6B / Luton FoE / R1503

 

Milton Keynes & S Midlands Sub Regional Strategy Examination in Public

Luton, Dunstable & Houghton Regis: comments from Luton Friends of the Earth  Mar 04

 

 

6B1   Growth strategy

 

When the ODPM said (ODPM Update issue 30, Sep 02 page 3) it was "committed to turning around the problems of low demand and abandonment", no one dreamed this meant demolishing thousands of well-built houses in the north.  We urge a reversal, and greater support and regeneration for these communities.  Luton is acutely aware of deprivation: failure of planning to deliver habitation and regeneration in the north encourages unduly large growth areas in the south, but this may not benefit deprived areas as hoped. 

 

Net immigration makes only a small contribution to the UK.  The last census showed that, due to emigration, there were 800,000 fewer people than expected.  There are a million empty homes in the UK, enough for everyone.  Prescott (5 Feb 03): "In London & South East 70,000 privately owned homes have been empty for over 6 months. This is not acceptable. Councils should be able to bring empty properties back into use through compulsory leasing, and end Council Tax discounts on empty homes." 

 

There is no population growth to justify the proposals, which have caused considerable upset to local people: few would be unaffected.  Beds County Council's graphs show housing need going down.  The trend to smaller families cannot continue - it must plateau soon.  Importantly, the present and future social and environmental needs of the population who actually live here are not reflected in the policy. 

 

Is the vision appropriate for this area?  The answer is that :

 

-   the scale of growth does not relate to the need of the local population (see 6B4 Housing) 

-   there are many ways to raise low skills and poverty levels.  But local measures being delicately evolved to combat poverty and deprivation, in line with objectives in  A Sustainable Development Framework for the East of England (East of England Regional Assembly, Oct 2001), would be undermined by a massive, densely built housing estate north of troubled Marsh Farm

-   the plan is undeliverable: the amount of countryside to be concreted flies against sustainability principles:  A Sustainable Framework for the East of England, under "Location for growth", includes as challenges: "Ensuring development maintains and contributes to protected landscapes, biodiversity, the character of settlements and the wider countryside"; and "improving the quality of life in urban areas to reduce the need for people to migrate in search of a suburban/rural idyll".  Its key objectives, which the plan cannot meet, include -

 

·        "to concentrate development through the reuse of previously developed land and buildings and by urban extensions only where the development of greenfield land is unavoidable" (see Sequential Approach, under 6B4 Housing, below)

·        "to reduce the need to travel through closer integration of housing, jobs and services" (see 6B2 Employment, and 6B5 Infrastructure, below)

·        "to guide development away from important landscape, biodiversity and historic features" (see 6B3 Environment, below)

·        "to protect landscape character, and be sustainable in use of resources, eg energy, water (see 6B3 Environment, below)

 

The drivers for growth (we should aim for a stable, sustainable population) are too narrowly focused, strongly socially exclusive, undemocratic and likely to increase poverty.   There is no master plan for the growth period: this threatens long-term provision of sustainable infrastructure.  The SRS would increase congestion, pollution, deprivation and crime.  It is devoid of the holistic strategy required, and is not a path towards sustainable development.  

 

Growth must focus on people and communities.  It does not have to be physical, or bring urban sprawl - a town can grow internally, making better use of what is there already.  Efficiency, reducing waste and energy is a means of growth.  Bricks and mortar are only one way to support need - a plan which sees building as the main focus is seriously flawed.  The plan must fully explore environmental capacity, respect existing neighbourhoods and boundaries, sense of place, community and heritage, landscape and biodiversity, and existing social and physical infrastructure.  To see environmental limits as a constraint to development, and try to override them, is a recipe for disaster. 

 

6B2   Employment matters

 

The number of jobs is far fewer than the number of homes proposed.  This would increase unemployment and social instability.  Detail about job creation is scant - too focused on big business, over too few sectors, to represent a sustainable strategy.  Increasingly the best stock market returns come from small to medium sized companies; ethical performance is now a key factor.

 

Jobs must link with housing to provide local, worthwhile jobs for local people, and reduce travel.  (Employers can give incentives for short, non-car journeys.)  But this is not enough: for an acceptable quality of life, the strategy needs synchronised creation of jobs, housing, public transport, walking, cycling, water, utilities, health, social and green infrastructure.

 

'All eggs in one basket' reliance on the airport is unwise - it assumes unrealistic and environmentally disastrous levels of expansion, unrelated to proposed housing north of Luton-Dunstable.  The airport is popular because its size brings convenience.  To double or treble throughput would hurt the economy, encouraging far greater spending abroad.

 

Most jobs are in the centre or south. Building north of Luton-Dunstable would cause north-south commuting, which the town's roads could not support, bringing chaos and loss of mobility for residents paying for better things.  More people travelling longer distances - the opposite of what is needed.  The plan should ensure most people don't have to cross the large conurbation daily.  Most who live and work in Luton, or travel in and out, will still need the town centre. Yet the scale and position of housing proposed would cause unacceptable levels of traffic, and gridlock the centre - already hard to reach.  Congestion is bad for the economy.

 

Employment suggested is road based, narrowly focused, and does not celebrate the area's diversity.  Clusters like automotive, electronics and manufacturing will remain, but emphasis on knowledge-based and biotech industries is a mismatch between jobs and skills available.  This is fundamentally unsustainable, and would attract new in-commuting journeys rather than providing local jobs.  New houses linked to a major trunk road would encourage outward commuting, exacerbating existing trends.  This would threaten the economic viability and sustainability of the whole area. 

 

Initiatives are underway to stimulate community enterprise and small businesses suited to the area.  Government Offices want to involve voluntary and community sectors in planning and delivering services.  Greater attention should focus on this and home working.  More local goods or services is best for the economy.  The plan does not encourage environmentally sustainable, satisfying employment. 

 

Workplaces and homes should be sustainably built and energy efficient.  The UK needs new renewable energy sources, but there is nothing about achieving local contributions.  Encouragement is needed for life cycle analysis, design for re-use and recyclability to reduce virgin materials and waste, cut costs, improve efficiency and bring environmental improvements.  Partnership working between businesses and clusters can deliver efficiency and savings, eg procurement, recycling, energy, freight, joint travel plans.

 

Food is a major industry on which we depend.  Sustainability requires degrees of self-sufficiency, but conurbations depend almost wholly on trucked-in food.  Some local food processing takes place.  A focus on growing local fruit, vegetables and other crops, particularly organic (an increasing market), would stimulate community involvement and pride.  Building on countryside would prevent this.  Silsoe could be a leading player in helping develop sustainable local food production and processing, and setting up co-operatives like Yeo Valley.   Inreasing food production may be particularly suited to Luton's culturally diverse communities, already active in the area. 

Drivers include the need to :

 

-        provide food for an increasing population in the growth area

-        increase organic food production and reduce amounts imported (over 70%)

-        protect soil and environment to counter soil imbalance, erosion and GM unpopularity

-        reduce pesticides and harmful additives

-        reduce lorry journeys and congestion

-        counter obesity and poor health due to poor diet and lifestyle, discourage junk food

-        poverty and disadvantage (poor diet reduces ability to learn and perform)

-        increase the number of jobs involving exercise and fresh air

-        reduce over-reliance on the service sector

 

6B3   Environment  (also see response in 6C1 to Growth Area Assessments)

 

Government recognises it as a prime responsibility to protect countryside, town and country boundaries, landscape and biodiversity.  John Prescott stated "We will provide affordable housing across the country but this doesn't mean concreting over the green belt - in fact we have increased it by 30,000 hectares" (ODPM update issue 30, Sep 2002).  He stated he "will not tolerate urban sprawl"  and "is making a new commitment to the green belt in each region and other safeguards for the countryside".  

 

Searching the SRS for such a commitment north of Luton and Dunstable is futile.  It goes into chosen sites in much detail on houses and roads, without first having carried out any environmental appraisal.

 

The proposed scale of housing and north Luton bypass is not desirable, achievable or sustainable. To destroy substantial countryside north of Luton-Dunstable to the M1 is unacceptable. It would isolate and degrade several major biodiversity sites protected under the Wildlife & Countryside Act.  The road would cause severe damage to Areas of Outstanding Natural Beauty, and reduce biodiversity by enclosing Warden Hills SSSI, Bradgers Hill Local Nature Reserve, and Bramingham Wood, bringing urbanisation, pollution, dumping, fire, vandalism etc to ruin nationally rare habitats.  It would adversely affect quality of life for the majority of existing residents due to noise, congestion, pollution and health, and ruin open views of countryside for thousands who thought the Green Belt protected them. 

 

Bedfordshire has a comprehensive Biodiversity Action Plan, carefully developed by experts in the field.  (This includes urban areas; green and amenity spaces in Luton and Dunstable are inadequate, and all must be protected.)  The SRS, driven narrowly by economics, would tear up large sections of that Action Plan, together with much of our county's heritage landscape.  Areas of Outstanding Natural Beauty (in the path of the proposed north Luton bypass) are descriptive of real features, valued for their beauty and character: much would be lost.  Character, heritage, amenity areas, historic settings would be destroyed forever. 

 

Settlements have historically been based on river systems for good reasons.  There is no major river here. The area has the lowest UK rainfall.  However, Ouse tributaries rise here (some support the now rare native crayfish) and would be subject to pollution or abstraction threatening the Ouse washes, internationally important for birds. On water issues, the plan runs counter to sustainability principles, indicators - and common sense.  The water industry has serious concerns over deliverability and cost of water and sewage treatment.  Water would have to be brought from the Trent - a major engineering feat -  and new reservoirs constructed.  Large sewage upgrades would be needed.  It is uncertain if all this could be delivered within the timescale.  The plan could fail for this reason alone - but sustaining quality of life and environment bring many other challenges.

 

With climate change threatening our ways of life, this whole development would contribute massively to greenhouse gases, especially CO2.  This is against the Kyoto agreement, and it is hard to see how it could be countered elsewhere.  It goes against many of the government's own sustainability principles and indicators, as listed in A Sustainable Development Framework for the East of England.

 

The "economic vision" workshops in Feb-Mar 04 were unrepresentative of the general population.  Yet I was the only person who raised key environmental issues, the need to follow sustainability principles and concerns about quality of life - nearly all present were obsessed by building as many houses and roads as they could.  No relationship to real need was discussed, nor the sequential approach, which could meet a high proportion of need and prevent irreplaceable loss of our countryside, heritage and biodiversity.

 

6B4   Housing targets

 

It is essential to focus on meeting a proportion of local need.  Building that encourages inflow of population prevents local need being met and compounds future housing problems for the grown up children of both indigenous and incomers.  500 are in B&B in Luton, but not everyone on local waiting lists has urgent need to be accommodated locally; travel is rewarding and educational for young people, and to experience differing geographical areas and cultures.  They also like town centres; the north needs young, dynamic people to drive regeneration programmes.  43,000 new dwellings on green fields are simply not required - building on this scale would encourage far more 'need' than exists.  Creating demand, which this plan does, is unsustainable.  Communities have always evolved: numbers should be flexible, not prescribed.  Population is in decline - see Luton FoE submission for Matter 1A.

 

Local need must be addressed using the sequential approach, and an urban strategy based on this, to increase dwellings.  Urban capacity studies should not be based solely on ground areas - living space is three dimensional, and there is plenty of space in the sky.  All towns have potential for a step change in the number of dwellings by building upwards.  It is therefore entirely wrong to begin at the bottom of the sequential hierarchy with new build on Green Belt and green fields. 

 

The UK is borrowing billions: enormous sums should not be squandered on pointless exercises.  It is far cheaper to reoccupy empty housing.  It is absolutely not the function of Bedfordshire (north of Luton, Dunstable and Houghton Regis, whose transport and social infrastructure is at capacity) to house key workers for London.  The concept is impractical - such people cannot afford the fares. Teachers and nurses work long hours, and need to return to their homes quickly for rest and any social lives they can fit in.  London accommodation need must be met in Greater London, which has tens of thousands of suitable empty buildings.  Luton's policies favouring local people occupying new housing should continue.

 

The sequential approach is based on common sense and sound principles.  It is wrong to conclude that local shortages require new houses, especially on countryside and Green Belt.  Indeed, this is a wasteful and damaging distraction from more efficient ways to solve the particular problems of different categories of people needing a home.  The best solution is NOT to build on green fields. 

 

To build sustainable travel patterns, and protect quality of life and important environmental and amenity areas, the following sequential approach to identifying development locations should be adopted:

 

·        re-use and convert empty buildings: of 1500 empty buildings in Luton, only 60 are reoccupied a year.  Money should be made available immediately for new council staff to organise reoccupation of these. 

·        convert and expand occupied buildings - there is vast potential for new dwellings through building extensions, to the rear or over garages, or converting a house to maisonettes, suitable for rented accommodation or first time buyers.  This provides housing without destroying the heritage or significantly altering the character of a neighbourhood

·        convert to add residential floors to offices, with separate entrances (see below)

·        re-use previously developed land and remaining buildings (genuine brown field sites)

·        use other previously developed land well connected to public transport links

·        use new sites in urban areas, subject to protecting and conserving areas of recognised environmental and amenity interests

·       use other sites well located for sustainable development and reducing the need to travel.

 

Tackle housing shortages mainly in towns.  Fast-track rehousing people in B&B and on waiting lists:

 

-        build up the housing base owned by local authorities 

-        invest more in reoccupying empty housing (Sequential Approach) in partnership with other councils (not necessarily neighbours - north-south twinning arrangements could be developed)

-        focus on prioritising local homes for local people (all southern local authorities)

-        reoccupy town centre buildings with vacant offices on upper floors

-        add extra floors, particularly to town centre buildings, where partnerships with business could provide homes above offices with separate access, to suit young people, individuals, couples, students, homeless people or those on welfare who live in cramped accommodation with parents; with caretaker and lifts, such dwellings could provide for older and less mobile people, who cannot manage a garden, but would enjoy a view; or for learning disabled people.  This significantly reduces need to travel: the more people living in a town centre, the less need for cars and journeys generally, and the more vibrant the town.

 

This strategy removes the need to irreparably damage our countryside.  The proportion of affordable housing should be increased (planning must avoid 'ghettoes').  To achieve sustainable design and construction, the Ecohomes Very Good standard should be adopted as the norm.  The Plan should first -

 

·        adopt the sequential approach above

·        follow a thorough and fully consultative plan for the area based on the sequential approach

·        comprehensively reassess local housing need, remove any factor for London key workers, and reduce scale according to sequential approach success in delivery for need

·        have a clear Green Belt strategy: start with presumption that none will be lost except as last resort.  This is vital north of the Luton-Dunstable-Houghton Regis area where most Green Belt is under threat

·        develop a rigorous strategy to avoid urban coalescence, to protect quality of life and heritage

·        recognise this as one of the driest areas in UK; unlike historic settlements, building is not based on river catchments.  Show that for whatever new build is needed after sequential approach was followed, water supplies and sewage treatment can be provided, and by what timescale

·        demonstrate that no adverse impact will occur to the water environment through abstraction or decline in water quality

·       ensure cast iron guarantees on ways to fund full infrastructure costs, prioritising public transport and social infrastructure listed in Tym report, and environmental infrastructure costs not considered by Tym; no work to commence until a Strategic Environmental Assessment is produced.

 

6B5   Key local infrastructure

 

Key, high level, sustainability objectives to improve quality of life for all in the region  (A Sustainable Development Framework for the East of England) are :

-        to reduce consumption of fossil fuels (this can't be done by technology alone, road traffic must be cut by providing alternatives to the car and reducing need to travel)

 

The Sustainable Development Framework Indicators for high level objectives include :

-        distance travelled to work and mode of travel

-        number and length of journeys by environmentally damaging modes: car, lorry, plane

-        proportion of journeys by walking, cycle, bus, passenger rail, rail freight

-        traffic congestion

-        transport's share of region's greenhouse gas, particularly CO2 emissions

-        freight transport tonne/miles and empty lorry miles

 

Sustainable travel plans should be fast tracked among all businesses and schools to reduce car travel. Practical, integrated public transport needs to be put in place urgently.  "Economic vision" workshops in Feb-Mar 2004 were dominated by unrepresentative vested interests, obsessed by road building and air travel (the least sustainable modes).  The vital need to provide more railways was not discussed.  This slapdash, narrow focus would increase car dependency, and does not bode well for social infrastructure. 

 

The narrow, road-building focus in the strategy is unsustainable, and would bring a very unhappy future. 

To continue the Leighton-Linslade-M1 link eastwards would be a disaster.  A north Luton bypass would  severely damage AONB and biodiversity sites protected under the Wildlife & Countryside Act.  The A6 is at capacity and already needs park and ride: joining it to a major east-west traffic generator, even if not coupled with large scale new housing, would create millions of new journeys, bring gridlock, make the A6 and other major arteries unusable, and compound problems throughout Luton and Dunstable. 

 

Dependence on a north Luton bypass as the main artery would be highly undesirable for congestion, noise, pollution, wildlife and landscape.  It would bring many thousands of vehicles including heavy lorries, pushing new east-west journeys through the conurbation.  Luckily, it could not be built in time.

 

Rail or light rail are popular, providing real alternatives to the car, particularly late evening.  Unless rail was provided at the outset, car dependency would set in and people would be unlikely to switch to public transport later.  A study is needed to look at an additional east-west rail or light rail scheme north of Luton-Dunstable, which would be far less damaging and could provide a useful public transport choice, integrated with short north-south bus journeys.  New east-west rail routes could provide the opportunity for developing a local rail freight hub.

 

A Luton rail hub including east west rail on existing track, served by feeder buses, is needed now, without further development: airport expansion, substantial house-building or urban regeneration is impossible without it.  Fortunately, Beds County Council, South Beds DC, and Dunstable Town Council are aware of this.  Redevelopment of Luton rail and bus stations must focus on east-west rail interchange: one major operator has bid to provide this service, others are interested.  Luton-Dunstable hospital expansion should be served by a 3 minute bus service connecting at Chaul End or Skimpot with a new east-west rail line.

 

Transport must be integrated.  Rail is an essential part of a sustainable future: growth cannot take place without it.  The Draft Regional Transport Strategy incorporates hubs linked by transport spokes, referring to regional interchange centres, including Luton/Dunstable, linked by multi-modal corridors, priority given to overall accessibility by public transport.  To cut millions of car trips in the sub-region, including many on the M1, the most vital spoke is a rail connection across South Beds from the Luton hub on the Midland Mainline to a new station on the West Coast Mainline, for access to the hubs of Watford and Milton Keynes. A bid is on the table; rail reopening for the Luton-Dunstable section must be fast-tracked.

 

Translink's inefficiency (using ordinary roads over much of its journeys) and lack of capacity would be totally inadequate to convey people with luggage to the airport or serve proposed new development to the north.  Atkins and Arup confirmed that Translink would get no one out of their cars.  Translink is old thinking, and must be consigned rapidly to history.

 

Airport management states that every million passengers require 1000 employees.  It is desirable that most live in Luton.  75% of passengers arrive by car: each million extra creates 750,000 car journeys (assuming a return journey, 2 to a car).  Current throughput is 7m: if this rose to 10-12m, the town would gridlock.  As most employees and many passengers have to cross the conurbation from the west to reach the airport, gridlock would occur at 10-12m even if new roads were in place.  Soliciting passengers from the Midlands, which has its own airport, is unsustainable.  There must be no road east of the airport, to destroy areas of great landscape and wildlife value. 'Century Park' should remain attractive rolling fields, a buffer to airport activities.

 

Climate change is everybody's serious problem.  Aviation is the fastest growing source of greenhouse gases (eg CO2, see indicators above) and NOx (damages health and ozone layer).  Expansion would reduce quality of life (noise, health, pollution, congestion) for thousands, due to effects of lengthened runway.  Luton airport uses 22% of the energy of the county of Bedfordshire (Beds Renewable Energy Strategy Consultation).  This is unacceptable: a robust independent energy audit is needed to achieve a step change in reducing car use and energy generation across all airport activities. 

 

An obvious strategy would include train and coach fares in flight prices, and prioritise introduction of rail from the west.  The most environmentally damaging travel should cost more, yet flying can be cheaper than rail: no aviation fuel tax allows fares that don't cover 'externalities'.  Growth should not take place regardless of costly impacts to environment, health and society.