Policy SP6: Sustainable Transport

I wish to object to Section EL1, EL2, EL3 Land east of Luton as I believe there are several areas where the Plan is unsound:
1. Removing this land from Green Belt status to meet 'Luton's Unmet Need':
The National Planning Policy Framework document states that the removal of Green Belt status does not fit the Government's criteria of "Except in Exceptional Circumstances". Luton's unmet need is NOT an exceptional circumstance. It also states "an unmet need is unlikely to outweigh the harm to the Green Belt unless there are very special circumstances". There are sufficient undeveloped Brown field sites in Luton to meet its unmet needs;
The removal of this land from the Green Belt as proposed in the NHDC Local Plan leaves this land unprotected and open to applications from developers.
2. The infrastructure surrounding the development, both into North Hertfordshire and Luton:
Luton Borough Council base their traffic modelling on an unbuilt link road to the A505 at Lilley. A Freedom of Information request states: "This transport modelling includes the alignment of the proposed spine road through that development site and Luton Borough Council have also assumed by 2031 that will be extended at its northern end to join the A505 near its junction with the road into Lilley". See Bloor Homes "Access and Masterplan slides" - "Newly constructed relief road linking Luton Road with Chalk Hill - is this the spine road?
However NHDC state on p.72 of the NHDC Local Plan, Para. 4.222 - "Our assessments show that this level of development can be accommodated without a significant adverse impact on the wider highway networks of Luton and Hertfordshire".
3. The proposal is completely out or proportion. 2,100 homes is 14% of the total allocation of houses in the NHDC Local Plan, a 1,025% increase on the 205 houses in the three hamlets, placing these, and the houses in Wigmore bordering the development into the middle of an estate.
Please acknowledge receipt of my representation.

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Representation on the Local Plan 2011-2031 submission document ("LPSD")
Notice
I have many objections to the LPSD and believe that changes are necessary, principally to eliminate the 2,100 new homes proposal for Luton. I wish to participate in the formal oral Examination of the Plan.

Objections
1.1 The LPSD proposal of 2,100 homes to the East of Luton will destroy the rural nature of the village of Cockernhoe. Reference to Cockernhoe can be backdated to the 10th Century by a manuscript of 980AD. The village of Cockernhoe, incorporating Mangrove, numbers 130 dwellings. Cockernhoe ward numbers 205 dwellings. The nearest point of Cockernhoe village to the existing Luton dwellings is 200 metres and this boundary around the village should not be encroached upon as it is surely the minimum needed to retain Cockernhoe's rural nature. In my view the release of Green Belt land surrounding the required settlement boundary of Cockernhoe would not meet the "tests of soundness" set out in the National Planning Policy Framework ("NPPF") -see 1.5 below.
1.5 The NPPF specifically seeks to stop urban sprawl where this affects communities. This is clearly the case with regard to Cockernhoe and other villages/communities affected by this East Of Luton proposal, which should be stopped.
1.7 The 2,100 homes to the East of Luton proposal is not "exceptional circumstances". Considering the objections to the proposal by residents of Luton in addition to those of North Herts it is disturbing that NHDC has recommended this proposal.
There are alternative areas, such as land adjacent to Butterworth Green and North of the A505, which could be developed without encroaching upon any existing settlement. There is no need to destroy the rural nature of an existing community, Cockernhoe, which has existed for more than 1,000 years.
The need to properly assess the need for development is difficult. In December 2012 NHDC concluded the need was 10,700 dwellings. By 2014 this had increased to 12,200 for their own needs and now in 2016 to 14,000. This must be due to immigration and therefore it must be concluded that "Brexit" will reduce this figure - but NHDC say not! None of us knows what the result will be! To make a decision in the next 5 years to destroy the rural nature of Cockernhoe and associated communities in Cockernhoe ward and the affected areas of Luton is surely irresponsible! The 14,000 dwellings required by NHDC for its' own needs already represents an increase of 25.5% compared to the 55,000 dwellings existing in NHDC in 2011. In England as a whole there were 22,976,000 dwellings in 2011 (Housing statistics release 28th April 2016 by the Department for Communities and Local Government). A 25.5% increase overall in England would mean this number of dwellings increasing by 6.0m by 2031,representing a population increase of 14m which is clearly incorrect. In the period from 31st March 2001 to 31st March 2015 the increase in dwellings in England was 2.3m. In conclusion the need for 14,000 new homes is virtually a guess having increased by 31% from the estimate in 2012. Thus these additional new homes should not be added to by the extra 2,100 homes for Luton. See clause 2.8 below for calculation of the figure needed.
1.8 The duty to co-operate should be qualified as to "where they are able to". A significant proportion of residents of North Herts already work outside the district, see clause 2.76, and this would be the same with the 14,000 homes required for North Herts own needs. Thus surely NHDC has already complied with its' duty to co-operate.
1.9 To the West of Luton Redrow is building some 350 homes at Caddington Woods. This is some 650m from the outskirts of the Bedfordshire village of Caddington. Why is this development so small? There was a proposal to build 5,500 homes there in 2015 that was rejected by Luton, see www.bushwood.info/docs/Bushwood-Masterplan.pdf. This was as close to Caddington as the 2,100 dwellings are to Cockernhoe. I believe Luton councillors were concerned about objections from residents of the village of Caddington but obviously completely ignored the objections by North Herts residents and those from affected areas of Luton. Similarly the majority of NHDC councillors have ignored the objections from their community.
1.19 Whilst NHDC have consulted with the local community on the incorporation of the 2,100 homes to the East of Luton they have ignored their objections. There is little purpose in requiring a consultation process if you ignore the result.
1.22 Similarly to 1.19 above the previous consultations have been ignored.
1.26 Similarly to 1.19 above the previous consultations have been ignored.
1.27 Similarly to 1.19 above the previous consultations have been ignored.
2.8 The forecast of an increase in population in North Herts of 24,000 by 2031 does not require the building of 16,000 new dwellings. Assuming households on average of 2.4 this would require 10,000 new dwellings. There is significant inconsistency in these figures. If you then add the 1,600 households on the housing register (clause 2.25) you would need a maximum of 11,600 homes.
2.77 The intention to improve physical and mental wellbeing for the several thousand residents of Wigmore, Luton and Cockernhoe ward affected by the 2,100 homes to the East of Luton is completely ignored by this proposal.
2.83 The new development of 2,100 homes East of Luton will not:
(a) Enable the village of Cockernhoe to embrace their role within North Herts. The village will be lost forever and just be part of the urban community of Luton
(b) The District's historical rural areas will not be protected
3.7 Cockernhoe is being sacrificed and it is clear is outside NHDC's strategic objectives for ENV2, ECON4, ECON 6. I do not believe that ECON8 will be possible for the 2,100 dwellings proposed and think the road infrastructure will not be possible to accommodate this growth. I cast doubt on the methods of collection of the data. For instance in the last two months we have had 3 occasions where the roads have been gridlocked for various reasons. When you are sitting in such a traffic jam how does the cables across the road measure that. They surely measure the traffic that crosses them and not the queue of traffic wanting to cross them. SOC 4 is being completely ignored for the rural community of Cockernhoe where its' residents have objected to these plans over the course of the last 8 years.
4.0(b) Once again Cockernhoe is being excluded from this policy. The 2,100 homes surrounding Cockernhoe are twice as big as the future increase to the District's largest town of Hitchin (1,009).
4.9 The settlement boundary of Cockernhoe, within the classification of a Category "A" village, should not be expanded to include the area covered by the land allocated for the 2,100 homes. Such area should be given a classification of its' own so that objections can be raised against that but not reflect on Cockernhoe's own inclusion within the policy of category "A" villages.
4.13 Similarly to 4.9 above the East of Luton development should not be associated with Cockernhoe's own settlement boundary.
4.53 I disagree that the 2,100 proposal East of Luton, resulting in the rural nature of Cockernhoe being destroyed, qualifies as existence of "exceptional circumstances".
4.55 Green Belt is surely pointless if it can be removed by Council at will and against the will of the local community affected by its' removal.
SP6 I do not believe that adequate proposals have been made to deal with the road infrastructure needed for the 2,100 homes proposed.
SP8 (b) I disagree with this policy.
SP19 This policy should be cancelled as inappropriate and undeliverable to the satisfaction of residents of Cockernhoe and the affected parts of Luton.
13.66 I totally disagree with inclusion of the East of Luton expansion within the Cockernhoe settlement boundary. It should have a classification of its own.

Support
4.9 Policy SP2 concerning general development being allowed within the defined settlement boundaries of the Category "A" villages is a significant step forward. These 23 villages include Cockernhoe but the settlement boundary of that village has been expanded to include space for the 2,100 new homes planned. This is wrong the settlement boundary of Cockernhoe is clearly shown on the map in white. The additional area coloured brown should not be associated with Cockernhoe's settlement boundary but should be attributed a classification of its' own.
SP5 (a) (iii) I support the definition of settlement boundaries for villages, including Cockernhoe, in SP2, see 4.9 above that were previously "washed over" by the Green Belt.
SP7 I'm in full agreement with this policy.
4.128 I agree with the NPPF, which supports the argument to exclude the proposed 2,100 new homes East of Luton.
8.5 Policy HS2 I agree with fully.

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