Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
Representation ID: 8511
Received: 19/05/2021
Respondent: Mr David Dorman
The 8,500 quoted as the housing capacity of Luton through to 2031 is now more like 14,700 using up to date numbers. Luton's revised OAN of July 2020 shows a lower requirement of 14,700. Luton's unmet need through to 2031 is only 2,000 and not the 9,300 in the Luton Local Plan. Central Bedfordshire Council has allocated 20 sites with a capacity of 8,850 dwellings to meet Luton's unmet needs. Luton's failure to hold its required Review by mid-2021 under its Policy LLP40 would reveal this. NHDC does not need to build houses on Green Belt land at Cockernhoe.
The figure of 8,500 as Luton's house-building capacity is hopelessly outdated. Analysis of the 2019 SHLAA for house completions and projections on identified Luton sites through to 2031 show 10,903 dwellings. The Luton Planning & Development Control Committee has since then approved such a significant increase in building sites for completion prior to 2031, on sites not in the 2019 SHLAA, that the housing capacity of Luton is now 14,700. This coupled with the decrease in the Objectively Assessed Need for Luton identified by Opinion Research Services in July 2020 as now 16,700 and not the 17,800 in the Luton Local Plan means that the true unmet need from Luton is no more than 2,000 (16,700-14700). This unmet need is first of all to be directed towards Central Bedfordshire Council (CBC)as the 'best fit' and CBC has allocated 20 sites totalling 8,850 dwellings for this purpose, many now under construction. There is no unmet need required to be fulfilled by NHDC around Cockernhoe on significant Green Belt land. All this would have been revealed had Luton abided by the requirement in its Policy LLP40 to hold a Review of its Plan by mid-2021 - a Review on which work by Luton has only just started - two years late.