Sustainability Statement 060705 - Luton · Kimpton Road, Luton, Sustainability Statement This...

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Kimpton Road, Luton, Sustainability Statement Sustainability Statement KIMPTON ROAD, LUTON Client: SOUTHSIDE & CITY DEVELOPMENTS LTD July 2005

Transcript of Sustainability Statement 060705 - Luton · Kimpton Road, Luton, Sustainability Statement This...

Kimpton Road, Luton, Sustainability Statement

Sustainability Statement KIMPTON ROAD, LUTON

Client:

SOUTHSIDE & CITY DEVELOPMENTS LTD

July 2005

Kimpton Road, Luton, Sustainability Statement

This report has been prepared by Waterman Environmental, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating of our General Terms and Condition of Business and taking account of the resources devoted to us by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at its own risk.

© Waterman Environmental 2005

Author:

Name Kate Bellew BSc (Hons) MSc

Reference:

Status:

Date:

R/EN4871/R/1.4.1/JF

FOURTH ISSUE

July 2005 Signature

Position Graduate Consultant & Registered BREEAM Offices Assessor

Issued by:

Waterman Environmental Kirkaldy House 99 Southwark Street London SE1 0JF

Approved by: Telephone: 020 7928 7888

Name Jacqui Fincham BSc (Hons) Postgraduate Diploma in Sustainable Development

Fax: 020 7902 0981

Signature

Position Associate Director

[email protected]

www.waterman-group.co.uk

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Contents Page

CONTENTS

1.0 Introduction 2.0 The Site and Surroundings 3.0 Background to the Development 4.0 The Proposed Development 5.0 Sustainable Development 6.0 Policy Objectives 6.1 National Policy Objectives 6.2 Regional Policy Objectives

6.3 Local Policy Objectives 7.0 Approach to Sustainability at Kimpton Road, Luton 7.1 Sustainability Workshop

7.2 Building Design 7.3 Sustainability Energy Options

7.4 Rainwater Harvesting and Recycled Water 8.0 Sustainability Statement

8.1 Energy 8.2 Water 8.3 Waste and Pollution 8.4 Transport 8.5 Community and Social Needs 8.6 Natural Environment 8.7 Built Environment 8.8 Economic Prosperity 8.9 Land Use

9.0 Summary

10.0 References

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1.0 Introduction and Sustainability Vision for Kimpton Road, Luton

Southside & City Developments Ltd is seeking to obtain outline planning permission for the redevelopment of the Kimpton Road site in Luton. During the development of the masterplan Waterman Environmental facilitated a Sustainability Workshop to provide initial advice on sustainability issues to the design team in light of relevant national, regional and local policy requirements.

This Sustainability Statement, submitted in support of the outline planning application and accompanying Environmental Statement, describes the approach that the team has taken to sustainability during the design process and considers the extent to which the development proposals accord with the principles of sustainable development. It has been prepared by Waterman Environmental following a review of national policy and local objectives including those outlined in the ‘Designing for Sustainability’ Supplementary Planning Guidance (SPG) published by Luton Borough Council (LBC). The Statement represents the outcome of a series of design meetings with the development team comprising:

• David Lock Associates (town planners, architects and urban designers);

• Wardell Armstrong (contamination consultants);

• BWB Consulting Ltd (transport engineers);

• the Applicant (Southside & City Developments Ltd);

• Aukett Fitzroy Robinson (Architect)

• Waterman Gore (mechanical and electrical engineers);

• Waterman Partnership (structural engineers); and

• Waterman Environmental (environmental consultants).

Opportunities for incorporating sustainable features into the development were explored as a fundamental part of the masterplan design process, to ensure that where possible, the proposals achieve the latest standards in sustainable design. Consideration of the principles of sustainable development has therefore formed an integral part of the design evolution and the resulting scheme reflects this.

Southside & City Developments Ltd are committed to ensuring that the Kimpton Road redevelopment is a sustainable development. The three cornerstones of sustainability; economic, environmental and social responsibility, are equally supported and addressed by Southside & City Developments through their commitment to the protection and enhancement of the environment and their promotion of ‘zero tolerance’ of unsafe practices; they encourage a culture that allows people to

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make the best decisions, and to initiate and implement safety on the job. Southside & City Developments are an equal-opportunity employer and aims to bring itself to the forefront of the development business by not only encouraging its own people to develop and learn, but also to create strong partnerships with local companies and people. They only believe in partnering with companies who share these sustainable principles, values and standards.

Southside & City Developments Ltd have a highly experienced management team that are committed to delivering truly sustainable developments that are innovative in design and compliment the existing urban environment, as evidenced by their strategic planning, extensive research and consultation process. Southside & City Developments propose the exciting regeneration of the Kimpton Road site in Luton into a 22.72ha mixed-use development comprising commercial and leisure premises, housing, retail and entertainment premises. By working closely with the design team and LBC, social, environmental and economic issues have been carefully considered within the proposed masterplan. To this end a Sustainability Appraisal was undertaken at an early stage in the design process to provide advice and guidance for the future design of the site.

Southside & City Developments sees the success of the Kimpton Road redevelopment as being embedded within achieving a scheme design that meets the principles of sustainability as well as being the best possible scheme for its location, considering the constraints of the site and the social, economic and environmental needs of the local area, region and nation.

By working proactively with the community, a regeneration scheme that addresses their needs can be achieved sustainably. Southside & City Developments Ltd aims to counter social and economic exclusion through, for example, the incorporation of a mix of housing types, including both affordable and private dwellings; these issues were taken into consideration in the planning of the Kimpton Road redevelopment. Southside & City Developments Ltd ultimately wishes to see the community share in the project’s success and aims to bring a feeling of community to the area.

It is the aim of Southside & City Developments to develop strong partnerships locally, with the community, LBC, contractors, consultants, specialists and others, to ensure the creation of a vibrant and highly desirable urban development that people will want to live, work and relax in. Through good relationships, they seek to create a development that everyone can be proud of.

Communities are dependent on the provision of viable employment opportunities. With the regeneration of the Kimpton Road redevelopment, employment opportunities will be created for the benefit of the local community and will be aided through the commitment to employing local labour, where possible.

The regeneration of the site by Southside & City Developments Ltd will not only provide local employment but also establish a development that is attractive in its local as well as regional setting, encouraging prosperity to Luton and the region. The development will attract a variety of employment opportunities, markets and activities locally, regionally and nationally, that will enhance and enrich Luton and the site’s locality.

Southside & City Developments Ltd envisions a successful, sustainable development that will enliven Luton. Details of the various issues considered and the sustainable measures that are proposed to be included within the scheme at this early framework planning phase are described further in Section 8.

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2.0 The Site and Surroundings

The proposed Kimpton Road development is situated on the site of a former General Motors car manufacturing plant. It is located on the southeastern outskirts of Luton and to the north-west of Luton International Airport. The buildings of the current General Motor van manufacturing facility and the A505 are located to the east of the site, and Kimpton Road is located to the south. The site is currently unoccupied and comprises large production buildings, office buildings and large areas of surface car parking. Two development options have being considered as part of the development of the masterplan, Option 1 provides a large bulky goods retail floorspace with a casino illustrated in Figure 1, and in Option 2 the casino is excluded and a larger component of bulky goods retail floorspace is provided, illustrated in Figure 2. For details, refer to the Land Use Budgets within the planning application.

Figure 1: Development Framework Plan Option 1 Figure 2: Development Framework Plan Option 2

3.0 Background to the Development

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The site was initially developed in the 1905, to provide the original manufacturing plant for General Motors (GM). Progressive development of the site took place between 1938 and 1960, to largely reflect its present day form. The car assembly plant was closed in 2000 as part of a restructuring strategy, although the GM van production lines remain in operation and are located immediately to the east and south of the site.

The closure of the car assembly plant resulted in the release of a large amount of land with considerable development potential. The site is 22.72 hectares and provides the opportunity to enhance the local environment and promote regeneration, whilst making a significant contribution to wider economic and growth objectives for Luton. As a consequence of the plant closure, a significant number of jobs were lost with wider implications on employment in the manufacturing sector within Luton as a whole. The applicant has therefore appointed the design team to implement the redevelopment of the site to produce a practical design solution that optimises the potential environmental, social and economic benefits of the site. The key objectives of the design process have been to:

• Create a highly sustainable scheme; • Create new employment uses; • Improve pedestrian and road access to the site and provide improved public transport links, where possible; • Respect existing views from Luton Hoo and Capability Green; • Provide new housing and community facilities; • Create a vibrant new environment; and • Improve the local townscape and amenity.

The team were also instructed to consider various design constraints, namely, the challenging topography of the site, which is visible from the boundaries of Luton Hoo and Capability Green, both are designated as Areas of Great Landscape Value (AGLV). In particular, careful consideration to the reprofiling of the site and building heights is required for the preservation of existing views across the site. The steep contours have an important influence on the design and nature of roads and drainage systems. As a result of the site’s historic industrial usage and existing residual contamination, an appropriate remediation strategy will be developed to ensure that the site is suitable for its desired uses. A full EIA has been undertaken to ensure all potential impacts are appropriately mitigated through the design. The resulting Environmental Statement is also be submitted in support of the outline planning application.

4.0 The Proposed Development The proposed scheme will comprise of the following: Creation of a mixed use development to include:

• up to 1,000 mixed tenure residential units (C3); • up to 45,000m2 office accommodation (B1); • up to 12,500m2 general industrial accommodation (B1/B2); • up to 10,500m2 conferencing facility (C1); • 200 bed hotel and fitness centre; • multi-deck car park to provide 5,000 off-airport related car parking spaces;

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• the provision of associated infrastructure and services including car parking, roads and drainage; • landscaping; • 4,000m2 of local services and neighbourhood retail (A1/A2/A3/A4/A5/D1); • formation of 2 new vehicular accesses to Kimpton Road; • enabling works to include demolition of existing buildings, ground remediation and remodelling;

Together with:

up to 7,432m2 of bulky goods retail floorspace (A1); up to 10,500m2 of casino (D2); and, up to 4,000m2 of conferencing facility

Or

up to 9,290m2 of bulky goods retail floorspace (A1)

In response to the design objectives and mindful of the constraints imposed by the nature of the site, it is proposed that the site at Kimpton Road, Luton undergoes major redevelopment. The key elements of the redevelopment can be summarised as follows:

• Demolition of the existing buildings on site; • Minimal reprofiling of the site; • Reuse of existing ground floor slabs and foundations where possible. • Redevelopment of the site to provide a mixed-use development comprising new business, retail, conferencing facilities and residential uses; • Improved access and a new road layout; • Provision of safe and direct pedestrian routes within the site; • Improvements to existing green spaces around the site; and • Be sensitive to potential visual impacts from boundaries of Luton Hoo.

5.0 Sustainable Development

In May 1999, the Government published a sustainable development strategy entitled 'A Better Quality of Life - A Strategy for Sustainable Development in the UK' (Ref. 2). This sets out the key issues, aims and priorities for sustainable development in the UK. Many definitions of sustainable development exist, although the common objective for all is the integration of economic, social and environmental issues to ensure a better quality of life for people today, without compromising the needs of future generations. In applying the principles of sustainable development to the UK, the Government identifies four aims that should be met concurrently:

• Social progress which recognises the needs of everyone; • Effective protection of the environment;

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• Prudent use of natural resources; and • Maintenance of high and stable levels of economic growth and employment.

In July 2002, the Government also published a paper entitled 'Sustainable Communities - Delivering Through Planning' (Ref. 3) which sets out proposals for maximising the planning system's contribution to the delivery of the Government's sustainable development aims and objectives.

In March 2005, the Government published a new strategy for sustainable development entitled ‘Securing the Future’ (Ref.4) which updates the previous strategy to take account of new policies produced in the UK since 1999. The Strategy demonstrates a new determination to make sustainable development a real priority and highlights the renewed international push for sustainable development. The new Strategy was developed following the World Summit on Sustainable Development held in Johannesburg in 2002 and presents five basic principles that form a new basis for sustainable development policy in the UK. These principles are:

- Living within environmental limits; - Ensuring a strong, healthy and just society; - Achieving a sustainable economy; - Promoting good governance; and - Using sound science responsibly.

In addition, the new Strategy sets out 250 commitments within four main priority actions areas for the UK. The priority action areas are: - Sustainable Consumption and Production - Climate Change and Energy - Natural Resource Protection - Sustainable Communities

The Strategy also proposes a new code for sustainable buildings that will establish new voluntary standards on key issues such as energy, waste, water and materials.

6.0 Policy Objectives

6.1 National Policy Objectives

6.1.1 Planning Policy Statement (PPS) 1: Delivering Sustainable Communities

PPS1 was published in February 2005 (Ref. 5) and sets out the key policies and principles, which should underpin the UK planning system. It puts sustainability and community involvement at the heart of the planning process. PPS1 emphasises the importance of building well-designed homes, offices, factories and leisure facilities that will benefit the local community and be successful in the long term. Effective community involvement is crucial and requires processes for informing

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people about policies and proposals in adequate time; enabling communities to express their own ideas and participate in developing proposals and options; consultation on formal proposals; and feedback.

6.1.2 Draft Planning Policy Statement (PPS) 10: Planning for Sustainable Waste Management

Draft PPS10 (Ref.6) was published for consultation in December 2004 and will replace PPG10 in due course. It emphasises the need to drive the management of waste up the ‘waste hierarchy’ of reduction, reuse, recycling, composting and energy recovery. Draft PPS10 promotes the concept of waste as a potential resource with the disposal of waste as the last option. Waste management should be given significant weight in planning applications with the aim to, ‘ensure the layout and design of new development supports sustainable waste management’.

6.1.3 Planning Policy Statement (PPS) 22: Renewable Energy

PPS22 (Ref. 7) published in August 2004 sets out the national Government policy on renewable energy and emphasises its role in achieving sustainable development. It states that all new development should consider opportunities for incorporating renewable energy systems with regard to technologies such as biomass heating, wind turbines, Photo Voltaic cells and Combined Heat and Power (CHP) systems.

6.1.4 Creating Sustainable Communities in the East of England, 2004

This document provides a brief summary of the ongoing work to regenerate communities in the East of England (Ref.8). This report accompanies Making it Happen: The Northern Way (Ref.9) which reports on the progress made in urban and rural areas on implementation of the Government’s £22 billion Sustainable Communities Plan published in 2003.

This report describes the East of England (a newly defined region which includes East Anglia and the South East) as being a region that is relatively prosperous with some districts being the most prosperous in England and others being amongst the 300 most deprived in England. As it is a dry region, there are pressures on the valuable and diverse water environment from continued economic growth and new housing development. The primary area for regeneration and growth in the region is a significant part of South Essex that falls within the Thames Gateway.

The report identifies two key issues being faced by the region these are:

• To meet the needs of growing communities, ensuring growth is managed sustainably.

This should be achieved through addressing problems of rapidly rising house prices, maintaining high levels of recruitment and staff retention, improving transport infrastructure, and reconciling the tensions between growth and environmental and natural resource management.

• To ensure that the benefits of growth are spread across the region.

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By tackling the problems of communities facing multiple disadvantage, improving access to jobs and services for disadvantaged communities and addressing the local authority owned housing stock that is below the Decent Homes Standard across the region.

The report identifies the need for the region to work together to deliver the ‘step-change’ in growth set out in the Sustainable Communities Plan by meeting adopted targets.

6.2 Regional Policy Objectives

6.2.1 Regional Planning Guidance for the East of England

The Regional Spatial Strategy (RSS) for the East of England is currently published as three separate documents:

• Regional Planning Guidance for East Anglia (RPG6) covering the counties of Cambridgeshire (including Peterborough), Norfolk and Suffolk, published in November 2000;

• Regional Planning Guidance for the South East (RPG9) covering Bedfordshire (including Luton), Essex (including Southend-on-Sea and Thurrock) and Hertfordshire, published in March 2001; and

• Milton Keynes / South Midlands (MKSM) Sub Regional Strategy which spans three regions, the East of England, the South East and the East Midlands. In the East of England it sets out a spatial strategy for the growth locations of Bedford/Kempston/Marston Vale, Luton/Dunstable/Hougton Regis and Leighton Linslade.

The site is located in close proximity to Luton and therefore at the regional level, the proposal should be compliant with the requirements set out in RPG 9 for the South East published in March 2001 (Ref. 10). RPG 9 will be replaced by a South East Plan once it has received Government approval. This document will set out a vision for the region through from 2006 - 2026. The primary purpose of RPG9 is to provide a regional framework for the preparation of local authority development plans and the Mayor’s London Plan. It has a vision of encouraging economic success throughout the region, ensuring a higher quality of environment with management of natural resources, opportunity and equity for the region’s population and a more sustainable pattern of development.

6.2.2 Draft East of England Plan: Draft revision to the Regional Spatial Strategy (RSS) for the East of England, December 2004

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The RSS (Ref. 11) seeks to control planning and development in the East of England region to the year 2021. The 14-week consultation period for the Draft Plan ran from the 8th December 2004 to 16th March 2005, and the RSS will now undergo a review process. The final RSS will be published in late 2006. The RSS covers economic development, housing, the environment, transport, waste management, culture, sport and recreation, mineral extraction and implementation.

The vision for the East of England, as stated within the draft Plan is, ‘to sustain and improve the quality of life for all people who live in, work in, or visit the region, by developing a more sustainable, prosperous and outward-looking region, while respecting its diversity and enhancing its assets.’

The Plan sets 13 clear and specific objectives for meeting the vision against which the performance of the regional strategy will be measured.

In general, the Plan aims to improve the quality of life of those living in the region, and sets out proposals which will influence where people choose to work and live and how they move about the region. It also seeks to address issues such as social exclusion, the need for regeneration and the impact of climate change. The RSS is seen to have a key role in contributing to the sustainable development of the region.

6.2.3 A sustainable Development Framework for the East of England, October 2001

This report (Ref. 12) was prepared by a joint working group of the East of England Regional Assembly (EERA) and the Regional Sustainable Development Round Table (SDRT) and provides an overarching guidance for encouraging adoption of sustainable development principles in all Regional Strategies and Action Plans. This framework sets out a vision for sustainable development in the region, and identifies the region's contribution to sustainable development at the national level. The document defines the strategic aim for the region as being, ‘To improve quality of life for the people of the East of England.’ To achieve this aim nine high-level objectives for the region have been selected based on an analysis of key issues identified by stakeholders during the consultation on the development of the Framework, the objectives present a 'bottom up' rather than a 'top down' view of priorities.

6.2.4 The East of England Regional Assembly (EERA) and the East of England Sustainable Development Round Table (EESDRT), Sustainable Development Toolkit

The broad aim of East of England toolkit (Ref. 13) is to highlight the economic, environmental and social impacts of policies, development proposals and other new initiatives within the region and provide information which can help to improve them. It therefore provides decision support rather than prescriptive solutions and any responsibility for actions taken as a result of using it lies with its users.

The toolkit incorporates objectives set out in the Sustainable Development Framework for the East of England (SDF) and can be used to help identify key issues that need to be addressed by the development.

6.3 Local Policy Objectives

6.3.1 Bedfordshire and Luton Structure Plan 2016 (deposit draft to be adopted in June 2005)

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The deposit draft Structure Plan (Ref. 14) sets out strategic land use and transport policies up to 2016, and forms the framework for local plan policies. Driven by national policy and guidance, the adopted Structure Plan 2011 (adopted 1997) gained national recognition for its innovative and groundbreaking focus on sustainability. In the deposit draft 2016 Structure Plan, sustainable development remains firmly established as a key issue in the planning agenda. This is reflected in a number of different policy areas.

Policies relating to the conservation and enhancement of resources aim to encourage the protection of all natural resources including biodiversity, land, air and soil resources, landscape character and that pollution is minimized (Strategy 1). New developments are encouraged to use previously developed land, incorporate sustainable waste management, energy efficiency and the provision of renewable energy schemes. The design and layout of new developments should also provide safe and easy access for all.

The Structure Plan 2016 seeks to ensure that the scale, type and location of new development are appropriate to provide access to a range of local services and reduce car dependency through maximizing the potential for public transport provision, cycling and walking. Good urban design principles including sustainable construction materials, promoting pedestrian priority and enhancing local distinctiveness is also encouraged (Strategy 2).

6.3.2 Luton Local Plan (Second Deposit Draft)

The Second Deposit Local Plan (Ref. 15) provides more specific policy guidance in relation to the Kimpton Road proposals. The overall aim of the Second Deposit Local Plan is to achieve sustainability in Luton and is implemented through three key policy areas.

Social policies; H4 Residential Density, H6 Affordable Housing, LC2 – Provision of Green space, LC4 – New and Extended Community Facilities, aim to ensure the provision of appropriate housing, amenity space and local facilities to meet the needs of the local community.

Economic policies; EM1-Employment Sites, S1 – Retail Strategy encourage the creation of new employment opportunities to compliment existing employment uses.

In line with the Structure Plan’s strategy for the conservation and enhancement of natural resources, relevant environmental policies include; ENV5 Protection and enhancement of nature conservation, ENV6- Archaeology, ENV9 – Design Principles, ENV10 – Landscaping, ENV 14 – Water Environment, ENV15 – Pollution and ENV16 – Contaminated Land.

6.3.3 Luton Local Plan 2001-2011 – Report of Inquiry, 2004

The inspectors report seeks to change the policy stating that the Vauxhall car-manufacturing plant site should be a Key Employment Site as the site is large and would not be easily redeveloped exclusively for industrial and business uses. As such the inspectors report seeks to see a change in this policy that would look to grant planning permission for the comprehensive mixed-use redevelopment and/or re-use of the former Vauxhall car plant. This is in line with the principles of PPS1 which identifies the importance of mixed-use development and its overall objectives for sustainable development. The inspectors report seeks to ensure any redevelopment of the Vauxhall site will:

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- Maximize both the quantity and quality of job opportunities; - Maximize the opportunity presented by this major previously-developed site; - Ensure that any proposed development does not have an adverse effect upon the operation or amenity of neighbouring uses; - To enhance the overall appearance of the site to the maximum possible effect; - Seek to ensure development within a reasonable period of time; and - Ensure that any development does not have any adverse effect upon the vitality or viability of the town centre.

These principles of development for the site are in line with sustainable development principles.

6.3.4 Designing for Sustainability: A Summary of Good Practice, Supplementary Planning Guidance.

The ‘Designing for Sustainability’ Supplementary Planning Guidance (SPG) (Ref. 16) was adopted by LBC in January 2003. This SPG sets out the requirements for good sustainable design and energy conservation principles based on Government advice and good practice. In particular, the SPG focuses on two of the key aims of sustainable development; effective protection of the environment and the prudent use of natural resources. The guidance highlights a number of sustainable development considerations which should be addressed by developers through the following principles;

• Location;

• Mix of Development;

• Site Layout;

• Building Design; and

• Energy Consumption and Biodiversity.

7.0 Approach to Sustainability for the proposed development

The Sustainability Appraisal (SA) was undertaken in three main stages. Stage 1 involved a desktop document review process that focused on gaining an understanding of the guiding policy on sustainability in the location of the site. To achieve this, a regional and local level policy document review was undertaken.

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This has been briefly summarised in the above section. During this stage, the SA assessment framework was developed. This framework drew on the broad UK Government aims applying the four elements of sustainability;

• Economic;

• Environmental;

• Social; and

• Natural resources.

The headline issues to be assessed covered the five main areas addressed within the Supplementary Planning Guidance (SPG) namely; location, mix of development, site layout, building design and energy consumption and biodiversity. These were then supported and enhanced by adding further indicators set out in the EEDA Sustainability Checklist. This bespoke checklist (Ref.16) was then used as the framework for the Sustainability Appraisal Workshop undertaken in Stage 2. The Workshop was held following a design team meeting; therefore, all members of the team were present. Stage 3 involved the appraisal and report production.

7.1 Sustainability Workshop

A workshop session with the design team co-ordinated and facilitated by a Sustainability Consultant provides the ideal environment in which to complete the Sustainability Checklist. The workshop offers an informal forum in which the issues of sustainability can be discussed. The objectives of this workshop are two-fold. Firstly, to explore potential design options which will deliver a scheme that contributes to sustainable development within the constraints imposed by the site and the requirements stipulated by Luton Borough Council. Secondly, to demonstrate to the Council how the principles of sustainable development have formed an integral part of the design evolution of the proposals and to ensure transparency in decision-making.

7.2 Building Design

An assessment of the potential benefits and constraints of a range of different technology and design options was undertaken by Waterman Gore the M& E engineers with the aim of reducing energy consumption.

The principal focus of the sustainability approach for Kimpton Road will be to provide an energy efficient building fabric and plant to reduce CO2 emissions (the first priority in the Energy Hierarchy).

The building form, external envelope and materials will therefore be selected to maximise the penetration of useful sunlight whilst limiting the amount of winter heat loss. In order to reduce energy needs and ensure compliance with the revised 2005 Building Regulations, the following measures will be essential in the development of the design:

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• High performance double glazing to reduce the requirements for cooling on the east, west and south facades; and • Argon filled cavities for all double glazing.

These are discussed further in Section 8.1 of this report and within the “Kimpton Road: Sustainable Energy Options” report written by Gore in April 2005 (Ref. 17). A summary of this report follows.

7.3 Sustainable Energy Options

Use of a range of renewable energy options have been assessed by Waterman Gore, the M& E engineers. The technologies investigated are those that are considered to be potentially commercially viable and technically feasible for a development of this nature and scale. A brief summary of each of the renewable energy options considered is provided below:

Combined Heat and Power (CHP) - CHP is the simultaneous generation of thermal and electrical energy from a single stream of fuel. It improves the efficiency at which energy is used in power generation and therefore presents significant environmental benefits. However, CHP require a consistent heat load for which the heat generated by the CHP plant can be utilised. There are also ongoing maintenance requirements and the need for adequate fuel storage which would need further consideration within the context of the Kimpton Road site; however the development presents a number of strong reasons to seriously consider the CHP option and therefore CHP has been identified as the most feasible renewable energy option for the site. As such provision of an Energy centre on site that could accommodate a Biomass CHP system or a primary sub-station has been included within the masterplan at this stage to ensure the opportunity remains available to the scheme at detailed design.

Ground Water Cooling - Ground water cooling would potentially utilise groundwater from the underlying aquifer, sourced via boreholes to cool the buildings. Whilst this option offers many benefits such as the reduction of groundwater levels to reduce flooding, there is no guarantee that the required yield would be obtained. Recent experience from borehole users in the area indicates the potential for these systems to silt up. The initial installation and investigation costs for ground water cooling are high, therefore with such uncertainties, this option is not likely to be viable for the Kimpton Road site.

Surface Water Cooling - Surface water-cooling would potentially utilise overland water supplies such as lakes, rivers or the sea to directly or indirectly cool the buildings. There are several design issues that have to be overcome for this method to be successful including; the need for an abstraction license which could lead to potential environmental impacts on aquatic species downstream of the outlet point; high capital costs of implementation due to the requirements for filtering out silt. Due to the complexity of these issues, surface water-cooling is not considered to be a viable option for the Kimpton Road proposals.

Geothermal Energy – Geothermal energy requires the use of a heat exchanger buried in the ground and a high efficiency heat pump to utilise ground temperature for heating and cooling. Geothermal systems provide a number of benefits including cost and CO2 savings. However, due to contaminated land and ground water issues at Kimpton Road, a detailed geology study is required before feasibility could be confirmed.

Ground Source Heating – Ground source heat pumps are used to extract heat from the ground, heat pumps take in heat at a certain temperature and release it at a higher temperature using the same process as a refrigerator. Whilst a heat pump cannot be considered wholly renewable as the energy sources it uses is

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electricity the renewable component is considered to be the heat extracted from the ground. This technology could be applicable to the development, however further studies would be required to determine its feasibility.

Photo Voltaics (PVs) - PVs are semiconductor devices that convert sunlight into electricity. PV’s could potentially be used to supply a proportion of the developments energy requirements and would also help to achieve the requirements of the new proposed Part L Building Regulations.

7.4 Rainwater Harvesting and Recycled Water

The use of rainwater harvesting systems and grey water systems at the Kimpton Road development are being investigated. The development will seek to meet best practice with respect to water reclamation guidance. The design team have already provided initial guidance and advice on options for incorporating these systems within the development. Based on the findings of further investigation the scheme will look to implement the most appropriate system for the site, based on available roof area, additional plant cost requirements, the need for separate pipework and the associated cost of this and the aim to meet Government aspirations with regard to renewable resources.

8.0 Sustainability Statement

Following a review of the relevant national and local sustainability objectives outlined in section 6.0, the following ten sustainability topics have been identified against which the development proposals were evaluated:

• Energy; • Water; • Waste and Pollution; • Transport; • Community and Social Needs • Natural Environment; • Built Environment; • Economic Prosperity; and • Land Use.

The following sections provide a general overview of each sustainability topic together with a table detailing the site-specific initiatives committed to by the applicant and a commentary on how the initiatives comply with the objectives of sustainable development.

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8.1 Energy

Since the beginning of the industrial revolution, the concentration of greenhouse gases in the atmosphere has risen. Although CO2 is less harmful than other greenhouse gases on an equal mass basis, the quantity of CO2 is so large that it is the main contributor to climate change. Approximately 50% of the total UK CO2 emissions are attributable to energy used in heating, lighting and cooling buildings and a further 10% from energy used during the production and transportation of materials and the construction of the building. An additional 22% is due to the energy consumed by occupants travelling between buildings.

As well as producing CO2, fossil fuels such as oil, coal and gas are finite resources and the electricity they produce should therefore be used as efficiently as possible in homes and workplaces. Appropriate building design can minimise heat loss and maximise solar heating, natural lighting and passive ventilation to reduce energy requirements, whilst electrical appliances and fittings are becoming increasingly energy efficient.

Table 1: Energy

Initiative Description Commentary E1 Minimise the need for energy Where possible the development of the Kimpton Road site will maximise the reuse of the existing foundations and basement

platform as part of the new development elements. Efforts will be made to maximise the reuse of aggregate from demolition arisings conserving new stocks. Where steel elements are recovered during the demolition phase this will be resold for recycling, in addition efforts will be made to seek buyers to purchase the existing production line as a working entity. The design team will be exploring the possible retention of the existing foundations and structure of the car park. This will reduce the amount of energy required to removed and reconstruct these elements. Unfortunately, due to the nature of the existing buildings on the site being functionally designed as warehouse structures it will not be possible to reuse these within the new design and therefore the majority of the existing buildings will be demolished. However, since the current buildings on site are old, incompatible with the development and not energy efficient the removal of all these buildings will increase the likelihood of achieving long-term energy efficiencies and ensure compliance with Part L of building regulations.

As part of the development a commitment has been made to utilise local labour during construction, as appropriate, and ensure there is a balance of cut and fill to minimise traffic movements for removal of material off site, thereby reducing travel distances and associated energy consumption.

The procurement of materials for the development will prioritise renewable or sustainable sources with low energy impact, for example, all timber will be sourced from Forest Stewardship Council (FSC) certified product suppliers or equivalent. In addition, there is a commitment for the redevelopment to maximise the reuse and recycling of aggregate (concrete slabs from basement) on site. It is envisaged that an on-site concrete crusher will be used.

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Table 1: Energy

Initiative Description Commentary E2 Maximise use of passive energy Through the development of the masterplan, attention has been paid to optimise solar gain, therefore maximising the benefits the

buildings will receive from the sun. At this stage primary consideration has been given to location and orientation of the elements of the scheme on site. During the detailed design stage further consideration will be given to the use of passive energy through the incorporation of standard construction features such as the use of overhangs and shading, insulation, the inclusion and location of windows within 30 degrees of due south, and consideration of thermal mass. Throughout the detailed development of the masterplan the intent will be to design spaces with dual aspect increasing access to daylight and sunlight. In addition, materials will be selected based on their ability to maximise solar gain.

E3 Increase Energy Efficiency During the development of the masterplan, consideration has been given to ensuring that the design will meet the requirements of Part L of the Building Regulations appreciating that the anticipated changes to Part L (2006) which deals with the conservation of fuel and power in buildings throughout the UK will also need to be met. One key aspect of the masterplan design seeks to increase densities of accommodation on site which will assist in the minimisation of heat losses through building envelopes and therefore reduce energy requirements for heating. In general, the masterplan will seek to reduce energy demand through the delivery of energy efficiency by ensuring that the technology and distribution systems used will be as close as possible to 100% efficient. For example, the lighting system will be energy efficient using low energy light bulbs where possible and reducing the need for lighting when areas are not occupied.

E4 Renewable Energy Sources The appropriateness of renewable energy types has been considered through a preliminary energy study. The study reviewed different renewable energy options against the proposed mix of uses within the masterplan. This identified that a CHP solution is likely to be the most viable. There is a commitment to undertake further feasibility studies to assess the potential application of the most suitable renewable technologies at the site, namely, CHP, solar water heating, photovoltaics and ground source heat pumps. At this stage the masterplan allows for the incorporation of appropriate renewable technologies, through the provision of an Energy Centre that could accommodate either a primary sub-station or a CHP plant once suitable levels of feasibility and design elements have been reached.

E5 Conservation of transport related energy

The level of car parking proposed is below the current level on site and will seek to meet the planning requirements for the site. Suitable provision of cycle parking and associated facilities will be achieved throughout the masterplan encouraging the use of bicycles to access and move around the site. This, in conjunction with the site's reasonably good links to existing public transport services, will contribute to a reduction in reliance on the private car - a major user of fossil fuels and source of atmospheric pollution. Local materials, suppliers and labour will also be used during construction wherever practicable to reduce the need to travel.

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8.2 Water

Water is becoming an increasingly scarce resource as demand continues to grow. To satisfy this increase in demand, new sources of water and associated infrastructure have been required. However, the construction and operation of this infrastructure (for example reservoirs and treatment works) is expensive, energy intensive and damaging to the environment and therefore measures should be taken to reduce water consumption where possible.

Table 2: Water

Initiative Description Commentary WAT1 Water conservation Southside & City and Developments have received initial advice and guidance from the design team on options for incorporating

water conservation measures into the scheme. It has been identified that there is the opportunity to recycle rainwater from roof run-off within the development. There is a commitment from Southside & City Developments to commission more detailed and specialist advice on the opportunities to install rain water harvesting/ grey water systems as part of the detailed design of the specific plots of the development, as the feasibility of these systems will depend on the building form and user requirements.

WAT2 Sustainable drainage The use of Sustainable Urban Drainage Systems (SUDS) on the site has been investigated. Due to the levels of contaminants on site, the site being partly situated within a Groundwater Source Protection Zone (SPZ) and the density of the development SUDS systems such as swales, filter strips, balancing and attenuation ponds are considered to be unsuitable for this development. However, permeable paving and attenuation methods will be implemented where practicable in line with Environment Agency (EA) requirements, with the most suitable system likely to be sub-surface storm cells or equivalent. There is scope to introduce an off-line attenuation system in the form of a geocellular structure for the 1 in 100 year event within the open space area in front of the hotel/conference centre.

WAT3 Flood Prevention The site is not within a zone that is considered to be at risk of flooding, however because the area of the site is over 1 ha, a flood risk assessment has been undertaken.

WAT4 Pollution Prevention All surface water will be directed into existing connections with the main sewer along Kimpton Road. If there is an outdoor parking area, Southside & City Developments will consider permeable pavements which could also act as a storage system but will require lining to prevent groundwater contamination.

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8.3 Waste and Pollution

Waste, if not managed safely, can also result in pollution of the environment. The most sustainable approach is to reduce the overall amount of waste generated 'at source'. Wastes that are generated should then be reused wherever possible, or recycled as the next best environmental option. The least sustainable waste option is disposal (e.g. landfill).

Chemical pollution can have significant adverse health effects on humans, animals, plants and ecosystems. It can also reduce the amenity value of the environment and damage buildings. As well as affecting plant and animal species, other forms of pollution such as light and noise can cause nuisance to neighbours. The reduction or prevention of pollution is therefore critical to sustainable development.

Table 3: Waste

Initiative Description Commentary WP1 Waste management during the

construction phase Southside & City Developments are committed to reducing waste during the construction phase of the development. This will be achieved through initiatives such as seeking to ensure there is a balance of cut and fill to minimise the removal of material off site, seeking to design in for the use of standardise components, modular structures and pre-fabricated components etc. Southside & City Developments understands that to successfully reduce waste means building in measures from the project outset, as such waste management has been considered at this early framework planning phase. In addition, Southside & City Developments will seek to ensure that the contractor is obligated, through the Contract Specification, to develop and implement a site-wide strategy for maximising the recovery of materials and reducing, reusing and recycling construction waste on-site wherever possible. It will be a contract requirement to select materials and components that are able to be recycled at the end of their design life, wherever practicable. There will be a further requirement for them to monitor and set targets on waste generated during the works.

WP2 Waste management during the operational phase

On completion of the development, recycling will be encouraged through the provision of adequate storage for recyclable materials in line with the EcoHomes requirements. There is also an aspiration to provide facilities for composting.

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8.4 Transport Certain modes of transport use significant amounts of energy, and are a major source of greenhouse gases and air pollution. In addition, increased road transport raises other considerations such as congestion and safety. The promotion of more sustainable modes of transport; encouraging accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling; and reducing the need to travel particularly by private car, are key aims of sustainable development.

Table 4: Transport

Initiative Description Commentary T1 Reduce the need to travel The proposed masterplan is fully mixed use, offering employment use, retail use, and residential use to the north adjacent to an

existing residential area thereby contributing to an overall reduction in the need to travel. The site is easily accessible by public transport and lies within 800m of Luton Airport Parkway Rail Station. In addition, the proposed masterplan layout seeks to optimise accessibility to public transport resulting in the whole site being within 400m of an existing bus stop. Off-site pre-fabrication will be used wherever practicable, reduces the number of construction vehicle journeys necessary for the transport of materials to the site and therefore reducing their associated environmental impacts. Local materials, suppliers and labour will also be used during construction wherever practicable to reduce the need to travel.

T2 Encourage more cycling, walking, use of P.T.

The masterplan offers a network of safe and direct pedestrian routes throughout and beyond the site including re-using the cycle and pedestrian route onto Devon Road. This will encourage the use of this more sustainable means of transport. It is also intended that changing facilities including lockers for clothes and showers will be provided throughout the scheme elements where suitable. Public transport facilities are within easy reach of the site, with bus stops being easily accessible from the site offering a service at least every 10m and Luton Airport Parkway Rail Station being within 800m of the site. The boundary of the site actually falls within 100m of rail services and 50m of a bus stop. Opportunities to divert bus routes through the site are being explored. If the diversion is found to be feasible, it may actually reduce travel times due to existing congestion being experiences on Devon Road. The total parking provision on the site will be below the maximum allowable for the site.

T3 Reduce traffic congestion As part of the Transport Assessment (TA) a travel plan framework will be developed for the whole site setting out how a detailed Transport Plan for the different elements of the scheme could be operated and maintained providing possible elements that could be included within the detailed Travel Plan for each occupier. The TA will provide suggestions for routing of construction traffic to help reduce nuisance during the works.

T4 Reducing freight travel Freight movements will be reduced where possible for example, on-site remediation, prefabrication and the use of construction materials in reprofiling.

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8.5 Community and Social Needs

How a development effects society in terms of the interaction of occupants with neighbouring communities and the general public is fundamental to sustainable development. Issues include access to education, health, welfare, community, recreational facilities and public open space, as well as public safety and crime prevention. It is important that office developments are situated near to shops and services reducing the need to travel by car.

Table 5: Community and Social Needs

Initiative Description Commentary CSN1 Improve access to green space Whilst some new amenity space will be provided on site as part of the developing masterplan, there is an aspiration to make

improvements to existing green spaces around the site. This is due to the limited potential for the provision of green space on-site as a result of the site topography and density constraints.

CSN2 Access to opportunities, services and facilities for all

The proposal will include the provision of accommodation intended for local community use in the ‘main boulevard’ area, these could include a mixture of local community/leisure/retail and employment uses. In addition, there are existing facilities along Kimpton Road, easily accessible to users of the site, there is also a retail park in close proximity to the site.

CSN3 Increase access to leisure facilities

There are existing facilities on Gypsy Lane that would be available to users of the site these include a sports club. There is potential for a gym to be provided within the hotel element of the masterplan which could be used by residents.

CSN4 Reduce the fear of crime The masterplan design seeks to reduce opportunities for crime through design of direct pedestrian and cycle routes throughout the site. These routes will be well overlooked by other elements of the scheme offering natural surveillance. In addition, CCTV surveillance will be provided throughout the development in line with Secured by Design requirements.

CSN5 Encourage a feeling of community spirit

A mix of 1, 2 and 3 bed housing types will be provided to help meet the local housing need, including the contribution of affordable housing which will be agreed with Luton Borough Council. It may be possible to provide accommodation for community facilities along the boulevard frontage; the type of facility provided will be dependent on what is required within the area, this will be investigated in consultation with LBC.

CSN6 Reduce the level of noise A noise assessment of the proposed scheme has been undertaken in line with PPG24 which has confirmed that the site is suitable for residential development. Throughout the development of the masterplan efforts have been made to ensure the design layout will avoid unnecessary disruption to users of the site, therefore residential components are being located to the north of the site, away from Luton Airport and the General Motors remaining operations.

CSN7 Disabled Access Appropriate facilities and access for disabled users will be incorporated into the Development Framework Plan, as it gets developed to meet the requirements of the Disability Discrimination Act (DDA).

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Table 5: Community and Social Needs

Initiative Description Commentary CSN8 Create a more attractive

environment The Development Framework Plan proposals will seek to maintain vegetation where possible to maintain the stability of the existing steep slopes on the site. A landscaping strategy has been developed to maximise landscaping on the site where appropriate.

CSN9 Create a more inclusive community

Overall, the development of the Kimpton Road site will remove an otherwise sterile site directly adjacent to a residential area. The introduction of more residential uses, a central boulevard of retail uses and new commercial uses will ensure a less separated community enhancing social inclusion in the area. The proposed masterplan will provide a retail element along the ‘main boulevard’ that will provide opportunities for social interaction and inclusion. In addition, there will be accommodation provided intended for community use which will increase the amount of community interaction opportunities available to residents in the area.

CSN10 Improve health Through the improvements of existing pedestrian and cycle routes to the site and the incorporation of new routes throughout the redeveloped site, opportunities for walking and cycling will be improved. As stated for CSN3, there is potential for a gym to be provided within the hotel element of the masterplan which could be used by residents.

CSH11 Wider community involvement in the design and provision of services

A range of community consultation techniques such as exhibitions and workshops will be used to consult with the community prior to and after planning submission. In addition, the public will be informed and consulted through a roadshow to demonstrate the development proposals. Community liaison officers will be identified to consult with the public throughout the project.

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8.6 Natural Environment

The conservation of biodiversity is another essential element of sustainable development. Two key causes of reduced biodiversity are habitat loss and habitat fragmentation. During the planning of developments an opportunity exists to lessen or remove the causes of biodiversity reduction by reusing previously developed sites and therefore relieving pressure on greenfield wildlife habitats, as well as creating opportunities to increase biodiversity within the redevelopment. Sites that already have significant ecological resources should ensure that preservation and enhancement are key considerations during the development of landscaping infrastructure.

Table 6: Natural Environment

Initiative Description Commentary NE1 Retain existing habitats/wildlife

sites The majority of the site is comprised of hardstanding and is considered to be of low ecological value. Although the ecological potential of the site is low, efforts have been made within the proposed masterplan to retain existing vegetation where possible.

NE2 Create/enhance habitats/wildlife sites

The use of native species within the landscape proposals will be encouraged with the potential inclusion of green roofs and nesting boxes within the scheme. Whilst measures to enhance the ecological potential of the site will be investigated where possible, opportunities to enhance the ecological value of the site is limited therefore it is envisaged that off-site ecological improvements will be made to enhance surrounding green spaces for wildlife and conservation.

NE3 Protect species at risk An initial site survey has confirmed that there are no legally protected species or habitats on site. Any proposals that increase green space or native species on the site are likely to represent an overall beneficial impact to the site and surrounding area.

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8.7 Built Environment

Planning policy seeks to promote good design in developments in order to create attractive high quality living environments in which people will choose to live and work. In addition, designs should maintain and enhance those buildings and areas, which, by their visual and architectural and/or historical significance, contribute to the urban and rural character. Strategic and locally important views should also be protected. An additional benefit of a well designed site layout and building is that it can also contribute to a safe and secure environment for future occupants.

Table 7: Built Environment Initiative Description Commentary BE1 Protection of Listed Buildings There are no listed buildings on site, the nearest is a Grade II listed building approximately 0.5km away. The building will remain

unaffected by the development, however, the redevelopment will improve its overall local environment and contextual setting. BE2 Protection of Archaeological

remains An Archaeological Assessment has been undertaken on the site. This assessment has shown that there is only limited potential for archaeological remains to survive within the site area and no known archaeological sites or findspots are located within the boundaries of the site. As a result of the large level of terracing which has taken place on the site, survival of archaeological material of earlier date than the motor works will to be minimal. As such, it is likely that, should any below-ground archaeological remains still exist, they will have also have been disturbed and truncated.

BE3 Landscape and Visual The proposed masterplan is designed to be sympathetic to the character and context of the local area and respect existing landscape designations. The development provides a valuable opportunity to significantly improve the local landscape within certain design constraints. For example, the maximum height of the scheme will look to limit any visual impacts from Luton Hoo and Capability Green, which are designated as Areas of Great Landscape Value (AGLV). The reprofiling of the site will ensure that the development is graded into the existing topography improving the overall appearance of the site from different viewpoints. The masterplan design aims to create a vibrant and integrated mixed use neighbourhood focusing upon the importance of urban design, the quality of the built environment and the relationship between the design of the development and its users. The design seeks to enhance the local character through the creation of vistas, focal points, landmarks and public squares to create a richness and give identity of place. A high profile public square will be located in front of the Hotel, adjacent to the office block units. This space will be designed to create a formal, hard landscaped open space for use by visitors, residents and employees within the site. The development will integrate into the existing street pattern via two new road links via Kimpton and Devon Road.

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8.8 Economic Prosperity

The creation of employment opportunities and the strengthening of local economies are recognised within the context of sustainable development as being of equal importance to environmental and other considerations. To meet the challenges of sustainable development, a skilled and adaptable labour force and a flexible labour market is necessary. The promotion of jobs and employment, better education and training are considered essential.

Table 8: Economic Prosperity

Initiative Description Commentary EP1 Diversify the economy and

increase manufacturing Through the development of the masterplan, efforts have been made to respond to local economic opportunities and needs. As such, the development will provide a range of business size units to facilitate a mix of business types to compliment existing businesses and skills in the local area. Through an assessment of the potential socio-economic impacts of the development, appropriate mitigation will be implemented where necessary to minimise any potential effects on existing services.

EP2 Encourage entrepreneurial activity and contribute to local regeneration initiatives.

The redevelopment of the site will result an estimated 4000 jobs in option 1 or nearly 3000 jobs in option 2. Whilst it is difficult to predict the level of part-time opportunities this is estimated to be well in excess of 500. To ensure that employment generation contributes to local regeneration of the area, commitment has been made to source construction jobs locally where feasible. As well as utilising local skills, indirect impacts through expenditure will also have some benefits for the local economy. The masterplan proposals have evolved with the aim of providing accommodation for a mix of employment uses to create appropriate and varied job opportunities. It is anticipated that the development once in operation will provide in excess of 4,000 jobs. Through the inclusion of manufacturing units together with smaller size, more flexible units, the masterplan has responded to the local skills base generated by the closure of the former car manufacturing plant at the site, together with the need to encourage new business opportunities. In addition, it is possible that appropriate training schemes will be implemented as part of the scheme development to maximise these impacts and help localise the effects wherever possible.

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8.9 Land Use

A sequential approach should be taken in locating new development. This means giving preference to previously developed land or buildings within urban areas, followed by development on the edge of existing urban areas with the development of greenfield (previously undeveloped) sites as a last option. National Government targets require 50% of new housing to be located on previously developed (brownfield) land. This requirement reflects the desire to retain important urban space and the need to achieve conservation objectives therefore contributing to social and environmental aspects of sustainable development.

Table 9: Landuse

Initiative Description Commentary L1 Encourage the development of

previously developed land. The development is situated on the site of a redundant manufacturing plant, located within the existing urban area of Luton. The majority of the site is comprised of existing buildings and hardstanding and is therefore classified as an area of previously developed land. Through the provision of high density housing and employment uses, the development will help meet the local need for housing and jobs, whilst preventing the development of protected ecological sites and areas that are important for nature conservation.

L2 Help to reduce the number of vacant buildings and derelict land

The site currently comprises a number of vacant manufacturing buildings associated with the former manufacturing plant. As a result of these former uses, there is residual contamination on site that will be addressed through the redevelopment of the site since the proposed masterplan aims to redevelopment the site, providing necessary remediation to return the site to an appropriate use.

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9.0 Summary

This Sustainability Statement provides a review of the proposed development in relation to sustainable development criteria and the aims and priorities of the LBC and EEDA, which in turn reflect national sustainability objectives.

Clearly, certain aspects of sustainability are not relevant to, or are not achievable at this site due to specific site constraints such the complex topography and the density of the development. However, it is considered that the development, as detailed in the planning application, accords with many of the goals of sustainable development. The sustainability appraisal of the Kimpton Road redevelopment proposals has identified a number of sustainable elements within the proposed Masterplan. These elements are highly commendable and illustrate a commitment to sustainability from the developer. A summary of the sustainability initiatives integral to the scheme are detailed below:

• the commitment to use renewable/sustainable sources and recycled aggregates in construction; • the commitment to achieving a design and choosing building materials that promote energy efficiency; • the consideration and investigation into the potential for the use of renewable energy sources; • the commitment to a project wide preference for local materials, goods, services and labour where possible; • the consideration and investigation into the potential for the incorporation of grey water/ rain water harvesting systems to reduce water consumption; • the commitment to include measures within the scheme to reduce run-off and minimise pollution; • the commitment to waste minimisation during construction and the promotion of future waste reduction and recycling; • the provision of a high degree of accessibility by public transport, walking, cycling; • the commitment to the provision of cycle parking and associated facilities as appropriate throughout the development; • the provision of housing, facilities and employment opportunities to meet local needs; • the commitment to a design that enhances the local landscape character; • the commitment to enhance existing green spaces in the surrounding area; and • the proposals are for the redevelopment of previously developed land.

The sustainability assessment indicates that the masterplan, with its aim of providing a mixed use development in Luton, can make a substantial contribution to the economic development and social amenity of the immediate area. It is believed that the design process has benefited from this debate, and that the development has and will be considerably strengthened in terms of its sustainability performance.

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10.0 References

1 Luton Borough Council (LBC) 2003: Designing for Sustainability: A summary of Good Practice. LBC.

2 Department for the Environment, Transport and the Regions (DETR), 1999: A Better Quality of Life - A Strategy for Sustainable Development in the UK. DETR.

3 Office of the Deputy Prime Minister (ODPM), 2002: Sustainable Communities - Delivering Through Planning, ODPM, London.

4 Department for Environment, Food and Rural Affairs (DEFRA), 2005, Securing the Future: Delivering UK Government Sustainable Development Strategy, HMSO.

5 Office of the Deputy Prime Minister (ODPM), 2004: Planning Policy Statement 1 (PPS1): Delivering Sustainable Communities. ODPM, London.

7 Office of the Deputy Prime Minister (ODPM), 2004: Planning Policy Statement 10 (PPS10): Planning for Sustainable Waste Management (Consultation Draft). ODPM, London.

8 Office of the Deputy Prime Minister (ODPM), 2004: Planning Policy Statement 22 (PPS22): Renewable Energy. ODPM. London

9 Office of the Deputy Prime Minister (ODPM), 2004: Making it Happen: The Northern Way. ODPM, London.

10 Regional Planning Guidance for the South East (RPG9), March 2001. SEERA. London

11 East of England Regional Assembly (EERA), 2004, Draft East of England Plan, EERA, Flempton.

12 East of England Regional Assembly (EERA) & the East of England Sustainable Development Round Table (EESDRT), 2001: A Sustainable Development Framework for the East of England. The Breacon Press, East Sussex.

13 East of England Regional Assembly (EERA) & the East of England Sustainable Development Round Table (EESDRT), ‘Sustainable Development Toolkit for the East of England’.

14 Luton and Bedfordshire County Council (L&BCC), 1997, Bedfordshire and Luton (adopted) Structure Plan 2016, L&BBC.

15 Luton Borough Council (LBC), 1997, Luton Local Plan (Second Deposit Draft), LBC.

16 Luton Borough Council (LBC) 2003: Designing for Sustainability: A summary of Good Practice. LBC.

17 Waterman Gore (2005), Kimpton Road, Sustainable Energy Options’. Waterman Gore, London.