Policy SP19: Sites EL1, EL2 and EL3 - East of Luton

I strongly object to this proposed residential development for the following reasons:
* This proposal would destroy a large amount of North Hertfordshire's Green Belt land, including large swathes of prime countryside which is designated of special significant landscape value. Government policy on Green Belt land is completely ignored in this proposal. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open.
* In March and October 2014, the Government updated its online Planning Practice guidance on the policies in the NPPF. This makes it very clear that unmet housing need in a particular area is unlikely to meet the "very special circumstances" test to justify Green Belt development. It also confirms that local authorities have the ability to "safeguard their local area against urban sprawl and protect the green lungs around towns and cities". The government said that it wanted to make planning policy clear that housing need does not justify the harm done to the Green Belt by inappropriate development. This development does not meet the "very special circumstances" test and would seriously harm the Green Belt.
* North Hertfordshire District Council seem intent on allowing their land to be used for building a large number of houses for Luton's alleged unmet housing need, but there is evidence available which clearly indicates that they are not required. .
* If this development went ahead, the ancient villages of Mangrove Green and Cockernhoe would be swamped and lose their individual identity and destruction of local community values
* There will be a devastating impact on wildlife in the area.
Green spaces are essential to the health and well-being of the population but this proposal would mean that access to the countryside for relaxation, recreation and tranquillity will be severely reduced. Many miles of country footpaths enjoyed by many and not least including Luton residents will be concreted over. Plans for green areas within the development will not compensate for this huge loss of green spaces.
* The road infrastructure in the area is already unable to cope with current levels of traffic. Roads into Luton, Luton airport and those which access the M1 are gridlocked at certain times of the day at present. This will be further exacerbated if this development went ahead.
* There are already long tailbacks of vehicles at both the Luton and Hitchin ends of the A505 with frustrated drivers taking to inadequate country lanes to try and avoid the worst bottlenecks. This continues through this part of Luton and towards the motorway. Further development will significantly exaggerate this, increasing danger to pedestrians and the many local school children who walk to school.
* Many local roads in the vicinity of the proposed site are narrow country lanes with single track stretches and they too will be unable to cope with increased traffic, particularly public transport vehicles and large delivery vans and lorries which will be required to serve the development.
* The proposals on transport infrastructure in the application do not do enough to assure us that they will mitigate or improve the problems outlined here. Further independent assessment and research should be undertaken before outline planning permission is granted.
* Local schools at Cockernhoe and Wigmore are already oversubscribed. The application does not indicate where the additional children will be educated.
* Emergency services will struggle to access and serve the community.
* There are no realistic plans for increased provision of essential services such as GP surgeries, hospitals, emergency services, police and adequate public transport. The number of dwellings in this proposal means that all these services will require more resources.
* This proposal is for 660 dwellings. This is an overwhelming number for such a small area. A development of this size in such close proximity to an expanding airport with its associated noise and pollution will not provide a good, healthy lifestyle for the residents.
Ancient bluebell woods will be completely over-run and risk destruction by additional residents new to the development.
I cycle in this area very regularly for my rest and relaxation, to enjoy fresh air and beautiful open countryside to maintain my health fitness.
Do not let it be destroyed.
I sincerely hopes that these objections will ensure that this application is rejected

I am writing to object to aspects of the proposed Local Plan which relate to the East of Luton development around Cockernhoe and Mangrove Green.
Green Belt
The land in question is protected Green Belt. Reading through the National Planning Policy Framework (NPPF) it states that:
A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:
* buildings for agriculture and forestry;
* provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it;
* the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building;
* the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces;
* limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan;
* limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.
The requirement for fulfilling Luton's unmet housing need by constructing 2,100 houses, vastly overwhelming the 205 houses in the villages it will surround, is clearly substantially beyond "limited infilling" and therefore does not fit these criteria. It will also essentially mean that these villages cease to exist and become part of Luton.
According to the NPPF, "inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances". The above points make clear that the development proposed in the Local Plan is categorised as inappropriate above.
The NPPF also states that "'very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations". It also states that "Green Belt boundaries should only be altered in exceptional circumstances". I cannot see how fulfilling Luton's Unmet Need is sufficient to fit these criteria when alternative, less harmful options, exist including undeveloped Brownfield sites within Luton itself which have been identified during previous planning consultations.

Transport Infrastructure
A significant concern is the road infrastructure to support this development. The Local Plan Proposal just mentions that "principal access to be taken from Luton Road and integrated into Luton's existing highway network via Crawley Green Road". There is no mention of access in the other direction to Hitchin where the route would be via single track country roads.
The roads both towards Hitchin and the A1 as well as Luton and the M1 already struggle with current traffic levels, especially during rush hour. The surrounding narrow country lanes are used as rat runs for people trying to avoid the Luton traffic and are becoming dangerous at peak times.
These problems will only increase with the planned extension of Luton Airport and building of a substantial number of houses.
A Freedom of Information request has uncovered that "This transport modeling includes the alignment of the proposed spine road through that development site and LBC 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". This would presumably be the route towards Hitchin but is omitted in the current proposal and would have a very significant impact on the surrounding countryside.
The statements in the Local Plan Proposal about the required changes to the road network and that "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." is therefore incorrect and misleading. It will also have a far larger impact than the statement in the proposal "Built development contained within the Breachwood Ridge and avoiding adverse impacts on the wider landscape of the Lilley Valley or the Chilterns AONB as informed by detailed landscape assessments" would appear to indicate.

In summary, I believe this proposal:
* does not satisfy the required circumstances to remove Green Belt land
* includes a disproportionate number of houses which will destroy the villages they will surround essentially subsuming them into Luton
* ignores the significant impact on local transport infrastructure and seeks to mislead by not mentioning the additional highway link to the A505 at Lilley which any analysis has been based on. This will impact even more Green Belt land as well as an Area of Outstanding Natural Beauty (contrary to the statements made in the proposal). It also exacerbates the already struggling infrastructure heading into both Hitchin and Luton which is no way remediated by either the disclosed or undisclosed assumptions.

I urge you to reject this unsound proposal and that a more appropriate, viable and transparent option is put forwards.

Environment Bank welcomes the opportunity to briefly respond to the Consultation for North Hertfordshire District Council's Local Plan 2011-2031 Proposed Submission Draft. We support Policies SP12: Green infrastructure, biodiversity and landscape, SP14, SP18 and SP19, along with points 4.76, 4.185, 11.38, 11.39 and 11.48, and their requirements for No Net Loss / Net Gain of biodiversity, metric assessments of biodiversity impacts and offsetting to deliver compensation.

About us:
Environment Bank is a private company working to broker biodiversity compensation agreements - offsets - for developers and landowners. We act as impartial advisers to Local Planning Authorities and are experts in biodiversity impact assessment and No Net Loss (NNL) strategies. We have partnerships and support relationships with over 25 LPAs across 15 counties - providing advice on local policies, planning guidance and strategies, together with support in implementation and individual planning cases. We have seen biodiversity No Net Loss, Net Gain and offset policies be adopted in Local Plans across the country.

Working on individual developments on behalf of developers and planning authorities we calculate the biodiversity impacts and enhancements of development proposals using approved Government metrics, determining residual biodiversity losses, if any, and proposing offset solutions. Our ecological experts then match a developer's compensation requirement with sites put forward by landowners and conservationists who undertake biodiversity enhancements on their land to generate conservation credits available as compensation. Offset schemes must be the right type of site, of the right size, in the right place, at the right time, for the right cost. Credits are sold in exchange for the creation or enhancement of habitats, generating biodiversity gain. Thereafter, legal and fiscal systems assure planning authorities that such compensation measures have been arranged independently and delivery will be overseen and guaranteed in the long-term, providing net biodiversity gain across a district.

I am writing to object to aspects of the proposed Local Plan which relate to the East of Luton development around Cockernhoe and Mangrove Green.
Green Belt
The land in question is protected Green Belt. Reading through the National Planning Policy Framework (NPPF) it states that:
A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:
* buildings for agriculture and forestry;
* provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it;
* the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building;
* the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces;
* limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan;
* limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.
The requirement for fulfilling Luton's unmet housing need by constructing 2,100 houses, vastly overwhelming the 205 houses in the villages it will surround, is clearly substantially beyond "limited infilling" and therefore does not fit these criteria. It will also essentially mean that these villages cease to exist and become part of Luton.
According to the NPPF, "inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances". The above points make clear that the development proposed in the Local Plan is categorised as inappropriate above.
The NPPF also states that "'very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations". It also states that "Green Belt boundaries should only be altered in exceptional circumstances". I cannot see how fulfilling Luton's Unmet Need is sufficient to fit these criteria when alternative, less harmful options, exist including undeveloped Brownfield sites within Luton itself which have been identified during previous planning consultations.

Transport Infrastructure
A significant concern is the road infrastructure to support this development. The Local Plan Proposal just mentions that "principal access to be taken from Luton Road and integrated into Luton's existing highway network via Crawley Green Road". There is no mention of access in the other direction to Hitchin where the route would be via single track country roads.
The roads both towards Hitchin and the A1 as well as Luton and the M1 already struggle with current traffic levels, especially during rush hour. The surrounding narrow country lanes are used as rat runs for people trying to avoid the Luton traffic and are becoming dangerous at peak times.
These problems will only increase with the planned extension of Luton Airport and building of a substantial number of houses.
A Freedom of Information request has uncovered that "This transport modelling includes the alignment of the proposed spine road through that development site and LBC 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". This would presumably be the route towards Hitchin but is omitted in the current proposal and would have a very significant impact on the surrounding countryside.
The statements in the Local Plan Proposal about the required changes to the road network and that "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." is therefore incorrect and misleading. It will also have a far larger impact than the statement in the proposal "Built development contained within the Breachwood Ridge and avoiding adverse impacts on the wider landscape of the Lilley Valley or the Chilterns AONB as informed by detailed landscape assessments" would appear to indicate.

In summary, I believe this proposal:
* does not satisfy the required circumstances to remove Green Belt land
* includes a disproportionate number of houses which will destroy the villages they will surround essentially subsuming them into Luton
* ignores the significant impact on local transport infrastructure and seeks to mislead by not mentioning the additional highway link to the A505 at Lilley which any analysis has been based on. This will impact even more Green Belt land as well as an Area of Outstanding Natural Beauty (contrary to the statements made in the proposal). It also exacerbates the already struggling infrastructure heading into both Hitchin and Luton which is no way remediated by either the disclosed or undisclosed assumptions.

I urge you to reject this unsound proposal and that a more appropriate, viable and transparent option is put forwards.

The badger group, together with colleagues from Beds Badger Group have visited all areas with proposed planning applications and found badger implications on many of them. On behalf of the committee of Herts and Middlesex Badger Group, I wish to inform you of our major concerns regarding areas within the current North Herts development plans.

As I am sure you are aware, badgers and their setts are protected by law in the UK by the Badger Act of 1992 and the Wildlife and Countryside Act of 1981.
It is illegal for any person to:
Kill or injure a badger
Dig or take a badger
Possess a dead badger or part thereof
Interfere with, or disturb, a sett.

The most worrying proposed plan is in the proposed GA2 especially Nine Acre Wood and surrounding areas, where there is a very active badger wood with 2 large setts, outlying holes nearby and signs of extensive badger activity. There is a wildlife corridor down the hedgerow to Longdell Wood where there are also active badger setts. If you are planning to close these setts you would need a licence from Natural England and be prepared to give somewhere for the badgers to relocate taking account of existing badger density. As you are proposing to build on all the fields in which they forage too, there is nowhere in your current plan to accommodate them. We are very concerned that the extensive development of this area could not be completed without severe damage to the large badger population. I am going to forward the details of this to the Badger Trust Crime team to keep them informed of this too.

Other areas with badger implications are as follows

a) The northern part of IC3 Ickleford has badger setts and badger activity
b) EL1 and EL2 Cockernhoe/Mangrove Green have signs of badger activity and therefore the development has badger implications, particularly Stubbocks Wood and Messina Plantation public footpath
Stubbocks Wood
1. Sett with four entrances : active TL13932398
2. Sett with two entrances : recent use TL13872400
3. Sett with two entrances: active TL13762401
4. Sett with seven entrances: active TL13762396
5. Sett with two entrance: not active TL13252369
Messina Plantation public footpath
6. Sett with single entrance: used recently with badger print on spoil. TL12742425 hedgerow
7. Sett with four entrances: active with latrine nearby TL12762427 hedgerow
c) North of Stevenager NS1: Very active sett with several fresh latrines, run to huge hole in field and bucket latrine. Also border with SB2 has snuffle holes and latrines showing badger implications.
d) RD1 Active badger sett (5+ holes) in scrub ~10m N of proposed site

We have sett records and grid references for all the setts we have found and will continue to add to this information as brambles and ground cover dies down over the next month. We would be very pleased to meet with yourselves and/or your ecological surveyors regarding these sites and any other areas where you have concerns, to discuss these issues.

I object to the NHDC local plan 2011-2030 and want to change parts of the local plan and participate in all examination stages.
My objection is around parts EL 1, 2 and 3 which involve the development of 2100 homes in an area of green belt and close to the boundary with Luton Wigmore ward.
My objections are
1 2100 homes will generate a minimum of 4200 cars which will only have access to 2 roads Crawley Green Road and Eaton Green Road both of which are already heavily congested and have no capacity to be enlarged to carry any more traffic yet they are the only routes the residents of these homes will have to access the M1 and Luton Town for employment and shopping etc.
2 the local doctors are already full and can not accept any more patients yet no provision is provided in the plan to create the kind of infrastructure to support the development.
3 The primary and secondary schools are oversubscribed and the only way the children from these homes to get to schools is for them to either be bussed or driven to schools further afield which will create more traffic on the congested roads.
4 the nearest Police, Fire, Ambulance and Hospital are all in Luton in Bedfordshire yet the homes will be in Hertfordshire so they will be paying their Council tax to Hertfordshire County Council.

The best area for the development of this housing would be to the West of Luton where not only the housing but the required infrastructure could be provided.

Infrastructure and transportation networks are inadequately addressed in the parts of the plan relating sites East of Luton, to meet Luton's Unmet Housing Need East of Luton. I object that there is no justifiable need to declassify Land East of Luton from the Green Belt. There are many viable alternatives, so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary." I wish to change this plan. I want to participate in the Examination.

This will impact all of Luton; Wigmore, Stopsley, Eaton Green, and even Round Green, Stockingstone Road, and even the over-stretched Luton and Dunstable Hospital! The loss of green space will have a detrimental effect on the health and well-being of local residents, both those in Cockernhoe and in the Wigmore and Stopsley areas.

Building more than 2,105 houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which is planned simultaneously for this side of town. Air quality and pollution has not been assessed in the residential areas around the airport.

The Transport Assessments were not robust. The their data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity, they were not carried out for long enough, and some studies from Luton Borough Council assumed roads that did not even exist. Traffic congestion in Wigmore is at unacceptable levels, especially during the rush hours.

Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.

The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.

If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.

Wigmore currently consists of about 4,500 houses, so this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.

Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.

There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.

The unmet housing need figure also shows inaccuracies. During Executive Meetings LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment to re-examine once more the Unmet Housing Need figure assumptions, due to their estimated nature but far-reaching consequences and drastic impact upon the area. Luton's unmet housing need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.

So please consider this as my notification that I wish to change the Local Plan and participate in the Examination.

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I write on behalf of our client London Luton Airport Operations Limited (LLAOL)
with regard to the current consultation on the draft proposed submission Local
Plan for North Hertfordshire district.
As highlighted within previous representations on the emerging Local Plan
(preferred options consultation paper) consultation in December 2014, London
Luton Airport (LLA) has a sphere of influence, which extends beyond its
immediate vicinity into surrounding districts, including North Hertfordshire.
The current consultation relates to the Draft Proposed Submission Local Plan,
and LLAOL considers it appropriate to refer to the test of soundness as outlined
within paragraph 182 of the National Planning Policy Framework (NPPF) as
follows:
"A local planning authority should submit a plan for examination which it
considers is "sound" - namely that it is:
* Positively prepared - the plan should be prepared based on a strategy
which seeks to meet objectively assessed development and
infrastructure requirements, including unmet requirements from
neighbouring authorities where it is reasonable to do so and consistent
with achieving sustainable development;
* Justified - the plan should be the most appropriate strategy, when
considered against the reasonable alternatives, based on proportionate
evidence;
* Effective - the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities; and
* Consistent with national policy - the plan should enable the delivery of
sustainable development in accordance with the policies in the
Framework."
Should the Local Plan fail to acknowledge (to a suitable level), the presence of
LLA and its strategic importance, and not incorporate appropriate policies in
order to protect its on going and future operations, there is a risk that the plan
can be found unsound at examination.
LLA plays a pivotal role in the economy of the local area and surrounding subregions.
Along with the M1 and local railway connections, the airport provides accessibility for people and businesses alike. The accessibility that it facilitates helps to improve business performance and create jobs across all sectors.
In November 2015 Oxford Economics produced a report on "The economic
impact of London Luton Airport". The report found that in 2013 LLA sustained
16,000 local jobs contributing an economic value of £732 million to the local
economy (including direct annual business and expenditure, indirect supply
chain effects and the wages and salaries of workers). In the same year the
economic activity created by LLA contributed some £1.3 billion to UK GDP and
is estimated to have sustained 27,000 jobs.
It also stated that current growth proposals estimate that passenger numbers
will increase from 9.7 million in 2013 to 18 million in 2030, this will in turn
contribute £2.3 billion in UK GDP and is estimated to sustain 37,700 jobs.
Locally it is predicted that airport expansion will sustain 6,600 additional jobs by
2030.
The Aviation Policy Framework, March 2013, sets out the Government's
objectives for aviation. Paragraphs 1.1 - 1.3 states:
1.1 "The UK has always been an outward-looking nation - an island
economy that for centuries has owed its prosperity to the transport and
trade routes linking it with the rest of the world. With the increasing
globalisation of our economy and society, the future of the UK will
undoubtedly continue to be shaped by the effectiveness of its international transport networks.
1.2 We believe that aviation infrastructure plays an important role in contributing to economic growth through the connectivity it helps deliver.
For example, it provides better access to markets, enhances communications and business interactions, facilitates trade and investment and improves business efficiency through timesavings, reduced costs and improved reliability for business travellers and air freight operations.
1.3 There is broad agreement that aviation benefits the UK economy, both at
a national and a regional level. While views differ on the exact value of
this benefit, depending on the assumptions and definitions used,
responses to both the scoping document and the consultation
demonstrated that the economic benefits are significant, particularly
those benefits resulting from the connectivity provided by aviation. In
addition we believe there to be social and cultural benefits from aviation."
LLAOL fully supports this clear statement of the importance of aviation to the UK
economy and in general is happy that LLA's importance has been recognised to
an extent within the current draft of the Local Plan. However, LLAOL has
concerns regarding the strength of policies relating to protecting the interests of
LLA, by ensuring the development strategy for future developments do not
prejudice the airport's ongoing and future operations.
Having reviewed the draft submission Local Plan the following sections of this
representation highlight where it is felt the strategic importance of LLA should be
given further recognition.
Policy SP19: Sites EL1, EL2 & EL3 - East of Luton
As expressed in our previous representation LLAOL has no objection in principal
to the housing sites allocated within policy SP19. However, due to the proximity
of the sites to LLA (within 1,000m of the airport's boundary) there are a number
of points which should be addressed; specifically relating to noise and highway
impact.
Noise
The operation of LLA obviously has some implications with respect to noise.
With regard to housing proposals in close proximity to the airport, LLAOL wishes
to highlight paragraph 123 of the NPPF, of which bullet point 3 states:
"recognise that development will often create some noise and existing
businesses wanting to develop in continuance of their business should not
have unreasonable restrictions put on them because of changes in nearby
land uses since they were established".
LLAOL supports the inclusion of section j of policy SP19, which requires the
proposed housing sites to incorporate:
"j. Appropriate noise mitigation measures, to potentially include insulation
and appropriate orientation of living spaces;"
However whilst the inclusion of such a policy requirement is welcomed, LLAOL
does not believe that the current form of wording is strong enough to protect the
amenity of future residents or the interests of LLA in terms of noise. To that effect
we suggest the policy wording be amended to read:
"j. Sites EL1, EL2 and EL3 are within close proximity to London Luton
Airport, and therefore any schemes will need to demonstrate that
any noise issues have been appropriately addressed and internal
noise levels within any new homes are within relevant guidelines.
Appropriate noise mitigation measures should include insulation
and appropriate orientation of living spaces"
Highway impact
Given the close proximity to LLA, the potential impacts of the proposed
development sites (EL1, EL2 and EL3) on the surrounding highway network are
a key concern to LLAOL. Within the supporting evidence of the Local Plan
preferred options consultation paper, it was outlined that Transport Assessments
would be required for all three sites within policy SP19 in order to assess the
impacts of the developments upon Luton and the M1 motorway.
Within our previous representation LLAOL requested that these Transport
Assessments also consider the transport impacts of the proposed housing sites
on the accessibility and operation of LLA. As outlined, the airport currently has
planning permission to expand capacity to 18mppa. LLAOL's masterplan covers
the period to 2028, so this expansion would be delivered within North
Hertfordshire District Council's proposed Local Plan period. Any Transport
Assessment for the allocated sites will therefore need to consider this permitted
increase in operational capacity. We suggest the following wording is added to
policy SP19:
"As part of any development proposal a Transport Assessment must be
undertaken in order to assess the impacts of the development upon
Luton, the M1 motorway and London Luton Airport."
With regard to the above comments relating to noise and highway impacts,
LLAOL would also like to formally request to be involved in the master planning
process, in order to ensure that airport-related matters are appropriately
addressed during the design stage. This would help ensure that final master
plans are appropriate and consider all issues, and reduce the potential of any
future objections to the development proposals on airport-related grounds. We
therefore request that the following wording be incorporated within the policy
supporting text:
"During master plan development London Luton Airport Operations
Limited should be consulted in order to ensure that airport-related
matters are appropriately addressed."
Should such policies/paragraphs fail to be incorporated into the Local Plan, there
is the potential that the plan could be found un-sound during examination.
KW1: Land west of The Heath, Breachwood Green
Due to the location of the proposed Breachwood Green housing site (KW1)
noise is a key consideration for developments in the area. LLAOL therefore fully
supports the inclusion on paragraph 13.180 of:
"Breachwood Green is located on the approach and departure flightpaths
from Luton airport and any schemes will need to demonstrate that noise
issues have been appropriately addressed and that internal noise levels within
any new homes are within relevant guideline levels."
SI1: Land South of Waterdell Lane & SI2 Land South of Stevenage Road
Although these sites are located some way from LLA, they do lie under the
departure flight path and therefore have the potential to be impacted by noise
from airport activity. LLAOL therefore requests that a paragraph is included
within the supporting text that acknowledges the location of those sites under
the flight path and that development proposals take account of noise-related
issues. We suggest such a paragraph be worded as follows:
"St Ippolyts is located under the departure flight path from London
Luton Airport and any schemes will need to demonstrate that noise
issues have been appropriately addressed and that internal noise levels
within any new homes are within relevant guideline levels."
Conclusion
In general LLAOL supports the proposals within the North Hertfordshire Draft
Submission Local Plan 2011-2031.
Specifically, LLAOL wishes to support the plan's acknowledgement of the
airport's presence. However as stated LLAOL considers it to be of maxiumum
importance for the plan to recognise LLA's strategic significance, specifically its
existing and future contribution to the national and regional economy. It is vital
that this significance is properly reflected within local planning policy and that
future proposals for new development within the area do not constrain the
operation of LLA, either now or in the future.
LLAOL therefore respectfully requests that the considerations provided within
this consultation response be reflected within any further modifications of the
North Hertfordshire Local Plan.
We trust that these comments will be fully considered in the continued
progression of the Local Plan. Please do not hesitate to contact us should you
have any queries in relation to the content of this letter.

Our nation and our planet need Green Belts and areas.
Please let common sense prevail before it is to late for us and our grandchildren.

I want to participate in the examination stage for NHDC local plan 2011-30, and wish to change parts of the plan under pre-submission/regulation 19. The area I object to is EL1/2 & 3. Government guidelines state that communities should not coalesce, but this is exactly what will happen under this plan. This area is part of the green belt, and Luton residents cannot afford too lose this. I notice in your Local Plan, you wish to make land between Offley and Whitwell that is presently outside the Green Belt, and change it's designation into Green Belt. This would only benefit the rich landowner, who owns this complete area. There is no infrastructure to support this development. The roads that this development would impinge on cannot cope with the traffic at the moment, 2000 buildings would mean between 2-3000 extra vehicles per day, most of these would be moving within a two hour period, morning and evening. The Doctors, Dentists, Schools, Police, Fire, Ambulance, Hospitals that are nearest to this area are all in Luton, and could not cope with this influx. Luton Council Taxpayers fund all the precepts for these, North Herts Council Taxpayers would be using these services and be paying nothing for the privilege. Residents in Luton would go further down the waiting list. No consideration in your plans have been given for the Luton Airport expansion plans and the increased pollution this will bring to this area, depending on weather conditions, kerosene fumes are often smelt and tasted in this area. What NHDC needs to look at are more smaller developments around the villages in North Herts that your plans do not include. This means 1 and 2 bed bungalows, that the residents of much larger properties would like to buy, myself included. This would free up these much larger properties for those who need them, but no government or council seems to recognise this kind of thinking. Be the first ?.
NHDC local plan makes much of this area meeting Luton's unmet housing needs, none of Luton's residents will be able to afford the houses in this development. As there is less than 20 percent social housing in this site, are they going to restricted to those on Luton's housing waiting list, I doubt it.
Luton would not have an unmet need for housing, if they developed the Bushwood site. When the M1 motorway was built, two large tunnels where installed for future access to this area, where housing was planned for, they are still there and waiting. As I understand it Central Bedfordshire Council have not co-operated in the use of this valuable plot, that has all the infrastructure within a very distance, roads, services close proximity to the motorway, and hospital, this area is ideal for Luton's needs. Your plan specifically excludes the land west of Stevenage for development, you seem to want to keep this for future use, post 2061. This is illogical, especially as all infrastructure is close by. When the inspectorate from the Government is involved, I suggest that he visits all sites, and talks to local residents in the street, not make his decision from his office.

I strongly object to the above document, especially the sites EL1, EL2 and EL3 which affect the settlements of Cockernhoe, Mangrove Green and Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wanden End, Wigmore and Brick Kiln Lane. The following are my reasons.

The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, while protecting those area that are valued most, including the Green Belts. This area is Green Belt and the applications do not meet the 'Very Special Circumstances' required to build on as stated in Paragraphs 80 and 83 of the National Plannning Framework and also the House of Commons briefing note on the Green Belt. 'The Green Belt boundaries should not be amended in response to individual planning applications on Green Belt'. (para 83). Luton's unmet need does not class as an exceptional circumstance, nor will the unmet need outweigh the harm to the Green Belt. The land under this section of Green Belt is an important recreational area, and vital to a wide range of wildlife. By its own admission Luton has sufficient Brown field sites within its boundaries to meet its need. Therefore would development only be permitted in this area if Luton could make an exceptional case for it being the only possible area to meet its unmet needs??

The removal of the Green Belt will leave this land unprotected and open to the applications from developers. There are at present 205 dwellings in the 3 settlements covered by this area. The land is presently being sought by developers for building 2100 dwellings of which only 150 are for North Herts. use, the remaining 1950 are for Luton's unmet needs. The three existing settlements will be entirely swamped by this level of development and are bound to lose their sense of identity and individuality.

Such a development does not seem to have been adequately researched. Schooling, medical, social and emergency service provision have so far not been fully explained, and there is no provision for extra transport infrastructure to cope with the proposed development. Towards Hitchin there are only 2 narrow roads with passing places, and towards Luton there are roads which already have severe queues at junctions leading to the town centre, Vauxhalls and the motorway. Add to this the extra traffic generation through the development of the airport (an extra 9.25 million passengers by 2030), new business areas planned to the east of the airport, the developments on the Vauxhall site and traffic congestion continues to grow before this new development from North Herts sends extra cars towards the town and motorway. Luton is expecting an extra spine road to be built to the A505 at Lilley. In the North Herts report Page 72 para 4.222 it states that 'this development could not be accommodated without a significant adverse impact on the wider highway networks of Luton and Hertfordshire' - including access into and through Hitchin.

I trust these points will be taken into consideration. I want to participate in the Examination Stages for the NHDC Local Plan 2011 - 2030 and wish to see changes made to parts of the Plan.

I strongly object to the above document, especially the sites EL1, EL2 and EL3 which affect the settlements of Cockernhoe, Mangrove Green and Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wanden End, Wigmore and Brick Kiln Lane. The following are my reasons.

The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, while protecting those area that are valued most, including the Green Belts. This area is Green Belt and the applications do not meet the 'Very Special Circumstances' required to build on as stated in Paragraphs 80 and 83 of the National Plannning Framework and also the House of Commons briefing note on the Green Belt. 'The Green Belt boundaries should not be amended in response to individual planning applications on Green Belt'. (para 83). Luton's unmet need does not class as an exceptional circumstance, nor will the unmet need outweigh the harm to the Green Belt. The land under this section of Green Belt is an important recreational area, and vital to a wide range of wildlife. By its own admission Luton has sufficient Brown field sites within its boundaries to meet its need. Therefore would development only be permitted in this area if Luton could make an exceptional case for it being the only possible area to meet its unmet needs??

The removal of the Green Belt will leave this land unprotected and open to the applications from developers. There are at present 205 dwellings in the 3 settlements covered by this area. The land is presently being sought by developers for building 2100 dwellings of which only 150 are for North Herts. use, the remaining 1950 are for Luton's unmet needs. The three existing settlements will be entirely swamped by this level of development and are bound to lose their sense of identity and individuality.

Such a development does not seem to have been adequately researched. Schooling, medical, social and emergency service provision have so far not been fully explained, and there is no provision for extra transport infrastructure to cope with the proposed development. Towards Hitchin there are only 2 narrow roads with passing places, and towards Luton there are roads which already have severe queues at junctions leading to the town centre, Vauxhalls and the motorway. Add to this the extra traffic generation through the development of the airport (an extra 9.25 million passengers by 2030), new business areas planned to the east of the airport, the developments on the Vauxhall site and traffic congestion continues to grow before this new development from North Herts sends extra cars towards the town and motorway. Luton is expecting an extra spine road to be built to the A505 at Lilley. In the North Herts report Page 72 para 4.222 it states that 'this development could not be accommodated without a significant adverse impact on the wider highway networks of Luton and Hertfordshire' - including access into and through Hitchin.

I trust these points will be taken into consideration. I want to participate in the Examination Stages for the NHDC Local Plan 2011 - 2030 and wish to see changes made to parts of the Plan.

It is with great dismay that I learn yet again of the intention to develop on land to the east of Luton. I thought this had been eradicated but it has reared its ugly head again. When are they going to get the message they are NOT wanted here? Apart from the fact that they want to destroy an area of outstanding natural beauty, destroy wildlife (i.e deer, red kites, buzzards etc.) habitat, there is no infrastructure to accommodate the building of more homes. There are no major roads in the area to accommodate the extra 2000 plus cars .The Wigmore area is already at full capacity. Also the emergency services wouldn't be able to cope. Developers are not interested in building to house people, they are only interested in making money, regardless of who they upset. If they have to build, there are other sites to the west & north of Luton that are considerably less attractive, to build on. There is a large population on the Wigmore side of Luton and nobody wants the green belt touched. Please leave it untouched so the wildlife can live in peace and unthreatened, and the human population can continue to walk and enjoy this beautiful part of the world.

I strongly object to the NHDC Local Plan 2011-2031.

Infrastructure and transportation networks are inadequately addressed in the parts of the plan relating sites East of Luton, to meet Luton's Unmet Housing Need East of Luton. I object that there is no justifiable need to declassify Land East of Luton from the Green Belt. There are many viable alternatives, so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary." I wish to change this plan. I want to participate in the Examination.


This will impact all of Luton; Wigmore, Stopsley, Eaton Green, and even Round Green, Stockingstone Road, and even the over-stretched Luton and Dunstable Hospital!

Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport.

The Transport Assessments were not robust. The their data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity, they were not carried out for long enough, and some studies from Luton Borough Council assumed roads that did not even exist. Traffic congestion in Wigmore is unacceptable levels.

Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.

The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.

If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.


Wigmore currently consists of about 4,500 houses, so this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.


Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.

There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.

The unmet housing need figure also shows inaccuracies. During Executive Meetings LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment to re-examine once more the Unmet Housing Need figure assumptions, due to their estimated nature but far-reaching consequences and drastic impact upon the area. Luton's unmet housing need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.

So consider this written address that I wish to change the Local Plan and participate in the Examination.

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I have lived in Copthorne Stopsley for over 30 years and I last wrote to you in February 2015 objecting to the proposed massive home building proposals.

We now have Plans for over 2000 additional homes and Airport Expansion/ Business Park that will attract another 7,000 Employees. We have the building under way on the old Vauxhall ground in Kimpton Road, and a new School being built in Gypsy Lane, all that in itself is going to generate a few Thousand more vehicles in this small congested area.

Wigmore Lane, Eaton Green Road and Crawley Green Road
The prospect of this going ahead is absolutely frightening and really scares me. The local Roads where I live namely Wigmore Lane, Eaton Green Road and Crawley Green Road that are already congested with traffic at peak times will not be able to cope with any of this expansion in vehicle movements.

Any New road linking with the A505 will not stop the traffic from using these 3 Roads for access into Luton Town Centre or getting to the Asda Store and other shops areas including Stopsley Village. These 3 roads will still be the main method of choice for thousands of drivers making their way to the M1. If all this building and Airport Expansion were to go ahead it would be complete madness resulting in no assessable Roads to Luton and destroying our lives.

It is with great dismay that I learn yet again of the intention to develop on land to the east of Luton. I thought this had been eradicated but it has reared its ugly head again. When are they going to get the message they are NOT wanted here? Apart from the fact that they want to destroy an area of outstanding natural beauty, destroy wildlife (i.e deer, red kites, buzzards etc.) habitat, there is no infrastructure to accommodate the building of more homes. There are no major roads in the area to accommodate the extra 2000 plus cars .The Wigmore area is already at full capacity. Also the emergency services wouldn't be able to cope. Developers are not interested in building to house people, they are only interested in making money, regardless of who they upset. If they have to build, there are other sites to the west & north of Luton that are considerably less attractive, to build on. There is a large population on the Wigmore side of Luton and nobody wants the green belt touched. Please leave it untouched so the wildlife can live in peace and unthreatened, and the human population can continue to walk and enjoy this beautiful part of the world.

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