic is horrendous specially at the end of moor
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street joining Dunstable Rd and all the way through Dunstable Rd, it’s nightmare and most of it is caused by bus where the 3 bus stops are picking passengers and hold up the traffic. I would like to emphasise on disabled parking bay, there are no parking for disabled along Leagrave Road, as disabled person and having difficulty parking in leagrave Rd, I would appreciate if you could look into that. There’s another problem in Dunstable Rd..there are only two disabled parking spaces in that road and it’s always the disabled space is occupied by vehicles which does not have a blue badge, I would suggest you look into this as well. INADEQUATE TIME HAS BEEN GIVEN FOR PUBLIC CONSULTATION AND ADDITIONAL TIME FOR CONSULTATION IS NEEDED Need bus bays so the normal traffic can flow Also in Bury Park shopping areas not stopping All shopping areas should have res route not the entire Road lenght Put camera outside AA carpets birchlink which will make traffic flow wuicker Better traffic light phasing, and better parking provision for public and retail use This needs to be implemented and ‘policed’ people have no regard for parking restrictions in this area I worry about increased traffic parking either legally or illegally just outside the red route areas. In particular outside Beech Hill Primary School, with people then walking to the red route areas. I’m not sure whether the red lines will make a difference to the drivers in the area anyway. Enforce existing parking rules properly Venue Central on Leagrave Road cause traffic congestion More parking attendants patrolling
No the area affected needs to be much larger From my house in Marsh Rd I use a rollator when walking to the local shops , there are times when cars and vans parking on the pavements prevent me from getting through .As a result I have to walk out onto the road , as do mobility users and women pushing prams . I am referring to the area by the new block of flats No. 224 .This is compounded in having two Virgin Media units making the issue worse .In the past I called the Police traffic control twice re problem ,to which they responded ,but the perpertrator just ignore .Having to walk out onto the road makes it teneous given the volume of traffic using Marsh Rd everyday Illegal and inconsiderate parking lots s a nightmare for bus passengers and pedestrians. The red route will mean that mothers with prams and those in wheelchairs can safely proceed along the pavements. Currently, many pedestrians have to walk into the road to get around cars parked on the pavement. The red route solution should be implemented as soon as possible. We are a business in Marsh road. Our company is being crippled by unpoliced illegal parking at the junction of Marsh Road and Nursery Rd. We consider that red routes would be of great help PROVIDING that the are taken round the corners and cover the first 100m of so of each side road. If this does not happen it will just make matters worse for us and other commercial traffic forcing reversing of HGV’s into the main roads where illegal parkers have been displace to the side roads Worst possible suggestion by LBC and yet another waste of money Red routes should not be implemented where congestion is not a major issue Red rood will kill Bussiness in the area Manchester St Red route. upper George St red route bute St, silver St, Chapel St should all be red routes Ways to increased parking bays would be a better way to direct people to safer places to park. This will hamper business and shoppers without providing alternative parking provision Take out middle space more room for road Your best solution to reduce traffic is to re introduce bus bays which will significantly reduce blocking, the red route solution is going to KILL the retail industry in this area which is already dying.
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Im sure all the professionals in the council can tell you this, if NOT then i am sorry to say none of the people who sit on the board to make such decisions for RED ROUTES are in touch with the area and people trying to make a hard living. Once can only judge whether these proposals are sensible by assessing the alternatives such as better enforcement of existing restrictions, and balancing the cost to the benefit. I cannot find any documents that give me adequate information. you need to cancel your dead line and start cunsultanting the community Loading bay for AA carpet. Footpath is too big make it half size will reduce traffic and make the bus run on time I wonder who was bribed to change from old to new n then make further alterations due to incompetent engineering. Who’s paying, we are. Red route along complete stretch of main Luton roads is ill thought out and does not address the reasons for congestion in localised parts of Luton and alternatives planning should be considered which address the problem without drastic upheaval and damage to local businesses. This will have a massively adverse effect on all busy park business. As customers after getting fined will find alternative shopping areas. Will be impossible to take deliveries as it is already extremely difficult. Just marking need more Wardon need to look A car park in Bury Park would help. Give bus laybys so bus doesn’t stop in middle of road causing traffic queue Above Consult the public in these areas first before coming up with any proposals.where do you think cars will park in future possibly in side streets causing congestion and pollution in residential area.Also increase parking in bury park as if not buisiness will reduce and close resulting in dereliction and property prices will fall resulting in fall in rate revenues for Lbc and loss of jobs in one of the most deprived wards of lutonThis will push back 20 years of hard work done to improve Bury park Need more traffic warden implementation.
Marsh Rd is my local parade of shops and I both drive and walk frequently in this area. I fully support the introduction of the Red Route proposals along Marsh Rd. Please note above my comments on: 1) Enforcement:There will need to be extensive camera enforcement. This consultation gives no details of any proposed enforcement measures. In London Red Routes are successful because they have comprehensive camera enforcement including on buses and a central control room 24/7. There needs to be far more detail about the proposed camera enforcement in Marsh Rd, Leagrave Rd and Dunstable Rd. Once Red Routes are introduced and the public finds enforcement is no different from now, the infringements will continue. 2)Loading bays: there may not be enough additional loading bays proposed for the Woodland Rd to Rondini secion of Leagrave Rd where there are a number of small businesses. 3)Parking on the pavement: this is a huge problem the length of Marsh Rd currently and existing restrictions are not enforced. If the Red Routes are successful many will just drive up onto and along the pavement to park. They already do without any sanctions. Sometimes it is so bad outside banks and take-aways it is impossible to walk along the pavement, far less take a child’s buggy or mobility scooter through. The tree tubs, seating and bollards have been successful in part in prventing vehicles from mounting the kerb - but many bollards have been deliberately removed to allow pavement parking. The licensed vehicle premises along Marsh Rd park vehicles on the pavements and on existing restricted yellow line areas day and evening with impunity. 4) Speed of traffic. If successful in improving traffic flow and illegal parking, the introduction of this Red Route could cause a considerable increase in traffic speed. The 20 mph area on Marsh Rd is very welcome and may need to be extended along Leagrave and Dunstable Rd if traffic flows improve. Overall the introduction of the Red Route is most welcome the length of this proposal. The main question mark is adequate enforcement and credibility of the scheme. Please publish enforcement details.
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More silly ideas to create more congestion. No thank you. Loading bays should be added in areas Red route will kill all the business along Dunstable road and will have a devestaing effect on bury park as a whole . The traffic issues that exist in Bury Park are no different from the build up of traffic outside all Luton schools both morning and afternoon during pick up. Yet I see nothing done to help ease congestion. Why target businesses who are already suffering with online competition and business rates eating into profits. This idea will only accelerate the demise of a small independent high street location and will increase the council’s finances with the amount of fines handed out, at the detriment of local businesses. Railings along dunstable road would stop the pedestrians crossing Willy nilly. That is a cheap and effective solution to improve safety. Reducing footfall is NOT the answer. Have they considered any other options like enforcing present traffic parking restrictions and put public parking in the Sainsbury’s car park Red route will deter customer coming from out of town which we desperately need this will put us in red line Do not use red route for this area otherwise all businessmen will shut. This red route proposal will cause many major issues. It will impact all local buisnesses as customers will not want to come to these area. Also the red route will cause major loss to property owners as a red route outside your property will slash the price of your buisness and property. Who will compensate for this? People who live along the red route will not even be able to stop outside their own homes for even a matter of seconds. Millions of pounds worth of overall loss will be caused. Change parking bays This will cause more problems for people and will put business at risk There is no problem of congestion on marsh road or Leagrave road up to Britannia estate. The real impact of the red route on the business has not even been considered by the Council. Bury park shopping is popular with Luton and its surrounding areas as far as Oxford, Coventry, Peterborough and further afield and travel by car is the preferred option for many customers. By implementing red route, the customers will be driven away from the area. My own business and many other businesses take deliveries during the day and this will impact negatively on the trade and a thriving area which is a major revenue source for the Council. I accept that there are a lot of cars on the road which may be due to increasing population and popularity of the area. That is fact which London and other towns have accepted. I also accept that there is an issue with inconsiderate parking which has to be dealt with in an alternative way; more enforcement of the current parking restrictions. Further, the slow traffic and congestion is caused by the current design where the buses stop on the main carriageway causing long tailbacks. This must also be addressed in a different way by implementing bus bays. All the shop keepers in the area and upset and angry about this proposal that the business impact is not being considered in this consultation.
Live in Biscot, hardly any resident parking available. Parking taken by customers to local businesses or the central revenue building. Particularly on a weekend where parking is very limited. Sometimes have to park away from house and walk because of this. Walk along Bury Park and there cars are all parked on the pavement, cannot walk through. Waste of money in these straightened times. Spend it on a campaign to raise awareness about rubbish dumping and social responsibility in respect of recycling and a campaign YES a campaign however ironic it may sound on Lets Make Luton Beautful! Start with the town centre around St Georges Square. How dare the council allow business owners to have shop fronts which are plain hardboard signage with a token PIZZA sign for example. Wouldn’t happen in St Albans. I absolutely oppose to the idea of the red routes anywhere in Luton. The council car park in Hazelbury Crescent, opening up is a help but hardly anyone knows that you can park there. It is not very well advertised. As I use the buses every day to go to and from work and can say that the ignorance of people who stop on any of the above roads causes considerable delay to these services I have noted that people are saying that this will cause businesses in the area to lose out
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This is not the case there are ample places to park safely along these routes it just means that they will have to pay like everybody else to park correctly I hope this scheme is put into place very quickly Specially on side road corner red line and cameras so that wheelchair can cross safely without going to the main road Some geniuses park on the corner wheelchair users can’t cross the side road safely. Restrictions on loading and unloading Bus don’t cause traffic in bury park it’s the delivery vans and lorry’s parking on Dunstable Rd Bus only stops for minute or two lorry stops for hours causing mayhem and frustration LBC please help Currently there is a balance of flow of traffic, if you implement the red route, it will drastically reduce traffic from those areas but will heavily impact other smaller and residential routes around, so it’s not a good proposition to ahead with. Rather we need more introduction to more adequate parking facilities in various busy parts of Luton as more cars grow on the roads day by day! Since the road work in Bury Park has been done there has been awful lot of traffic especially when your stuck behind a bus thats mainly when its traffic No red route Red route is not the answer all that will do is fill the pockets of greedy councils that don’t have a clue and embark on knee Jerk reaction. Enforce the current existing restrictions properly by having more patrols in the area. Provide proper pay and display parking bays so law abiding citizens can park safely and waiting the law. Business’s will suffer the most as this will drive away trade as customers will avoid the area in fear of getting a parking fine. Will increase and encourage motorist to break the speed limit as they will have an open road, and people are morel likley to drive above the speed limit. There is a place for red routes and that would be in crowded town centres, after the off slips on motorways etc but not in the middle of residential streets and small business areas. This will render bury park like high town and drive away business. The council will also lose out in revenue as business get closed and leave the area. This proposal woukd only divert traffic to other smaller roads , business would suffer massively Your plans are going to effect the businesses around the area. You will be killing off the high street. The economy is already struggling you will be making it worse. Stop thinking about your pockets and arriva and think about the people of luton. How can business people survive when you enforce the red route. Just because you want a bonus from the money generated from the fines. Move the bus stop from outside 312 leagrave road so i can park my car in the driveway and then the red route does not affect me, if you dont move the bus stop then i will be affected. I don’t feel that there is sufficient congestion on our stretch of Marsh Road. It will affect the operation of our business and will result in redundancies within our organisation. On top of that I will consider to use red lines on Biscot Rd. Narrow bury park pavements The majority of the roads are providing local access and shopping facilities and only the limited access sections of the A505 would seem appropriate for red route status (but these sections do not suffer from loading / parking !) please create more parking spaces. marsh road is often single file due to bad parking on both sides of the road N/a £2000000 was spent on bury park which has made the area worse than before.Pls consult residents and businesses in these areas who can give u a better understanding on what to implement Ridiculous idea with no alternative parking options going to cause more disruption and make the roads unsafe This is a crazy proposal, I see no logic for this The current parking spaces are wasting space, cars should be able to park diagonally. You have many areas which can be converted to parking spaces. i dont know Also, there should only be loading vichels allowed in the area between certain times for
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example one hour in the morning and one hour in the evening that would help more Placing Red ban will only irate residents and affect businesses in Luton. Our businesses for the town are vital. Many will stop going shops. Time zone can be applied. Increase car park ticket. Build car park for bury park which would take all that traffic off. I strongly agree with red route in bury park , it’s the only way forward Thank you Use our money wisley and not creating problems for normal people Waste of tax payers money Who ever came up with the idea of red routes does not actually live in Luton. People have houses on this route and half of the people are without drive way. Where they will park or will do pick and drop. It will effect business specially in bury park and marsh road. It’s not a good idea. I drive through Bury Park daily several times a day and cars stopping have minimal impact to congestion. Removing the bus lanes was a ridiculous idea and we are now all paying the price. Red route is simply not the solution when go along leagrave double pared cars stop traffic when going home extra parking and loading times I do hope this will be a start on tackling the problem of school parking. Driving across town when the schools turn out is all but impossible. Stopsley high school has rows of illegally parked cars, all with the diesel engines running & it’s the same outside every school. Tackle that & you might get across town in less than an hour. Good luck with that! Luton council deliberately caused the congestion by changing our road layout so they can introduce the red route. My other suggestion is make all the street corners the red route so awkward parking gets tickets. This should have incorporated into the design before changing the design of the road in Bury Park there are tailback from side of Dunstable Road to the other and the same goes for Leagrave. We can spend money on something useful. Red routes would increase bad parking elsewhere To many drivers be they commercial or private vehicles abuse parking currently and the only way to deal with this is red route Enforce traffic wardens and speed humps. Do it. It will be the best thing you’ve ever done for that area, reducing congestion, improving road quality and potentially reduce the amount of short hop cars that are free (currently) to indiscriminately park. Have traffic wardens enforce yellow lines I believe main cause of traffic is busses and loading others wise the traffic will flow plus to many traffic lights on dunstable road is another probl8 Surely you can a traffic car or warden who keeps traffic moving that just covers leagrave road and burypark. It would only take one. Businesses will say no. But the public and drivers who drive through outnumber and outweighs the cons Please don’t 😓😓 parking on marsh road is a problem as the pedestrian area is very wide and by putting traffic lights everywhere does not help traffic flow. In these areas there is very lillle parking available to accomdatte local people need.. Red route will make it worse for local residents and shopper from out side. This will be bad for local businesses is well Red route is probably one option but with increasing number of cars on the road alternative parking such as multi story car park should be built in bury park area to provide parking for shoppers. Shops abuse the loading bay section and park for hours. It’s a pathetic idea and more waste of money. We live in these areas and this is the worst possible decision that can be made if they go ahead with a red route plan. The council need to have a look at how other towns are prospering and take ideas from them to guide Luton to a better town. Ridiculous idea despite all the populated businesses bound to suffer! Someone clearly wasn’t
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thinking the effect it has on businesses Red routes will affect businesses Waste of money proposals I met the guy in charge today came across as a very pompous and arrogant person who does not even live in luton Red route is long over due in Luton. Red route will ease the traffic in and around luton town centre. Will stop people parking on main roads Follow the Pakistan style of reducing the traffic Over head roads Roundabouts N/a Red route is not good Stop wasting money Leave it alone There should be a wider consultation and more public awareness about this ad many are unaware. There should be visible parking enforcers, more education on impact of poor parking. I think this is a great ide! The council need to provide facilities and make it easier for the residents not to make it harder and just for money make people life dificult. I feel that the red route will not be useful for my road due to the fact that parking is not an issue for us as residents. I feel that the red route will only cause more problems. Red route will cause severe implications for local business and will harm out economy Original system of Bus bays was better. Need more parking for customers and oublic in the area I feel that this would be a waste of time and effort. It will affect the businesses in bury park as less people will want to come shop due to parking issues. No If the proposal is implemented then it will reudce the amount of people getting to those buinesses located on those roads, so there will be less sales red route down dunstable road will cause a massive problem all businesses will suffer massivly please dont do it You will get a lot of backlash from the people in bury park. Mosques are organising against this. Ignore them or you will have traffic issues forever. Traffic warden to enforce yellow.lines perhaps Parked vehicles are not the main cause of traffic jams. The area has a very high volume of traffic due to it being a CBD. Also narrowing the roads and making the footpaths wider has not helped. The red route will not help in anyway. Introducing red routes will have a negative impact on businesses as you will be greatly reducing the parking in bury park It’s bad enough as it is. Please don’t make it worse. Traffic has got worse in luton over the years this has increased further since the congestion in Bury park when the lanes were made single and when the buses stop everything grinds to a halt. Get rid of the cycle lanes and give houses that are on main road parking on the road.. we harldly see any cyclists on marsh road and leagrave road and when we do they use the pavement or the middle of road they don’t use the cycle lane. I believe it will cause further congestion on the side roads which are already so busy with residents vehicles. The bus stop in the middle of the road , the central reservation in Bury park makes it difficult for drivers to manoeuvre out from behind a bus. Traffic lights will inevitably cause traffic jams, if you haven’t realised there are so many more vehicles on the road. Red routes wont stop that. One alternative suggestion is to make Bury Park a one way route I don’t think they need to go so far up side roads Does the red route mean buses will stop in the road.
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LBC has in the past declined planning permission for car park on Dunstable road and the convoluted one way roads has lead to congestion. Luton council is very bad and making more traffic in bury park N/A My property is already in double yellow line area, this new red route will only make it worse. Red route will not work it will make things worse Most traffic on these roads is coursed by the busses when they pull up at a bus stop right in the middle of the road Build a car park. Traffic wardens to enforce yellow lines A law to make only 2 cars per household. Stop shop keepers from putting too much things on pavements Need more parking bays Say and stick to no. Listen to the people and listen to bussnisesmen/women it affects along with it brings 0 benefit in my eyes! The red route will kill the town and its businesses, make it like dunstable town. Businesses will have to close, council will not get Council Tax and will struggle to find funding. You planning to put cameras up and down the red route to enforce it, why can’t you do it on yellow line? It’s the same thing just a different colour I totally agree people park how and where they like shops think they own all the land in front of there shops illegal street trading Make bus bays to collect the passengers or jus re route bus routes As the route for the buses is the in the councils hand The red route will mean drivers with fast cars will be able to drive high speeds down leagrave road. Ibrahim who was knocked down was a family member and we live and own 41 to 43 leagrave road. The the result of red route will be faster drivers when quite. Make it so parking is available down one side and one way down leagrave road. People people pop in and out so that is the solution. I would hate to see another accident down that partbof leagrave road. N/A Red route would significantly impact the access of people to the shopping area of bury Park, and in turn on businesses. This will have a disproportionate impact on the elderly and disabled also. This is a terrible idea and will cause absolute chaos !! Don’t kill off the Bury park area of the town. Just because it’s mainly Asian area disent mean you can run roughshod over us . Make all the side roads as free of parking 24/7... I think if there was awareness campaign and education to the road users this can make a big difference. Buses should be provided with lay-bys to pull in when picking/dropping off. Cameras should be used to enforce any breach and there should be more parking bays for the shoppers. There should be zero tolerance for parking on zebra crossing and footpaths. Plus local businesses will suffer more because loss of income so they should come first as a resident of luton I totally disagree with red route thanks I think entrance to Ash road, exit of Oak road, entrance to Beech Road, Ivy Road and Kenilworth road red route must be imposed at least up 9pm Same as above. This is a ridiculous suggestion. I can not see any reason why a red route would make this route any easier. re-route the buses or add bus bays pls.
You have to have exceptions for deleveries to businesses in the area and local Hackney and private hire drivers It’s money making scheme for government and will hit the public hard. Red route is not a reasonable or justifiable solution to the problem. If LBC invested in enforcing the law around parking and got the busses off the roads, the problem would be solved. Luton is overcrowded with vehicles so you will have a certain amount of congestion Traffic in bury park increased when the council decided to widen pavement, removing bus
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bays and parking/ loading bays. Buses and delivery vehicles stopping in the road is the problem. Red route will not solve this. advertise and making parking reasonable costs for customers How is this going to be monitored ? Are there going to be cameras that issue a fine when someone disobeys the sign? Make Bury Park a red route also Please stop thinking of road infra structure for possible new housing estates (hatters way) to detriment of Bury Park - please remember the lessons of Dunstable town centre No The proposals are not conducive to the residents who live on Leagrave road, Bury park side: the residents there have no recourse for a parking permit, believe me we have tried, also there will be a huge problems for me who has a disabled elderly parents, being unable to stop in front of our own home seems ridiculous. Residents would be on board if you at least gave us some recourse to parking newrby! Red routes will close down most businesses in bury park as they rely on people to shop.people will not cone into bury park when u put on red routes as they don’t won’t to get fined for a 2 minute stop.there is not enough parking available for people either. If you do introduce it you have to make sure you enforce it especially in Bury Park. Will you employ more wardens paid for by the fines. If the red route goes ahead, it will also ease traffic around bury park as people can now drive straight through the middle. Bury park does need more parking and something does need to change but restricting the traffic will harm a lot of the local business and convenience for the elderly and disabled and careers who have to keep their disabled child adult with them safely Red route will cause trouble to residents of local street who dont have driveways and have to park on street. this will be extra cost and trouble .... I think traffic will just get worse with this proposed red route! Where is the impact analysis? How have you allowed for increased parking in other areas outside of residential areas for visitors to Bury Park? I think its stupid and just a way for you to line your pockets with unecessary fines.. Theirs limited parking in all these areas anyway so its probably just an attempt at making pay for parking thus inflating those already high prices. Think about your residents and making the town better by investing in art and culture aand transport If the council wishes to be seen as anti business then these proposals are good, otherwise I think they are very extreme and could seriously harm business in the bury park area. As a luton resident and as someone who frequents london and other areas with red routes, the traffic is still horrendous, will a red route help ease congestion, yes possibly however to introduce such measures without first tackling the parking problem seems very heavy handed and could have a very detrimental impact on local businesses. Traffic wardens to do more patrols and issues tickets for anyone parked illegally. Luton Borough council should invest more in bigger roads for drivers as in the past 18 years the number of road users have increased by 70% Have a 7 days traffic wardens in the area I have noticed a few bus stops where they have made the pavement bigger so the bus ends up stopping in the road and not being able to stop on the side. This would make Leagrave Rd much safer and better for traffic flow and buses. Specially near my Rd spencer Rd. We do not want red routes No routes It is the best thing so far. There’’s ways accidents on leagrave road due to traffic The congestion in Dunstable Rd/Leagrave Rd is legendary, whether you can enforce it, is a different matter. n/a Multi story car park in burypark Bury Park is severely congested because of roads blocked by cars belonging to shoppers.
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There needs to more parking for shoppers. Possibly demolish builds to create space for new multi storey car park. make sure that these new parking restrictions are strictly enforced. Apply red route would force ppl to go park in dnagerous obstructing areas plus if the side roads hav restriction where are ppl meant to park to access shops. Its a very inconsiderate plan that has been made. This will cause difficulty to all the residents living in these proposed areas. On top of that you are trying to make money off of the residents by making them buy permits to park in front of their own homes. Atleast allow residents to park free of charge in front of their own homes. This is not a good idea espcially for residents on side roads who struggle to find parking as it is. Now u want to make it even more difficult and make residents pay for a permit to park THEIR OWN CARS infront of THEIR OWN HOUSES. Leave the Luton roads alone, ure messing up every area w**kers Do it It’s money maker not a solution Luton borough council is a disgrace fix up and help the residents with proper proposals. Who ate all the pies you fat councillors. Hitchin round green side needs to be looked at create more parking bays, and bus lay bys I think Dallow Road should also be included. A lot of people use this road to avoid Hatters Way, and the cars parked along the yellow/double yellow lines cause a major hazard. The 20 mph speed limit is also rarely observed, and with schools along this road, combined with the hazardous parked cars, the danger to life is very high. Businesses rely on deliveries,and drop and go for people to access the shops. Have no stopping zones on the red routes as people will stop in the middle of the roads to load vehicles. Make bury park a no car zone or perhaps one way with a perminate bus zane running through it to keep traffic following. We need bus bays like we had before. This stopping on the main road to pick up passengers is not fair for other road users. While the buses are making profit at other road users expense. If red route implements most of business will suffer and close down soon. Burypark will be a dead place I am directly affected by this because I am a resident living in the area. It is Hard enough as it is to tackle traffic and park our cars let alone stressing I am completely against this. Firstly the reason being is that we have no parking facilities for the cars in our household, we do our shopping and unload our cars whilst parked outside then have to park our cars away quickly. Secondly, we have members in household that are elderly and must have access to be dropped off and picked up on a regular basis. It really frustrates me how some drivers think that they can park in which ever way they feel like, often leaving us from accessing the front of my house, despite of this I don’t think that these red routes should go ahead as it’s not something that will be affecting them but the residents and the businesses. It is something that is a long term and should be carefully thought about . Residents should be considered and Other options should be looked at such as camera controlling. Making all the roads red route will not solve traffic problems Start with town centre then increase to other parts of Luton. I don’t believe a red route will solve anything & will put local businesses out of business. In recent years all the traffic calming measures that have been put in place have proven to be a waste of taxpayers money as the situation is now worse than 10 years ago. There are more cars on the roads but the congestion is a result of the inadequate planning policies of LBC. The aim of LBC seems to be to make life difficult for local residents and spend taxpayers funds on consultants and impractical solutions. In the case of Bury Park the central area should be completely pedestrianised and the traffic routed round with a car park at the Leagrave end and a further one by Sainsbury’s. Why not but half the car park from Sainsbury’s and make that a low cost council run car park? Think its a great idea! I live by marsh road and the traffic is a nightmare! Especially outside iceland and Barclays bank. Busses struggle to move! And im fed up with they way these idiots
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drive. There have been a number of occasions u had to moan at someone for parking on the side of the roads. The road get blocked and we have traffic is because of buses they stop in the middle of the road leagrave is already and cycle lane Red routes will only stop cars parking but when buses stop there is no way to go the the congestion will stay. Red route will adversely affect local business If there is a red route we need alternative parking around leagrave road area and bury park as i work in a garage and theres already limited parking spaces Pre pay parking If you put red routes in leagrave road or dunstable road many businesses may get effected This will not solve the “congestion problem” We are the residents in these areas we use these roads daily. The biggest problems with traffic occurred after they removed the bus bays. Now buses stop in the middle of the road and cause blocks. Go back to how it was originally and stop wasting money. The red route is not for our benefit it’s just another way of making more money for the penny snatches in the town hall. need more free parking bays for residents We need more bus lanes to flow the traffic and emergency services. Shame on the Dunstable road where the road is very narrow a ambulance can’t go pass. Red Route will have a detrimental effect on the area being suggested, current congestion problems is due to drivers not able to pass larger vehicles, due vans/lorries/trucks loading and off loading goods on the road. Tesco Express on Dunstable road, the delivery times has to be altered or completely changed. The lorry stops in the middle of the road making it one way pretty much and causes so much delay on Dunstable road leading into bury park I hear the proposal will cost a whopping £180000. Why? Red routes will affect business which will affect families which will affect the community l. Which will affect children as the families aren’t making as much money. Which will affect the future generation of Luton Youth. This red route will be the end of this town. Do not do it. Bus lane would be a better option. I think this is targeting businesses. By implanting a red route, this will bring down business in the area and also cause a lot of parking problems for customers. Having cctv and more traffic lights are good to help congestion and keep residents safe however, the red route proposal is not the way forward! I highly disagree with this! everybody and everywhere else is being targeted by a weak and pathetic council. Trying to force the SME’s on Marsh rd and Kimpton rd and other proposed routes out of business, rather than enforce regulations. The harsh reality for all Lutonians is, even if this was bought into force our limp council still wouldn’t go into Bury.Park. Sad indeed. More should be done to provide parking for customers in these commercial areas. Red routes will have a negative impact on the commercial activities in these areas. The council needs to avoid taking the easy option of red routes, which may ease traffic flow, but will have a long term negative impact on business in the area This is clearly a bs scheme to make money. We are already getting poor services from the council and there are pot holes still around from 2 years ago. Fix real issues and stop wasting money and time on useless schemes like this. Red route is not the solution to reduce traffic conjunction it will create more problems and increase congestion Waste of tax payers money, it’s a moneymaking scheme for the authority Marsh Road dose not require a red route. The on street parking rarely causes a problem . The biggest issue is the turning into Lloyd’s bank car park . This can increase congestion dramatically as it is single lane into the car park. The red route will decrease the foot fall in these specified areas which will cause a strain on local business’es none All the shops will suffer as we will start shopping elsewhere. Make roads safer by having bus bays and not trying to make this profitable business. Iv got a son who has enxity and can’t wait long or stay in buses because of these cars parked
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and traffic. By stopping people parking the council is just trying to make more money and lead us to believe it will put it back into the community. Small businesses along the roads will be forced to shut as customers won’t be able to park and pop in. Air quality will not be improved by stopping parking along the roads this is a false statement, the same amount of vehicles will still use the roads. Red zone would be perfect. The people who own the garage have been knocking on our doors and saying to us, don’t except the red root. They want us to attend 2 meetings and sign against the red root. We are fed up with the traffic on Leagrave Rd. We really hope that the red route gets accepted. It’s been too long that nothing has been done with this traffic problem. Even buses can’t park on there stops because the garage has so much cars parked on bus stop and around it. Please do something for the red route. My Naibour was saying some councillors are going to back the people and stop the red route. Please help us who live in this area. Please as my wife is on a wheel chair and have cars parked on pavements broken down. Can’t even go past them. Without going into the road . Thank you These proposals should include pilot schemes Whoever designed the area of Bury Park on Dunstable Road doesn’t seem to have taken congestion into account. There could have easily been bays for buses so that traffic could pass. Having red routes will be chaotic and cause major problems for consumers, businesses and the general public turning those areas into a graveyard. As above create a carpark also in bury park I live on leagrave road and have a driveway but sometimes be in a rush and just park on the road and get a ticket for being outside my house then have to write to ticket office as well so I do not agree sometimes also there is a emergency and need to park up quickly so it will be hard if I have to go find a spot on side road or far please consider the people who will find this hard to cope with on leagrave rd it is quite a wide road even if there is s car parked people have managed fine this is all just to make money that’s all Make more loading bays Make vertical parking bays Allow buses to come through bury park rd I think is not fear for residents It will making it difficult for residents and force them to buy a permit when they don’t need to. Visitors will find it difficult too. Also it will hit local businesses. This is not a good idea If this comes into operation then it MUST be policed as it is not very much now. People are allowed to dump cars, clean cars and mend cars and park on the path in Leagrave Road and not much is done about it. I live on Althorp road and I share the opinion of a lot of residents on this road. I support the councils proposals inc making althorp road a one way only. And the replacement of single yellow line with parking bays will help us the residents a lot as we struggle to find a parking space on our own road specially on weekends as the area is flooded with cars attending the venue central weddings. I do hope the council also implement the resident parking system mon to sat 8am till 8pm at least. Thanks This is my regular commute route (I walk from town to Hockwell Ring via Leagrave Rd), and I am frequently forced to walk in the road due to illegal/inconsiderate parking/stopping. Having additional enforcement for existing traffic management structures is a must, whether the red route is introduced or not. as an electric wheelchair user I understand and appreciate the problems with path parking, but a bigger problem for pushers, prams & wheelchair users are wheely refuse bins that are left on the path for weeks at a time. Cars which are too large for the front garden and extend across the footpath are also a problem. A footpath user then has to go onto the road to negotiate past such obstacles Very dangerous! please kindly Residents Parking Permits times to 8am to 10pm Monday to Sunday I think this is a good idea but does the council have the staff to enforce it. Also the Police should be involved and dealing with drivers who drive around Luton with no thought for other
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traffic, pedestrians or cyclists. Driving through red lights, cutting into queues of traffic and parking wherever they like Efforts have been made before to improve traffic flow and pedestrian safety in Dunstable Road, with very little effect, and in a relatively short time it returns to what is has been previously. Unless there is a way to control pedestrians, to stop them crossing at will across the road, irrespective of what the traffic lights say and to control parking in one direction on each side of the road. To stop traffic turning right into Waldeck Road and control the loading bays for the shops, then you will never improve traffic flow through Dunstable Road. It is the main artery for nearly all the busses out of Luton to Dunstable, Marsh Farm etc.so with several busses every hour it is almost impossible to control. ??? 1. Shut all shops in dunstable road burypark. 2. Move luton football club and make multistory car park. 3. Make it red route anyway sod the rest business will close due to lack of football. Thank you Luton Council for putting us out of business A no non-sense olicy should be brought in to fine those who do not obey rules. Scheme will increase safety and avoid accidents too. After reading through your leaflet on the proposed red lines on Marsh Road, we would like to raise the following objections/points: Mrs. Dunne has a restricted mobility disability but appears to be a non-person in the eyes of Luton Borough Council. If the proposed changes are implemented we will be unable to have family, visitors, carers, nurses, doctors etc call at our home. Mrs. Dunne rarely leaves our house and relies heavily on on•line shopping. Now we find that L.B.C. propose to stop any parcels being delivered - does this also apply to the Post Office deliveries as their van parks outside our house every morning? Nor, apparently, can we have groceries delivered. These restrictions will place severe restrictions on Mrs. Dunne's quality of life. Your question "Do you consider yourself to have a disablity"? • Your list does not include any mention of a restricted mobility /physical disability - the majority of your tick boxes are for mental health disabilities. Yes, there is a space for "other", but, to be honest, it is quite insulting that restricted mobility is not included in the first place. A few houses away, there is a gentleman who also has a restricted mobility disability so, in our row of houses, there are at least two people with a mobility restriction yet still L.B.C do not feel the need to include this in their tick boxes. It appears that mental health disabilities are far more important to L.B.C than mobility disabilities. We also note that there are no plans to provide a parking bay for people with a Blue Badge along Marst Road. Why not? Are you saying that people with restricted mobility are not welcome to shop on Marsh Road? We have lived on Marsh Road for nearly 40 years and in that time have seen many traffic restrictions put In place outside our house from yellow lines, to a continuous white line and the present cycle lane which, incidentally, we have never seen being used. The pavements are the preferred choice for cyclists along Marsh Road. To date, absolutely none of these restrictions have ever made any difference to drivers blocking our off road parking- we find it doubtful that drivers will take any notice of the proposed red lines either. Nor will they stop taxi drivers using our end of Marsh Road as a car park! While we understand that the proposal for red lines is needed along the shopping parade as the congestion is excessive and sometimes dangerous, the restrictions these red lines would place on residents is patently unfair. Disabled people rely on deliveries to their homes and you are proposing that these will be stopped. Once again, we must reiterate that this will have a detrimental impact upon the quality of life for disabled people in a similar position to Mrs. Dunne. Between Icknield road and Norton road a disabled bay, would serve our patients and possibly the dentist ( a parking bay is outside their premises ) but is usually full in business hours. Elderly and disabled patients would find the new system difficult to
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acces our services. We had an application for dropped kerb refused in May 2016 at our premise. General comment: In a residential area and a red route how would you get, as an example, delivery of bricks or sand. They often delivered by lorry with a crane? There must be other cases of needing to park for a small time during daytime. Are there arrangements for this sort of thing to be "licensed" etc? Bury Park is a nogo area, at best it is like a car park!! Bury Park is generating revenue for the council. Do you want all the shops to be closed and no revenue for the council. Think about this seriously I cannot wait for the red lines to be extended to the whole of Luton. My son lives near B&Q Dallow Rd - and Dallow Rd/Chaulend Lane/Dunstable Rd/Kingsway and Beechwood Rd are horrendous with illeglal drivers Make place for buses to pull onside so rest of traffic can carry on going No red route in luton Your proposed red route is directly aimed all of business areas where ever small or large are please reconsider don't kill peoples My only objection for myself is that my sister just drops me off with my shopping. We won't be able to stop for just a few minutes and also the side roads will be so blocked up, nowhere to park? It's bad enough now, as people park right on corners and you can't see what's coming. the red lines will make the side roads worse My son lives with me along Marsh Road, he has a car which he needs to get to work he usually parks on the road, where is he suppose to park if there is a red route system, can he apply for some kind of permit New bus lane OR new trambus route 24 from Marsh Farm to Town Centre via Leagrave Road's red route. Car drivers can using to move passes on the public transportation as welcomed. Parking habits along leagrave road are a joke. Nobody takes any notice of double yellow lines or cycle lanes. I applaud this initiative and hope it educate those inconsiderate member of the local community to realise you cannot park where you like Parking restrictions need to be enforced. No point having them if the deterent I.E fines are not dished out Red rouite to my opinion will actually worsen the traffic situation, and have a detrimental affect on the area. Red route will affect local business and public who are living on side of any of proposed road so please look into this. No red route Shop keepers have to display the good out of foot path The red routes will have to be policed properly ie law breakers must ALL receive FPNs so that they will not do it again. Cameras HAVE to be introduced everywhere - because a van or traffic warden cannot be everywhere all of the time - and unless there is a guaranteed deterrent people will always take risks There is a doctors surgery near the traffic lights of Woodland Ave - Bishopcoat Rd and Denbeigh Rd. Parking off road is limited which causes the need to park on the road. Having the red route will causes misery for people who are possibly ill and disabled. Fines meted out to transgressors will seem an added financial tax on their illness. I do have concerns for the emergency vehicles which come up and down Woodland Ave with great frequency and are impeded by parking on both single and double yellow lines. they and the people needing their services would greatly benefit from the enforced red route. More enforcement would illeviate this problem. This proposal is 20yrs too late. This proposal of red route has not been thought throguh properly - reason - high streets including Bury Park will die dlowly killing it. This is a vibrant revenue generating area for the Borough Council - it will drive customers away from this area making it a gost town should be dismissed. We currently live near a chemist along Marsh road. Customers frequently park on our
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driveway - uninvited and without permission. If a red route is implented I believe this situation will be worse. Also it is absolutely ridiculous that the likes of Tesco Home Deliveries/Iceland etc will not be able to park outside our home to deliver - expcept after 7pm if single red. Also for dial a ride etc how are the elderly and infirm meant to get to their required transport if short term pick up/drop off is not allowed. We need to help and support local businesses and communities in the areas. Do not implement these restrictions which will take away people for supporting these areas and facilities. DO NOT bring London style controls within our area.
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Appendix D - Emails
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Table 1
Could you pls contact me by texting on my mobile number. We are based at 49-53 Alma Street, Luton, LU1 2PL and operate a Day Centre for adults with an acquired brain injury on a daily basis. Many of our clients have physical disabilities including wheelchair users. We utilise Luton Borough Council disabled transport to bring our clients to and from the Day Centre and can have between 3 and 4 minibuses attending twice a day. From your map all of our property now falls within the Red Route and we will need to use the dropped kerb that also falls within the Red Route. You have said that Dial a Ride are not able to stop on a Red Route who also bring in some of our clients and I am unsure if your own transport will be allowed to stop (I assume they are deemed the same as a Dial a ride bus). This is going to cause us extreme difficulty in accessing the building safely with our clients with mobility problems. Is it possible that someone could come and discuss this issue with me? Also we have frequently raised concerns about the illegal parking in Alma Street (caused mostly by people visiting the dentist opposite) and speeding cars round the corner from Upper George Street into Alma Street (sometimes even racing going around several times). These issues also need to be addressed if you are talking about peoples safety within Luton. On Kimpton Road would kill the livelihoods of the shops and cafe that are positioned there. If you do insist on the Red routes you should supply adjacent parking for customers only. I am a frequent user of the Sicilian Cafe, DIY Store and the news agents in the versinity I am generally in agreement with the principal of Red Routes as a means of improving traffic flow around the town, and as a long time resident of Waller Avenue which, is of course, a main artery between the M1 and routes East, witness at first hand the problems of inconsiderate parking. During busy periods particulalry in the morning and late afternoon the delays caused by cars and vans parked opposite each other severely restrict the road width with resultant hold-ups especially with so many heavy lorries using the route. As the A505 Waller Avenue does seem to suffer more than other parts of the route, such as Stockingstone Road. The problems are exacerbated by what appear to be car sales business's, judging by the number of vehicles parked around various locations in the road. Should Waller Avenue become a Red Route this would undoubtedly impact on myself in terms of visitors, plus the inconvenience of getting into and out of my property with my own car, and potential drop in value of the property, however, in the interest of 'the greater good' I would recommend that the road be considered for Red Route Status. I attended the consultation held outside the Luton central library which was on the 22nd may and was impressed with the drawings but have a major concern which I would like to address to you. I live at XXX Leagrave road and my parents live at XXX Leagrave road, we have a bus stop outside our properties which has restricted our parking for many years. Our drives are big enough to situate 5 cars but presently we can only park 3 due to the size of the bus shelter and raised kerbs on both sides. You have chosen to relocate 2 other bus stops down the road and I would like a proposal for the relocation of this bus stop also. The relocation I’m proposing is in between Norman road and Holland road, there are no houses and is presently used as a car parking facility which is a perfect location for it. We also don’t have parking across the road from our houses which are also not in the plans so we will be restricted completely which is unfair to us so please consider this
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change in your proposal as it would make a world of a difference in parking for our both households. We have to deal with daily litterings, abuse and damage to our vehicles on a regular basis because of this bus stop and would like this change considered please. I run a Post Office on Marsh Road and am very concerned with the Red route Proposal effect on small businesses. My core business hours are 9.00 am- 5.30 pm. As I serve the local community and without adequate parking my business will shut down if the proposal goes ahead. Royal Mail, Parcelforce or any other carriers will have problem collecting mail from my office and will have a Hugh effect on footfall as customers will be forced to use other Offices. There is no real issues on the flow of traffic on Marsh Road or Leagrave Road. Very rarely there is congestion on these roads. The council is out of their minds and haven’t thought about the long term effect on small businesses. What help and compensation will the council give to small businesses? On your proposal there is no mention of limited parking space available outside my Post Office. You will need to move the bus stop towards the library and give our customers parking space instead, should you go ahead with the proposal. Unfortunately I will not be able to make it in the opening evening for this event However I will like to applaud the council for introducing this scheme and is a great idea It is much needed around leagrave Road and bury park . This is the best thing to happen in Luton, the risk of accidents is still high at present regarding people parking ruthlessly on the pavement. I strongly agree with the proposed plans. I am a resident of Ivy rd luton, I am in favour of the proposed red route. It will elevate illegal parking and congestion in the areas. As a resident I feel we are mostly ignored and our voices are not heard. Majority of the business people’s do not live in the area and they have no regard to the local people. As local resident we have been suffering from this for a long time. I hope this red route goes ahead. I have spoken with most of the local residents and they are all in favour of it. Most of the problems are caused by people parking on the corner of Ivy Rd on the double yellow lines. On many occasion the emergency services found it extremely difficult to gain access to Ivy Rd. Same thing with Kenilworth Rd Beech Rd, Waldeck Rd, Please let me know if you need any further information I would like to let you that i fully support the luton RED Route proposal. i believe its a great initiative and it will greatly benefit in better movement of traffic. there are too many inconsiderate drivers who have no consideration for other motorist. too many people parking or stopping at wrong place and this often leads to build of traffic and congestion Yes int name of saftey pollution.About time .if you do one area.then do all.london can do it.so can luton.take back control of luton.rather than just the town center been patrolled.the people who don't want it moan about congestion pollution and safety of others.are the first to refuse it.self centered and only think about money .and using religion to further pressure,If they don't like it. Also bring the red route to schools. . Red route London also have timed loading unloading bays in london.and the public get stopping places.make sure you enforce it if your gonna do it. I have just seen the consultation on the proposed red routes in and around town. My view is it is a great idea snd hoping many more people will agree. I live in Luton This is a great idea Hope this idea is placed As it will let traffic flow through luton more smoothly
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This will improve traffic by about 35% during busy times For once Luton borough council is thinking about the people of Luton This will ease traffic and remove all illegal parking. It will improve living conditions of the local residents. I just want to say i am very happy with the Red route proposal , I know many people won’t like it but it’s the only way forward Great work & I’m really proud of ur team We have been informed that LBC have launched a public consultation which includes the change of Airport Way and Kimpton Road into red routes. We discovered this information by chance and are somewhat surprised that residents of Airport Way and the surrounding businesses were not directly informed as the impact of any implementation will affect them more severely than anyone else. I have repeatedly raised the issue of illegal parking on Airport Way and Barratt Industrial Park. Introducing red routes will no doubt compound the situation and make our business environment even more uncomfortable through the illegal nature of parking on our industrial park. Every day we are confronted with abuse and continual mess that our staff has to deal with. This should not be our problem -it is caused by visitors to the airport and therefore the responsibility should be resolved by the Airport and Luton Borough Council. On behalf of Bell Packaging I hereby object to the proposed change and request that Airport ay is not made into a red route. I refer to the Red Route consultation that is currently in progress for three areas of Luton. Arriva strongly support the proposal and the benefits that would be felt by having more free flowing areas in some of the busiest areas of the town centre. We are particularly supportive of the proposals for red routes in Marsh Road, Leagrave Road and Dunstable Road as well as the town centre as this will massively improve the reliability and punctuality of our services that operate through these areas as they currently experience difficulty on a hour by hour, day by day basis. Currently we do not have major issues with the area around Kimpton Road but clearly with the developments taking place that may change in the future so would also support the red routes here too. Clearly it will be imperative that the routes are enforced but I presume that will be automated rather than manual enforcement Arriva are very keen to support the council on all initiatives that improve the overall congestion of the town and encourage people to use public transport for both the congestion and environmental benefits. Kind Regards General Manager, Arriva Midlands - Luton Depot It seems I find my self writing to you once again, previous letters that have been ignored were appeals to you not to take away parking opposite the row of shops on Kimpton Road ( one of which I am a owner operator with a long lease and a steadily declining customer base) the other highlights were to beg you not to take away a large percentage of parking directly outside the our shops, which again was totally ignored, we now have parking for five cars and full time residents who permanently take up 3 of the spaces, next you pushed all remaining parking so far down the road that any customers wishing to buy a paper or a sandwich will really have to think twice and more often than not will go to McDonald’s or Starbucks. Next on the agenda was the proposed pay by phone on the remaining parking bays - any
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objection please contact Alex Constantinides - your thoughts are welcome and we really care about you hard working independent traders etc etc. I did get a reply on this letter informing me that my views have been taken in to consideration ... So here’s the latest, now you have done all of the above regardless of any objections, petitions, emails and half hearted consultations but these all pale in to comparison to your latest plan - the red route. Do you honestly think that any of the shops will survive this? If this goes ahead who will be our customer base and please don’t insult my intelligence by suggesting it will be people living in the new development opposite as this is not going to make up the shortfall and they are a long long way from being complete. On the bright side It heartens me to see you are putting the decision of the red route in to the publics hands in the form of a survey, it was unusual but very encouraging to see that we could see the results of the survey once completed - looking at the results so far 90 plus percentage seem against the proposal, it was great to see our customers objecting in their hundreds while the those in favour were in the twenties...their were around 13 I don’t knows, I don’t understand the last sample group, who does this survey and puts down they don’t know? It was really encouraging and quite motivating in a way, I have a screen capture of the results as of Friday which was sent to me by one of my customers, this in turn seemed to bolster the customers I kept showing it to so they could vote while I prepared their lunch, they thought it was great that you have provided a platform to allow their opinion be heard. According to one of my customers the ability to see the results has now been removed but it’s reassuring for all those who took it prior that it appears that the votes of the people are being listened to and that common sense and decency will prevail and the red route will not happen - long live democracy!! After all why do a survey? Please this time stop thinking of the airport for 5 minutes and think of the small traders who are desperately trying to make a living. Regards ( cheese and pickle sandwich bar) I'm am against the red route on leagrave road
1/ it's a mainly residential area 2/ parking bays are limited and we never find any bays to park in 3/ venue central,units 1 & 3,the local garages and shops park on the residents bays. 4/ when there is a wedding they park on the bays and then on leagrave road,now with a red route anyone that parks on leagrave road at the moment will end up parking on the side roads so we will never find parking. 5/ red route will not stop venue central from holding weddings. 6/ because of venue central, a red route will upset residents further.
I'm not happy how you have not advised the side roads, Saxon, Dane, Spencer road etc about the red route as it will impact them alot more as non residents and customers will park on side roads taking up residents bays and residents of the side roads have no idea about this policy. You must post fliers to ALL residents in this vicinity.
You must make all residents bays mon-sun 24/7 for only permit holders.
More parking bays for residents.
You can put in urban clearway
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Double yellow lines More parking patrols when weddings take place on weekends and half term between 13pm-4pm and 7pm-11pm. Speeding cameras Road humps Make parts of road one way
A red route will be a disaster.
You are punishing residents.
Because you made a mistake by allowing venue central to open who only have 30 private parking spaces you're putting a red route to stop this issue but this will not work.
(Second email) Also where will I drop my elderly patents? What about my wife and small kids ? We will have to park miles away and then walk. How will we bring in the shopping Remember most residents on leagrave road have no off road parking and no bays in front of the house. It will devalue the price of our houses.
You have many complaints about parking on side roads so how will a red route make it better ? It will become worse.
https://www.birminghammail.co.uk/news/local-news/council-drops-red-route-plan- 126868
I am totally against the idea of having a red route placed within any streets of Luton. I believe the problem is not related to vehicle displacement but a lack of consideration and initiative by Luton Borough Council to look at ways of providing further parking facilities. I see this as just another way for Luton Borough Council to increase funds by way of making our lives more miserable. Sorry but this is just not on!!. Luton Red Routes Consultation May 2018 Thank you for your e-mail inviting Historic England to respond to the Luton Red Routes Consultation. As a result of the number of consultations we are currently receiving, we regret that we are unable to comment specifically at this time. We do however recommend that the advice of your local authority conservation and archaeological staff is sought as they are best placed to advise on local historic environment issues and priorities, including access to data, indicate how historic assets may be impacted upon by the proposals, the design of any required mitigation measures and opportunities for securing wider benefits for the future conservation and management of the historic environment. If you have specific questions relating to the historic environment that cannot be answered by your local conservation and
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archaeological specialists, please contact Historic England’s regional Historic Places Team, who can be reached on 01223 582749. Although we have not been able to provide a substantive response at this stage, this does not mean that we are not interested in further iterations of the document. Please note that we may still advise on, and potentially object to, any specific development proposal(s) which may subsequently arise from this or later versions of the documents subject to the consultation. Please do not hesitate to contact us if you have any questions. Yours sincerely, Historic Environment Planning Adviser, Planning Group The red routes are completely unnecessary in a town like Luton. The problems cited for their introduction simply do not exist. In certain areas there are short lived parking problems, but no real delays outside rush hour and the school run. Otherwise traffic flows well in most areas. Any problems are due to chronic under investment in Luton's road infrastructure and the council's love affair with the traffic light. Lights are expensive to install and maintain and operate at 02:00 when there is virtually no traffic. None have flow detection intelligence installed and result in unnecessary stopping and delay, increasing pollution and fuel use. The town's roundabouts function well, though those which are light controlled, could at least be part-time. Let us not forget the debacle at the junction of Chaul End Lane and Dunstable Road. What about the costs of implementation of the lines and camera installation. Oops, I forgot the fines. Many of the routes have lines already, but unfortunately no will to enforce them. Take the focus away from the town with a bypass. If one of the aims is achieved, to allow increased traffic flow, then accidents will increase, as racers go even faster. Congestion really only exists in the centre and parking is not a pressing problem. Basically Luton is fixing a problem which does not exist but may provide a useful revenue stream for council. Great inconvenience to residents and visitors. Takes focus away from the real problems of infrastructure and a bypass. Might treat the symptoms of low traffic capacity not the cause. Luton's illogical approach is exemplified by driving westbound on the dual carriageway from the airport to M1, where no right turn is possible towards Luton Parkway. Traffic all forced via Gypsy lane or up to the new magic roundabout near the M1. Is this what our councillors do? Think of new ways to waste money? Thankfully we have the prospect of future local elections. Some of the routes illustrated in Holly Patel's informative article in the Herald and Post:-
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Ashcroft Road - not really a problem, delays caused by traffic levels at peak times not all day. Certainly not by parking, unless very inconsiderate, or near junctions. Parking is mainly at night and serves to slow traffic. Any hot spots could be helped with pedestrian crossing - Ashcroft has none and stretches double yellow lines. In some places the verge is wide and could be used to create road space, to allow parking and 2-way traffic. Cars will now be entering onto the carriageway from driveways and side roads causing increased accidents and congestion. This will force parking onto side streets, including my own, causing real access problems for residents and emergency vehicles. Hitchin Road - Classic illustration of "if it ain't broke don't fix it". Traffic always flows Kimpton Road - this wide road causes no problems. However the introduction of traffic lights in place of roundabouts will. Why Luton has sought this expensive solution is incomprehensible. This will cause damage to the businesses which have been there for many years providing facilities for residents and tax income for Luton. This has always been a good route to get to the Windmill and Gypsy Lane retail areas, especially now that Crawley Green Rd had been slowed by the traffic lights and the roundabout which has ceased to function since their introduction. New Bedford Road - never a problem. Motorists generally park considerately and vehicles can pass easily. Flows well at the junction with Stockingstone Any congestion only occurs near the town centre. Local problems could be dealt with using yellow lines.
[Second email]
Again, you seem to have listened to those who complain and not those who don't.
These routes may be problematic at peak times and near the town centre, but not any other time. I drive them regularly.
Ashcroft Rd is not a problem, Hitchin Rd - only on the lower part of the hil into town.
New Bedford Rd - never.
If people are parking inconsiderately on yellow lines, it is up to you to police them We advocate Red Routes as suggested by the council. This said however we consider and would request that such red routes do not stop at the main road in question but continue around the radii of the corners and onwards for another 100m or so. What is happening at present with Marsh Rd/Nursery Rd is that parking from 0-100m back from the junction is forcing both our and other LGVs to reverse back into the main road which is frankly life threatening for pedestrians and vehicle occupants. Whilst this should help the situation it will require constant ‘policing’ and we would request not just wardens visibly patrolling but also cctv, both by car and the adjacent council controlled street camera, enforcement.
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The positioning of large signs would help greatly. I am happy to meet anyone anywhere to discuss this however a field visit on a Friday afternoon should give you a clear indication of how untenable the present situation is. Although there are other solutions to the end of Nursery Rd, with influx of so many Londoners into the borough and the fact that they generally do not respect parking restrictions, red routes would seem the best options. Aftercrete Constructional Eng. Co. Ltd. I feel it is completely unnecessary to put a red route along Kimpton Road it is already a very wide road. If it becomes a Red Route what will happen to the businesses some of whom have been there for many many years. Where are their customers going to park? They need parking outside their shops. I have been asked by some who were unable to get to one of your consultations. I attended one and raised certain questions. Firstly, Bury Park to Marsh Road urgently needs change, in particular Bury Park to allow buses to run to timetable and to stop eg buses stopping in the middle of the road to board and let off passengers opposite nadeem plaza because although the bus stop area is marked (but no bus stop signage), cars park their even though it says no parking between 7 and 7 pm. As for the area mentioned in my heading The cycle lane is not used by cyclists but by vehicles (half parked on pavement and in cycle lane). This needs to be stopped as pavement users (wheelchairs, prams) cannot pass). When it is Refuse collection day, the bins are in front of the properties and their is about a foot gap to squeeze through or you have to walk in the road which is unsafe. Bus Stop Near Spencer Road - This can remain but start the bus stop road marking from 180 to 186 Leagrave Road to garage entrance clearer. The garage should not be using the bus stop area for clients. 2/3 Parking spaces if necessary between Spencer and Althorp Bus Stop between Saxon and Dane Road - This area is constantly used as a spill for the mosque and venue central (coaches and cars) with no regard for the buses. Their should be no parking from outside the venue central until the cycle lane at any time except buses. Parking on the residents side should only be 2 spaces either end of that block where the shops are and no parking in the middle so to enjoy their living space without natural light blocked out by coaches and high vehicles. Parking would be better from dane road up to Cavendish on the Britannia estate side using the existing cycle lane As a business owner I alongside others have managed to compile a petition for No Red Route on Wellington Street. Please find attached copies of the Petition. The hard copies will be handed in to the Town Hall later today. We Do No want a Red Route on Wellington Street as it will be of No Benefit. We need an evening Warden/Police patrol in this area and it will help the area to improve.
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I do not understand How the Purple Flag was awarded. If they came to the area near the Town Hall in the evening they would understand how bad it is in the evening for our businesses. Regards Wellington Street says No Red Route
This petition had been signed by 65 residents but we have removed their information from this report to ensure we comply with GDPR.
I called in May when we received your information regarding the Red Route for Marsh Road and as of today I have not had a call back. We have a business on the corner of Marsh Road and Icknield Road and we believe this will effect deliveries to our site and would like to raise this as a concern for Specialist Cars. As far as I am concerned I will come and help you paint the lines, it is long over due . I am fed up of people who have no consideration whatsoever for anyone else but themselves, parking anywhere they like blocking access damaging paving it s got to stop. I don’t suppose it will be an easy route to go down but you have my support 100% and I hope the fines will hit them hard! A petition against the proposed red route trial in the Buy Park area was received with 1,791 signatories.
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Appendix E – External communications
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E-mail sent to
Name Organisation
East of England Ambulance
East of England Ambulance
Bedfordshire Fire and Rescue
David Woodroofe Sustrans
Freight Transport Association
John Loughlin Bedfordshire Police
Steve Welham Bedfordshire Police
Mark Cunnington Bedfordshire Police
Luton and District Driving Association
Mark Broadhead The Mall
Roy Greening The Mall
Neil Thompson Luton Airport
Nick Orwin Luton Airport
Steve Stewart Luton Airport
I White Road Haulage Association
Linsey Frostick Arriva
Mohammed Hanif Arriva
G2bus
David Shelley Grant Palmer
Mick Rossiter Centrebus
Melisa Cole Centrebus
Errol Thomas National Express
Ross Burton Stagecoach
Gwen Jones Stagecoach
David Streeton Central Bedfordshire
Cliff Ward Arriva
Kevin Best Arriva
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Alison Macpherson Affinity Water
Andrew Cahtfield Anglian Water
Andy Neeves Anglian Water
Anthony McGarth Virgin Media
David Bloomfield UK Power Networks
David Giles National Grid
Geoff Spiller Affinity Water
Jon Kelly Open Reach
Keith O’Brien Vodafone
Kevin Packer National Grid
Khyati Pugh Anglian Water
Louise Venable networkrail
Mandy Arnold Thames Water
Martin Bailey Virgin Media
Matthew Monaghan Kier
Michael O’Mahony Virgin Media
Neil Sanders Fulcrum
Paul Mooney Affinity Water
Paul Sparrow Open Reach
Peter Walker Open Reach
Richard Aston Wright The Clancy Group
Richard MacGowan Western Power
Steve Burley Anglian Water
Steve Bunker Virgin Media
Tim Ingman Virgin Media
Communications e-mail alert
Total of 805 notifications via e-mail including
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Organisation
Bedfordshire Local Nature partnership
Bedfordshire Fire and Rescue Service
Brook
Sustrans
Groundworks
Luton BID
Bedfordshire Climate Change Forum
Woodlands Trust
Private Advisory Centre Ltd
Historic England
50 Posters advertising red route exhibitions went to
Libraries – Bury Park, Stopsley, Leagrave, Luton Central, Marsh Farm, Lewsey, University of Bedfordshire
Community Centres – Bury park, High Town, Farley, Bedfordshire African,. Chaul End, Dallow Learning, Park Town, Raynham Way, Hockwell Ring, Bushmead, Lewsey, West Indian, Luton Turkish, Luton Health and Training, Wigmore Valley, Hindu Temple,
Churchs – St Marys , Blenheim Crescent, Beechill Methodist, Central Baptist, St Matthews, Ramridge Baptist
Mosques – Luton Central, Bury Park, Baitur Abrar Jami Mosha, Masjid al Madani, Jamia Masjid Ghousia, Jamia al Akbaria, Al Hira, Bilal Mosque
Others – Hat factory, Town Hall
Quality
© Project Centre Luton red route trials Page 369 of 478 140
It is the policy of Project Centre to supply Services that meet or exceed our clients’ expectations of Quality and Service. To this end, the Company's Quality Management System (QMS) has been structured to encompass all aspects of the Company's activities including such areas as Sales, Design and Client Service.
By adopting our QMS on all aspects of the Company, Project Centre aims to achieve the following objectives:
Ensure a clear understanding of customer requirements;
Ensure projects are completed to programme and within budget;
Improve productivity by having consistent procedures;
Increase flexibility of staff and systems through the adoption of a common approach to staff appraisal and training;
Continually improve the standard of service we provide internally and externally;
Achieve continuous and appropriate improvement in all aspects of the company;
Our Quality Management Manual is supported by detailed operational documentation. These relate to codes of practice, technical specifications, work instructions, Key Performance Indicators, and other relevant documentation to form a working set of documents governing the required work practices throughout the Company.
All employees are trained to understand and discharge their individual responsibilities to ensure the effective operation of the Quality Management System.
© Project Centre Luton red route trials Page 370 of 478 141
DOCUMENT CONTROL
Project Centre has prepared this report in accordance with the instructions from Luton Borough Council. Project Centre shall not be liable for the use of any information contained herein for any purpose other than the sole and specific use for which it was prepared.
Job Number Issue Description Originator Checked Authorised
4037 1 Proposed red Sally Irving Nichola Chris Harrison
routes in Luton dd.mm.yy Mansfield 02.07.18 29.06.18
4037 2 Nichola Chris Harrison
Mansfield 05.07.18 05.07.18
4037 3 Sally Irving Nichola
12.07.18 Mansfield 13.07.18
File path: G:\Project Centre\Project-BST\1000004037 - Luton Red Routes
© Project Centre Luton red route trials Page 371 of 478 142
A Page 372 of 478 APPENDIX B - Integrated Impact Assessment Form (IIA)
The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement that
‘The needs of Luton’s people will be first in everything we do’.
Why do I need to do an IIA? The aim of this impact assessment process is to: • Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council. • Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens. • Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion. • Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified.
When do I need to do an IIA?
• An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.
• The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA. • If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA. • An IIA must at all times identify those who will be affected by the decision, policy or strategy. • At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens. • Your first early draft is to be sent to the Social Justice Unit for comments and guidance • Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit. If you need further guidance please contact the Social Justice Unit (SJU). Please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.
1
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Proposal Title: Pilot of network of Red Routes in Luton Lead Officer Name: Laurence Pratt Date of IIA: 4/12/2017
Date updated after consultation: Early draft Seen by: Maureen Drummond, Cohesion and Equalities Adviser, 4 January 2018
Finalised IIA Signed and seen by SJU : Name: Maureen Drummond Cohesion and Equalities Advisor Date 27 July 2018
Names of all other contributors and Christine Davy stakeholders involved in the preparing of Tony Stefano this proposal who have been consulted with and agreed this assessment: (Please note the IIA must not be carried out by one person) If there is any potential impact on staffing please include the name/s of the trade union representative/s involved in the preparation of this assessment or any supporting evidence of request to participate:
2
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Proposal Outline
Information supporting the proposal (who, what, where, how). Breakdown of present users by ethnicity, age, gender, disability, religion/belief, sexuality (if recorded). Show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered. The proposal is to pilot the use of Red Routes on three routes in Luton with a view to implementing them on a network of strategic routes in the future.
It is Luton Borough Council’s duty (as the Highway Authority) under the Traffic Management Act 2004 to ensure expeditious movement of traffic. Parking and stopping on some roads creates significant delays to traffic flows.
Waiting restrictions (double and single yellow lines) are used in Luton to try to restrict parking. However, they do not prevent drivers from loading or unloading (except where there is a loading ban) nor stopping to drop off or pick up passengers.
A Red Route is a clearway where vehicles cannot stop and includes the footway and verge as well as the carriageway.
The Red Routes will affect all road users.
Following consultation it is proposed to
a. Implement the Town Centre pilot scheme with minor modifications based on the comments received e.g. installation of more loading bays, drop off area, reduction of red lines in side roads.
b. Implement Airport Way only part of the pilot scheme. This would assist with the enforcement of the illegal and inconsiderate parking in the area and assist bus punctuality
c. Put the other schemes on hold while the issues brought up in the consultation are considered and implemented (as appropriate)
3
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Impact Table The purpose of this table is to consider the potential impact of your proposal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.
Once you have completed this process you should have a clearer picture of any potential significant impacts1, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.
Citizens/Community Staff (for HR related issues) Protected Groups Positive Negative Neutral Positive Negative Neutral Race √ Gender √ Disability √ Sexual Orientation √ Age √ Religion/Belief √ Gender Reassignment √ Pregnancy/Maternity √ Marriage/Civil Partnership
(HR issues only) Care Responsibilities2
(HR issues only) Social & Health3 Impact on community cohesion √ Impact on tackling poverty √ Impact on health and wellbeing √ Environment Impact on the quality of the natural √ and built environment Impact on the low carbon agenda √ Impact on the waste hierarchy √ Economic/Business Impact on Luton’s economy and/or √ businesses Impact on jobs √ Impact on skills √
1 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large. 2 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 3 Full definitions can be found in section 3
4
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Please answer the following questions:
1. Research and Consultation
1.1. Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate. Click here for local demographics and information See Red Route Strategy report dated May 2017.
Consultation is part of the proposed pilot scheme.
1.2. Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate). Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.
Click here for the LBC Consultation Portal This will be part of the proposed pilot scheme
Yes – (add link when available)
1.3. Have you carried out any specific consultation with citizens likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document. For advice and support from Consultation Team click here This will be part of the proposed pilot scheme
Yes – (add link when available)
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APPENDIX B - Integrated Impact Assessment Form (IIA)
2. Impacts Identified
2.1. Where you have identified a positive impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. Guidance Notes: By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic? The positive effects of red routes eg improved traffic flows, reduced road traffic accidents will have an equal effect across all groups.
2.2. Where you have identified a negative impact please explain the nature of this impact and why you feel the proposal may be negative. Outline what the consequences will be against each group identified. You will need to identify whether mitigation is available, what it is and how it could be implemented. Specific actions to be detailed in action plan below. Guidance Notes: By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic? Along the proposed pilot roads Airport Way, New Bedford Road, Gordon Street, Upper George Street, Inkerman Street, Wellington Street, Dunstable Road (Cardiff Road to Telford Way), drivers will not be able to stop or park on the roads when the red lines are operation except in marked bays. Although the will be no loss of the existing parking facilities implementation of red routes will have a disproportionate effect on the following groups.
Disability – although, there will be an exemption for stopping and dropping off for blue badge holders, people with disabilities who currently park on yellow lines along the roads involved will not be able to and will have to park in designated parking bays. However, if successful it is proposed to extend to more main roads. Residents with a blue badge may apply for a disabled bay to be introduced near their home (subject to meeting the approved criteria). Disabled bays are installed free of charge.
Age – Elderly people and parents with children will be affected as they may have further to walk to their destination as drivers will not be able to stop to drop them off. The distance will vary depending on location but would usually be the nearest side street or available parking space
Pregnancy/maternity – will have to walk further to their destination as drivers will not be able to stop to drop them off. The distance will vary depending on location but would usually be the nearest side street or available parking space 2.3. Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. Guidance Notes: By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic There will be no specific impact on the following groups Race, gender, sexual orientation, religion/belief (no place of worship is situated directly on the proposed pilot scheme roads) and gender reassignment.
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APPENDIX B - Integrated Impact Assessment Form (IIA)
3. Social & Health Impacts
3.1. If you have identified an impact on community cohesion4’, tackling poverty5 or health and wellbeing6, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children. Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.
For advice & support from the Social Justice Unit click here
For advice and support from the Public Health team click here The improvement of highway infrastructure contributes to a sense of place in that unmaintained or neglected areas can attract anti-social behaviour consistent with a negative perception of an area.
There is a neutral impact on poverty and inclusion because the schemes will improve the pedestrian and cycle access but reduce the amount of on-street parking available for the disabled and deliveries.
The impact on health has been assessed as positive with the reduction in obstruction of footways encouraging walking and cycling. Congestion will also be reduced which will result in less vehicle pollution although the speed of traffic may increase.
4 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 5 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 6 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services?
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APPENDIX B - Integrated Impact Assessment Form (IIA)
4. Environment Impacts
4.1. If you have identified any impacts related to the built and natural environment7, low carbon8 and waste minimisation please describe here what this may be and who or where you believe could be affected Guidance Notes: Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:
Waste Hierarchy
For advice and support from the Strategy & Sustainability Team click here The reduction in congestion will result in less vehicle pollution due to idling and it should improve the punctuality of public buses thereby encouraging more people to use them resulting in a decrease of the use of the private car and subsequent reduction in emissions.
7 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution. 8 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport.
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APPENDIX B - Integrated Impact Assessment Form (IIA)
5. Economic Impacts
5.1. If you have identified any impacts related to Luton’s economy and businesses 9, creating jobs10 or improving skill levels 11, please describe here what this may be and who or where you believe could be affected Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below. Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below.
For advice and support on Economic Development click here Although, some businesses will be adversely affected through controls to their deliveries overall the reduction in congestion will result in quicker journeys which will benefit businesses in Luton. Additional loading bays are being installed within the town centre red route pilot area.
9 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 10 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well-being and the reduction of poverty in the social box. 11 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships?
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APPENDIX B - Integrated Impact Assessment Form (IIA)
Impact Enhancement and Mitigation Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:
Responsible Date Completed / Action Deadline Intended Outcome Officer Ongoing Public consultation Mar/April Christine Davy To inform feasibility study July 2018 2017 Experimental traffic Feb 2019 Christine Davy To further inform regulation order on feasibility of two areas (Town implementation of red Centre/ Airport Way) routes
A review of the action plan will be prompted 6 months after the date of completion of this IIA.
Key Contacts Name Position
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APPENDIX B - Integrated Impact Assessment Form (IIA)
Next Steps • All Executive Reports, where relevant, must have an IIA attached • All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment) • All reports are to be forwarded to the Social Justice Unit, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline • On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager
Completed and signed IIA’s will be published on the internet once the democratic process is complete
Useful Documents Corporate Plan Equality Charter Social Justice Framework Family Poverty Strategy Joint Strategic Needs Assessment (JSNA) Community Involvement Strategy
Page 38311 of 478
Page 384 of 478 Report For: Executive Item No: Date: 20 August 2018 Report Of: Service Director, Public Realm 16 Report Author: Laurence Pratt – Highways Service Manager
Subject: Road Safety Audit Policy Lead Executive Member(s): Councillor Castleman Wards Affected: All Consultations: Councillors ☐ Scrutiny ☐ Stakeholders ☐ Others ☐
Recommendations 1. Executive is recommended to Approve the revised Road Safety Audit Policy.
Background 2. Currently Road Safety Audits are carried out in accordance with the Council’s policy set out in the Executive report dated 16 November 2009 which is broadly in line with the Government Standard HD19/03 and the guidelines on Road Safety Audit published by the Institution of Highways and Transportation in October 2008. These give local authorities additional guidance on how road safety audits should be carried out on local roads.
The Current Position 3. A new Government Standard for Safety Audits was published by Highways England In 2015. This made some changes to the previous standard. Although mandatory for all motorway and trunk roads it remains guidance for local authority roads.
4. Some minor changes have been made to the Luton policy including:
a. Removing the specific reference to Vulnerable Road User Audit – although road safety auditors consider vulnerable road users for safety purposes, vulnerable road users audits should be carried out prior to design works and therefore, are now the responsibility of designers.
b. Minor changes to when a safety audit/ safety check/ designer check shall be carried out putting more emphasis on the impact of the scheme on the road users rather than the cost of the scheme.
c. Minor changes to the titles of the stages of safety audit to correspond with the HD03/15.
d. More details on how the road safety audit stage 4 shall be carried out.
Goals and Objectives 5. To bring the current Road Safety Audit policy up to date.
Proposal 6. To adopt the revised Road Safety Audit Policy.
Page 385 of 478 Key Risks 7. Road Safety Audits are an integral part of the design and delivery of engineering schemes and are part of the Council’s duty of care. Failure to approve and implement a Road Safety Audit Policy would leave the Council open to significant financial risks from claims/legal action and would damage the reputation of the Council.
Consultations 8. No specific consultation has taken place.
Alternative options considered and rejected (please specify) 9. Not to revise the Road Safety Audit Policy and continue with the existing policy – Luton’s road safety audit policy would not be in line with the latest guidance.
10. To drop the Road Safety Audit Policy and not carry road safety audits out on schemes - Although road safety audit is not mandatory for local authorities, its adoption and use is a line of defence should collisions occur.
Appendices Attached Appendix A – Road Safety Audit Policy and Procedures Appendix B - Integrated Impact Assessment
Background Papers Executive reports dated 16 November 2009 and 10 April 2006
Page 386 of 478 IMPLICATIONS
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated Road Safety Audit is not mandatory on local authority Steven Sparshott 25th July roads but is prudent to adopt as an ‘industrial Solicitor 2018 standard’ to the design and construction process in order that the number and severity of accidents is kept to a minimum.
Such a policy stance could also be used if necessary to defend potential claims against the Council. Consequently as the standard has changed the policy should be updated.
Finance Clearance Agreed By Dated There are no direct financial implications. The Darren Lambert, Finance 1st August revised road safety audit policy does not affect the Business Partner 2018 cost of implementing engineering schemes.
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated Road Safety auditors may pick up road safety issues Maureen Drummond, 27th July that adversely affect people with a disability or age Cohesion and Equalities 2018 related which allows the designer to rectify the issue. Adviser Environment Clearance Agreed By Dated There are no environmental implications with this Katarzyna Wysocka, 31st July policy Strategy and Sustainability 2018 Service Health Clearance Agreed By Dated Road Safety auditors may pick up road safety issues Patsy Richards 3rd August in scheme designs which may have an impact on 2018 health and wellbeing by reducing the risk of road Senior Public Health traffic collisions occurring, as well as reducing risks Manager to pedestrians and cyclists.
Consideration should be given by those undertaking the audit: • to ensure current legislation and best practice
Page 387 of 478 is adhered to in terms of health and safety • Air quality and how identified hot spots could potentially be improved • Sustainable transport systems that promote cycling and public transport
Community Safety Clearance Agreed By Dated
Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
Page 388 of 478 Draft Road Safety Audit Policy APPENDIX A
Luton Borough Council
Road Safety Audit Policy and Procedures
2018
Officers Draft
Alex Constantinides Director – Public Realm Town Hall Luton LU1 2BQ
For further details contact Christine Davy on Tel 01582 54 6962 or Chris Godden Tel 01582 54 6266
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Contents
Page
1.0 INTRODUCTION 1
2.0 PURPOSE OF POLICY 2
3.0 DEFINITIONS OF SAFETY AUDIT 2 LEVELS
4.0 ROLES AND RESPONSIBILITIES 3
5.0 HIGHWAY DEVELOPMENT 4 CONTROL SCHEMES
6.0 ROAD SAFETY AUDITORS 5 QUALIFICATIONS
7.0 ROAD SAFETY AUDIT 5
8.0 ROAD SAFETY CHECK 8
9.0 DESIGNER SAFETY CHECK 9
10.0 AUDIT RECORDS
APPENDIX A COSTS OF AUDITS FOR DEVELOPERS 10
APPENDIX B ROAD SAFETY REQUEST FORM 11
APPENDIX C SAFETY AUDITORS AIDE MEMOIR 13
APPENDIX D STAGE 1 TO 3 REPORT TEMPLATE 15
APPENDIX E STAGE 4 REPORT TEMPLATE 19
APPENDIX F ROAD SAFETY CHECK REPORT TEMPLATE 22
APPENDIX G DESIGNER SAFETY AIDE MEMOIR 25
SAFETY AUDIT PROCESS FLOW CHART 27
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1.0 INTRODUCTION
1.1 Road Safety Audits have been carried out in Luton since 1997. The first policy was agreed by the Executive on 10 April 2006. This is an update to the 2009 policy and is based on guidance from Highways England document HD19/15.
1.2 A road accident can be defined as a rare, random, multi-factor event where one or more road users have failed to cope with their environment. Road accidents have a number of contributory factors either
a) behavioural - lack of skills and experience, aggressive driving, inappropriate speed, risky manoeuvres, reaction time, thrill seeking, lapses in concentration, misjudgement of situations or alcohol and drug impairment etc.
b) vehicle defect - mechanical breakdown, engine and tyre functions etc.
c) environmental factor - the width, alignment, layout, surroundings, signing, markings, weather conditions, road surface and light condition or
d) a combination of the above.
1.3 Engineering measures primarily concentrate on highway factors i.e. modifying the road environment, but also have an indirect impact on behavioural factors such as inappropriate speed.
1.4 Road Safety Audits are one tool to assist in the reduction of road accidents. The Road Safety Audit is a formal, systematic, independent assessment of the potential road safety problems associated with a new road scheme or road improvement,1 as ‘Prevention is better than cure’.
1.5 The safety audit process can influence the design and implementation of new road and highway improvement schemes at the design stage.
• To ensure that schemes are not introduced with safety defects included in their design that could become crash problems in the future. • To minimise the risk of crashes occurring on the scheme and to minimise their severity. • To consider the road network as a whole and prevent the displacement of crashes to other parts of the network as a direct result of introducing the scheme. • To consider the importance of scheme design in meeting the needs of all road users including vulnerable road users
1 Institute of Highways & Transportation – Road Safety Audit published Oct 2008 1 Page 391 of 478 Draft Road Safety Audit Policy and achieving a balance between conflicting needs of all parties. • To reduce long-term costs and maintenance of schemes by introducing safe practice and avoiding expensive corrections at a later stage. • To improve the awareness of all involved in road design, planning, construction and maintenance of the highway, and promote the consideration of safety audit at all stages of design and implementation.
1.6 It should be remembered that a safety audit is NOT
• an opportunity to redesign a scheme • a technical check • a design standards check
2.0 PURPOSE OF THE POLICY
2.1 This policy updates Luton Borough council’s previous policy approved by the Executive in November 2009 and sets out how Luton Borough Council will carry out Road Safety Audits.
2.2 The overall process for undertaking safety audits and safety checks is summarised in the flow chart at the back of this Policy document.
3.0 SAFETY AUDIT LEVELS
3.1 Any scheme could have the potential to influence future injury collisions, the likelihood is proportional to the complexity of the features being introduced or maintained. Three levels of safety assessment are to be adopted by Luton Borough Council.
1) Road Safety Audit (RSA) 2) Road Safety Check (RSC) 3) Designer safety check (DC)
3.2 Road Safety Audits shall be carried out on all improvement schemes that have a significant effect on the road user in terms of how they use the road. These will be generally the large and medium size scheme.
3.3 Road Safety checks shall be carried out on all small schemes where there is an impact on road users.
3.4 All other highway improvement schemes and like for like maintenance scheme should have a designer check.
2 Page 392 of 478 Draft Road Safety Audit Policy 3.5 The Network and Safety team can give the designer advice but it is the designer’s responsibility to ensure an appropriate level of safety checking is carried out.
4.0 ROLES AND RESPONSIBILITIES
Network and Safety Division 4.1 The Network and Safety team has responsibility to:-
• Appoint the audit team and arrange the safety audit within one week of receiving all the documentation from the Project Sponsor/ Design Engineer. Ensure that the audit team leader and members are qualified to an acceptable level of expertise/ experience. • Ensure that the audit team leader and members are qualified to an acceptable level of expertise/experience. • Invite Safety Audit observers as appropriate. • Invite police and any other experts to attend as appropriate. These Expert Advisors do not formally constitute part of the audit team. • Ensure that all documentation required for the safety audit is available prior to the safety audit being carried out. • Ensure that a Designers Response with Exception Form is completed by the Project Sponsor/ Design Engineer and filed. • Agree with the designer what the level of the audit should be carried out as per 3.0 above. • File all paperwork, reports and exception reports copies for a period of 7 years following Stage 4 audit as recommended in the Retention Guidelines for Local Authorities 2003 reference no 11.6 and 11.8. This will be in electronic form with any handwritten notes being scanned.
The Project Sponsor/ Design Engineer 4.2 The Project Sponsor/ Design Engineer is responsible for initiating the safety audit process and responding to the audit including:-
• Ensuring that the appropriate level of audit is carried out as per 3.0 above. • Notifying the Network and Safety team of any departures from standard and any reasons for changes. • Ensuring that the audit is repeated if there are any significant changes to the scheme or traffic prior to implementation. • Providing an audit request form detailing the aims of the scheme • Providing information relevant to the audit including plans to the required standard, schedules and accident data
3 Page 393 of 478 Draft Road Safety Audit Policy • Deciding on any action to take following audit recommendations and any redesign required. • Providing a written designer response/exception report incorporating all elements that are accepted/ not accepted including reasons and signed by the Designers Group Manager. • When the scheme is generated or designed by an external party they shall ensure the scheme is audited to this policy by arranging their own safety audit in which case they must invite an auditor from LBC to attend the audit as a team member (LBC may decline and in which case the external party should provide the whole audit team) or request that the LBC audit team carry out the audit (see section 5.0 for charges).
Road Safety Auditor 4.3 The Road Safety Auditor is required to:-
• Identify potential safety problems in the proposed scheme design. • Not be tempted to re-design or comment on the principles of the scheme. • Consider all road user needs and suggest solutions if needs conflict. This may entail driving, walking and riding the scheme. Bicycles are available to borrow from the Sustainable Travel team. • Provide impartial, constructive recommendations to alleviate the identified problems in a clear, concise report. • Ensure that technical/ maintenance issues are included as advice notes. • Sign the final audit report to signify agreement to its contents.
5.0 HIGHWAYS DEVELOPMENT CONTROL SCHEMES
5.1 The Highways Development Control team is responsible for ensuring the safety audit process is followed by Developers.
5.2 Developers may carry out the safety audit process in-house following this policy or arrange for the audits to be carried out by Luton Borough Councils Safety Audit team at the Developer’s expense. The costs are shown in Appendix A and will be reviewed annually and updated as necessary.
5.3 The Developer shall request the safety audit/safety check using the developer’s request form in Appendix B2. The safety audit will be carried out within 21 days unless otherwise informed. Payment is required with the request form.
4 Page 394 of 478 Draft Road Safety Audit Policy 5.4 If the safety audit is being carried out by the Developer then the Highways Development Control team is responsible for ensuring that the Safety Auditors have been approved by the Network and Safety team prior to the safety audit being carried out and a member of Luton Borough Council’s Safety Audit team has been invited to provide a team member.
6.0 ROAD SAFETY AUDITORS QUALIFICATIONS
6.1 The following qualifications are required
Audit team leader • Minimum of 4 years Accident Investigation, Road Safety or Traffic Engineering experience. • Completion of at least five road safety audits/checks in the past 12 months as a team leader or member • At least 10 days of formal Accident Investigation or Road Safety training • HNC in Civil Engineering or equivalent qualification or Civil/Highways engineering experience • Be qualified as a team member
Audit team member • Minimum of 2 years Accident Investigation, Road Safety or Traffic Engineering experience • Completion of at least five road safety audits/checks in the past 24 months as a team leader, member or observer. • Minimum of 2 days Continuing Professional Development in the field of Road Safety Audit, Accident Investigation & Prevention, Road Safety Engineering or Traffic Engineering in the past 24 months. • Completion of 4 days road safety audit training or equivalent experience. • ONC in Civil Engineering or equivalent Qualification or Civil/Highway engineering experience.
Audit Observer • A minimum of six months Accident Investigation, Road Safety or Traffic Engineering experience.
6.2 Road Safety Auditors from Consultants will be required to submit a detailed CV for approval by the Network and Safety team in advance of undertaking Road Safety Audits.
7.0 ROAD SAFETY AUDIT
5 Page 395 of 478 Draft Road Safety Audit Policy 7.1 Where a Road Safety Audit (RSA) is required as per Section 3.0 of this policy the following procedures shall be followed.
7.2 The RSA team shall comprise a team leader and at least one team member, who have had no substantial involvement with the design. These officers must, be suitably qualified to undertake the audit as detailed in Section 6.0.
7.3 If the RSA is to be undertaken by an external consultant paragraph 7.2 still applies and one of the team members should be a member of the Councils Road Safety Audit team unless agreed otherwise.
7.4 Observers may be invited to any stage of the audit for training purposes.
7.5 It is the Project Sponsor/ Design Engineers responsibility to ensure that adequate time is allowed in the programme to allow for the audit process to be carried out and for possible post-audit changes to be included in the design.
7.6 The Project Sponsor/ Design Engineer shall complete a road safety audit request form (Appendix B) describe the scope of the scheme, its context and relevant constraints. The drawings etc. do not need to be ready at the time of the request but an audit cannot be carried out until all the documents are available.
7.7 A report shall be completed and agreed by the Safety Audit team as soon as possible after the audit has been conducted. If circumstances do not allow the report to be agreed by all the team within one week of the audit then a draft report shall be submitted to the Project Sponsor/ Design Engineer.
Stage 1 Preliminary Design 7.8 On large schemes (generally over £250k) safety implications should be considered as early as possible in the design process. Stage 1 gives an opportunity for route choice, standards, continuity and links with the existing road network, junction type and consideration of all road users to be discussed and gives an opportunity for safety issues to be highlighted at an early stage.
Stage 2 Detailed Design 7.9 The design work should be complete and detailed drawings available which would enable the scheme to be built without significant input from the designers. Auditors have the right to reject inadequate, incomplete or inaccurate plans and schedules at this stage. Stage 1 audits should be reviewed and any unresolved issues from previous audits should be addressed if auditors consider the issue to still be a safety point. The recommendation may change. All safety issues which affect road users should be considered.
7.10 Stage 1 and 2 may be combined.
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Stage 3 Substantial Completion 7.11 A Stage 3 Safety Audit should be carried out as soon as possible after the scheme is completed. As the majority of work within Luton is carried out on live carriageways Stage 3 will usually be carried out at post- opening phase. The Project Sponsor/ Design Engineer (in consultation with the Network and Safety team) should decide whether a Stage 3 Safety Audit should be carried out prior to the scheme being open to traffic. This will mainly occur on new roads. Stage 1 and 2 audits should be reviewed and any unresolved issues from previous audits should be addressed if auditors consider the issue to still be a safety point. The recommendation may change.
7.12 A darkness Stage 3 Safety Audit should also be carried out but this may be on a different day to the Stage 3 daytime audit. This should occur where practicable within 4 months of the Stage 3 daylight audit. The audit team members may be different but must be independent from the designers of the scheme.
7.13 Appendix C is an aide memoir for the audit team leader. The team leader should detail items discussed during the audit which were not included in the report along with the reason for not including them and keep in the audit file.
Stage 4 – Monitoring 7.14 A review of the accident records should be carried out one year - Stage 4 (1) and three years - Stage 4 (2) after completion of the scheme which has received a Road Safety Audit. The crash data before and after implementation of the scheme should be compared and conclusions drawn as to the safety of the scheme with reference to the safety audit recommendations made at the earlier stages and relevant exception reports.
7.15 A site visit will be made by the audit team members who may be different from the previous stage auditors but independent from the designers of the scheme if:-
• There is a higher than expected number of personal injury collisions since the scheme became operational. • Where the personal injury collision rate or severity has increased since the scheme became operational. • Where characteristics within the personal injury collision data shows unexpected common trends.
7.16 Recommendations will be considered and added to the programme of works as appropriate.
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Audit Reports 7.17 The Road Safety report shall use a modification of the style described in HD19/15 and shown in Appendix D for Stage 1 to 3 and Appendix E for Stage 4.
Audit Recommendations 7.18 The Project Sponsor/ Design Engineer will:
• Decide which audit recommendations are to be implemented and arrange necessary changes. • Document which audit recommendations in the Safety Audit report will be implemented and document with reasons. • Complete a Designer Response with Exceptions Form and arrange for it to be signed and returned to the Traffic team.
7.19 The Designer Response with Exceptions Form will be completed for all safety audits.
7.20 The final decision as to whether an audit recommendation is exempted will be the responsibility of the Project Sponsor/ Asset and Engineering’s Manager or where appropriate, the Service Manager or Service Director. They should sign the Designer Response with Exceptions Form to show their acceptance.
8.0 ROAD SAFETY CHECK
8.1 Where a Road Safety Check (RSC) is required as set out in section 3.0 of this policy the following procedures shall be followed.
8.2 It is the Project Sponsor/ Design Engineer’s responsibility to ensure that adequate time is allowed in the programme to allow for the checking process to be carried out and for possible post-check changes to be included in the design.
8.3 The Project Sponsor/ Design Engineer shall complete a RSC request form (Appendix B) describe the scope of the scheme, its context and relevant constraints. The drawings etc. do not need to be ready at the time of the request but a check cannot be carried out until all the documents are available.
8.4 A RSC should be carried out by one trained auditor at the same stages as for a Road Safety Audit. The auditor shall decide whether a darkness safety check is required and note decision on report. The auditor should carry out a site visit and give recommendations in the form of a report to the designer (Appendix F).
8 Page 398 of 478 Draft Road Safety Audit Policy 8.5 The Project Sponsor/ Design Engineer shall respond by documenting which recommendations will be implemented and which not with reasons on the Safety Audit report with reasons and complete a Designer Response with Exceptions Form. This should be signed by the Project Sponsor/ Design Engineer’s Team Leader or Group Manager as appropriate.
9.0 DESIGNER SAFETY CHECK
9.1 Where a designer safety check is required as per section 3.0 of this policy the following procedures shall be followed.
9.2 The designer shall consider safety aspects within the design and document in the design file. Appendix G can be used as an aide memoir.
10.0 AUDIT RECORDS
10.1 The Network and Safety team will monitor and maintain records of all Road Safety Audits and Road Safety Checks.
10.2 Records will be disposed of after a period of seven years following completion of the Stage 4 (2) safety audit.
10.3 The Network and Safety team will maintain a spreadsheet of all Safety Auditors carrying out Safety Audits for the Borough including qualifications, experience etc.
9 Page 399 of 478 Draft Road Safety Audit Policy Appendix A Cost of safety audits for Developers
Stage of Value of highway works audit Safety <£25k £25- £125- >£250k check £125k £250k Stage 1 n/a £420 £560 £770 Quotation required Stage 2 or £210 £560 £700 £980 Quotation 1/2 required Stage 3 £350 £840 £1120 £1330 Quotation (includes required darkness and Stage 4(1)
If LBC provide a team member this will be charged at an hourly rate of £70.
To be reviewed annually and updated as necessary
10 Page 400 of 478 Draft Road Safety Audit Policy Appendix B1 REQUEST FORM
To From Network and Safety Team xxx
Please carry out safety assessment as detailed below
Scheme name:
Audit/check required Stage 1 Stage 2 Stage 3 Tick appropriate box: Safety Audit
Safety Check
Cost Code:
Date scheme details will be available:
Audit required by (Minimum 21 days required):
Names of officers involved in design:
Objectives of scheme:
Brief details of scheme:
Deviations from Standard Design Guidelines: (Give details of who authorised deviations) • Enclosure checklist: Plans (please supply 2 copies of each plan) • Scheme Details • Sign Schedule • Accident Data • Designer responses/Exception Reports (from any previous Audits)
Engineer’s Signature Date
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Appendix B2 REQUEST FORM FOR DEVELOPERS
To From Network and Safety Team xxx
Please carry out safety assessment as detailed below
Name and address of company requesting audit:
Name and position of person requesting audit
Scheme name:
Audit/check required Stag Stage 2 Stage e 1 3 Tick appropriate box: Safety Audit
Safety Check
Were any LBC officers involved in design? (include names):
Objective of scheme:
Brief details of scheme:
Deviations from Standard Design Guidelines: (Give details of who authorised deviations) • Enclosure checklist: Plans (please supply 2 copies of each plan) • Scheme Details • Sign Schedule • Accident Data • Designer response/Exception Reports (from any previous Audits)
I enclose a cheque for £______.
Signature Date
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Appendix C Safety Auditors Aide Memoir
General Review of previous road safety audits Secondary effects on surrounding road network
Carriageways Horizontal and vertical layouts and alignments which may produce hazards Sight lines (junctions and private accesses) Conspicuity of junctions on approach, and sight lines from minor road approaches and private accesses Control of speed Provision for turning traffic Appropriateness of corner radii or curvature in relation to approach speed Road Users’ perception of road layout Carriageway and lane widths Obstruction by parked vehicles
Road signs and markings Location of signs and markings to aid, inform and warn of hazards, without obscuring visibility or misleading drivers Consistency of signing and marking information for road user perception Can signing be rationised to reduce the information road users have to take in?
Lighting and signals Consistency of lighting within the scheme and with the adjacent network Safe positioning of lighting columns, signals and operational equipment Confusion or conflict between lighting and traffic signals Positioning of heads for traffic and pedestrian signals to ensure clarity to appropriate road user, and avoid confusion to others to whom they do not apply Are phasing, staging and timings (including inter-green and clearance periods) optimised for safety? Safe access and servicing arrangements Facilities for vulnerable road users Appropriateness, location and type of crossing facilities Visibility
Pedestrians Are footway widths adequate? Obstructions by street furniture, signal posts, trees etc. Are refuges large enough to accommodate prams and cycles? Is illegal parking creating a problem?
13 Page 403 of 478 Draft Road Safety Audit Policy Are the types of crossings and layouts appropriate for road width and speed limit? Are crossing on desire lines?
Cyclists Are cycle lanes widths adequate? Is there sufficient width for other vehicle lanes? Do cyclists and pedestrians need to be segregated? Is headroom adequate for cyclists (2.4m for structures, 2.3m for signs) Is the footway/cycle track of adequate width?
Buses Are bus lane widths sufficient? Is the layout at the start and end of the bus lane safe? Location of bus stops
Landscaping Potential obstruction to visibility from landscaping, taking account of future growth and road user perception Potential for trees to become collision objects: choice of appropriate species Ability to maintain planted areas safely
Protective aids Positioning of safety barriers and guardrails to protect against vehicle conflicts or roadside objects (poles, columns, statutory undertakers’ apparatus, etc)
Surface characteristics Appropriate surfacing for high-speed roads, or locations (e.g. bends) which are potentially hazardous when wet Appropriate surfacing for approaches to junctions and thresholds to residential areas in towns, to encourage lower vehicle speeds
Other Provision of safety aids on steep hills Potential for flooding/ ponding due to inadequate drainage
Vulnerable Road User Are dropped crossings/tactiles provided within scheme? Needs of pedestrians addressed Needs of cyclist addressed Needs of motorcyclists addressed Needs of the elderly Needs of the people with disabilities Needs of the young people
14 Page 404 of 478 Draft Road Safety Audit Policy APPENDIX D NAME OF SCHEME
STAGE X ROAD SAFETY AUDIT
Carried out by:
Highway Services Luton Borough Council
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NAME OF SCHEME
INTRODUCTION
This report results from the Stage X “Road Safety Audit” carried out on the above scheme. The design was carried out by xxxxxxx and comprises of xxxxxxx. The audit is at the request of xxxxxx of xxxx.
The audit was carried out during XXXX 201X. XXXX of Bedfordshire Police and XXXX of XXXX also attended the audit to provide expert advice. XXXX were/was invited but declined to attend. XXX attended the audit as an Observer.
The Audit Team was as follows:-
Name of team leader Job title
Name of team member Job title
The audit took place at the Kingsway Depot offices of Luton Borough Council. The audit comprised an examination of the documents provided by XXXX. These consisted of drawing No. XXXXX. A site visit was carried out on XXX in the morning/afternoon. The weather conditions were XXX. No other information was provided.
The terms of reference of the audit are as described in Luton Borough Councils Road Safety Audit Policy 2018. The team has examined and reported only on the road safety implications of the scheme as presented in the road safety comment section and has not examined or verified the compliance of the design to any other criteria. However, any technical/maintenance or other comments which are considered helpful to the road user or design are made in section B.
All comments and recommendations are referenced to the design drawing and the problem sites located on the drawing enclosed.
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A Safety Audit Comments
A1 LOCATION Location of problem SUMMARY Summary of risk/possible accident occurring PROBLEM Description of problem. RECOMMENDATION Solution recommended
B Technical/ Maintenance Comments B1 LOCATION Location of problem PROBLEM Description of problem.
AUDIT TEAM STATEMENT
We certify that this Road Safety Audit has been carried out in accordance with Luton Borough Council’s Road Safety Policy 2018.
AUDIT TEAM
Name of team leader Team Leader
Name of team member Date
17 Page 407 of 478 Draft Road Safety Audit Policy NAME OF SCHEME
STAGE X ROAD SAFETY AUDIT
Designers’ Response with ‘Exceptions’ to Safety Audit
Carried out by:
Luton Borough Council, Highway Services, Kingsway Depot, Luton LU4 8AU
DESIGNER’S RESPONSE
Name: ……………………………... Date: ………………..
GROUP MANAGER’S APPROVAL
I have agreed to the recommendation items reference A1, C2 etc as appropriate. not being implemented for the reasons given.
Signed: ……………………………. Date: ………………..
Name: ………………………………
Group Manager
18 Page 408 of 478 Draft Road Safety Audit Policy APPENDIX E NAME OF SCHEME
STAGE 4 (X) ROAD SAFETY AUDIT
Carried out by:
Highway Services Luton Borough Council
19 Page 409 of 478 Draft Road Safety Audit Policy NAME OF SCHEME
INTRODUCTION
This report results from the Stage 4 (X) “Road Safety Audit” carried out on the above scheme. The report has been produced as part of the Luton Borough Council’s Road Safety Audit policy 2018.
A site visit was conducted on XXXX 201X. The weather conditions were XXXX or not conducted(delete as appropriate).
SCHEME DETAILS
The scheme was to XXXX and comprised on XXXXXX and was completed in XXX 201X.
The scheme was subjected to a Stage X Road Safety Audit in XXX 201X, a Stage X Audit in XX 201X etc.
PURPOSE OF REPORT
The purpose of this report is as follows:
• to undertake an in-depth study of the accidents that have occurred on the scheme during the year/ three years since opening
• to identify any road accident problems
• to suggest possible measures that would contribute to accident reduction on the scheme
• to review the recommendations from the Road Safety Audit at Stages 1 to 3 and the Exception reports to identify if they had any effect on the scheme.
ANALYSIS OF ACCIDENTS
During the period XXX to XXX (1 year or 3 years) a total of X personal injury accidents were recorded within the scheme.
Description/analysis of accidents
TRAFFIC CONDITIONS
Any changes to traffic conditions
STATEMENT OF SAFETY PROBLEMS
Problems Identified
20 Page 410 of 478 Draft Road Safety Audit Policy Identification of any problems
Review of Previous Road Safety Audit Report and Exception Reports
Have all recommendations that were accepted been implemented?
Were any of the accidents as a result of problems identified in the previous road safety audits. If yes were they accepted or exempted.
Options for Treatment
Options for treatment.
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APPENDIX F NAME OF SCHEME
STAGE X ROAD SAFETY CHECK
Carried out by:
Highway Services Luton Borough Council
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NAME OF SCHEME A safety check has been carried out with a site visit on XXXX. The weather conditions were XXXXX and the following problems have been noted:-
A Safety Audit Comments
A1 LOCATION Location of problem SUMMARY Summary of risk/possible accident occurring PROBLEM Description of problem. RECOMMENDATION Solution recommended
B Vulnerable Road User Comments B1 LOCATION Location of problem PROBLEM Description of problem. RECOMMENDATION Solution recommended
C Technical/ Maintenance Comments C1 LOCATION Location of problem PROBLEM Description of problem.
Safety Auditors Name Safety Auditors Job title
Page 413 of 478 Draft Road Safety Audit Policy Name of scheme
ROAD SAFETY CHECK
Designers’ Response with ‘Exceptions’ to Safety Check
Carried out by:
Luton Borough Council, Highway Services, Town Hall, Luton LU4 4AU
DESIGNER’S RESPONSE
Name: ……………………………... Date: ………………..
GROUP MANAGER’S APPROVAL
I have agreed to the recommendation items reference A1, C2 etc as appropriate not being implemented for the reasons given.
Signed: ……………………………. Date: ………………..
Name: ………………………………
Group Manager
Page 41424 of 478 Draft Road Safety Audit Policy APPENDIX G DESIGN SAFETY CHECK AIDE MEMOIR
Speed The scheme ensures an acceptable compliance rate. The speed limit signed correctly to enable enforcement.
Signs Sign posts are located so that they do not obstruct pedestrians. All signs can be seen clearly (at night as well as during the day). The correct mounting heights for sign are used (pedestrians/cyclists cannot hit head). Reinstatements are complete. Signing and lining is consistent with existing. Minimum amount is used so that road users do not have too much information to absorb at any one time.
Road Surfaces including anti-skid surfacing The coverage is adequate to prevent differential PSV values between nearside and offside road tyres. The start/end locations are appropriate (ie not on a bend, extending to the crossing piint on a controlled crossing). Detector loops are not affected. Road Markings are replaced/can be seen. Existing surface is in good enough condition to ensure bonding.
Parking Bays Parking bays are correctly signed and lined Sight lines are not interrupted at junctions. Drivers passing parking bays have the correct visibility to oncoming vehicles.
Bus Stops – new and improved Sight lines are not interrupted at junctions. There is adequate footway width for pedestrians, especially when assessing location of bus shelters. Minimum of 500mm or greater clearance for bus shelters from vehicle swept path. Bus stop poles and feeder pillars do not obstruct visibility sight lines, existing signs or footways. Locate at back of footway if possible. Location and type of lighting is appropriate to illuminate pedestrian crossing points. If any parking is transferred – ensure safe location away from visibility splays. Ensure that bus boarders and build outs are visible. Ensure the bus shelters do not obscure existing signs Ensure that stationary buses will not block visibility of controlled pedestrian crossing points. Ensure all reinstatements are complete to required standard.
Cycle Parking Ensure sight lines are not interrupted at junctions. Ensure vehicle/pedestrian entrances are not obstructed. Ensure adequate footway width for pedestrians, especially when assessing location of
Page 41525 of 478 Draft Road Safety Audit Policy cycle parking. Ensure all reinstatements are complete to required standard.
Pedestrian guard rail Is pedestrian guard rail needed? Ensure sight lines are not interrupted at junctions. Provide high visibility guard rail and supports if pedestrians are likely to enter the road from behind the last panel. Ensure the guard rail does not ‘trap’ pedestrians on the wrong side when crossing from the opposite side of the road. Ensure adequate footway width behind guard rail. Ensure minimum of 500mm or greater clearance for vehicle swept paths. If guard rail is acting as a barrier to pedestrian/cyclists ensure that there is a minimum of 1.2m gap between the barriers and any other obstacle. Ensure the barriers do not obstruct mobility scooters. Ensure all reinstatements are complete to required standard.
Pedestrian Mobility Ensure dropped kerbs are flush. Ensure the correct tactile paving is used in the correct pattern. Ensure pedestrians/cyclists cannot run directly onto the carriageway from a footpath. Ensure all reinstatements are complete to required standard.
Page 41626 of 478 Draft Road Safety Audit Policy Safety Audit Process Flowchart
Designer determines type of audit/check Designer carries out Design Check, required and completed relevant request and documents (Appendix I) form (Appendix C)
Traffic Team appoints Audit team, Experts and site visit arranged
Safety check carried out and Safety audit carried out and report report completed (Appendix Appendix E/F) completed by Team H) Leader and agreed by all auditors
Electronic copy of report sent to Designer and copy saved in appropriate folder in 1public/safety audits
Designer reviews report. Amends design as appropriate. Completes Designer Response incorporating all elements accepted/ not accepted
Designer Response to be signed by Group Manager and returned to Traffic team for filing
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Page 418 of 478 APPENDIX B Integrated Impact Assessment Form (IIA)
The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement that
‘The needs of Luton’s people will be first in everything we do’.
Why do I need to do an IIA? The aim of this impact assessment process is to: • Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council. • Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens. • Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion. • Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified.
When do I need to do an IIA?
• An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.
• The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA. • If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA. • An IIA must at all times identify those who will be affected by the decision, policy or strategy. • At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens. • Your first early draft is to be sent to the Social Justice Unit for comments and guidance • Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit. If you need further guidance please contact the Social Justice Unit (SJU). Please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.
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Page 419 of 478 APPENDIX B Integrated Impact Assessment Form (IIA)
Proposal Title: Road Safety Audit Policy 2018 Lead Officer Name: Christine Davy Date of IIA: 24/7/18
Date updated after consultation: Early draft Seen by: (Please send an early draft of your IIA to the SJU to ensure all impacts are being considered at the appropriate time)
Finalised IIA Signed and seen by SJU : Name: Maureen Drummond Cohesion and Equalities Adviser Date 27 July 2018
Names of all other contributors and Sandra Comersamy stakeholders involved in the preparing of Chris Godden this proposal who have been consulted with Laurence Pratt and agreed this assessment: (Please note the IIA must not be carried out by one person) If there is any potential impact on staffing none please include the name/s of the trade union representative/s involved in the preparation of this assessment or any supporting evidence of request to participate:
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Page 420 of 478 APPENDIX B Integrated Impact Assessment Form (IIA)
Proposal Outline
Information supporting the proposal (who, what, where, how). Breakdown of present users by ethnicity, age, gender, disability, religion/belief, sexuality (if recorded). Show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered. Update of the existing Road Safety Audit policy. Road Safety Audits are carried out on road schemes to ensure that the safety of all road users has been considered. They form part of the Councils statutory duty under the Road traffic Act 1988, section 39 to take appropriate action to reduce road traffic collisions.
It benefits all road users but especially road users that are disabled/elderly/young to ensure the designer has considered the road safety implication of these groups for example that dropped kerbs and tactile paving is provided and installed correctly. That drivers approach junctions correctly so that they are able to see vehicles and cyclists approaching especially if it is not easy for them to turn their neck.
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Page 421 of 478 APPENDIX B Integrated Impact Assessment Form (IIA)
Impact Table The purpose of this table is to consider the potential impact of your proposal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.
Once you have completed this process you should have a clearer picture of any potential significant impacts1, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.
Citizens/Community Staff (for HR related issues) Protected Groups Positive Negative Neutral Positive Negative Neutral Race √ Gender √ Disability √ Sexual Orientation √ Age √ Religion/Belief √ Gender Reassignment √ Pregnancy/Maternity √ Marriage/Civil Partnership
(HR issues only) Care Responsibilities2
(HR issues only) Social & Health3 Impact on community cohesion √ Impact on tackling poverty √ Impact on health and wellbeing √ Environment Impact on the quality of the natural √ and built environment Impact on the low carbon agenda √ Impact on the waste hierarchy √ Economic/Business Impact on Luton’s economy and/or √ businesses Impact on jobs √ Impact on skills √
1 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large. 2 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 3 Full definitions can be found in section 3
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Page 422 of 478 APPENDIX B Integrated Impact Assessment Form (IIA)
Please answer the following questions:
1. Research and Consultation
1.1. Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate. Click here for local demographics and information Luton’s Road Safety Audit Policy 2009, The Institution of Highways and Transportation Road Safety Audit guidelines 2008, Design Manual for Roads and Bridges - HD03/15
1.2. Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate). Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.
Click here for the LBC Consultation Portal None required
1.3. Have you carried out any specific consultation with citizens likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document. For advice and support from Consultation Team click here None required
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APPENDIX B Integrated Impact Assessment Form (IIA)
2. Impacts Identified
2.1. Where you have identified a positive impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. Guidance Notes: By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic? Road Safety Auditors may pick up problems with the design and put forward recommendations that would improve the design for all road users but especially children, elderly and the disabled.
2.2. Where you have identified a negative impact please explain the nature of this impact and why you feel the proposal may be negative. Outline what the consequences will be against each group identified. You will need to identify whether mitigation is available, what it is and how it could be implemented. Specific actions to be detailed in action plan below. Guidance Notes: By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic? N/A
2.3. Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. Guidance Notes: By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic With the exception of age and disability highway works does not have specific impact on different groups and therefore, road safety audits do not take account of gender, religion etc.
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APPENDIX B Integrated Impact Assessment Form (IIA)
3. Social & Health Impacts
3.1. If you have identified an impact on community cohesion4’, tackling poverty5 or health and wellbeing6, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children. Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.
For advice & support from the Social Justice Unit click here
For advice and support from the Public Health team click here Road Safety Audits are designed to ensure the safety of road schemes and therefore, have an impact on health and wellbeing by reducing the risk of road traffic collisions occurring as a consequence of a road scheme.
There are no community cohesion or poverty implications.
4 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 5 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 6 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services?
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APPENDIX B Integrated Impact Assessment Form (IIA)
4. Environment Impacts
4.1. If you have identified any impacts related to the built and natural environment7, low carbon8 and waste minimisation please describe here what this may be and who or where you believe could be affected Guidance Notes: Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:
Waste Hierarchy
For advice and support from the Strategy & Sustainability Team click here There are no environmental impacts with road safety audits.
7 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution. 8 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport.
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APPENDIX B Integrated Impact Assessment Form (IIA)
5. Economic Impacts
5.1. If you have identified any impacts related to Luton’s economy and businesses 9, creating jobs10 or improving skill levels 11, please describe here what this may be and who or where you believe could be affected Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below. Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below.
For advice and support on Economic Development click here There are no economic impacts in terms of creating jobs and improving skills however, they may prevent a road traffic collision which has an economic benefit.
9 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 10 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well-being and the reduction of poverty in the social box. 11 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships?
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APPENDIX B Integrated Impact Assessment Form (IIA)
Impact Enhancement and Mitigation Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:
Responsible Date Completed / Action Deadline Intended Outcome Officer Ongoing
A review of the action plan will be prompted 6 months after the date of completion of this IIA.
Key Contacts Name Position
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APPENDIX B Integrated Impact Assessment Form (IIA)
Next Steps • All Executive Reports, where relevant, must have an IIA attached • All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment) • All reports are to be forwarded to the Social Justice Unit, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline • On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager
Completed and signed IIA’s will be published on the internet once the democratic process is complete
Useful Documents Corporate Plan Equality Charter Social Justice Framework Family Poverty Strategy Joint Strategic Needs Assessment (JSNA) Community Involvement Strategy
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Page 430 of 478 Report For: Executive Item No: Date: 20 August 2018 Report Of: Dave Stevenson Service Manager Specialist 17 Operations Report Author: Liz Bailey, Team Manager, Food, Safety & Environment
Subject: Food and Feed Law Enforcement Service Plan 2018/19 Lead Executive Member(s): Councillor Khan Wards Affected: ALL Consultations: Councillors ☐ Scrutiny ☒ Stakeholders ☐ Others ☐
Recommendations 1. That the Executive is recommended to approve the 2018/19 Food and Feed Law Enforcement Service Plan as set out in Appendix A to the report.
Background 2. The Food Standards Agency (FSA) is an independent Government department set up by an Act of Parliament in 2000 to protect the public's health and consumer interests in relation to food.
3. The primary function of the FSA is to ensure local authority food enforcement is carried out in an effective, comprehensive and collaborative manner. It is proactive in setting and monitoring standards and auditing local authorities’ enforcement activities to ensure they are both consistent and effective.
4. The Agency requires all local authorities to draw up an annual plan for food and feed law enforcement services and for it to be approved by the relevant elected member forum to ensure local transparency and accountability, which in this case is the Executive.
The Current Position 5. The Service Plan is seen as an important part of the process to ensure national priorities and standards are addressed and delivered locally. The draft Service plan for Luton Borough Council’s Food, Safety & Environment team is set out in Appendix A.
6. The work of the Food, Safety & Environment team has the potential to impact on a number of the key themes of the council, and recognises its role in contributing to the wider public health agenda and helping businesses thrive and prosper.
7. Priorities include:
• Undertaking 100% food hygiene inspections of our highest risk food premises. • Using our enforcement powers to respond to public health emergencies and imminent risk (for example pest infestations in food premises) in order to safeguard public health. • Promoting business support and provision of advice and guidance to raise levels of compliance
Page 431 of 478 Goals and Objectives 8. The aim of the Plan is to set out how, with the resources available, Luton Borough Council will meet and prioritise the Food and Feed Law Code of Practice requirements over the 2018/19 year and inform elected Members of actions to be taken
Proposal 9. To approve the Food and Feed Law Enforcement Service Plan for 2018/19.
Key Risks 10. Effective food law enforcement is vital to ensuring the production and sale of safe food in Luton and requires officers to hold specific qualifications that direct the level of authorisation they are permitted to hold. Competency-based assessments and consistency exercises are held during the year as part of officer development, in addition to obtaining the 20 hours Continual Professional Development requirement as stipulated by the relevant Food Law Code of Practice.
11. The key risk is resource shortage and the necessary levels of enforcement experience and competence which would affect the ability to meet statutory requirements set by the Food Standards Agency in respect of inspection frequencies and follow up action taken in respect of non compliance (both existing and continued) and in cases of imminent risk to health.
12. The food safety team has been provided with the additional resource of an external contractor to assist the team in completion of the food hygiene inspection programme set by the Food Standards Agency. This funding ceased in 2017/18. Any future cut to resource in terms of both FTE and levels of experience and competency required, would put the Council at risk of not achieving it’s statutory food inspection responsibilities. Having the appropriate levels of qualified, experienced and competent officers available to take follow up and / or enforcement action is critical. The function is leanly resourced given the levels of non compliance and expected follow up enforcement action required within the Borough to improve standards.
13. The following mitigation is in place to minimise the risk: (a) officer authorisations are regularly reviewed to ensure they have the authority to operate at the highest level of complexity (within the limitations posed by the current code of practice), (b) a ‘market supplement’ allowance is currently in place.
14. Priority will be given to the highest risk categories of food premises where for example there is a resource shortage due to unfilled / vacant posts, or where other activities of urgency divert resource such as food poisoning outbreak investigations or other immediate priorities to protect public safety
Consultations 15. The Lead Executive Member for this service area, Councillor Khan, has been consulted on the Service Plan set out in Appendix A.
Alternative options considered and rejected (please specify) 16. To not adopt the Food and Feed Law Enforcement Service Plan for 2018/19, and ask officers to develop alternative proposals.
Appendices Attached
Page 432 of 478 Appendix A - Food and Feed Law Enforcement Service Plan 2018/19
Appendix B - Integrated Impact Assessment
Background Papers Food Standards Agency Food and Feed Law Code of Practice
https://www.food.gov.uk/about-us/food-and-feed-codes-of-practice
Page 433 of 478 IMPLICATIONS
For Executive Reports: • All grey boxes must be completed • All statements must be cleared by an appropriate officer
For CLMT Reports: • Only the dark grey boxes must be completed • Clearance is not required
Legal Clearance Agreed By Dated There are no direct legal implications other than Samantha McKeeman, 14th June those raised in the report. Senior Solicitor, Legal. 2018
Finance Clearance Agreed By Dated There are no direct financial implications associated Darren Lambert, Finance 18th June with the report. The team is resourced to the Business Partner 2018 minimum level to deliver the Service Plan, and so any increase in workload may not be able to be supported within existing budgets
Integrated Impact Assessment (IIA) – Key Points
Equalities / Cohesion / Inclusion (Social Justice) Clearance Agreed By Dated An IIA has been completed and the impact has been Maureen Drummond, 21 June identified as neutral overall but positive for race as Cohesion and Equalities 2018 translation of hygiene reports and at food hygiene Adviser training sessions is made available Environment Clearance Agreed By Dated There are no direct environmental impacts of this Keith Dove, Strategic Policy 15th June report. Indirectly, however, making residents aware Adviser 2018 of the performance food businesses along with publicising healthy eating and other health promotion activities could also encourage people to adopt other aspects of a more healthy lifestyle, including travelling more sustainably which benefits the environment.
Health Clearance Agreed By Dated Through the inspection and enforcement of food Lucy Hubber - Service 16/07/18 premises and activities, in addition to investigating Director – Healthy Lives cases of infectious disease and food complaints, the and Children’s Joint health of residents and visitors to the borough will be Commissioning (Interim) impacted positively. Public Health, Commissioning and Procurement Community Safety Clearance Agreed By Dated
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Staffing Clearance Agreed By Dated
Other Clearance Agreed By Dated
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APPENDIX A
FOOD SAFETY, FOOD STANDARDS & FEED LAW ENFORCEMENT SERVICE PLAN 2018/19
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In accordance with the Food Standards Agency Framework Agreement on Official Feed and Food Controls by Local Authorities, as amended 2010.
1.0 Introduction
Luton Borough Council is required to prepare an annual food and feed law service plan in line with the Food Standards Agency’s (FSA) Framework Agreement on Food Law Enforcement.
This Service Plan sets out how Luton Borough Council intends to provide an effective food law enforcement service to safeguard public safety in terms of food, drink and feeding stuffs produced, prepared or sold within the Borough during 2018/19.
The Council’s food service is delivered by the Food, Safety & Environment Team, which is part of the Place and Infrastructure Directorate.
2. Service Aims and Objectives
2.1 Aims
The key aim of the food service is to ensure that food and drink intended for human consumption that is produced, stored, distributed, handled or consumed within the district is without risk to health and safety of the consumer.
In delivering the service, the food and safety team aims to
• Protect public health
• Improve and promote food safety standards within the borough
• Deliver services in a professional, courteous and competent manner
• Provide clear information, guidance and advice to help food business operators meet their legal responsibilities and requirements
• Provide a consistent approach to the interpretation, implementation and enforcement of legislation and guidance
2.2 Objectives
The key objective of the food and safety team is to promote and maintain a good standard of food safety taking appropriate enforcement action for continued non-compliance, and in particular where there is a serious risk to human health or flagrant disregard.
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The food and safety team will
• Carry out programmed food hygiene, food standards and feed hygiene interventions in accordance with the Food Law Code of Practice (England), issued under Section 40 of the Food Safety Act 1990
• Continue to promote the National Food Hygiene Rating Scheme (FHRS), enabling members of the public to make an informed choice as to those businesses they choose to purchase food from, and to encourage food business operators to improve and maintain hygiene standards
• Take appropriate enforcement action in accordance with the council’s Food Safety Enforcement Policy and Food Law Code of Practice and Guidance
• Respond to service requests and complaints about food premises, food standards and feeding stuffs
• Respond to cases of food poisoning and food borne illness, advising on appropriate control measures
• Provide advice to businesses and members of the public on food safety matters
• Take food samples and arrange for the testing of foods and feed produced and/or on sale within the borough, including imported food
• Ensure all staff involved in the delivery of the food, food standards and feed service are properly qualified and competent to enable them to undertake their work, providing the necessary equipment and facilities and contracting out relevant duties where required
The Food, Safety and Environment team complies with an enforcement policy which embraces the principles of the Regulators’ Code1 and Crown Prosecution Guidelines. The document is available via the Council’s website and is referred to in all formal correspondence with businesses.
Links to Corporate Objectives and Plans
1 The Regulators’ Code can be viewed at https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/300126/14-705-regulators- code.pdf 2 2011 Census Data, Luton Borough Profile https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Planning/Census/2011%20census%20 data/LUTON%20BOROUGH%20PROFILE.pdf
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The Council’s corporate mission statement is ‘Enabling Luton to be proud, vibrant, ambitious and innovative’
The Council’s vision is that as a leader and shaper of Luton, the Council will
Deliver high quality services to improve the life opportunities of our people Work with our partners to ensure Luton is dynamic, prosperous, safe and healthy Celebrate our diversity and vibrancy and come together to build sustainable communities Provide strong leadership and a voice for the town
The Council’s strategic priorities are:
Building economic growth and prosperity Enhancing skills and education Improving health and wellbeing Developing quality homes and infrastructure Supporting safe, strong and cohesive communities Integrated, efficient and digital service delivery- striving for a ‘One Luton’ approach
3.0 Background
3.1 Profile of the Authority
Luton Borough Council is a unitary authority, with a population of 203,2012, covering an area of 17.74 square miles.
The Borough has a high population density in the region of 50 persons per hectare and is predominantly urban.
There are approximately 1580 registered food premises and 19 feed premises. The food business profile is typically made up of small retail and catering food businesses. 6.1% of the local population is employed in the accommodation and food service sector.
The main concentration of food premises is located in the town centre, which has a large covered shopping mall, enclosed market and surrounding high streets. Centrally located within the town is the University of Bedfordshire with a large population of students. Just outside of the town centre of Luton is the densely populated Bury Park area, with a high number of food premises, mainly of ethnic origin.
2 2011 Census Data, Luton Borough Profile https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Planning/Census/2011%20census%20 data/LUTON%20BOROUGH%20PROFILE.pdf
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Luton is a diverse, multi-cultural population that has excellent rail and road networks with London and the Midlands. London Luton Airport is also situated within the borough, with over 14 million passengers passing through the airport per year, and is growing, increasing passenger numbers to 18 million by 2020.
Luton hosts regular annual events attracting large numbers of the public including Luton Carnival (estimates of up to 10,000 attendees) and the annual Mela (up to 40,000 attendees), Eid and St Patricks Day festivals.
3.2 Organisational Structure
The food safety, food standards and feeding stuffs service is delivered by the Food, Safety & Environment Team located within Place and Infrastructure directorate.
The Team Manager (Food, Safety & Environment) is responsible for the day to day supervision of the team and also has specialist lead responsibility for the food hygiene function.
The council operates a cabinet committee system with a dedicated portfolio holder. Decisions may be referred to the Overview and Scrutiny Board, Executive and Council.
3.3 Scope of the Food Service
As Luton Borough Council is a Unitary Authority, the food and safety service is also responsible for food standards and feeding stuffs enforcement.
The Food, Safety & Environment Team are responsible for undertaking the following areas of food, standards and feed related activity:
• The registration of food, standards and feeding stuffs premises
• Food hygiene, feeding stuffs and food standards interventions at registered food premises, which includes fixed and mobile premises and public events
• The maintenance, updating and promotion of the National Food Hygiene Rating Scheme (FHRS)
• The investigation of food, food standards and feeding stuffs complaints
• The investigation of food poisoning allegations and outbreaks
• Responding to food alerts
• Consultation on planning, building control and licensing applications
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• Implementation of annual sampling plan for food hygiene and food standards
• The provision of guidance and advice to businesses and members of the public
• The approval of food premises manufacturing certain products covered by Regulation (EC) 853/2004 e.g. meat product manufacturers and approved cold stores
• Primary Authority for Tesco, Hilton Hotels, Just Eat, Compass Catering, Costco, One Stop, Martin Brower and other significant companies at the sign up stage.
The team is also responsible for the following areas outside the scope of this plan,
• Health and safety inspection and enforcement
• Accident investigations
• Petroleum Licensing
• Inspection and registration of skin piercing licensed premises
• Enforcement of smoke free legislation
• Attendance at the council’s Safety Advisory Group Meetings
• Private water supplies
• Fly tipping on commercial land
• Air Quality
The team take necessary enforcement action where public safety is at risk or there are serious breaches or continued non-compliance for food safety.
During 2017/8 there were 5 voluntary closures of food premises for food safety offences, 15 Hygiene Emergency Prohibition Orders served to close businesses where imminent risks to health were identified, in addition to 11 premises being subject to Hygiene Improvement Notices and 1 prosecution.
A further 5 prosecutions are currently under consideration and are progressing through the legal system for food hygiene offences.
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Service delivery points and times available
The Food, Safety & Environment Team are located on the 2nd Floor of Clemitson House 44-48 Gordon Street, Luton and can be contacted in the following ways:
Telephone (01582) 510330 Monday, Tuesday, Thursday and Friday 8am-6pm. Wednesday: 10am-6pm.
General enquiries [email protected]
Primary Authority enquiries only [email protected]
3.4 Premises Database- Number and Type of Premises
Food Hygiene Premises
There are 1580 food premises on the council’s food premises register/database
The food premises are split between the following categories as defined by the Food Standards Agency
Primary Producers 2 Manufacturers and Packers 15 Importers/Exporters 8 Distributors and Transporters 44 Retailers 442 Restaurants and Caterers 1069 Total 1580
There are currently 7 European Union (EU) approved premises within the borough which are approved under product specific food legislation under Regulation (EC) 853/2004 with an additional 2 premises that have applied for approval status. A number of cold stores are being assessed as to whether they may be subject to approvals.
These premises are required to meet higher EU standards and follow a specific approval and inspection process, with approval status being able to be withdrawn where the food business is not compliant.
Current approvals issued cover the following food handling operations
Cold store Minced meat and meat Dairy products preparations Egg products Meat products
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Live bivalve (molluscs) Fishery products
4.0 Service Delivery
In April 2016, the food law enforcement function was subject to a core audit by the Food Standards Agency. It is usual for local authorities to be audited approximately every 5 years. Luton had not been audited for a significant number of years.
The audit focussed on database management, standard operating procedures, officer training, authorisation and competency, inspection and enforcement and internal monitoring. The audit report is openly published on the Food Standards Agency website3 .
Feedback from the auditors at the closing meeting was positive, recognising the similarities that the borough has to that of a London authority in terms of the level of inspection and enforcement required and the types of premises and levels of compliance.
4.1 Food Hygiene Interventions at food establishments
The Food Law Code of Practice states that food businesses should receive an intervention in accordance with the minimum frequency as set out below.
Category Intervention Frequency Total Number of Premises in Luton Borough Council (1st April 2018) A At least every 6 months 7 B At least every 12 months 102 C At least every 18 months 334 D At least every 2 years 406 E At least every 3 years 518 (can be alternative enforcement strategy- for example low risk questionnaires) UNRATED Newly registered premises not yet 128 operating or require first inspection. Outside of the intervention Premises not included in the 85 programme inspection programme (e g mobile premises in the district but registered with other Authority)
3 https://signin.riams.org/files/display_inline/45616
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Elected members have previously confirmed that activity must be focused on those premises that present the highest risk to food hygiene with high risk inspections being undertaken in accordance with the Food Law Code of Practice and guidance.
All officers who are authorised to undertake inspections, take food samples, investigate complaints and give advice meet the qualification and experience requirements appropriate for their role as detailed in the Food Law Code of Practice. Where required qualifications are not in place, as is the case with animal feed related work, arrangements are in place for this work to be undertaken on behalf of the Council.
The borough continues to have a high turnover of new businesses and changes in ownership. This can significantly increase the inspection workload of the team during the year but is difficult to predict and quantify. Approximately 10 new food registrations are received per month as a result of a new business opening or changes in ownership.
The service becomes aware of new businesses by:
Receipt of food premises registration forms (legal requirement to register food businesses with the local authority) General surveillance by officers Advertisements seen in local press / flyers in the post Information from existing businesses / public During a routine or reactive intervention
New businesses receive an initial assessment to determine whether they are likely to be high or low risk. Those deemed potentially high risk are prioritised for an inspection within 28 days of registration or start-up wherever possible, and are then risk rated in accordance the Food Law Code of Practice.
Food Hygiene Inspection Programme 2018/19
During 2018/19 the following food hygiene inspections as highlighted in the table on page 10 are due for an intervention. The team will strive to achieve 100% of all due inspection interventions.
Due to resources, priority will be given to carrying out inspections or audits in category A, B & C rated premises, those category D rated premises that prepare open high risk foods and category E inspections where an inspection is assessed to be beneficial.
Those category D premises which do not handle open high risk foods can be subjected to interventions that alternate between an inspection ( official control) and a ‘non official control’ in line with the Code of Practice. Officers will also make use of ‘Partial Inspections’ as defined within the Code of Practice where relevant.4
4 Page 75, Paragraph 5.2.2.4 https://signin.riams.org/files/display_inline/45497
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Requirement to revisit- Food Hygiene
Food businesses that fail to comply with significant statutory requirements must be subject to appropriate enforcement action and revisit(s). Revisits will focus on the contraventions identified at the programmed intervention and ensure that they have been remedied before deciding that no further action is required.
The timing of the revisit will be determined by the action taken as a result of the earlier intervention. Such a revisit will, whenever practicable, be undertaken by the officer who undertook the original intervention.
Such businesses will be identified by a compliance score of 15 or higher for hygiene and / or structure and / or a confidence in management / control procedures score of 20 or higher as set out in the intervention ( equivalent to a Food Hygiene Rating of 2 or less)
Table to show the number of food hygiene inspections due 2018/19
Risk category and Number of hygiene % to be completed Estimated number inspection frequency inspections due and of revisit overdue from 2017/18 inspections in brackets (minimum) A (highest risk) 7 (none overdue) 100% 4 (6 monthly) B (high risk) 102 (none overdue) 100% 40 (12 monthly) C (medium to high risk) 196 (none overdue) 100% 50 (every 18 months) D (low risk) 100% of those with 30 for 20 (every 2 years) 167 (none overdue) type of food (focus on those handling open food or where intelligence suggests a visit required) E (lowest risk) 165 (58 overdue/to 100% to be reviewed / sent 20 (due to changes in Alternative intervention be re assessed) questionnaire operation noted) strategy at least every 3 ( intelligence / complaints that years indicate public health risk may trigger inspection or change in nature of business) New businesses which 106+ in year newly 100% of those new 15 are unrated registered premises businesses deemed as high estimated 100 risk and open for trade will be (includes those that inspected. have not yet commenced trading)
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4.2 Interventions for Food Standards
The Food Law Code of Practice requires food businesses to be subject to official interventions under Food Standards legislation. Food standards is concerned with the composition and labelling of foodstuffs. Businesses that are classed as high or medium risk for food standards are often not high or medium risk for food safety.
Wherever possible food standards interventions are carried out as part of planned hygiene interventions to minimise burdens on businesses. Whilst there remain 177 currently unrated food businesses under food standards legislation, none of these fall into the high risk food standards category. Low risk standards interventions will only be carried out if intelligence received indicates a public health risk.
During 2018/19, 1 category A and 63 category B food premises are due a food standards intervention in addition to overdue category A & B inspections from previous years. Category C rated premises are subject to an alternative intervention, or may be subjected to an inspection where intelligence suggests.
Due to resources, Category A rated premises will receive an inspection and a target of 50% of Category B and unrated premises where possible will have their standards inspection combined with a food hygiene intervention.
During 2018/19 an increase in combined food hygiene and food standards inspections will be carried out.
Historically, where food inspections have been carried out by a contractor, there has not been an opportunity to also carry out a food standards inspection at the same time, due to lack of qualification. This has impacted on inspections achieved over the past few years due to the number of food hygiene inspections that the contractor has carried out without a combined food standards inspection. Resources have also had to be prioritised towards other higher risk duties such as food hygiene inspections and infectious disease control where there have been resource shortages within the team.
Requirement to revisit- Food Standards
Such businesses will be identified by a level of (current) compliance score of 40 and / or a confidence in management / control systems score of 30 as set out in the Intervention Rating Scheme within the Code of Practice.
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Table to show Food Standards inspections / interventions due 2018/19
This table refers only to food standards (composition and labelling matters) not to food hygiene matters.
Risk Band No. of standards % to be done Estimated no. of (inspection interval) inspections due and secondary visits overdue from 2017/18 in brackets A (high risk) 1 ( 2 100% 0 (12 months) overdue)
B (medium risk) To be undertaken as part of a 30 (2 years) 63 (126overdue) food hygiene visit where the food hygiene inspection falls
within the 2018/19 programme C (low risk) 32 (220overdue) Alternative Intervention Targeted projects Strategy; only where (5 years) only, if resources intelligence / complaints allow indicate a need for a sector based project
Businesses which are Estimated 100 (117 Any new businesses which 10 unrated which may overdue) are deemed high risk and need to be inspected open for trade will be inspected as part of the initial
hygiene intervention
4.3 Animal feeding stuffs interventions
There are currently 19 businesses in the borough registered for animal feed inspection that either import /export, manufacture, or distribute food on for feed purposes through retail activities.
Animal feed premises are required to be inspected in line with those frequencies set out in the Food Standards Agency Feed Law Code of Practice. In line with inspection frequencies, 3 programmed inspections were carried out in 2017/18 and 2 inspections are planned for 2018/19.
Due to qualification restrictions, the inspection and enforcement of feed premises has been contracted out to a neighbouring authority. A review exercise was carried out during 2015/16 by the contractor to ensure that all feed premises were assigned the appropriate risk rating category and classification.
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4.4 Feed and Food Complaints
The team dealt with 618 service requests in 2017/18, in comparison with 599 service requests in 2016/17, 476 in 2015/16 and 450 in 2014/15. The increase in service requests is largely as a result of the Food Standards Agency introducing an eform on their website for consumers to submit complaints and allegations about food and premises to the relevant local authority.
Graph to show food complaint type received over previous three years.
250 Food Complaints- Micro, Physical, 200 Chemical Hygiene of Premises 150
100 Composition, labelling, 50 presentation Other food related 0 enquiries 2017- 2016- 2015- 2014- 2018 2017 2016 2015
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4.5 Imported Food Control at London Luton Airport and inland enforcement of imported foods (wholesale/retail premises)
Imported food activity at London Luton Airport from countries outside the EU remains limited and subject to seasonal variations. Imported food trade through the airport has the potential to increase due to the proposed expansion of the airport runway. Provision and resource for this important role must be maintained.
Food imports into the airport are monitored through an electronic notification system whereby the cargo centre informs the council of food consignments entering the port.
Officers then determine whether to inspect the consignment based on the risk associated with that product, knowledge of the importer and intelligence received from the Food Standards Agency.
Communication between the airport cargo office, the enhanced remote transit sheds (ERTS) and the food and safety team will continue in line with local authority port health controls.
Imported food control remains a key priority for the Food Standards Agency and activity in inland premises, such as wholesale and retail businesses, will continue in 2018/19 to identify and take relevant enforcement action in terms of illegally imported food.
Meetings are programmed in to meet with airport colleagues to share information on current imported food issues and to review processes.
The Food Standards Agency attended a meeting with the food safety team and London Luton Airport in April 2017 and more recently in April 2018 to discuss imported food matters and awareness raising, with a view to conduct enhanced surveillance for illegally imported foods with assistance from Customs during 2018/19.
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Food Premises- Imported Foods
During routine inspections and complaint investigations, officers look for evidence of illegally imported foods from third countries and will ensure that any identified product is removed from sale.
During 2017/18 illegally imported food from a third country was removed and destroyed from a food premises in Luton which had been personally importing and was displaying for sale.
4.6 Primary Authority Scheme & Regulating Our Future FSA Strategy
Primary Authority allows businesses to form a statutory partnership with a local authority, which is there to provide robust and reliable assured advice and inspection plans that other regulators must take into account when carrying out inspections or investigating non-compliance.
The aim of the scheme is to ensure that local regulation is consistent at a national level and sufficiently flexible to address local circumstances. The regulations governing partnerships provide for local authorities being able to recover their costs.
In November 2016, Luton entered into Primary Authority partnerships with major companies, in a new self-funding arm of the team which is to be developed and built on during 2018/19. Luton is currently partnered with the following companies has several in the pipeline
Tesco One Stop Tesco Maintenance
Hilton Hotels Pristine Conditions Papa John’s Pizza
Costco Engie Loungers
Compass Group Just Eat
Tesco is a major primary authority and very high profile. It is one of the largest environmental health primary authority partnerships in the country and both Tesco and Luton are committed to developing the relationship to demonstrate and promote best practice. Through this work, the team lead and steer relevant national sub groups and carry out pilot studies for national regulators such as the Food Standards Agency to help shape future delivery of food inspection and enforcement as part of the Food Standards Agency ‘ Regulating our Future5’ strategy. This strategy aims to review how
5 https://www.food.gov.uk/about-us/regulating-our-future
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businesses register and are inspected, recognising the importance and relevance that primary authority schemes play in potential concepts such as National inspection Strategies where a business can demonstrate systems are in place to determine an exemption or reduction in food inspection frequency at a local and national basis, freeing up time for a Local Authority to direct resource at poor performers.
By building on the primary authority element of work, the council has put itself at the leading edge of service delivery, and is in a favourable position to realign resources and shape services to fit the new regulatory delivery model of the future, leading to potential income generation, self-funding and expansion of services on offer to businesses.
4.7 National Food Hygiene Rating Scheme (FHRS)
The council uses the Food Standards Agency National Food Hygiene Rating Scheme (FHRS) to rate food businesses, giving food operators and consumers clear information on food hygiene and standards noted at the time of inspection. Some businesses such as manufacturers or those premises that are not traditionally thought of as food businesses, such as chemists are exempt from the scheme.
At the end of an inspection a food premises is given one of six ratings between 0 and 5.
The top rating of ‘5 ‘means that the business was found to have ‘very good’ standards of hygiene. Any business should be able to reach the top rating.
The rating is calculated using three elements of the risk rating assigned at the end of a programmed inspection. The elements are as follows
• Hygiene- how hygienically the food is handled and what measures are taken to prevent food form becoming contaminated with bacteria
• Structure- the structure of the establishment- cleanliness, layout, lighting, ventilation and equipment
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• Confidence in management- management controls in place including attitude and the presence of a documented management system.
Food business operators have a right of appeal and can request a revisit subject to certain conditions. Further information is published on the council’s website www.luton.gov.uk and www.food.gov.uk
To encourage businesses to apply for a re-rating revisit, auto texting and emailing has been set up to food business operators’ mobile phones and email addresses with a link to an eform to request a revisit.
During 2017/18 there were 38 revisit requests received, in comparison with 59 in 2016/17, 61 in 2015/16 and 46 in 2014/15.
A rating of 3 is classed as being ‘broadly compliant’ with food hygiene requirements.
Chart to show distribution of food hygiene ratings in Luton over time
FHRS Rating Nov - Dec - Jan - Feb - Mar - Apr - 17 17 18 18 18 18 5 - Very good 494 494 506 509 509 519 4 - Good 221 221 226 229 229 221 3 - Generally satisfactory 176 176 173 175 175 171 2 - Improvement required 79 79 76 75 75 77 1 - Major improvement required 48 48 50 50 50 49 0 - Urgent improvement required 13 13 14 15 15 13 Total rated establishments 1031 1031 1045 1053 1053 1050 Establishments with rating of 3 or 891 891 905 913 913 911 better Total establishments 1064 1064 1080 1085 1085 1085
The Food Standards Agency as part of the ‘Regulating our Future’ review are considering the introduction on mandatory display of food hygiene ratings by businesses, as is currently the case in Wales and Ireland. This has the potential to raise compliance levels as ratings will be more visible and consumer awareness will lead to choosing to eat at those premises that are rated more highly. It is anticipated that once mandatory display comes in to effect in England, businesses will be motivated to improve their rating and apply for a hygiene rating revisit.
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Figure 2 below compares the food hygiene rating position between the years of 2014- 2017/18 as a percentage of those total number of premises within the scheme.
Figure 2. Graph to show annual % distribution of National Food Hygiene Ratings Figures in brackets show number of premises within the rating scheme.
50
40 0 FHRS 30 1 FHRS 2 FHRS 20 3 FHRS 4 FHRS 10 5 FHRS 0 2018(1049) 2017 (996) 2016 (892) 2015 (874) 2014 (779)
4.8 Advice to businesses
The food and safety service is committed to working with and supporting businesses, particularly small and medium enterprises, to help comply with the law and encourage best practice.
This is achieved through a range of activities including:
• Advice given during the course of inspections or other programmed interventions. • Provision of advice leaflets, guidance notes and information mail-shots. • Signposting to other sources of information (e.g. the council’s Economic Development service). • Responding to enquiries from businesses for advice and assistance. • Information posted on the council’s website. • Provision of hygiene training, at competitive rates, for food handlers. • Provision of seminars and workshops tailored to specific subject areas • Working with the council’s traded service for Pest Control • Signposting to other relevant council departments such as Trade Waste, Planning, Building Control, Licensing and Public Health
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Better Business for All6
The service is committed to meeting the principles of the Better Regulation Agenda and the Better Business for All agenda and is represented on the South East Midland Local Enterprise Partnership (SEMLEP) Steering Group.
Joint working with the council’s pest control team, Thames Water and partners such as Luton’s business improvement district (BID) and The Mall will continue during 2018/19 to look at common issues such as pest control and commercial waste contracts.
4.9 Feed and Food Sampling
Food and Feeding stuffs sampling
The service will target its food and feed, microbiological and analysis sampling programme according to risk to public health and issues of national concern. Sampling activity will be undertaken in accordance with a sampling programme, which sets out planned sampling activities for the year. All sampling undertaken by officers will be in accordance with the relevant legislation and the Food Law Code of Practice.
In preparing the annual sampling programme consideration will be given to participating in relevant sampling initiatives devised and coordinated by our local and national partners including the FSA, East of England Trading Standards Authorities (EETSA) the Hertfordshire and Bedfordshire Environmental Health (HEBEG) Food Study Group, and Public Health England (PHE).
Reactive sampling following intelligence or complaints indicating a particular problem. Hygiene swabbing samples from catering premises Participation in national and regional sampling programmes and surveys
The team have historically undertaken microbiological sampling of water from bowsers supplying aircraft at London Luton Airport. The responsibility of having safety management systems and where necessary; verification and validation arrangements through sampling rests with the companies. The team will continue to undertake microbiological water sampling if intelligence suggests there is a problem and will use its enforcement powers where necessary.
6 https://www.gov.uk/government/publications/business-regulation-better-business-for-all
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Planned food sampling activity for 2018-19
The council takes part in national and regional food sampling studies where relevant.
The studies serve to identify a snapshot of microbiological standards of a specific foodstuff to inform whether further food safety advice or guidance is required to be issued to food businesses; or to inform of emerging food safety and microbiological issues. Samples are also taken to determine composition, identify illegal substitution or identify undeclared ingredients and/ or potential allergies. See Appendix 1 for the national surveys that the council are invited to participate in.
4.10 Control and Investigation of Outbreaks and Food Related Infectious Disease
The team are routinely notified of cases of infectious disease for follow up and investigation with the aim of wherever possible identifying the cause of illness and preventing further spread; either within the household or community.
Food related infectious disease will be investigated in accordance with procedures agreed with the Public Health England (PHE) Consultant in Communicable Disease Control (CCDC). All notifications of illness will be responded to within 3 days and any infection activity indicating an outbreak will be communicated to the CCDC without delay and responded to within 24 hours. Investigation of outbreaks will be in accordance with the Outbreak Control Plan agreed by the Bedfordshire Control of Infection Committee and Luton’s Director of Public Health.
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The service will continue to work with the South Midlands and Hertfordshire Public Health England Centre in the development of working arrangements for the investigation of infectious diseases and protocols for outbreak management. This will include regular liaison with Bedfordshire Health Protection Advisory Group to review infectious disease issues in the area and identify actions to deal them.
The service will also continue to work closely with the council’s Public Health team to identify and remove gaps and overlaps in the respective roles.
79 cases infectious diseases notifications were received and investigated in 2017/18 by the team compared to 92 cases in 2016/17 and 70 cases during 2015/16.
Salmonella poisoning continues to be the most common type of food poisoning, accounting for 57% of all cases, Dysentery accounting for 10 % and Cryptosporidium accounting for 16% of cases received.
Salmonella is usually contracted from poor hygiene practices involving poultry products and raw eggs, for example undercooking or poor handling of raw and ready to eat foods.
Depending on the type of illness, follow up stool samples need to be sent for analysis until a clear sample is obtained, with procedures available to prevent a person returning to work, school or nursery where there is risk of spread of infection to other persons. Significant numbers of illness are travel associated.
4.11 Feed/Food Safety Incidents
The council will respond to food alerts in accordance with the Food Law Code of Practice. These are notifications received from the Food Standards Agency relating to potentially harmful foodstuffs that are on sale for human consumption. The alerts set out the urgent actions councils are expected to undertake.
Food Alerts are transmitted electronically via a designated secure e-mail link. On receipt of the Alert the responsible officer will ensure it is distributed electronically as appropriate to other council services, the council’s communications team, Home Authority businesses who have requested food alert details and the Trading Standards Service. All actions taken will be in line with the advice given in the alert.
Due to the unpredictable nature of the alerts it is not possible to predict the impact and workload on the team. As many food alerts received commonly relate to product recalls from manufacturers these require minimal input from the team.
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4.12 Liaison with other Organisations
The service is committed to ensuring the enforcement approach it takes is consistent with other local authorities. Regular dialogue on food enforcement matters occurs through local, regional and national forums.
The team will continue to attend and contribute to:
• the Hertfordshire and Bedfordshire Food Study Group • the EETSA Food Task Group • the Bedfordshire Health Protection Advisory Group • the Luton Health Protection Committee • Regulatory Delivery (RD) ( formerly BRDO) • The Food Standards Agency (FSA) • Department for Environment, Food and Rural Affairs (DEFRA)
4.13 Feed and Food Safety and Standards promotional work, and other non- official control interventions
The council will actively promote national campaigns such as the Food Standards Agency National Food Safety Week and Christmas campaign, making use of promotional toolkits provided.
5.0 Resources
5.1 Financial allocation
The 2018/19 budget for this service is £350,378 (2017/18 budget was £350,680).
5.2 Staffing allocation
The current profile for officers having a direct food law enforcement role is set out below:
Officers with direct food law FTE enforcement role Team Manager 0.5 EHO (3) 4.0 Technical Officers (2) 2.0 Total 6.5 Primary Authority Officers 2.0 Technical Support 0.5
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5.3 Team development plan
The Food Law Code of Practice has increased the required number of annual continuing professional development hours (CPD) to achieve from 10 to 20 hours.
Whereas in previous years the Food Standards Agency has provided free training for officers; this free training is no longer available. The team will therefore need to identify other suitable sources of low cost training to ensure that food enforcement staff receive structured ongoing training throughout the course of employment to maintain the competency and experience demanded by the work undertaken.
New and existing staff through annual personal performance appraisals will have training and development needs identified.
In house peer review exercises and records of training attended will be maintained.
Shadowing, peer review and joint inspections are common place to encourage sharing of best practice and consistency in approach. National consistency exercises are published by the Food Standards Agency; which the team partake in.
5.4 Quality Assessment and internal monitoring
The following monitoring arrangements are used to assist in the quality assessment of work carried out:
• Review of a selection of post inspection paperwork by the Team Manager • Peer review assessment of inspections (at least 1 per year per officer) • Team meetings • One to one Meetings • Annual performance appraisals • Development of consistency and peer review exercises for the Herts and Beds Food Liaison Group
5.5 Inter Authority Peer Review Audit
During 2015/16 the Authority took part in a Herts and Beds wide inter authority audit focussing on the National Food Hygiene Rating Scheme and its implementation in terms of consistency across the region by the 13 Authorities represented.
Audit documentation provided by the Food Standards Agency was used, and the Team Manager and a member of the team formed part of the lead auditor group.
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Following on the success of this audit, there are proposals for a similar exercise to be carried out in 2018/19.
To promote best practice and availability of CPD for officers within the region, Luton created a CPD Training Day which was opened up to officers within Herts and Beds, which was well received with topical food hygiene related speakers and a consistency exercise. The event is to be repeated in 2018.
6.0 Review
6.1 Review against the service plan
Service plan commitments and associated performance indicators are monitored on a monthly and quarterly basis by the Team and Service Manager.
The current key performance indicators (KPIs) for the food and safety team are:
% of high risk inspections (A-C) that are due which are completed within 28 days of the inspection date. (100% to be achieved) % of 0, 1 and 2 rated premises that have improved to a rating of 3 at their next FHRS scoring visit/inspection.
The second of the KPIs is to reflect the team’s focus and inspection resources on the highest risk premises. It is envisaged that through a combination of inspection / enforcement strategies businesses will improve hygiene standards. Continued non- compliance however, will result in formal action being taken.
Budgeted resources mean that whilst activity has focussed on high risk activities and areas of work which have been shown to be of a significant food safety or standards matter for consumers, lower risk premises have not always received interventions unless intelligence received suggests an intervention has been required. The approach where such situations arise is to ensure that resources are prioritised in terms of the highest risk to protect public safety. This is particularly evident in terms of the food standards element of the team’s work programme. In food hygiene terms, it is not always possible to assume that a low risk premises is actually without risk; particularly due to the pest control issues that are prevalent in the borough, meaning the higher levels of enforcement action are sometimes required in a premises that would normally not require inspection interventions in other parts of the country.
6.2 Identification of any variation from the service plan
Performance indicators are reviewed on a quarterly basis by the Service Manager and significant variations reported to the Head of Service, identifying remedial action when required.
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The Team Manager is also responsible for the delivery of the service plan and team plan objectives and is required to provide a quarterly update to departmental management.
6.3 Areas for improvement
The Food Standards Agency require local authorities to carry out 100% of programmed interventions due in any given year with priority given to those that have the highest risk category.
The Food Standards Agency sets a target for local authorities to achieve 100% food hygiene inspections within 28 days of the inspection due date. This is a target that the team strive to and it forms one of the KPI’s for the team.
There have been instances where this has not been possible to achieve fully where for example, a business is seasonal, little/ no food activities have been noted at the time of inspection, meaning that an alternative inspection date is required, or where other demands on the service have taken priority; particularly in terms of reactive and ongoing enforcement action requiring intensive evidence gathering and production for legal proceedings.
The inspection programme is monitored on a monthly and quarterly basis, and where the 28 day target is not achieved, the reasons why are reviewed. Whilst it may not always be possible to achieve the 28 day target, 100% of inspections are completed.
In readiness for the potential introduction of mandatory display for food hygiene ratings, it needs to be ensured that those businesses within the scope of the national Food Hygiene Rating Scheme have been awarded with a food hygiene rating. Historically, due to resources and priorities, a significant number of newly registered premises that were assessed to fall within the risk band category E for food hygiene were subjected to a low risk questionnaire/ alternative enforcement strategy, instead of an inspection.
The Code of Practice states that on registration a risk rating visit must be carried out to determine the frequency of inspection thereafter.
The Brand Standard7; the Code of Practice for operating the National Food Hygiene rating scheme directs authorities not to issue a rating where a business that has not been subject to a physical inspection.
Since 2015, an exercise to clear the backlog of overdue risk category D & E inspections has taken place. This has also had the added benefit of ensuring the accuracy of the database.
7 https://www.food.gov.uk/sites/default/files/media/document/fhrs-brand-standards-guide_2017.pdf
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During 2017/18 those identified category E premises that require to be in the scope of the national Food Hygiene Rating scheme have been subject to inspection and this work will continue and conclude in 2018/19 to ensure that premises receive their appropriate rating, ready for the anticipated mandatory display of ratings which is likely to come into force after EU Exit.
The Food and Safety Team are committed to improving food businesses food hygiene ratings; particularly with regard to those 0, 1 & 2 rated premises.
The team will be evaluating the food hygiene ratings to identify history of non- compliance and engage with those poorer performing businesses during 2018/19 to educate and advise as to how the rating system works, encouraging businesses to apply for revisit requests where business operators have implemented works required in their inspection report, but have not requested a revisit.
Food Standards inspections need to be reviewed during 2018/19 to increase inspection activity and reduce the numbers of due inspections, where resources permit.
Planned activity for 2018-19
The team will be focussing on the following during this financial year:
Continue to target inspection and enforcement resources to the highest risk premises and to use the flexibility in the code of practice to undertake partial inspections and non inspection interventions for broadly compliant / lower risk businesses
A zero tolerance approach taking appropriate enforcement action where necessary; particularly in terms of continued history of non-compliance with food hygiene regulations or flagrant disregard. Food business closures and/ or prosecutions will be implemented where businesses fail to have adequate pest control procedures in place to prevent imminent risk to health.
To review the food hygiene rating scoping / status of premises on the council database to ensure that premises within the scope of the National Hygiene Rating Scheme are included on the website and awarded a rating.
To participate in the Herts and Beds Liaison Group work programmes and meetings
To participate in local, regional and national food sampling surveys for both microbiological and food standards
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To utilise the contracted resources in respect of feed law enforcement to carry out a review of those registered feed premises to ensure correctly risk rated and assigned the appropriate use category
Ensure that staff receive suitable and sufficient up to date training to meet the 20 hour CPD requirement as defined in the Food Law Code of Practice. To carry out peer review to promote consistencies in approach towards inspection, risk rating and enforcement of food law and food standards.
Track and consider impact of proposed changes to food law delivery currently under review by the Food Standards Agency, including the potential implementation of mandatory display of Food Hygiene ratings and charging for revisit requests under the scheme, in addition to any changes that may arise due to EU Exit.
To work in partnership with London Luton Airport, Customs and the Food Standards Agency in respect of enhanced surveillance for illegally imported foods via London Luton Airport.
Promote and sign up Primary Authority partnership opportunities and maintain and develop existing partnerships, including encouragement of assured advice, inspection plans and gearing up towards national inspection strategies as part of the Food Standards Agency Regulating Our Future programme.
To participate and promote Luton in national regulatory pilot schemes; such as continued involvement in the current pilot scheme with the Food Standards Agency for enhanced food premises registration and participation in the trailblazer group with Skills for Life for creation of an Environmental Health apprenticeship programme.
To carry out focussed projects such as ‘non English labelled’ foods; encouraging all businesses to ensure labelling requirements are met.
To review food hygiene training course provision and to tailor to customer need and demand.
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Appendix 1 National Food Sampling Surveys to participate in.
Table providing planned study timings for 2018-19 Programme:
Year 2018-2019 Months of sampling A M J J A S O N D J F M Study 63- Salmonella swabs Study 64- Pastry/bakery products Study 65- Swabs Study 66 – reactive study
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Page 466 of 478 APPENDIX B - Integrated Impact Assessment Form (IIA)
The key aim of an impact assessment is to ensure that all Council policies, plans and strategies support the corporate mission statement that
‘The needs of Luton’s people will be first in everything we do’.
Why do I need to do an IIA? The aim of this impact assessment process is to: • Ensure adherence to the legal duties contained within the Equality Act 2010 and associated Public Sector Duty to analyse the impact of decisions to be undertaken by Council. • Ensure the Council has due regard to equality taking a proportionate and timely approach to analysing the impact on citizens. • Minimise duplication of initial impact assessments with regards to Environment and Health and maximise consideration of other key Council priorities of Inclusion and Community Cohesion. • Ensure that the Council has been able to consider the social, health, environmental and economic impacts in its decision making in a single document and, where necessary enable the production of a comprehensive action plan to mitigate any potential negative impacts identified.
When do I need to do an IIA?
• An IIA must be started at the beginning of any project, policy or strategy, and cannot be finalised until such time as all consultations, as required, are undertaken.
• The Impact Table will help you to make early consideration of the potential impacts of your proposal and should be used from the point at which preliminary report is taken to Corporate Leadership and Management Team (CLMT) where appropriate. By using this table at your earliest point in the project, potential impacts can be highlighted and it will also be clear whether you need to carry out a full IIA. • If you complete this table and all impacts identified are neutral, i.e. there is no noticeable impact on characteristics and priorities listed and you are fully confident of this, please contact the SJU by email setting out how you have reached this judgement as it is unlikely you will need to carry out a full IIA. • An IIA must at all times identify those who will be affected by the decision, policy or strategy. • At a time of economic austerity IIA authors are minded to consider the whole range of decisions, both locally and nationally when analysing the impact on citizens. • Your first early draft is to be sent to the Social Justice Unit for comments and guidance • Once consultation has ended, the IIA must be updated with results of the consultation and returned to Executive, where required, for further consideration and approval – at this stage it will be signed off as completed by the Social Justice Unit. If you need further guidance please contact the Social Justice Unit (SJU). Please see links at the end of this document to key Corporate and Partnership documents that may help you complete this IIA.
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Proposal Title: Food and Feed Law Enforcement Service Plan 2018/19 Lead Officer Name: Liz Bailey Team Manager Date of IIA: 11th June 2018
Date updated after consultation: Early draft Seen by: (Please send an early draft of your IIA to the SJU to ensure all impacts are being considered at the appropriate time)
Finalised IIA Signed and seen by SJU : Name: Maureen Drummond Cohesion and Equalities Adviser Date 21 June 2018
Names of all other contributors and Sarah Hall, Service Director Public stakeholders involved in the preparing of Protection this proposal who have been consulted with and agreed this assessment: Dave Stevenson, Service Manager, (Please note the IIA must not be carried out by one person) Specialist Operations
If there is any potential impact on staffing Not Applicable please include the name/s of the trade union representative/s involved in the preparation of this assessment or any supporting evidence of request to participate:
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Proposal Outline
Information supporting the proposal (who, what, where, how). Breakdown of present users by ethnicity, age, gender, disability, religion/belief, sexuality (if recorded). Show areas in the town with the biggest and lowest needs. Greater emphasis is required at the start of the IIA on the service, how it is delivered now and how the new service will be delivered. The Food and Feed Law Enforcement Service Plan sets out how resources will be allocated during the year based on local priorities and a standard set by the Food Standards Agency. It is annual plan which needs to be endorsed by the relevant elected member forum, in this case the Full Council.
See Attached Service Plan 2018/19
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Impact Table The purpose of this table is to consider the potential impact of your proposal against the Equality Act 2010 ‘protected characteristics’ and the Council’s Social, Environmental and Economic priorities.
Once you have completed this process you should have a clearer picture of any potential significant impacts1, positive, negative or neutral, on the community and/or staff as a result of your proposal. The rest of the questions on this form will help you clarify impacts and identify an appropriate action plan.
Citizens/Community Staff (for HR related issues) Protected Groups Positive Negative Neutral Positive Negative Neutral Race Gender Disability Sexual Orientation Age Religion/Belief Gender Reassignment Pregnancy/Maternity Marriage/Civil Partnership
(HR issues only) Care Responsibilities2
(HR issues only) Social & Health3 Impact on community cohesion Impact on tackling poverty Impact on health and wellbeing Environment Impact on the quality of the natural
and built environment Impact on the low carbon agenda Impact on the waste hierarchy Economic/Business Impact on Luton’s economy and/or businesses Impact on jobs Impact on skills
1 “Significant impact” means that the proposal is likely to have a noticeable effect on specific section(s) of the community greater than on the general community at large. 2 This is a Luton specific priority added to the 9 protected characteristics covered under the Equality Act and takes into account discrimination by association. 3 Full definitions can be found in section 3
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Please answer the following questions:
1. Research and Consultation
1.1. Have you made use of existing recent research, evidence and/or consultation to inform your proposal? Please insert links to documents as appropriate. Click here for local demographics and information Local research only, i.e. analysis of data held by LBC on food business risk. No consultation undertaken. The Service Plan focuses on the “highest risk” businesses. This is defined using the Food Law Code of Practice which sets out the scoring regime for food premises in England.
1.2. Have you carried out any specific consultation with people likely to be affected by the proposal? (if yes, please insert details, links to documents as appropriate). Guidance Notes: If you have not yet undertaken any consultation you may wish to speak to the Consultation Team first as a lack of sufficient consultation could place the Council at risk of legal challenge.
Click here for the LBC Consultation Portal No. This is an annual plan required by the Food Standards Agency.
1.3. Have you carried out any specific consultation with citizens likely to be affected by the proposal? If yes, please insert details, links to documents, as appropriate above. Please show clearly who you consulted with, when you consulted and the outcomes from the consultation. Mitigations from consultation should be clearly shown in Action Plan at end of document. For advice and support from Consultation Team click here No.
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2. Impacts Identified
2.1. Where you have identified a positive impact, for communities or staff, please outline how these can be enhanced and maintained against each group identified. Specific actions to be detailed in action plan below. Guidance Notes: By positive impact we mean, is there likely to be a noticeable improvement experienced by people sharing a characteristic? See information in section 2.3 Care is taken to avoid any discrimination and the service adapts its approach to ensure businesses are not unfairly penalised. For example, those businesses where English is not their first language can receive translated food hygiene reports, and where relevant, officers would use the services of a translation service. . During food hygiene training courses, the test at the end of training can be carried out orally and papers in different languages are available.
2.2. Where you have identified a negative impact please explain the nature of this impact and why you feel the proposal may be negative. Outline what the consequences will be against each group identified. You will need to identify whether mitigation is available, what it is and how it could be implemented. Specific actions to be detailed in action plan below. Guidance Notes: By negative impact we mean is there likely to be a noticeable detrimental effect on people sharing a characteristic? n/a
2.3. Where you have identified a neutral* impact for any group, please explain why you have made this judgement. You need to be confident that you have provided a sufficient explanation to justify this judgement. Guidance Notes: By neutral impact we mean that there will be no noticeable impact on people sharing a characteristic There is no evidence currently available to suggest that the Policy will have a noticeable impact, either positive or negative, on the groups identified above namely:
Race, gender, disability, sexual orientation, age, religion/belief, gender reassignment, pregnancy/maternity, marriage/civil partnership and care responsibilities.
The Service plan and the activities of the team focus on protecting public health. The ratings given are derived from a national code of practice. Care is taken to avoid any discrimination and the service adapts its approach to ensure businesses are not unfairly penalised.
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3. Social & Health Impacts
3.1. If you have identified an impact on community cohesion4’, tackling poverty5 or health and wellbeing6, please describe here what this may be and who or where you believe could be affected, Please also ensure that you consider any possible impacts on Looked After Children. Guidance Notes: Please use this section to describe the social and health impacts and detail any specific actions or mitigations in the action plan below.
For advice & support from the Social Justice Unit click here
For advice and support from the Public Health team click here By ensuring through inspection and investigation that food and drink on sale and produced within the Borough is safe to eat, this will impact positively on the health and wellbeing of individuals. Investigation of alleged and confirmed cases of infectious disease, also helps prevent further spread thus positively impacting on the health and wellbeing of a community.
4 is the proposal likely to have a noticeable effect on relations within and between specific section(s) of the community, neighbourhoods or areas. 5 is the proposal likely to have a noticeable effect on households that are vulnerable to exclusion, e.g. due to poverty, low income and/or in areas of high deprivation 6 Is the proposal likely to have a positive or negative impact on health inequalities, the physical or mental health and wellbeing of an individual or group, or on access to health and wellbeing services?
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4. Environment Impacts
4.1. If you have identified any impacts related to the built and natural environment7, low carbon8 and waste minimisation please describe here what this may be and who or where you believe could be affected Guidance Notes: Is the proposal likely to impact on the waste hierarchy which includes issues shown in the table below:
Waste Hierarchy
For advice and support from the Strategy & Sustainability Team click here
7 Is the proposal likely to Impact on the built and natural environment covers issues such as heritage, parks and open space, cleanliness, design, biodiversity and pollution. 8 Is the proposal likely to impact on low carbon includes issues such as use of energy, fuel and transport.
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5. Economic Impacts
5.1. If you have identified any impacts related to Luton’s economy and businesses 9, creating jobs10 or improving skill levels 11, please describe here what this may be and who or where you believe could be affected Guidance Notes: Please use this section to describe the social impacts and detail any specific actions or mitigations in the action plan below. Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below.
For advice and support on Economic Development click here Officers will, whilst regulating businesses, also signpost them to local sources of business support and advice; the aim being to achieve complaint businesses that can thrive and expand in the town, creating new jobs. The team benefit from being co-located with the Economic Development Team. The team also offer a variety of food hygiene courses which improve food handler skill and knowledge in relevant food safety issues, potentially making individuals more employable due to their combined practical food experience with nationally recognised food hygiene qualifications.
9 Is the proposal likely to impact on Luton’s economy and businesses for example by creating an opportunity to trade with the Council, support new business opportunities? 10 Is the proposal likely to impact on the creation of new jobs in the local economy? This will also link to health and well-being and the reduction of poverty in the social box. 11 There are significant skills gaps in Luton’s economy. Is the proposal likely to create opportunities for up skilling the workforce or to create apprenticeships?
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Impact Enhancement and Mitigation Please detail all actions that will be taken to enhance and maintain positive impacts and to mitigate any negative impacts relating to this proposal in the table below:
Responsible Date Completed / Action Deadline Intended Outcome Officer Ongoing Continue to Ongoing provide translated food hygiene reports food hygiene Ongoing training courses test can be carried out orally and papers in different languages are available.
A review of the action plan will be prompted 6 months after the date of completion of this IIA.
Key Contacts Name Position Liz Bailey Team Manager, Food, Safety & Environment
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Next Steps • All Executive Reports, where relevant, must have an IIA attached • All report authors must complete the IIA section of Executive Reports (equalities, cohesion, inclusion, health, economic, business and environment) • All reports are to be forwarded to the Social Justice Unit, Public Health and Strategy & Sustainability Unit for sign off in time for Executive deadline • On the rare occasion that the Social Justice Unit are unable to sign off the report, e.g. recommendations are in breach of legislation, a statement will be submitted by Social Justice Unit Manager or Equality and Diversity Policy Manager
Completed and signed IIA’s will be published on the internet once the democratic process is complete
Useful Documents Corporate Plan Equality Charter Social Justice Framework Family Poverty Strategy Joint Strategic Needs Assessment (JSNA) Community Involvement Strategy
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