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

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I wish to object to the building plans for the East of Luton on the following grounds:
1. You would be covering an area of outstanding beauty which is totally unnecessary as there are many brown field sites available in Luton for development for housing.
2. The local roads already gridlock at peak times. It can take up to an hour to get into the town centre from my house during rush hour - 3.5 miles. During the summer it was taking me 30 minutes to get past the airport to M1 junction 10 - just 3 miles. With this additional housing, the traffic will only worsen as the traffic will have to come through my area to get to the town centre or to exit the town.
3. The number of houses in the proposed development is out of proportion with the small villages that will be swallowed up.

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I wish to object to the NHDC local plan.
Firstly, in relation to the removal of land from Green Belt status, east of Luton for development of housing, to meet Luton's Unmet Need, this is not an exceptional circumstance because there is evidence that there is sufficient Brown Field Land to build the 2,100 dwellings, at the same density, within Luton's existing boundaries. An Unmet need is unlikely to outweigh the harm to the Green Belt unless there are very Special Circumstances (National Planning Policy Framework).
Secondly, the proposal is completely out of proportion. Currently there are 205 dwellings in Cockernhoe, Tea Green and Mangrove Green; an additional 2,100 dwellings will be an increase of 1025%. This increase represents over 14% of the total for the whole of NHDC Local Plan. These villages will cease to exist and their integrity will be lost.
Thirdly, there is no planned improvement to infrastructure in the NHDC Local Plan, neither into Luton nor to the two country lanes from Luton into North Hertfordshire. Potentially 2,100 houses will create 4,000-5,000 additional vehicle movements.
Fourthly, this is likely to be compounded by a massive increase in traffic owing to Luton Airport expansion, with regard to both projected passenger numbers of 22 million by 2030 and 7,000 new jobs. 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. Bloor Homes @Access and Masterplan slides see www.wanden park.co.uk (Newly constructed Relief Road linking Luton Road with Chalk Hill...). This suggests they expect a spine road to be built despite NHDC having no plans for this road development; however, NHDC state on page 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 networks of Luton and Hertfordshire. The views of North Herts and Luton are contradictory.
Lastly, Luton Borough Council have also proposed locating a new Airport Business Park and Century Park at Wandon End. This is a rural area near the airport accessed at present by narrow country lanes. Is the proposed spine road that is referred to above to service this new facility despite no provision by NHDC for a road. The NHDC Local Plan, Section Two: Spacial Strategy and Strategic Policies -c,iii states we will: provide the necessary infrastructure required to support an increasing population and c.iv states protect key elements of North Hertfordshire's environment including important landscapes, heritage assets and green infrastructure. The area of the proposed development is close to a designated AONB and if a spine road is built it will impact on this area as such a road would be likely to cut through it if it is to join to the A505 at the junction of Lilley. The loss of wildlife habitat and an amenity resource for both Luton residents, North Hertfordshire residents and from elsewhere is also a consequence of this plan.

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I wish to object to the NHDC local plan.
Firstly, in relation to the removal of land from Green Belt status, east of Luton for development of housing, to meet Luton's Unmet Need, this is not an exceptional circumstance because there is evidence that there is sufficient Brown Field Land to build the 2,100 dwellings, at the same density, within Luton's existing boundaries. An Unmet need is unlikely to outweigh the harm to the Green Belt unless there are very Special Circumstances (National Planning Policy Framework).
Secondly, the proposal is completely out of proportion. Currently there are 205 dwellings in Cockernhoe, Tea Green and Mangrove Green; an additional 2,100 dwellings will be an increase of 1025%. This increase represents over 14% of the total for the whole of NHDC Local Plan. These villages will cease to exist and their integrity will be lost.
Thirdly, there is no planned improvement to infrastructure in the NHDC Local Plan, neither into Luton nor to the two country lanes from Luton into North Hertfordshire. Potentially 2,100 houses will create 4,000-5,000 additional vehicle movements.
Fourthly, this is likely to be compounded by a massive increase in traffic owing to Luton Airport expansion, with regard to both projected passenger numbers of 22 million by 2030 and 7,000 new jobs. 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. Bloor Homes @Access and Masterplan slides see www.wanden park.co.uk (Newly constructed Relief Road linking Luton Road with Chalk Hill...). This suggests they expect a spine road to be built despite NHDC having no plans for this road development; however, NHDC state on page 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 networks of Luton and Hertfordshire. The views of North Herts and Luton are contradictory.
Lastly, Luton Borough Council have also proposed locating a new Airport Business Park and Century Park at Wandon End. This is a rural area near the airport accessed at present by narrow country lanes. Is the proposed spine road that is referred to above to service this new facility despite no provision by NHDC for a road. The NHDC Local Plan, Section Two: Spacial Strategy and Strategic Policies -c,iii states we will: provide the necessary infrastructure required to support an increasing population and c.iv states protect key elements of North Hertfordshire's environment including important landscapes, heritage assets and green infrastructure. The area of the proposed development is close to a designated AONB and if a spine road is built it will impact on this area as such a road would be likely to cut through it if it is to join to the A505 at the junction of Lilley. The loss of wildlife habitat and an amenity resource for both Luton residents, North Hertfordshire residents and from elsewhere is also a consequence of this plan.

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I object to the NHDC Local Plan 2011-2031. I want to participate in all examination stages and I want to change many parts of this Local Plan.

Should this plan go ahead there will be no going back; concrete would never be reverted back to the green & pleasant land we have at present.

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. 2,105 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 & Mangrove Green would no longer exist. It would destroy an entire rural community as we know it. 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.
What about the EMPTY 'student accommodation' in Eaton Green Road? What a waste of money that has been.

I wish to lodge my strongest objection to this proposed development of 660 Houses.

This is GREEN BELT and as such it's there prevent the urban sprawl from engulfing the surrounding villages thus maintaining agriculture, protecting wild life, giving people access to open spaces and keeping the identity of rural villages, all of which this land currently does.

To lose it would be catastrophic as the fields are farmed / harvested every year, the woods, hedgerows etc.are home to numerous animals and birds some of which are protected species and the footpaths are used by walkers, runners. cyclists and horse riders.

Re infrastructure - Schools, Surgeries and roads are already struggling to cope, even Asda car park is full and shelves empty during peak times. To add potentially 1.5 to 2.5 thousand people is ridiculous.

I note the map of the site shows that the trees / undergrowth adjacent to the bridleway [Herts/Beds border] have been removed and replaced with stagnant ponds (SUDS) backing onto affordable housing (multi story flats?) this would encourage water born parasites and rats, thus destroying the pleasure of using the pathway,

I understand that housing is needed for the growing population, but I feel there is no justification for this development as there is adequate land and brown field sites around Luton or North Herts. Also it doesn't comply with government policy regarding green belt land.

I am writing to object to the NHDC Local Plan 2011-2031 Policy SP19 as being unsound

Infrastructure and transport networks are not adequate, to meet the requirements of 2100 new homes.

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."

The policy will have a significant impact on all of Luton, in particular Wigmore, Stopsley, and Round Green, and put even more strain on existing local resources such as The Luton and Dunstable Hospital, Ambulance, Police and Schools

Building 2100 new homes will also lead to additional road traffic for this already congested area, particularly the immediately adjacent wards of Wigmore and Stopsley and the roads from these wards to the M1. All these roads are often at a standstill during peak morning and evening weekday rush hours. In addition there is a risk that Crawley Green Road would be overwhelmed with the additional traffic.

The Transport Assessments were not sound. The data was not accurate; as it did not include the impact of all new developments in the vicinity, and they were not carried out for an adequate period of time,

Both Luton Borough Council and North Herts District Council have noted concerns over the lack of necessary infrastructure and inadequate road network, to support the already existing traffic levels.

There is no rail station within easy walking distance of the area discussed in SP19, so the majority of rail commuters will need to use road transport (bus or car), to access a railway

Please accept this representation as my objection to Policy SP19 as being unsound

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In essence I believe that for the Wigmore/Cockernhoe area

*The infrastructure and transportation networks are not inadequately addressed (something that both LBC and NHDC have both voiced concerns over)
*There is no justifiable need to declassify land east of Luton from its Green Belt status. Viable alternatives exist so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary"
*In light of the number of other planned projects/developments air quality and pollution caused by the road traffic (cars and other transport) has not been properly assessed in the residential areas around the airport
*Cockernhoe Village would no longer even exist - the proposal would destroy an entire rural community and it would change the character of the area to an unacceptably
*The transport assessments undertaken are questionable in that they did not seemingly include the impact of all new developments in the vicinity (see list below) they were not carried out over a long enough period, and supposedly some studies from LBC made assumptions about roads that did not even exist!.

This proposed development will have an impact on all of Luton; but Wigmore, Stopsley, Eaton Green, St Anne's, Round Green, Stockingstone Road, Vauxhall Way, New Airport Way and even as far as the already over-stretched Luton and Dunstable Hospital in particular

The building of 2000+ houses will add to the already unacceptable road congestion especially in the light of the Airport's general expansion, the Luton Airport industrial zone, the Napier Park/Sterling Plaza development and to a slightly lesser extent the Luton Town FC/ Power Court development, which are all planned simultaneously for this side of town.

If you consider that Cockernhoe village currently comprises approximately 50 houses then the expansion threat is a massive 4,000+ per cent! - this is wholly disproportionate. Wigmore area itself currently consists of some 4,500 houses, so the proposal is not far off a 50% expansion for the whole area, therefore for satisfactory provision of infrastructure to be maintained it must be matched by a 50% expansion in infrastructure - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing, fire and health services etc would need to be also expanded. One has to question where the money/space for all this will come from?
Please consider this correspondence as a request to change the Local Plan and participate in the Examination.

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I strongly object to the outline North Hertfordshire Local Plan 2011- 2031especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick kiln Lane, for the following reasons:

1.The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

2. There are 205 dwellings in Cockernhoe, Mangrove Green and Tea Green currently. An additional 2,100 dwellings will be an increase of 1124%. This development is completely out of proportion to all other developments in the district - these villages and communities will cease to exist.

3. Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs, a number which hasn't been qualified when challenged.

4. There is no planned improvement to the already stretched roads/infrastructure:

a. Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5,000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and ASOS suffer equally.

b. The traffic Survey carried out in 2015 was not done to industry standards i.e. for a month and also the results of this survey showed a negligible or nil effect on local congestion when the results, and thus the underpinning of the proposal, were based on a road that doesn't exist, hasn't been proposed and has been stated by the council that there is no money to develop.

c. In the shorter term, the projected airport development/ business park/ light industry, will attract a further 7,000 employees (ref. LBC). The roads cannot cope with this increase in vehicles.

d. The two country lanes with insufficient passing places which lead out of the site into North Herts are already being used as dangerous rat-runs. This will increase as residents seek to access the Ml via Lilley Bottom and Lilley, and seek to access Hitchin/Stevenage through Offley.

5. The paths and woodlands are used by villagers and people from neighbouring Luton as a leisure area for walking/running/cycling. These will be destroyed despite the national push to encourage people to keep fit.

6. In the presentation of the local plan Councillor Levitt stated that "...the development plays a key role in supporting the growth of our economy planning for the right type and number of homes, in the right place to create sustainable communities." How can a development only linking North Herts by two single track lanes be considered as a sustainable community?

7. There is sufficient brown field land in Luton to accommodate 'Luton's Unmet Need' at the same housing density as this proposed development.

8. Teeming wildlife, owls, bats, deer, foxes, etc., will be displaced. Wildlife corridors are no substitute.

9. By the councils own environmental study of 2007 it stated that the water table was insufficient to sustain a large scale development and that there is a high risk of subsidence. Has this been taken into consideration?

10. The environmental effects of the carbon emissions of 5,000+ additional vehicles on the roads will be detrimental to our children and grandchildren's health and wellbeing with the accompanying increase of the incidence of childhood asthma and respiratory problems and diseases such whooping cough.

I urge the council to strongly think again and exclude this section from their proposed plan.

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