Accompanying photographs to our representation re: North of Luton The Chilterns Conservation Board objects to the scale of proposed strategic urban extension of Luton northwards because of harm to Chilterns AONB. It appears the M1-A6 Strategic Link Road has been positioned to maximise the amount of developable land. The allocation should be redesigned to exclude all land in the Chilterns AONB (including the road). It should also remove development from the east of the site which is in the setting of the AONB and would harm important views from Galley and Warden Hills. The development would appear as a major encroachment of built development northwards. The view to Galley Hill from AONB on the site and from John Bunyan Way footpath would be harmed. Buildings would also block the view of the chalk escarpment from the public rights of way within the site. The site itself is high quality countryside, with few detractors, in active productive agricultural use, some arable, some livestock. See photo below. This is not degraded urban fringe landscape. It is tranquil and has areas of mature broadleaf woodland, and attractive mature tree belts/ hedgerows. The site falls between the Galley and Warden Hills SSSI and Sundon Chalk Quarry SSSI and development should enhance and not sever green links between them. A full landscape and visual impact assessment should be undertaken and the development should be landscape-led to ensure harm is avoided. The landscape analysis in the Site Assessment proformas is not enough, it just states what development should achieve, without identifying issues and harm. The eastern part of the site is particularly visible from Galley Hill and Warden Hill, major sensitive viewpoints in the AONB. The special qualities of the Chilterns AONB include such views. These views should be protected by planning no development in the land between the A6 and the hedgerow/ tree belt along the western footpath snaking northwards from Betty Robinson House. This would allow the topography (which slopes away west of the tree belt) and trees to screen the development. The existing development of Bramington Park housing estate sits down on lower land (see photo below), new more elevated development would be more visible. There are uninterrupted views between the eastern part of the site and Galley Hill, with no visible built development in this view (see site visit photo below looking towards Galley and Warden Hills). The road would constitute major development in the AONB, to which NPPF para 115 applies. It should be realigned southwards to exclude land in the AONB. It is not clear why it has been drawn so far north. The junction of the new road with the A6 is likely to involve a roundabout and trigger the use of tall lighting columns which is highly likely to be harmful to the AONB. The new road should be carefully aligned to avoid creating a new traffic corridor which the eye would follow from the important AONB viewpoint of Galley Hill. As explained in our Position Statement on Development Affecting the Setting of the Chilterns AONB (attached) rooflines, roofscape, density, design and layout will all be crucial to avoiding harm to the AONB. The mixed education and residential parcel on the A6 should be relocated and tucked within the site, it will stick out into the AONB. Development should not sever the green corridor from County Wildlife Site running down into the Bramingham Park estate or between the SSSIs beyond the site. In terms of density, gardens and open space must be large enough to allow for the growth of mature trees. The existing high voltage cables should be undergrounded rather than accommodated within the design. The Board would object to the provision of formal playing fields (and possibly buildings) and children’s play spaces within the AONB – all of these facilities should be located within the main part of the development area. The Board considers that such facilities would neither conserve nor enhance the natural beauty of the Chilterns AONB. Any use of the land should be very informal with the provision of additional rights of way being the primary aim. The Parish GI plan contains aspirations to link Sundon Wood to Sundon Park, and create extensive green corridors linking Bramingham Park to George Wood, and Great Bramingham Wood to the pockets of woodland to the north. Current proposals do not deliver these GI aspirations. CCB would support such green corridors, in line with Lawton principles of making space for nature through more, bigger, better joined up protected areas and a wider countryside which is more permeable for wildlife. The GI proposals should be moved from aspirations to requirements. Cumulative impact on the AONB of this growth location, together with others proposed in this and neighbouring authorities, should be assessed. The Chilterns Conservation Board has recently published a Position statement on Cumulative Impacts of Development on the Chilterns AONB (attached). Proposals should be scaled back and appropriate mitigation secured. As well as landscape and visual impacts, other important types of impacts on the AONB need to be assessed. These include increased traffic through AONB (harming air quality, ecology, dark skies and tranquillity) and recreational impacts (increased visitor use of AONB). These impacts should be mitigated by identifying land management and visitor facilities projects in AONB and requiring the development to fund them. .