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LANDSCAPE STATEMENT Examination of Luton Local Plan Matter 24: Natural and Historic Environment – Policy LP29 Landscape and Geological Conservation For and on behalf of Claydon Land Development Ltd. c/o DLP Planning Ltd. November 2016 © James Blake Associates Ltd 2016

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Page 1: LANDSCAPE STATEMENT · 2016-11-14 · JBA 16/278-Doc1 . Document Ref: Landscape Statement ... It supports the hearing statement to Stage 3 of the ... however, due to the range and

LANDSCAPE STATEMENT Examination of Luton Local Plan

Matter 24: Natural and Historic Environment – Policy LP29

Landscape and Geological Conservation

For and on behalf of Claydon Land Development Ltd.

c/o DLP Planning Ltd.

November 2016

© James Blake Associates Ltd 2016

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Landscape Statement Matter 24: Policy LP29 Landscape and Geological Conservation November 2016

JBA 16/278 Land at Lynwood Avenue, Luton 2

A FINAL REB JBA JBA 08/11/2016

- DRAFT REB JBA JBA 07/11/2016

Revision Purpose Originated Checked Authorised Date

Document Number: JBA 16/278-Doc1

Document Ref: Landscape Statement

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Landscape Statement Matter 24: Policy LP29 Landscape and Geological Conservation November 2016

JBA 16/278 Land at Lynwood Avenue, Luton 3

Table of Contents

1.0 INTRODUCTION .................................................................................................................... 4

1.1 BACKGROUND ......................................................................................................................... 4

1.2 LAND AT LYNWOOD AVENUE LUTON ......................................................................................... 4

1.3 ASSESSMENT .......................................................................................................................... 5

2.0 LOCAL LANDSCAPE AREAS .............................................................................................. 5

2.1 DEFINITION OF LOCAL LANDSCAPE AREAS ................................................................................ 5

2.2 PROPOSED LOCAL LANDSCAPE DESIGNATIONS FOR LUTON ....................................................... 6

2.3 POLICY CONSIDERATIONS ........................................................................................................ 7

3.0 ASSESSMENT OF BRADGERS HILL AGLV ........................................................................ 8

3.1 LANDSCAPE CHARACTER ......................................................................................................... 8

3.2 BRADGERS HILL AGLV (CANDIDATE AREA G) ........................................................................... 9

3.3 ASSESSMENT OF LAND SOUTH OF LYNWOOD AVENUE (INCLUDING THE SITE) ............................ 10

4.0 CONCLUSION ..................................................................................................................... 11

4.1 SUMMARY AND RESPONSE TO THE INSPECTOR’S QUESTIONS .................................................. 11

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Landscape Statement Matter 24: Policy LP29 Landscape and Geological Conservation November 2016

JBA 16/278 Land at Lynwood Avenue, Luton 4

1.0 INTRODUCTION

1.1 Background

This Landscape Statement has been prepared by James Blake Associates Ltd. (JBA) on behalf of Claydon Land Development Ltd. It supports the hearing statement to Stage 3 of the Examination of the Luton Local Plan submitted by DLP Planning Ltd. (DLP) to Matter 24: Natural and Historic Environment which responds to the Inspector’s issues and questions.

The document specifically addresses Policy LP29 Landscape and Geological Conservation part A (“LP29A”), and in particular the proposal by Luton Borough Council (LBC) to designate local landscape areas.

The policy is supported by the evidence base documents ENV005 / ENV005a “Proposed Local Landscape Designations for Luton” and Appendices. This establishes a ‘two tier’ approach to local landscape designations – Areas of Great Landscape Value (AGLV) and Areas of Local Landscape Value (ALLV).

1.2 Land at Lynwood Avenue Luton

The statement is made in the context of our client’s interest in land at Lynwood Avenue, Luton (“the Site”), which lies within the Bradgers Hill Corridor (Policy LP29A ix.), one of six areas within the Borough proposed as AGLV (i.e. Tier 1). It follows representations made by DLP during the plan preparation process, including objections to the designation of the Site as part of the Bradger’s Hill Corridor AGLV.

The Site as shown on Figure 1 is approximately 3.18 hectares, and lies within the urban area to the south of Lynwood Avenue with Hitchin Road and Stopsley Way (the A505) to the east. Adjacent to the boundaries of the Site to the north and east is residential development, while to the south west is the corridor safeguarded for the East Luton Circular Road (Policy LP31), beyond which lies residential development along Sunningdale. The area is privately owned and to which there is no authorised public access.

The area was previously allocated for residential development and had the benefit of planning permission. Historic maps demonstrate that the vegetation on the Site has grown up since the 1960’s.

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1.3 Assessment

Section 2.0 of this statement considers the definition of each of the local landscape designations, the methodology of the assessment undertaken on behalf of LBC and general policy considerations. Section 3.0 provides an assessment of the Site and its landscape value in the context of the wider Bradgers Hill Corridor. Finally, in Section 4.0 it provides a response to the Inspector’s questions regarding LP29A on the justification and level of protection to be afforded to local landscape areas.

The assessment was undertaken by Rachel Bodiam BSc(Hons) DipLA CMLI. An extensive visit to the Bradgers Hill Corridor (including the Site) and adjoining Stopsley Common was completed on 27th October 2016.

2.0 LOCAL LANDSCAPE AREAS

2.1 Definition of Local Landscape Areas

Local Plan policy LP29A sets out the Council’s policy regarding the protection, conservation and enhancement of the ‘character, setting and natural beauty of national and local landscape areas.’ This statement principally addresses the Council’s policy on designations at the local level.

The Council identifies areas of ‘local landscape value’ comprising a two-tier framework of:

• Tier 1 – ‘Areas of Great Landscape Value’ (AGLV); and

• Tier 2 – ‘Areas of Local Landscape Value’ (ALLV).

This is in addition to statutory national landscape designations, including the Chilterns Area of Outstanding Natural Beauty (AONB) which lies to the north and south west of the borough.

The designations are supported by the “Luton Landscape Character Assessment” (LLCA)1 and the “Proposed Landscape Designations for Luton”2 both completed by the Greensand Trust in 2014. Only the latter document is included in the Council’s evidence base (reference ENV005 and ENV005a).

1 Luton Borough Landscape Character Assessment, Report by the Greensand Trust on behalf of Luton Borough

Council, June 2014 2 Proposed Local Landscape Designations for Luton, Final Report – produced by the Greensand Trust on behalf of

Luton Borough Council, June 2014

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Section 2 of ENV005 states that in order to simplify the system initially the use of a new single designation was considered; however, due to the range and quality of potential sites, it was subsequently concluded that it would be helpful to have more than one type of local landscape designation. The report subsequently acknowledges that as a result ‘greater clarity is required in explaining the differences between the different types of designation.’

The methodology used to determine local landscape areas is based on a scoring system, assessed against a predetermined set of criteria which ascertains ‘(a) whether the site / area meets the standard for designation of some kind and (b) whether it merits a higher level of designation.’ ALLV (Tier 2) represents those areas that meet the minimum score, with AGLV (Tier 1) used for the best areas / sites meeting a higher threshold score.

Despite the need for clarity, neither the evidence or the Local Plan Policy (including the supporting text in Section 10) attempts to set out a clear or understandable word based definition of AGLV or ALLV based on the defined criteria and threshold scores.

References to the Glossary (Local Plan Appendix 1) are misleading as the definition of AGLV refers to the designation as ‘a previous local policy designation.’ It is not clear whether the original definition from the Structure Plan is being carried forward to the new Local Plan. Local landscape areas and ALLV are not defined in the glossary.

2.2 Proposed Local Landscape Designations for Luton

The principle of creating a new local landscape designation is embedded in the LLCA; one of its key purposes being to identify areas of high landscape value not currently protected by designation, and to establish a process where such a designation could be developed through the Local Plan process. ENV005 sets out the need for this process to be rigorous, thorough and consistent.

Local landscape designations are set out as the only possible method to protect areas from inappropriate development. It is not clear from the evidence base or Local Plan process whether the use of a criteria-based policy linked to and informed by the LLCA or a combined approach i.e. a single local landscape designation in conjunction with a criteria-based policy, were considered as potential alternative options for protecting the landscapes within the borough.

Areas thought to potentially merit designation were initially identified through the LLCA process and added to areas already designated by the Saved Policies of the previous Local Plan to create a ‘long list’ of Candidate Areas. It is noted that some sites were omitted from the ‘long list’ due to existing equal or greater levels of designation, for example Wardown Park Registered Park and Garden; however, Putteridge Edge is similarly designated as part of the Putteridge Bury Registered Park and Garden, and the north eastern edge of the Bradgers Hill Corridor at Stopsley Common overlaps with the Chilterns AONB and both of these areas are assessed. This is inconsistent and all potential areas, regardless of other designations, should have been considered at this initial stage. This is recognised in ENV005 Section 2.

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It is not clear how the boundaries of each of the Candidate Areas were determined. It is noted that while some are identified as Landscape Character Areas (LCA) in the LLCA, for example Stockwood Park; other areas incorporate only part of an LCA, for example Hart Hill, or include areas from a number of different LCAs. As such the characteristics of some of the Candidate Areas vary considerably. Not all of the LCAs present are listed under the assessment sheets of each Candidate Area in ENV005a Appendix 2.

As set out above each of the candidate areas were assessed against a criteria-based scoring system. The list of criteria incorporating landscape character, heritage, ecological and visual aspects along with tranquillity and importance to the town and the AONB is considered to provide a broad assessment of landscape value. It is not clear as to the reasoning behind the inclusion of Criteria 19 ‘To what extent will designation provide for more effective safeguard, management or promotion of the special attributes of the area being considered for designation’; as ultimately this is one of the key purposes of the landscape designation.

The scoring system is based on high, medium and low, converted to a numerical value (generally 3, 2 and 1) with no weighting applied. To ensure objectivity and consistency, the numerical value for each criteria would benefit from greater explanation. It is noted that the assessment does take into account the urban nature of the borough, and as such scoring is generally higher than might be expected for similar areas in a rural context.

The evidence sets out a minimum total score for the Candidate Areas to be put forward:

• Potential ALLV – score of 35 out of a total of 55; and

• Potential AGLV – score of 45 out of 55 reflecting the higher standard required.

There is no justification as to how these threshold figures have been determined.

Of the sixteen candidate areas, fourteen are put forward as potential local landscape areas, eight as ALLV and six as AGLV. All of these areas have been incorporated into the Local Plan as proposed. This includes the proposed Turnpike Drive ALLV (adjacent to the AONB) which has planning consent for residential development (planning reference 14/01321/FUL granted in May 2015) prior to the publication of the Pre-Submission Luton Local Plan in October 2015.

It is therefore not clear whether the evidence has been reviewed in light of other designations (i.e. whether it would duplicate the function of other designated areas) or the need to achieve sustainable development as set out in ENV005 Section 6.

2.3 Policy Considerations

The approach and wording of Policy LP29A raises a number of issues:

• The policy is limited in its application to designated landscapes. There is no consideration of the wider landscape character of the borough or its distinctiveness;

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• The approach is inconsistent with other policies e.g. Policy LP28 Biodiversity and Nature Conservation establishes Tier 1 as being of national statutory importance, with Tiers 2 and 3 of regional and local importance respectively;

• There is no distinction in the level of protection or weight to be afforded between the different designations within the hierarchy i.e. between designations at the national and local level in accordance with the NPPF para 113. It is not evident that the greatest weight should be given to conserving the landscape and scenic beauty of the AONB in accordance with the NPPF para 115; and

• It is not clear whether there is a distinction to be made in the weight to be afforded to AGLV and ALLV, or whether the same level of protection will apply.

The wording of the policy provides limited explanation of how development proposals should ‘protect, conserve and enhance the character, setting and natural beauty of national and local landscape areas.’ There are no additional criteria to aid the decision-making process and provide guidance against which the effects of development on the landscape and visual amenity can be assessed. This could be achieved by reference to the key characteristics, quality / condition, sensitivity and opportunities and constraints of each area as set out in the LLCA.

Furthermore, the policy does not secure other opportunities for conservation and enhancement of local character and distinctiveness. Local Plan paragraph 10.37 notes that the LCA evidence also identifies Landscape Opportunity Areas. There is nowhere in the Plan to identify where such areas are located, or any planning policy that addresses it.

3.0 Assessment of Bradgers Hill AGLV

3.1 Landscape Character

The LLCA identifies thirty-three landscape character areas (LCAs) within Luton. Those areas to the north east of Luton are identified in Figure 1. Photographs demonstrating the character of Bradgers Hill and Stopsley Common are provided in Figure 2.

Bradgers Hill (LCA 8a) is a continuation of the chalk hills including Warden and Galley Hills to the north that extends as a sinuous steep scarp towards the centre of Luton. Despite the proximity of development, the area is relatively rural at its northern end, becoming more urban to the south, where the topography and vegetation ensures it remains a strong and prominent landscape feature. The steep slopes are dominated by chalk grassland, woodland and scrub and is largely undeveloped providing an important backdrop and setting to the eastern edge of Luton and offering panoramic views across the town (refer to Figure 2 Views v01 to v06).

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Bradgers Hill is recognised in the LLCA as an area of very high landscape value. The northern part is included in the Chilterns AONB, while the southern part is designated as AGLV in the previous Local Plan; both are physically and visually linked along the scarp corridor with Stopsley Common to the east. The ecological and heritage value is similarly recognised at both the national and local level with a mosaic of important habitats, along with historic features such as ancient routeways and strip lynchets. The area, particularly on the urban edge, provides an important local recreational resource, with access via a good network of rights of way and informal paths.

The LLCA clearly notes that the parts of the area outside of the AONB ‘would make a strong candidate for local landscape designation’ and as such should be put forward for consideration.

Stopsley Common South (LCA 9a) in which the Site is situated lies on the plateau to the east of Bradgers Hill and is visually and physically separated from the rest of Stopsley Common by Stopsley High School. The area is broadly flat, sloping slightly to the south and is dominated by the High School (currently undergoing redevelopment), with a narrow corridor of grassland, effectively left over space along the safeguarded route of the road, and Mixes Hill Wood (the Site) to the south. The latter includes some mature oak trees; otherwise trees are of no antiquity. The area is strongly enclosed by the surrounding urban areas and despite the elevation, views out of the area are limited (refer to Figure 2 Views v07 to v11).

The area is noted in the LLCA as being of lower quality than other adjacent green spaces, with a lack of positive management and a number of incongruous and detracting features. As such the LLCA identifies that ‘whilst not significant enough in isolation, this area could be considered for local landscape designation as part of the Bradgers Hill Corridor.’

This is unusual as the character and value of Stopsley Common South is completely different to that of Bradgers Hill LCA.

3.2 Bradgers Hill AGLV (Candidate Area g)

The extent of the proposed Bradgers Hill AGLV is shown on Figure 1.

As identified above the proposed Bradgers Hill Corridor AGLV includes parts of numerous areas identified in the LLCA; primarily the majority of Bradgers Hill (LCA8a), but also part of Stopsley Common South (LCA 9a including the Site) and the Vauxhall Way Green Corridor (LCA 11) to the east and Lea Valley Middle (LCA4b) and High Town (LCA18) to the south.

It is not clear how this boundary has been determined. While part of the area within the Chilterns AONB has been omitted, the Policies Map shows that there remains an overlap at its northern end; this is not a boundary which is evident on the ground.

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The assessment of the Bradgers Hill Corridor in ENV005 is the highest score of all the areas assessed. This is expected given the high value of the Bradgers Hill LCA which forms the majority of the area and its proximity / links to the Chilterns AONB, and the setting it provides to both the AONB and the town.

Due to the differences in character and condition, many of the criteria and subsequently scores applied to the Bradgers Hill Corridor do not apply to those areas away from the scarp, in particular those areas of Stopsley Common South along with the Vauxhall Way Green Corridor, which are noted by the LLCA as being of lower value. This includes the criteria of naturalness, condition, tranquillity, connectivity, heritage and ecological value and the contribution that the area makes to the setting of Luton and the Chilterns AONB.

3.3 Assessment of Land south of Lynwood Avenue (including the Site)

Based on the analysis above, JBA has completed a separate assessment of an area of land included in the proposed Bradgers Hill AGLV, which largely lies within the Stopsley Common South LCA and is considered to be distinct in character. The area (including the Site) is referred to as ‘Land south of Lynwood Avenue’ and is identified on the inset maps on Figure 2.

As far as possible, the assessment has been undertaken in accordance with the Greensand Trust’s criteria-based scoring system, and for consistency has been cross referenced against other candidate local landscape areas. The table and supporting text providing a comparative assessment between the proposed Bradgers Hill AGLV and Land south of Lynwood Avenue is provided in Table 1.

The total score for this individual assessment is 33 out of 55. This is not sufficient to meet the minimum threshold score required for an ALLV, and is considerably lower than the higher standard required for an AGLV. This is considered to reflect the local value of the area and its poor condition. Contained within the urban form, the area does not form part of the setting of the AONB or contribute to the wider setting of Luton, nor does it provide a setting to the Bradgers Hill and Stopsley Common LCAs.

The most important aspect of the area is its tree cover. The area, particularly the Site is densely wooded; however, historic maps demonstrate that this is a relatively recent characteristic which has occurred since the development of the adjoining estates in the 1960’s. The majority of the woodland is dominated by self-colonised ash, with many trees in a poor condition and in need of management3. Although not currently recorded in Luton (1st November 2016)4, Ash dieback is noted as being present in the surrounding area, and could have a significant impact on tree cover in future.

3 Tree Survey of Land at Lynwood Avenue Luton, Andrew Belson Dip. Arb (RFS) Arboricultural

Consultant on behalf of DLP Planning Ltd, May 2013 4 http://chalaramap.fera.defra.gov.uk/

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The presence of existing vegetation in landscape terms does not necessarily preclude development of the Site. The public amenity value that the vegetation provides could be maintained by a sensitive and well-designed development that identifies and safeguards trees of value alongside new planting to diversify the species and age of the vegetation present. This would provide a strong framework of green infrastructure into which the buildings could be set, with open space (including access) and the future of vegetation secured in the long-term with appropriate management. In this way both the green corridor to the south of the Site and the local distinctiveness of the area can be maintained.

Photographs of a similar high quality development within the urban area of Ipswich at Purdis Grange (completed by JBA on behalf of Taylor Wimpey) are provided in Figure 3.

4.0 Conclusion

4.1 Summary and Response to the Inspector’s Questions

This Landscape Statement has been prepared by JBA on behalf of Claydon Land Development Ltd. to support the hearing statement to Stage 3 of the Examination of the Luton Local Plan submitted by DLP to Matter 24: Natural and Historic Environment. The document specifically addresses Policy LP29, and in particular the proposal by Luton Borough Council to designate local landscape areas.

The statement is made in the context of our client’s interest in land at Lynwood Avenue, Luton (“the Site”), which lies within the Bradgers Hill Corridor (Policy LP29A ix.), a proposed Area of Great Landscape Value (AGLV). It follows representations made by DLP during the plan preparation process, including objections to the designation of the Site as a local landscape area.

The statement reviews the approach undertaken by the Council in defining local landscape designations and the methodology of the assessment undertaken. The key findings are summarised below:

• The principle of creating a new local landscape designation is embedded in the Local Plan process and supporting evidence. It is not clear whether the use of a criteria-based policy linked to and informed by the LLCA, or a combined approach i.e. a single local landscape designation in conjunction with a criteria-based policy were considered as alternative options for protecting all of the landscapes within the borough.

• The use of two local landscape designations within a small borough is potentially confusing. This is reinforced by the lack of a clear word based definition of AGLV and ALLV, and a supporting justification of the relative importance of each area.

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• The process for identifying potential local landscape areas set out in ENV005 and ENV005a provides a broad assessment of value; however, some aspects of the approach are inconsistent, while key parts of the methodology such as how the boundaries of the proposed areas have been determined and the value of threshold scores are not explained or justified.

• It is not clear whether the evidence has been reviewed in light of other designations (i.e. whether they would duplicate the function of other designated areas) or the need to achieve sustainable development.

The wording of Policy LP29 also raises a number of issues:

• The policy is limited in its application to designated landscapes. There is no consideration of the wider landscape character of the borough or its distinctiveness;

• The approach is inconsistent with other policies e.g. Policy LP28 Biodiversity and Nature Conservation which establishes Tier 1 as being of national statutory importance, with Tiers 2 and 3 of regional and local importance;

• There is no distinction in the level of protection or weight to be afforded between designations at the national and local level in accordance with the NPPF para 113. It is not made clear that the greatest weight should be given to conserving the landscape and scenic beauty of the AONB in accordance with the NPPF para 115; and

• It is not clear whether there is a distinction in the weight to be afforded to AGLV and ALLV, or whether the same level of protection will apply.

It is suggested that Policy LP29A is reworded to address these issues. This should incorporate:

• Greatest weight to the protection, conservation and enhancement of the character, setting and natural beauty of the Chilterns AONB;

• A single local landscape designation (effectively AGLV) to protect and conserve those areas which form the setting to the Chilterns AONB and make a substantial contribution to the overall setting and structure of Luton - to which relevant weight should be applied;

• Otherwise ensure that all development has regard to the LLCA and the character area in which it is located. This may include:

- The protection, conservation or enhancement of the key characteristics that contribute to the local distinctiveness of each area;

- The protection and enhancement of key features such as high quality trees and hedgerows;

- Responding to local character in terms of settlement form, pattern, density, scale and materials;

- Maintaining green corridors and links;

- Having regard to key views / visual amenity, including undeveloped ridges / skylines; and

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- Securing enhancements and improvements to the condition and management of areas and features where such opportunities exist.

In respect of land at Lynwood Avenue, it is considered that the area has a character which is distinct from the other areas of the proposed Bradgers Hill Corridor AGLV, and as such the value of the area should have been separately assessed.

In undertaking this individual assessment it is confirmed that the Site, as part of the land to the South of Lynwood Avenue, does not warrant designation as an ALLV or AGLV as it does not meet the threshold levels required. This is considered to reflect the local value of the area and its poor condition.

In the context of achieving sustainable development, it is considered that the value of the Site in landscape terms could be maintained by a high quality development set within a strong green infrastructure framework that safeguards existing trees of value, alongside new planting and the creation of multi-functional open space.

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Table 1: Comparative Assessment of Land south of Lynwood Avenue (including the Site) and the proposed Bradgers Hill Corridor AGLV (For the location of each area refer to Figure 2)

Criteria Score Notes

Greensand Trust Assessment of proposed Bradgers Hill Corridor AGLV

JBA Assessment of land south of Lynwood Avenue (incl. the Site)

1 Is there a strong sense of naturalness with limited human interference?

Yes = 3 Relatively natural/some natural features/some human interference through modification/management = 2 Highly modified/managed – few/no natural features = 1

Score = 3 Wooded chalk valley side

Score = 2 Areas of rough grassland / scrub and trees provide a feeling of naturalness, but surrounded by urban area, including school.

2 Does it demonstrate the underlying geology of interest? What influence do geological/geomorphological features have on the experience of the landscape?

Strong influence/reflecting naturalness = 3 Moderate influence = 2 Limited influence = 1

Score = 3 Underlying chalk geology creates a prominent, steep valley side

Score = 1 Plateau landscape with slight fall to south modified by surrounding development. Limited influence on experience of landscape.

3 Is the landscape unit visually intact? Yes = 3 Relatively = 2 Poorly = 1

Score = 3 Retains visual integrity, even into urban area.

Score = 2 Relatively intact. Urban development encroaches at edges.

4 Does it have logical boundaries, and is it a significant enough area to designate and make it practical to develop policies for its protection, management and promotion?

Yes = 3 No = 1

Score = 3 Boundaries largely dictated by geology, and significant in size. Agricultural and greenspace land on urban fringe included to help protect setting.

Score = 3 Yes, but only as a result of surrounding development. Relatively small area.

5 Does it have a distinct, coherent and recognisable landscape character?

Yes = 3 Moderate = 2 Indistinct = 1

Score = 3 Very distinctive.

Score = 2 Moderately distinctive due to woodland. Backing on of development creates a feeling of left over space.

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Table 1: Comparative Assessment of Land south of Lynwood Avenue (including the Site) and the proposed Bradgers Hill Corridor AGLV (For the location of each area refer to Figure 2)

Criteria Score Notes Greensand Trust Assessment of proposed Bradgers Hill Corridor AGLV

JBA Assessment of land south of Lynwood Avenue (incl. the Site)

6 Is it of high scenic quality through a combination of landscape features?

High = 3 Medium = 2 Low = 1

Score = 3 High quality due to wooded nature and steep slopes. At a more localised level lynchets create ‘stepped’ feel in places.

Score = 2 Some features including woodland but poor condition with a lack of positive management. Urban development including road encroaches at edges.

7 Is the landscape unit functional ecologically?

Yes = 3 Relatively, with reasonable habitats and connectivity = 2

Poor connectivity and few/fragmented habitats = 1

Score = 3 Strongly connected corridor, with mosaic of wooded and some open spaces with chalk grassland, through latter could be extended. Most of the area is CWS, Stockingstone Road greenspace is DWS.

Score = 2 Areas of grassland / scrub and woodland. Some connection along route safeguarded as road corridor to Bradgers Hill, connectivity to south severed by road. Majority of area is CWS / DWS. Would become isolated on construction of road proposal.

8 Are individual elements (trees, hedges etc) in good condition?

Good = 3 Moderate = 2 Poor = 1

Score = 3 Score = 2 Some important trees; woodland in poor condition. Ash is dominant species and may be affected in future by ash dieback. Needs long-term strategy.

9 Is there a degree of tranquillity, recognising this is an urban area?

High = 4 Moderate = 3 Low = 1

Score = 4 Particularly enhanced by wooded feel.

Score = 3 Low to south adjoining road. Otherwise contained by urban areas, although some tranquility in woodland.

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Table 1: Comparative Assessment of Land south of Lynwood Avenue (including the Site) and the proposed Bradgers Hill Corridor AGLV (For the location of each area refer to Figure 2)

Criteria Score Notes Greensand Trust Assessment of proposed Bradgers Hill Corridor AGLV

JBA Assessment of land south of Lynwood Avenue (incl. the Site)

10 Is the unit connected to the wider landscape outside the town? Does it relate to adjoining areas / LCAs? Does it form part of their setting?

Yes = 3 Moderately = 2 Not/poorly = 1

Score = 3 Relates strongly to (and is covered by) South Beds LCA Warden Hill to Stopsley Common Chalk Escarpment LCA – extends further into town than this.

Score = 2 Narrow connection along safeguarded road corridor to Bradgers Hill to north. Would be lost on construction of road proposal. Contained within urban area and does not form part of setting of adjoining LCAs.

11 Is it important to the setting of the AONB

Yes = 3 Score = 3

Score = 0 Contained within urban area.

12 Is it used for enjoyment/recreational activity?

Highly accessible with high usage = 3 Moderately accessible with medium usage = 2 Poor accessibility with little or no usage = 1

Score = 2 Steep slopes make access less easy, but still moderately used. Includes historic trails.

Score = 1 Single well-used footpath connection between Lynwood Avenue and Sunningdale. Mixes Hill Woodland is private land; access is unauthorised and the area is subject to misuse.

13 Is it important to local people, especially in terms its beauty of views of it or from it? Is there community support for its protection?

Very important/strong support = 3 Moderately important/medium support = 2 Low importance/little support = 1

Score = 3 Exceptional panoramic views in places, e.g. Stockingstone Road. Popular parks including People’s Park and Popes Meadow.

Score = 3 Views out from area contained by surrounding development and vegetation. Tree cover provides a local visual amenity from surrounding area including Stopsley Way and Hitchin Road.

14 Does it have any prominent or eye- catching features, or does it create a sense of scale/contrast?

Yes = 3 Some features/sense of scale/contrast = 2 Few/no features/little/no sense of scale/contrast = 1

Score = 3 Wooded nature makes it especially prominent, especially into town.

Score = 3 Trees in Mixes Hill Wood are prominent and locally provides contrast to the urban area.

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Table 1: Comparative Assessment of Land south of Lynwood Avenue (including the Site) and the proposed Bradgers Hill Corridor AGLV (For the location of each area refer to Figure 2)

Criteria Score Notes Greensand Trust Assessment of proposed Bradgers Hill Corridor AGLV

JBA Assessment of land south of Lynwood Avenue (incl. the Site)

15 Is it important to the setting of the town? Do its character and qualities of the landscape have special importance to Luton? Does it contribute to the distinctiveness of the town? Does it contribute to sense of place?

Yes, strongly = 3 Moderately = 2 Little/none = 1

Score = 3 Encloses town to east.

Score = 2 Woodland important along Stopsley Way / Hitchin Road and contributes locally to sense of place. Limited influence on setting of the wider town.

16 Is the landscape a rare one in the area, or represent a particular type of landscape?

Yes = 3 Moderately rare/representative = 2 No = 1

Score = 3 Highly representative of steep chalk valley side.

Score = 2 Woodland moderately rare within town, but locally prevalent.

17 Does it have cultural heritage features – built, landscape planting, field boundaries, cultural associations – significant cultural heritage features which dominate the landscape and strongly influence the character?

Yes = 3 Some cultural heritage importance = 2

Little cultural heritage importance/impact on landscape = 1

Score = 3 Mediaeval strip lynchets of particular value. Ancient routeways.

Score = 1 Relatively recent landscape modified by surrounding development. Mature oak trees provide evidence of former field boundaries have some influence, but obscured by surrounding vegetation.

18 Are there any incongruous features or detractors?

Yes, strong detractors = -3 Moderate detractors = -2 Weak detractors = -1 No detractors = 0

Score = -1 Becomes more urbanised towards southern end, with Stockingstone Road dissecting it.

Score = -2 Proximity and relationship to urban development (including school fence) and Stopsley Way / Hitchin Road to south.

19 To what extent will designation provide for more effective safeguard, management or promotion of the special attributes of the area being considered for designation?

High extent = 3 Moderate impact = 2 Little/no impact = 1

Score = 3 Particularly so for area outside the AONB

Score = 1 Protected by ecological designations and TPO (Mixes Hill Wood). Landscape designation unlikely to be any more effective.

TOTAL = 53/55 TOTAL = 32/55

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Landscape Statement | November 2016

Figure 1: Luton Landscape Character and Existing / Proposed Landscape Designations. Scale 1:20,000 @A3

KEY

Site Chilterns Area of Outstanding Natural Beauty (AONB) Proposed Local Landscape Area

10b

10c

9c

9e

9d

9b

9a 10a

11

14

13

12

8b

8a

7

4b

4a

2

6

518

Luton Borough Boundary

Luton Borough Landscape Character AreasLCA 4b Lea Valley MiddleLCA 8b Bradgers Hill CorridorLCA 9a Stopsley Common SouthLCA 9b Stopsley Common Mid LCA 10a Stopsley CentreLCA 11 Vauxhall Way Green CorridorLCA 12 Round Green to Hart Hill DipslopeLCA 18 High Town

Road Proposals (safeguarded)

Site of Special Scientific Interest (SSSI)

National Designations

Scheduled Monument

Registered Park and Garden

General

Landscape Character (LBC, 2014)

Proposed Local Landscape Areas

N

Proposed Bradgers Hill AGLV

AGLV Proposed Area of Great Landscape ValueALLV Proposed Area of Local Landscape Value

Turnpike Drive ALLVDevelopment consented 2015

Bramingham Park AGLV

Upper Lea Valley AGLV

Stopsley Common AGLV

Putteridge Edge ALLVOverlap with Registered

Park & Garden

Hart Hill ALLV

8a

Bradgers Hill AGLV

Putteridge Bury

Galley & Warden Hills

Site

Other

Source: Ordnance Survey Crown Copyright 2016. All rights reserved. License Number 100022432

Overlap AGLV with AONB

Wardown Park Registered Park & Garden

(not assessed)

Wigmore Rural ALLV

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Landscape Statement | November 2016

A. Bradgers Hill: Landscape Character

N Source: Ordnance Survey Crown Copyright 2016. All rights reserved. License Number 100022432

Figure 2: Representative Photographs of Landscape Character. Scale 1:20,000 @A3

v01 v02

v03

View v01

View v02

View v03

Land south of Lynwood Avenue

Stopsley CommonBradgers

Hill

Chilterns AONB

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Landscape Statement | November 2016

A. Bradgers Hill: Landscape Character

N Source: Ordnance Survey Crown Copyright 2016. All rights reserved. License Number 100022432

Figure 2: Representative Photographs of Landscape Character. Scale 1:20,000 @A3

Stopsley Common

Bradgers Hill

Chilterns AONB

View v05

View v04

View v06

v04

v05v06

Land south of Lynwood Avenue

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B. Land South of Lynwood Avenue: Landscape Character

Landscape Statement | November 2016

N Source: Ordnance Survey Crown Copyright 2016. All rights reserved. License Number 100022432

Figure 2: Representative Photographs of Landscape Character. Scale 1:20,000 @A3

View v07

View v08

View v09

v07v09

v08

Stopsley Common

Bradgers Hill

Chilterns AONB

Land south of Lynwood Avenue

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Landscape Statement | November 2016

B. Land South of Lynwood Avenue: Landscape Character

N Source: Ordnance Survey Crown Copyright 2016. All rights reserved. License Number 100022432

Stopsley Common

Bradgers Hill

Chilterns AONB

Land south of Lynwood Avenue

Figure 2: Representative Photographs of Landscape Character. Scale 1:20,000 @A3

View v09

View v10

View v11

v10

v09

v11

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Landscape Statement | November 2016

N Source: Ordnance Survey Crown Copyright 2016. All rights reserved. License Number 100022432

Figure 2: Representative Photographs of Landscape Character. Scale 1:20,000 @A3

C. Stopsley Common: Landscape Character

Stopsley Common

Bradgers Hill

Land south of Lynwood Avenue

Chilterns AONB

View v12

View v13

View v14

v12

v13

v14

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Landscape Statement | November 2016

Figure 3: Example of High Quality Woodland Development - Purdis Grange, Ipswich. Not to Scale @A3