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Luton Local Plan Issues Report

Comments from Luton Friends of the Earth March 2002        

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We welcome the opportunity to comment on the questions raised in this report. We have suggested ways forward on a number of planning and related matters which we believe would be of significant benefit to the community.  At the same time we would like to voice deep concern over the Government's proposed reforms of national and local planning, which would transfer power to unelected regional bodies and reduce people's right to object.  This could add to the disengagement felt by many, particularly the young, and could adversely affect the likelihood of our positive comments for reform being put into place.

 

 

Q1      How can the Local Plan promote sustainable development?

Remember in all planning decisions that citizens of Luton and those who work and visit here want to see an attractive town, with buildings that command respect and interest; and more, not fewer, green open spaces, trees and water features, all of which support as great a variety of wildlife as possible.  Small independent shops should predominate, rather than chains seen everywhere else.

Implement Planning for Sustainable Development: Towards Better Practice and other govt guidance.

 

Q2      How can best use be made of Luton's land?

Housing and employment applications should not override or dominate quality of life, or the need to protect and create green, open spaces and corridors for wildlife conservation, footpaths and cycle paths for the public, or threaten small shops and businesses.  The Nature Conservation Strategy and Biodiversity Action Plan should be considered an overriding priority in all developments.  All remaining green spaces (notably the large areas on the borough boundary) should be protected.  Employment should be directed to existing employment areas. These should be kept for employment, and no further private houses should be built there (eg Electrolux). 

 

The town's mature trees and hedges have a multitude of valuable functions, and a much higher priority should be given to protecting these, as well as increased tree planting  and extending hedges.  Tree Preservation Orders should be announced for all mature trees in the town. There should be a greater emphasis on conserving Luton's built heritage, eg through a presumption to protect, re-use or convert older buildings in all developments.  In new buildings and conversions, greater emphasis should be placed on attractive, diverse design and energy-efficiency.

 

Town centres should be living places, and upper floors may be converted to housing from offices.  Resist applications from retail units in inappropriate places (eg Power Court - retail should have been directed to Hightown to serve people who could walk to it.)

 

Q3      How can the green spaces be improved?

There is far too much 'sterilised' green space through over-mowing, and rings of pesticides around trees, under hedges and elsewhere.  Wildlife is suffering badly, and nature conservation should be a higher priority.  Most green spaces, particularly boundaries, should be converted to part meadow and wildlife space - minimum 2m unmown around all playingg fields.  More tree planting and extension of hedgerows.  See 24/25.  Create more town walks/green links/cycle routes to familiarise people with and improve surroundings.  Refer to Landlife (www.landlife.org.uk) for advice on converting green deserts to wildlife-friendly areas, as in Knowsley.

 

Q4      How can the housing and other needs of local people be met without damaging areas of conservation interest?

See 2.  Luton is full.  No new private housing should be built - we are too short of open space, and there must be no further encroachment.   We are very concerned that you have not included any question of conserving history or heritage apart from Q10 on Listed Buildings.  The same principle applies to nature conservation - it is not only designated areas that are important.  PPG15, 1.1 is quite clear that the historic environment encompasses far more than Listed Buildings and should be protected.  PPG15, 1.4-5 links conservation and economic prosperity.  The Local Plan should state that there will be a general presumption against destroying any existing buildings, which may be converted or extended as houses or flats.  Once lost, they cannot be replaced.

 

Agreements can be reached with developers that permission will be granted providing worthwhile existing buildings are retained to maintain historical character and continuity.  It should be made clear to developers that destruction of such buildings will be subject to heavy fines and/or refusal of permission.  Such problems might be anticipated by making use of Building Preservation Notices  (PPG15, 6.23-25.)  Where old buildings may be under threat, consult the Amenity societies (PPG15,A15). 

 

New buildings should have variety and style.   People's needs include not just a roof over their head, but quality of life, including a view of and access to natural and recreational green space, and a mix of old and new buildings.  They also need clean air, low noise, and cheap energy. To reduce pressure on natural resources and reduce the nation's energy bill, passive solar space and water heating, which is far more expensive to retrofit,  should be built into all new buildings, which should face south wherever possible.

 

The limited housing available should be targeted at local people.  Advertisers attract people from London and elsewhere - this should be discouraged.  Intensive but well-designed use of land for employment and housing will reduce pressure on green space and on 'brown' land which might be used to create new green space.  Sizeable applications for affordable housing should be regarded as an opportunity to create new green space and attractive, energy efficient buildings. 

 

Q5      Should all areas of nature conservation importance be protected regardless of development pressures?

Yes.  The whole cycle of wildlife in the UK is under threat.  New sites should be created - particularly where existing undesignated spaces could be expanded and new green links created, to counter previous losses.  Mature trees and hedges should be protected throughout the town.  The council has said that all trees throughout the town would be treated as if they had a TPO.  We applaud this statement, but it must be enforced.  There are many undesignated areas providing small but important refuges for flora and fauna, and these should be recognised, respected and protected.

 

Q6      Should the local nature conservation designations be refined in order to identify those that are of the greatest importance?

This is the wrong approach - see 5.  Putting nature in a box does not necessarily afford it greater protection.  All green spaces support some wildlife, and should be carefully protected.  Yet many kinds of wildlife are killed by the unsightly and counterproductive blanket use of weedkiller which replaces the cheerful bloom of spring with evil yellow or blue rings around trees and hedges all over the town. This costly and unnecessary practice must cease immediately. It reduces the ability of wildlife to flourish - consequently it is harder to designate new sites.  A general aim should be to upgrade all green space, pocket parks etc.

 

It was completely unacceptable to sell off part of the County Wildlife Site at Croda, Bath Road.  Sites are given protection for a reason, and nothing comparable must ever happen again. 

 

Q7      How can wildlife be encouraged?

No weedkiller, strimming or flail mowing should take place around or beneath hedges, which need to be thick for nesting to take place successfully and for insects to complete their lifecycle.  Mature trees must not be removed, even if they die - they are the only source of rotting wood and fungi, which is vital for many invertebrates such as beetles to survive, and to provide food for birds and small mammals. 

 

Hedges, particularly old ones, should be lengthened and replanted where appropriate. Verges (Hatters Way is good practice) should be encouraged for wildflowers etc.  New green links should be created.  Mowing contracts should be severely curtailed to reduce 'green deserts' such as along the river, where attractive meadows can be created.

 

Q8      How can sustainable construction and design be used to improve the quality of the built environment?

See 4.  Look at the many good practice examples.  Use state of the art guidelines on sustainable methods of construction and materials.  Use local materials wherever possible.  Toxic chemicals should be avoided (eg PVC). Simple measures like window boxes can be encouraged, especially in conservation areas.  Insist on energy saving measures, solar panels etc. 

 

New housing, such as it is, should face south and have built in passive solar space and water heating - this is more expensive and less easy to retrofit.  This is easy for Luton, which is too full for many new houses.  The new pool, school extensions, and any other new council properties, should be built with solar heating.  Encourage architectural innovation - there are far too many boring and ugly buildings in Luton.

See 'By Design - Urban Design in the Planning System - Towards Better Practice' (DTLR, 2000).

 

Q9      How can the existing built-up area be improved to enhance the quality of life for people using it?

See 4 and 8.  Encourage pride in the streetscape, and in the town centre by providing a more attractive place for those who live and work there.  More planting of suitable trees sympathetic to buildings.  Allow fences - particularly mesh ones - to develop naturally into hedges instead of maintaining them as eyesores with weedkiller.

 

Aim for traffic minimisation or removal - reclaim the streets!  More pedestrian and cycle space. Fewer and smaller car parks. (Bad practice: replacing Regent St car park with same high number of spaces as the old building encourages more car use and works against use of public transport.).

More bus lanes only if buses can be made more frequent.  Variety and character should be built into the street scene and traffic calming features (PPG15, 5.12-18).

 

Q10    Should the Conservation Areas and Listed Buildings be further enhanced, and if so how? 

Yes.  People's surroundings are very important and have been undervalued in Luton.  Many more buildings should be put on the Local List, to demonstrate a recognition and concern for environment and heritage (see 4.)  Any rebuilding in Hightown and Plaiters Lea should be innovative and interesting, but in keeping with the conservation area, where more could be made of historic buildings. 

 

Consider extending existing Conservation Areas or creating new ones.  Create more open/green space. A prime example of where this should be made to happen is on the NCP car park, Silver street.  The river can be brought to the surface, as it has beside the Galaxy.  Reclaim and slightly widen the historic Barbers Lane by taking a slice off the Cheapside car park.  Encourage small, interesting, independent shops here, as around the church in Hitchin.  Make the river and this green space a central feature of Plaiters Lea.  A fountain would be an attractive feature, with both covered and open seating for people to eat sandwiches. Bute Street,  as the main route from the station to the town centre, should be pedestrianised, and the footbridge refurbished. 

 

Q11    Should we further protect against flood risk, and if so, how?

Yes.  Obviously no building on flood plains.  Pipes and sluice gates should be installed from Mill Stream beneath New Bedford Road to the natural flood plain opposite - Moor Park.  Attractive water storage areas/lakes/'balancing ponds could be introduced along the Lea (and elsewhere) improving wildlife habitat and amenity, plus more 'tyre weirs' to aerate the water.  Any new development with large concrete areas of concrete run-off would make the problem worse, and must be resisted.  Any new build should make minimal use of concrete/tarmac, and car parking should be gravel/limestone. Indeed, existing areas of concrete should be broken up wherever possible to reduce run-off. 

 

Q12    How can contaminated land be brought back into productive use?

Remove contamination before any new build - do not 'cap' - this stores up trouble for the future, and threatens water sources / watercourses. The PreStar site has contamination, which must be removed, over one of Luton's main water supplies, and Dallow Road B&Q and Aldi sit over a 'capped site'.  The Gas site opposite Bury Park Sainsbury must be decontaminated if any building is to take place there. 

 

Q13    Is low-cost housing for sale 'affordable' in Luton, or is subsidised rented housing the only way to provide for our needs?

            Though people having a stake in their own home is more likely to give them some pride in maintaining it, once housing is sold there is no control over who occupies it in future, so sale of public housing should be minimised.  We should ensure that a good stock of affordable housing for rent is maintained.  See 4. 

 

Q14    Should affordable housing be sought on all sites or only the larger ones?  How much should be sought or should it vary according to the site?

            No more large sites should be accepted in the town, which is desperately short of green/open space for amenity/wildlife.  Given that all sites in Luton are going to be small, affordable housing  for local people should be encouraged on all sites, to discourage further migration to this overcrowded town.

 

Q15    Is there adequate housing provision for special needs groups such as older people and people with disabilities?

No. Progressively improve access where required.  Consult with Disability Resource Centre and other sources for best practice.  Current practice of closing rather than restoring is a false economy which will add to problems in the future.

 

Q16    Is there a need to provide another site for travellers/gypsies and if so, where?

Yes. Somewhere in South Beds.  Possibly in a temporarily vacant industrial area.  Should be at reasonable distance from residents, who could have their lives disrupted, and from sensitive nature conservation areas.

 

Q17    Where can new housing be allocated?

Luton must be considered full.  No more large housing sites should be accepted, including the Electrolux site.  Closure of Vauxhall may encourage migration from the town and reduce pressure on housing stock - on no account must the factory site be used for any housing development. This would be disastrous, bringing in more migrants, who would have to commute out  of town to work - the worst possible option in sustainability terms. 

 

In the town centre, offices above shops & offices can be replaced by dwellings.  Large and medium houses should not be demolished, but may be converted to flats to increase numbers of dwellings. 

There has been much bad practice in Luton, where demolition of non-listed but culturally important and structurally sound buildings with heritage value has been allowed.  This must change immediately.  Residents often moved where they were because they liked the view and surroundings: old buildings, trees, green spaces or wilderness areas provide valuable wildlife habitat and better quality of life: this should be respected.

 

Q18    If the housing needs to 2011 cannot be met on identified sites, what other areas should be considered for development?

Nothing within the Luton boundary.  If it is full, it is full.  Given the inadequate amount of open/green space, anything other than a small-scale incremental increase through reuse and conversion of existing buildings is not a sustainable option, and would lead to reduced quality of life.

 

Note that figures imposed by government are the result of demand - mostly from housebuilders lobby groups.  Trying to meet demand will in no way serve to meet real local needs.  Managing demand must be acknowledged by the planning system as a key principle of sustainability instead of assuming that land is an infinite resource, which on our small island is plainly nonsense.     

 

Q19    Should higher housing densities be sought and if so, under what circumstances?

            See 17.

 

Q20    Should the use of land for housing be given greater priority than employment?

No.  Important employment sites in high unemployment areas with dense housing have already had houses built on them against the Local Plan and all sustainability principles.  Employment, like shops and recreation, is needed near housing.  Providing a higher proportion of dwellings than employment creates new journeys, adding  to existing problems of overcrowded roads and inadequate public transport.

 

Q21    To what extent should non-residential uses be allowed in housing areas?

            Should be encouraged if no significant adverse effect on existing residents.

 

Q22    How much parking should be provided with new housing, and should it vary according to the level of accessibility by public transport?

As new housing should mainly be 'affordable', and where good public transport exists, a maximum standard of one car per dwelling, and less than one car per dwelling for affordable housing.  Introduce community car hire schemes.  This and Sustainable Travel Plans will eventually allow a restriction on individual car use to the level required to support key workers (eg bus drivers who have to get to the depot before services start) and disabled people.  Compare good practice eg BedZed (Zero emissions development) in Sutton. 

 

Q23    Are there enough facilities for sport, recreation and leisure?  If not, what is needed and where?

            Improve public transport to all existing leisure centres. A theatre, large concert venue and grass tennis courts are needed. Bath road pool should be replaced by a new pool on the derelict open-air pool at rear, and when open, extra leisure facilities could replace the existing site.

 

Q24    What are the needs for playing fields and other open space and how can they be met?

National Playing Fields Association shows a deficit in provision here, so open spaces in Luton should be increased where possible, and no school fields should be sold or built on except for extensions to school buildings.  School playing fields could be made more accessible to the community, and a greater variety of uses offered.  Action should be taken locally to reverse the national trend towards reduction of sport and leisure time in schools for reasons of health and fitness.   If Luton football club moves, the site should not be built on, but used to provide community open space.

 

Q25    What should be done about under-used open space and allotments?

More organic allotment holding should be encouraged and locally promoted, as should community based schemes and distribution or sale of local produce.  Disused and inappropriately sited allotments such as New Bedford Road (vulnerable to pollution from major roads) should be reallocated for wildlife or public walking space.  It should be ensured that allotments near the river are organic to prevent pesticides getting into the river.  We note that there is a planning presumption against building on allotments, which we strongly support.

 

Q26    What new cultural, religious or other facilities are needed?

Encourage greater use of church buildings for community uses.  Allow more land for extension of Stopsley cemetery.  (Butterfield Green development plans, which are against the wishes of residents, restrict cemetery expansion.)  Natural death facilities should be offered which would also reduce air pollution from cemetery (cardboard coffins, woodland burial ground, tree planting over graves etc.)  Cemetery and graveyards should be managed for wildlife (no pesticides; selective mowing only, coupled with tree and shrub planting). 

 

There should be no new religious schools, and the opportunity of the new ward boundaries should be used to introduce a quota to achieve a racial balance in all schools - these measures would encourage cultuural integration and understanding.  At the same time better public transport, walking and cycling arrangements could be planned for all schools to reduce car use and encourage independence and awareness of surroundings. See 28.

 

Q27    How can access to the countryside be improved?

Certainly not by cutting off thousands of north-east Luton residents from it by building an East Circular Road across protected sites such as Mixes Wood, Bradgers Hill and Warden Hill - it would act as Hadrian's wall but with noise and pollution !  This proposal and 'the North Luton bypass' would be too destructive, encourage thousands more car journeys, and should be removed from the Local Plan. 

 

Luton should join Parish Paths Partnership, and co-operate more with South Beds and Herts. More publicity and signage needed for walking and cycle routes to take you past the edge of town; also for all joining points on Sustrans river route now being developed.  Special public transport routes are needed to places of interest and special attractions in the countryside, eg Whipsnade.

 

Q28    How should the Local Plan reflect the changing role of schools and other educational facilities?

Also see 26. Use new local ward boundary changes to redesignate school catchment areas, and set quotas to achieve mixed race intake, eg min 30% white, or min 30% Asian/other.   Do not build on 'apparently surplus' land such as playing fields - these could be brought into community use, and parts should be used to create wildlife corridors. Old school buildings are often of architectural interest and heritage value, and should be conserved, eg Charles Street.  Introduce Safer Routes to all schools, incorporating Walking Bus for junior schools, encouraging cycling for ten plus, better public transport and school bus schemes. Concrete car parking areas in schools should be reduced.

 

Q29    What are the needs of the University and its students and how can they be met?

Students need to be at the heart of town life, and greenspace must be conserved.  Need for further buildings should be met by use or conversion of existing town centre buildings (eg Leicester).  Cycling / other active recreation should be strongly encouraged, and better cycle lock-ups provided, as Universities elsewhere. Car use by students living in Luton should be strongly discouraged.

 

Q30    Are there further land-use planning measures that the council can introduce to help reduce crime?

            Lighting to be improved where necessary.  Cycle lockups should be visible, in front of buildings.

 

Q31    What health facilities are needed and how can they be met?

Public transport to the hospital should be improved. (Translink would NOT help.)  More local surgeries and health centres may be needed in some areas.  A walk-in diagnostic centre is desperately needed to take pressure off the A&E dept at the hospital and give GPs immediate access to the best scientific diagnostic tools. This should be financed through HAZ and tied in with the walk-in centre already proposed.  Vigorous promotion of preventative medicine - healthy lifestyles, organic food and exercise would further reduce pressure on local health facilities.

 

Q32    What are the local employment needs and how can they be met?

There is a strong need for emphasis on local, worthwhile, sustainable and ethical jobs.  Attention should be paid to providing more employment in wards with highest unemployment. In wards where few opportunities exist, they need to be developed and encouraged.  Local employers should be encouraged to employ local people.  Beds CC publishes 'Made in Beds', a guide to local food and crafts. Luton BC should make this widely available and do its own research to  add to the guide.

 

Q33    Which, if any, key employment sites should be protected from changes to other uses?

All of them!  It is extraordinary that you even ask this question.  Electrolux, Dallow Road gasworks site etc should have been kept primarily for employment.

 

Q34    How much land is needed to meet anticipated employment needs and where should it be located?

            Attempts should be made to address a greater proportion of Luton's high unemployment locally, and allow for migration from the town rather than continuous growth.  Luton BC has considerably added to the problem by building housing on inner urban employment sites.  This puts pressure on Greenfield sites which the council has a responsibility to residents to resist, and encourages commuting out of the borough.  Existing employment land (wherever possible, conversion rather than demolition of existing buildings) and some 'brownfield' sites must form the major resource. 

 

Cycling and walking must be an integral part of any redevelopment., but good public transport links are vital, and not only within Luton, as a high proportion of the existing workforce live outside the conurbation.  East-west links are particularly poor, and the time factor in peak hours causes high car use, frustration, congestion and pollution.  Intercity inward car commuting should be discouraged: Translink would not help - trains or trams are needed.

 

Q35    Should surplus employment land be kept for new firms or should some sites be used to meet other needs such as housing?

            Government guidance states clearly that surplus employment land must be kept for future employment need, and green space at the edge of town should be kept green.  Parts of some sites could be used to create Pocket Parks to address the shortage of public green spaces.

 

Q36    How much additional shopping space is needed in the town centre and where should it be located?

            None is needed.  A change of emphasis away from national chains and toward small independent shops would give the town more character and interest to both residents and visitors.  Cafes and restaurants with outside tables are an attractive and popular feature in other towns such as Watford, and are badly needed in George Street.  The current application for a pub in the old ABC cinema, if accepted, should require outside tables where food and coffee would be served.  Vigorous support is needed to encourage small shops in Hightown.  See 10 for Plaiters Lea.

 

Q37    If there is a need, and it cannot be met in or adjacent to the town centre, should retail warehouses be allowed to locate elsewhere in the town?

There is no need for retail connected with station development at Power Court.  It is inappropriate there, and should be provided instead in Hightown to serve residents who could easily walk to it.  Further 'sheds', are probably not needed, but if allowed, should not be at the edge of town, but generally in the central area, and beside existing facilities to enable multi-trips,

 

Q38    Should all district and local shopping centres continue to be protected?

Yes - and particularly post offices, newsaagents, food/general stores, and cafes, all of which act as a focus and encourage use of neighbouring shops and facilities.  They provide a vital service to local communities, especially the elderly and disabled people, and those without cars.  They know their customers personally, which the supermarkets do not, and often offer home deliveries.  Every effort should be made to protect, support and develop them, possibly through low small business rates, and through provision of cashpoints, street furniture, planting and cycle stands.

 

Q39    Do local convenience shops need protecting?

            Yes - as 38.

 

Q40    Which areas of the town centre need to be improved, and if so, how?

            See 10, 36, 37 and 44. 

 

Q41    Should people be encouraged to live in the town centre if this is at the expense of other town centre uses?

            Generally there should be no conflict.  All existing ground level employment areas should be retained as such.

 

Q42    Is there a need for further night clubs/pubs/restaurants?  If so, where should they be located?

            No more night clubs or pubs. Existing pubs should be retained, together with their original names. Cafes and restaurants with outside seating should be located in George Street and Plaiters Lea (see 10 - new open area replacing NCP Silver Street car park) as soon as it is possible to do so. We note current application for a pub at ABC Cinema. This should only be allowed if food is served at outside tables (see Watford).  A canopy could be provided to protect against weather.

 

Q43    Should long stay town centre car parking be reduced?

It is difficult to determine whether the level is correct.  It should not be too expensive for those who cannot avoid using their cars, but should not be cheap enough to discourage those who could use public transport.

 

Q44    Does access to the town centre need improving, and if so, how should this be achieved?

By more frequent and reliable buses; and by trains or trams east-west to Dunstable and Leighton Buzzard, to give quick access both for local people (some of whom could access this line by revised bus services) and for the tens of thousands who have to travel to or from Milton Keynes and many other destinations on the West Coast Mainline, who currently have no practical alternative than to bring their cars and jam up local roads.  We are concerned that current plans for Luton Station  and Villa Link would aggravate congestion. Green Travel Plans must be promoted widely to reduce car use.  A revised traffic layout for Luton Town Centre may be beneficial, including Bute Street being pedestrian only and Guildford Street being one way for part of its length. 

 

The current situation at the bus station is completely unacceptable.  It is dark, threatening, there are no staff other than bus drivers, the refreshment facility and Tourist Office have gone, and lavatories were recently found to be closed after 8am.  Bus passengers deserve better, and these problems must be remedied immediately, not left as a blight on the town until the best solution, which is still unresolved, is found for the station area, which may involve moving the bus station.

 

Q45    Should mixed land uses be encouraged in certain areas and if so, where?

            Yes (see earlier comments).  But employment land should be retained as such.

 

Q46    Would it be appropriate to identify Transport Development Areas in Luton and if so, where?

            The whole area around the station and town centre.  The vital need for integrated transport would NOT be met by a busway and bus domination.   More bus routes should be diverted to meet trains at all stations. Buses need to serve Parkway.  People who walk and cycle should be given a much higher priority.  Station plans need to be reconsidered.

 

Q47    Does the Local Plan need to identify sites for freight facilities?

Yes - it says so in Local Transport Plan gguidance, emphasising the need to increase railfreight.      We would like to see at least limited use of Crescent Road for railfreight.  Several businesses along the Luton-Dunstable corridor would like to use railfreight on the disused line, which could be used to move Luton's waste.  Some of the larger cargos arriving by air should travel on by rail.  We have asked for many years for designated HGV routes in Luton to avoid residential areas and steep hills.

 

Q48    Can other sites be identified for park and ride, and how can congestion be further reduced?

A6 - Homebase or north of Turnpike Drive..  To make the service more efficient in peak hours, buses can use roads such as Culverhouse Road and Blenheim Crescent to reach the town centre. Butterfield Green should be a park and ride site whether or not any other development goes ahead.

 

To reduce congestion, a network of new cycle lanes and well-signed safe cycle routes on quiet roads must be put into place urgently. These are cheap to implement.  A vigorous programme is needed to engage workplaces in setting up green travel plans, and schools in setting up walking bus / safe walking and cycling routes.  Businesses should also be encouraged to allow employees to work from home one or two days a week where possible.  See 'Sustainable Moves' (a report based on three years' voluntary work by Luton's Agenda 21 Transport group) for other ideas.

 

Q49    What car parking standards should be applied to new developments?

            Maximum parking standards, not minimum.  Set an upper limit.  See 22.

 

Q50    Are there adequate facilities for cyclists and walkers?  If not, what is needed and where?

            Grossly inadequate - compare with other towns of similar size.  See 48 and 'Sustainable Moves'.

           

Q51    How can the Local Plan help to improve public transport in the town?

The preamble to this question is rubbish and shows a profound lack of understanding of the problems.  Real needs must be recognised.  The need to travel east-west throughout the region has been ignored for many years to everyone's detriment.  Bus services would be improved by interchange with train or tram to Dunstable, Leighton Buzzard, Milton Keynes and many other West Coast mainline destinations.  See 'Sustainable Moves' for many positive ways forward.

 

Q52    What controls need to be in place to ensure that expansion of Luton Airport is sustainable and addresses environmental concerns?

            Expansion of airports is against sustainability.  Expanding the activities of the airport brings a reduction in quality of life and health for Luton's residents.  Operations will continue to move away from sustainability as long as the growth in air movements is not matched by use of public transport.   The number of car journeys currently made to the airport should not be allowed to increase - it must be countered by a sharp increase in public transport use.  The only hope of achieving this is through blanket promotion of free bus and train journeys included in air fares, and providing a fast, reliable regional east-west rail or tram link from the West Coast Mainline.  At the same time, there must be vigorous promotion of Green Travel Plans giving incentives for take-up by airport employees.  Sustainability of flights and other airport activities must also be addressed.

 

Q53    What additional controls on telecom masts should be provided in the local plan?

Friends of the Earth believes that ICNIRP guidelines on safe limits are too high to safeguard health. They are lower in some countries, and there is ample evidence in Luton and elsewhere to show adverse health effects are demonstrated far below these limits.  Several local people are countering sleep deprivation by sleeping in metal cages.  Luton, in consultation with neighbouring authorities, should pay careful attention to the Government Response To The Tenth Report By The Trade And Industry Committee on Mobile Phone Masts, and PPG8.  To protect residents, it must do its own measurements of radiation levels, and close down masts that exceed permitted limits. 

 

Luton BC should consult widely, and object on principle to, all applications for new masts that are within 200m of dwellings or schools, and ask operators to provide evidence of  a need for additional coverage.  Where this can be demonstrated, masts should be resited to the nearest place at least 200m (preferably 300m) from dwellings.  Sensitivity to those in nearby workplaces should also be considered.  Guidance encourages planners to explore alternative approaches, including location. This is particularly important in an overdeveloped town like Luton.

 

Guidance states that mast sharing is not always the most suitable solution, and there is a limit on the number of antennas which can be installed on existing masts: authorities should consider the cumulative impact upon the environment of additional antennas sharing a mast.  Every effort should therefore be made to help residents affected by masts such as that at Wolston Close.  Environmental Health should note that the government has health worries about Tetra technology, which is among the features on the Wolston mast.

 

Guidance strongly encourages telecommunications operators and planners to have annual discussions about plans for each authority’s area.  Operators' general plans could be publicised, and the public would have then have more than the usual 3 weeks to consider and comment on proposals.  Publicity should be given by Environmental Health to reported health effects of mobiles phones on users, particularly children.

 

Q54    Is there a need for further recycling or other waste processing facilities, and if so, where should they be located?

Kerbside town-wide must include materials not already collected, eg cardboard, green waste, glass, textiles, tetrapack cartons and PS and PP.  Reduction of waste at source should be strongly encouraged among householders and business.  A Waste Minimisation Officer should be appointed, as in many other authorities.  The new Agenda 21 Officer soon to be in post could begin an A21 Waste Group to involve the community,

 

Waste should be moved by rail from Kingsway Depot.  None of Luton's waste should go to incinerators except a small proportion of hazardous and medical waste. There is plenty of government money to initiate a fast-track programme to -

·        bring kerbside from 90% up to 100%, including special arrangements for flats, old people etc

·        introduce green waste kerbside in 2002/3, process it nearby, eg the old Sundon tip, and sell it  as locally produced compost

·        add new separate kerbside collection of dry recyclables such as glass, cardboard and textiles

·        rebrand Tidy Tips as Recycling Centres with big, clear signage at the entrances and greater
variety of materials, inc household batteries, wood for reuse, not just sawdust or mulch.

·        begin new partnerships with business (including collection of glass from all pubs, restaurants and wine bars) and industrial estates, to reduce and recycle commercial waste and change the culture to treating it as a resource.  Pilot schemes should be devised for industrial estates, where recycling is chaotic and lack of any co-ordinated waste management or recycling generates absurd amounts of lorry journeys by different waste companies.
 

Q55    What are the future needs of the gas, water and electricity services and is there likely to be any surplus land available?

Water - see 11.  The gasometer in Dallow Road should become a listed building.  It could be turned from a rust-coloured eyesore into an attractive landmark overlooking the new housing by repainting in a pale sky colour with gradated tones, or even better, a cloud and sky mural, which could involve local people.  The LPG fuel points in the town should be increased, and these and the reduced prices for LPG vehicles need to be promoted. 

 

Q56    How can the Local Plan help meet renewable energy targets?

Refer to PPG22 and 'Planning for Sustainable Development - Towards Better Practice'  - Chapter 5 (DETR), as well as many non-government sources of information.

 

Q57    Are there other land use planning issues that should be considered?

            Probably!

 

 

 

 

David Oakley-Hill, Luton Friends of the Earth (in consultation with colleagues) March 2002

 

Tel 01582 724257  Email [email protected]

Website The WasteBook www.recycle.mcmail.com

Hosted by www.Geocities.ws

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