Luton Local Plan Issues
Report
Comments from Luton Friends of the Earth March 2002
___________________________________________
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