6C1
/ Luton FoE / R1503
Milton Keynes & S Midlands Sub Regional Strategy Examination
in Public
Comments from Luton Friends of the Earth Mar 04
6C1 Does Part B
statement and diagram provide adequate guidance at an appropriate level for preparation
of Local Delivery Documents by Bedford, Luton, South and Mid-Beds Councils?
No ! A few paragraphs and a diagram with coloured squiggles come nowhere near providing guidance which takes into account the necessarily wide set of issues and impacts associated with the project. Sustainable physical and social infrastructure (public transport, walking and cycle tracks, schools, hospitals, doctors, community facilities, emergency services etc) must be in place at the same time as housing. But the SRS does not begin to suggest how all this might be achieved. Such processes do not normally start from scratch - it evolves within existing communities.
The Luton Dunstable Houghton Regis Growth Area Study Final Report (!) which refers repeatedly to the useless Translink scheme, shows how environmentally damaging the proposals would be. It is notable that Figure LDHR2 (Growth options) are not combined with LDHR1 (Environmental designations) so the environmental damage from development cannot be easily assessed.
Designations are as follows -
Group 1 designations (of international and national
importance)
Ancient woodland, AONB, Ancient monuments, Historic parks
and gardens, fluvial floodplain, SSSIs, NNRs
Group 2 designations (relating to intrinsic quality of
the land, of strategic importance)
Strategic landscape, county wildlife, best and most
versatile agricultural land
Group 3 designations (relating to intrinsic quality of
the land, of local importance)
Local landscape, woodland, local nature conservation
Group 4 designations (primary purpose urban containment)
Green belt land; strategic gaps and areas of policy; restraint; local gaps and areas of policy; constraint
"Good
planning means the right communities with the right homes and jobs in the right
place…Not suburban sprawl. Not
dormitory towns. I am giving a
guarantee to maintain or increase greenbelt land in every region of
England" (Prescott, 5 Feb 03).
A key objective in the Sustainable Development Framework for the East of England is: "to minimise adverse environmental impacts, recognise and support environmental limits, and provide the highest level of protection for irreplaceable natural features (eg traditional species rich grassland, ancient woodlands, tranquil areas), aiming for no net environmental loss."
The LDHR Final report states (page 47) that in assessing sites for development potential, national and international planning/environmental designations relating to intrinsic quality of the land should be avoided altogether. However, remarkably, the evaluation (page 49, Table 5.1) seems to take no account of these important designations.
Site 1 (Northern edge of H Regis / Dunstable) The sewage works mentioned (Blue Waters) is the key to sewage treatment for the development of all dwellings on sites 1, 2 and 3, and would have to be considerably extended to deal with the outpourings from 43,000 houses that the documents try to assure us are needed. It is also a highly important international site for birds and other wildlife. Houghton Quarry is a SSSI, an important chalk wildlife site with lakes. The juxtaposition of the two gives them greater importance for biodiversity. Their status could be seriously degraded, and contravene an EU directive, if the development proceeded. Site 1 would also build on high quality agricultural land, suitable for local food production (at a distance from the M1).
Site 2 (Northern edge of H Regis / Dunstable) A combination of Group 1 and 2, the highest two designations - supposedly the most protected land. It would be assumed by most observers that this land would be completely safe from development.
Site 3 (Northern
edge of Luton) A combination
of Group 1 and 2, the highest 2 designations, very important for its mosaic of
habitats: the Countryside Agency objected to the north Luton bypass on these
grounds in the Structure Plan. It
includes the area around Sundon Springs, a remarkable chalk quarry lake site.
Sites 4,5,6 (East of Luton - Herts) pockets of Group 1 and Group 3 (woodland and nature conservation)
Roads and a massive housing programme would severely degrade
and reduce the species dependent on all these important sites.
To assess and oversee the major tasks involved in this ambitious programme is fraught with risk. It is far too great an undertaking for an LDV to plan, consult on inclusively, and manage over a short time period - probably far shorter than the life of the project. The whole process is a minefield. Who is to manage the managers? How will they be constituted? Will there be elections? Will those with a remit for democracy and accountability be in a majority? Will there be someone there with biodiversity knowledge specifically to protect the many important wildlife sites? How will democracy and accountability be ensured that does not undermine local authority, planning and normal democratic processes? How will the LDV relate to the community, to local authority executives? This is made harder, and success less likely, if not impossible, by the likelihood that the majority of citizens, who do not wish to see any degradation in their heritage, surroundings, mobility, and quality of life, consider the plan undesirable.
If the national housing strategy reappraisal and sequential approach suggested in FoE's response to 6B, and principles of sustainability listed below, are adopted in full, there may be a little less controversy. A way of working must be devised which recognises that "economic prosperity" is not achievable if environment and quality of life are ignored.
To achieve sustainability principles embraces accountability, and implies a lower and more paced level of growth based on the sequential approach. This is only likely to occur if the local delivery vehicle is populated by a more democratic and representative body of people than is suggested at present, which also represents the area in terms of women and ethnic groups. It would be helpful if it included two or three community representatives, someone representing tenants, an expert on biodiversity to protect designated sites, and someone capable of overseeing and reporting on general environmental issues, perhaps from the Environment Agency or Friends of the Earth.
No exit strategy is suggested. Suppose after, say five years, the LDV wishes to pass back the management - and any liabilities - to one or more local authorities, who may not want the responsibility and any liabilities that go with it? Perhaps the best guarantee of success would be if any liabilities were to remain personally with those on the LDV.
ODPM update, issue 30, Sep 02, stated that "the government is determined to drive improvements in the quality of new development to reflect our determination to have more sustainable forms of construction and more liveable communities". But the means is simply not fleshed out in the SRS. Where is the strategy for sustainable design, materials, construction, energy efficiency? The plan proposes to build houses on about 45 square miles of countryside. But how much more would be consumed by roads, workplaces, shops, car parks? What would be the final amount lost? This assessment must be carried out before anything begins, together with a Strategic Environmental Assessment.
Government policy on sustainability is being ignored as the few with vested interests jostle for power to drive forward the strategy before safeguards can be introduced. This is a recipe for disaster, and will bring urban sprawl, poor public transport access, lack of social infrastructure, increased deprivation and poor health. It is a worrying demonstration of how lessons of the past have not been learned: ways of moving forward democratically and inclusively must be devised. There are already signs that those likely to be on the UDC to progress these plans will not be a mix of people with the right skills and socially inclusive attitudes to manage such an important long-term venture.
It was a worrying experience to attend two recent 'economic visioning' workshops in South Beds and Luton, populated by leading players in development, very few of whom live in the area to be manipulated. It was supposed to look at 'key issues', yet sustainability principles and environmental issues were scarcely mentioned. No one had the holistic vision of growth outlined in A Sustainable Development Framework for the East of England (East of England Regional Assembly, Oct 2001).
A toytown vision was evident, compounded by the task of choosing the best of five scenarios for the year 2016. These were fiction, both frightening and humorous, but taken remarkably seriously. Many players seemed to have little concept of essentials to deliverability such as environmental capacity, water and sewage, utilities and energy generation, social infrastructure, or the effects on quality of life for existing or new communities. The focus was on numbers of houses, jobs and how soon roads could be built. Sadly, this to some extent reflects the SRS, but is not the way to plan the future, and these are not people to whom Luton and Dunstable's future should be entrusted. It raises serious concerns about influences on the proposed UDC, its powers, which may override local plans, and its accountability to the community.
This concurs with the response from the Regional Assemblies, but conflicts with GoEast advice that the strategy should address the environmental and cultural assets, biodiversity, and opportunities for environmental enhancement in more detail (matter 2D). This advice is fundamental to democracy, but Regional Assemblies do not seem interested in complying, stating "detailed local guidance on the environment is not appropriate in a sub-regional strategy", and "strategic policy on the environment is in national guidance and RPGs and does not need to be repeated". The Strategy simply does not balance, as the Assemblies claim, economic, social, environment and resources - the economy, which should serve human progress, is treated as God, subordinating all other considerations. The plan would be very destructive of the environment, and growth, even on a far smaller scale than suggested, simply cannot proceed without the importance of environmental issues at its heart.
The phrase 'sustainability' comes from the Rio Earth Summit.
Sustainability means making sure life is not worse for your children. A Sustainable Development Framework for the East of England (East of England Regional Assembly, Oct 2001) states that the document should be used as a central reference point for ensuring that regional and local strategies are consistent with the principles of sustainable development. A strategy must therefore be developed with sustainability principles at its core. You cannot take a countryside and farming landscape with a complex ecosystem, that has never been built upon and brings peace to those who live nearby, 'regenerate' it into a vast complex of housing and roads, and call this sustainable.
To provide an inclusive framework for the future of the
area, these should take into account
Sustainability Criteria. The following is a good model.
It should be the
principle objective of the study to ensure sustainable patterns of development
which improve the quality of life of all people whilst respecting environmental
limits and the ability of future generations to enjoy a similar quality of
life. In order to uphold this objective
all land use decisions must enshrine the principles of:
·
social justice: - putting people at the
heart of decision making, reducing social inequality and upholding
environmental justice in the outcomes of decisions
·
inter-generational equity: -
ensuring current development does not prevent future generations from meeting
their own needs;
·
environmental limits: - ensuring that
resources are not irrevocably exhausted or the environment irreversibly
damaged. This means, for example, supporting Climate Protection, protecting and
enhancing biodiversity, reducing harmful emissions, and promoting the
sustainable use of natural resources;
·
resource conservation: - ensuring that
planning decisions assist in the prudent and sustainable use of finite natural
resources;
·
the precautionary approach: -
where there are threats of serious or irreversible damage, scientific certainty
should not be used as a reason for postponing measures to prevent environmental
degradation;
·
the polluter pays: - ensuring that that those
who produce damaging pollution meet the full environmental, social and economic
costs;
·
the proximity principle: - seeking to resolve
problems in the present and locally, rather than passing them on to other
communities or future generations.
These
objectives must be secured through democratic, transparent and fair processes.
The duty to promote sustainable development should be expressed through all
policy and through all tiers of the planning process ((source: Friends of the
Earth, based upon 1999 UK
Sustainability Strategy/ Welsh Spatial Strategy).
We
should consider whether the plan's recommendations adhere to these criteria.
A rolling agenda might include (key factors omitted from Part B statement) :
delivery of housing, roads must be conditional on -
6C2 Does sub-regional strategy provide sufficient
advice on apportionment of housing provision among local planning areas?
No, because the plan is a blunt, insensitive instrument. Locally, South Beds gets it! Yet South Beds was planning for only 6000-8000 new homes in the plan period. Naturally, there is cross-party opposition throughout South Bedfordshire to the likely impacts of 43,000 by 2030. This concern is more justifiable than the rationale for the plan.
By focusing too intently on housing, roads and jobs, the plan fails to take into account wider factors -
1) national strategy not properly developed, increasing inequality in the north
2) potential to create new pockets of inequality, bringing social dangers and poor quality of life, by focusing large pockets of dense, affordable housing in certain areas, particularly if close to existing pockets of deprivation, eg Marsh Farm, Houghton Regis
3) too much emphasis on building new housing at the expense of physical and social infrastructure, environmental capacity including biodiversity, water and sewage
4) the need to protect the quality of life of existing communities, both in villages and on or near the borders of existing communities, currently protected by substantial areas of Green Belt which are set to be abandoned - a very unpopular measure which will greatly upset more people than it benefits
5) too ready and unfounded a jump from local and London housing need to the 'answer' as building vast numbers of new houses, with far too little attention to sustainability principles as set out in the sequential approach
This insensitivity is reflected in the BLEDP Economic vision
scenarios, listed under jocular headings which take little account of the need
to respect and protect quality of life for all sectors of society. These scenarios jump straight to new
Housebuilding, completely ignoring the concerns listed above, including the
sequential approach. These have been
top down, supported by workshops populated by about 60-70 people, 90% of whom do
not live in the Luton Dunstable H Regis conurbation!
Prescott said "The fundamental aim of the ODPM is to achieve thriving, inclusive and sustainable communities in all regions. Our task is to improve the day-to-day life and environment of all our people." (ODPM update issue 30, Sep 2002)
It is very sad then that in the MKSM, provision to protect
the quality of life of those living near the Luton and Dunstable borders, or to
keep the distinctiveness and separation of scores of villages, is entirely
absent.
Also see Luton FoE response to Matter 1C.