ED224

With reference to the above I would draw your attention to the following seven extremely salient points. I would implore you to take these into account in your deliberations and to conclude that the EOL proposal should be deleted, in its entirety, from the proposed Local Plan;
• Because of significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan;
• An updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• These two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• The Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• Had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• All this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

All three residents in our house object to the North Herts DC Local Plan's proposed development of 2,100 homes EOL required solely to meet an unmet need from Luton of 9,300 homes calculated back in 2017 as argued in ED224, for the following reasons:
• Valuable Green Belt land: no adequate exceptional circumstances
• Luton's house building is much higher than 2017 forecast, updated assessed needs are lower, unmet needs reduced to around 2,000
• Luton's unmet needs have already been more than covered by Central Beds as the designated 'best fit' neighbour; with many already in build
• Luton's failure to require adequate family housing from developers.

I object to the north Herts DC local plan’s proposed development of 2100 homes EOL required solely to meet an unmet need from Luton of 9300 homes calculated in 2017 as argued in ED224, for the following reasons:
Valuable green belt land; no adequate exceptional circumstances Luton’s house building is much higher than 2017 forecast, updated assessed needs are lower, unmet needs reduced to around 2000 Luton’s unmet needs have already been more than covered by central beds as the designated best fit neighbour; with many already in build Luton’s failure to require adequate family housing from developers.

We object to the North Herts DC Local plan’s proposed development of 2100 homes EOL required solely to meet an unmet need from Luton of 9300 homes calculated in 2017 as argued in ED224, for the following reasons;

- valuable Green Belt land; no adequate exceptional circumstances
- Luton’s house building is much higher than 2017 forecast, updated assessed needs are lower, unmet needs needs reduced to circa 2000
- Luton’s unmet needs have already been more than covered by Central Beds as the designated ‘best fit’ Neighbour; with many already in build
- Luton’s failure to require adequate family housing from developers

I would like to object to the object to the proposed building of 2,100 homes on the Green Belt surrounding Cockernhoe, Mangrove Green, Tea Green and Wandon End.
Reference: ED224.
• because of significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan;
• an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds – the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

We object to the North Herts DC Local Plan's proposed development of 2,100 homes EOL required solely to meet an unmet need from Luton of 9,300 homes calculated in 2017 as argued in ED224, for the following reasons:
• Valuable Green Belt land; no adequate exceptional circumstances
• Luton's house building is much higher than 20017 forecast, updated assessed needs are lower, unmet needs reduced to around 2,000
• Luton's unmet needs have already been more than covered by Central Beds as the designated 'best fit' neighbour; with many already in build
• Luton's failure to require adequate family housing from developers.

We object to the North Herts DC Local Plan’s proposed development of 2,100 homes EOL required solely to meet unmet need from Luton of 9,300 homes calculated in 2017 as argued in ED224, for the following reasons:

Valuable Green Belt land; no adequate exceptional circumstances
Luton’s houses building is much higher than 2017 forecast, updated assessed needs are lower, unmet needs reduced to around 2,000
Luton’s unmet needs have already been more than covered by Central Beds as the designated ‘best fit’ neighbour; with many already in build
Luton’s failure to require adequate family housing from developers.

I object to the plans to build 2,100 houses on the Green Belt to the east of Luton and referencing ED224 for the following reasons
• due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
• an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

I wish to object to the plans you have to build 2,100 houses on the Green Belt to the east of Luton with reference to ED224.

Those of us residents of Cockernhoe, Mangrove Green and Wigmore who are campaigning against this development have carried out a painstaking review of publicly available information on Luton’s house building programme and housing requirements. This concludes, with fully supported evidence, that:

• due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
• an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

I am emailing to object to the plans to build 2,100 houses on the Green Belt to the east of Luton, reference: ED224 for the following reasons:
· due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
· an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
· these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
· the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
· had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
· all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
· Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

I am against the development for the following reasons

• due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
• an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

I wish to object to the plans to build 2,100 houses on the Green Belt to the east of Luton (reference ED224) and make the following representations:
• due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
• an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

I object to the plans to build 2,100 houses on the Green Belt to the east of Luton and reference ED224 for the following reasons.:
1) due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
2) an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
3) these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
4) the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it hasallocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
5) had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
6) all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds – the most important neighbouring local authority to Luton - was not a party to this Statement;
7) Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

Residents of Cockernhoe, Mangrove Green and Wigmore, I being one of those residents who are campaigning against this development have carried out a painstaking review of publicly available information on Luton’s house building programme and housing requirements. This concludes, with fully supported evidence, that:
• Due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
• An updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• These two facts mean the unmet housing needs from Luton drops to around 2,000 (16,700 -14,700), compared to
9,300 (17,800-8,500)in the Luton Local Plan;
• The Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• Had Luton carried out its review, these figures would have been formally identified; meaning that NHDC does not need to allow development at EOL;
• All this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans.
Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.
May I urge you to review this evidence in support of our opposing this development.

We object to the North Herts DC local plans proposed development of 2100 homes EOL required solely to meet an unmet need from Luton of 9300 homes calculated in 2017 as advised in ED224, for the following reasons:
-valuable green belt land; no adequate exceptional circumstances
-Luton’s house building is much higher than 2017 forecast, updated assessed needs are lower, unmet needs reduced to around 2000
-Luton’s unmet needs have already been more than covered by central beds as the designated ‘best fit’ neighbour; with many already in build
-Luton’s failure to require adequate family housing from developers
-extra pressure on Luton’s essential services despite this being a Hertfordshire development eg doctors, schools, hospitals and other essentials which are already under pressure with the existing population.

I object to the North Herts DC Local Plan’s (NHDC) proposed development of 2,100 homes East of Luton (EOL) required solely to meet an unmet need from Luton of 9,300 homes calculated in 2017 as argued in ED224, for the following reasons:-

1. Due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. Compared to 8,500 stated in the LBC Local Plan;
2. An updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
3. These two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800 - 8,500) in the Luton Local Plan;
4. The Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundred of those houses are already built or under construction;
5. Had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
6. All this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor homes and the Crown Estate sticking to the out-of-date numbers to continue justifying it’s EOL plans. Central Beds, the most important neighbouring local authority to Luton, was not a party to this Statement;

Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This of extreme concern but we believe our investigations have identified the accurate facts.

I OBJECT to the proposed building of 2,100 homes on the Green Belt surrounding Cockernhoe, Mangrove Green, Tea Green and Wandon End

I object to the North Herts District Council (NHDC) Local Plan of the proposed buildings on the GREENBELT, the proposal has been based on out of date evidence in document ED224.

ED224, defends the need for the development, known as “East of Luton” (EOL), but that has been based on HISTORICAL calculations.

The NHDC has included the EOL development in its Local Plan, but this is based on out-of-date information concerning Luton’s unmet housing needs.

Luton’s Local Plan was adopted in 2017 including a Policy LLP40 to Review its Local Plan commencing in 2019 and completing by mid-2021.

Luton has confirmed, this March, that the Review is at an early stage and it has no exact date when it will be finished. This is at least two years LATE. This failure to carry out the Review in due time means that the number of houses required and being built in Luton, and the resulting unmet need in the town, has not been formally updated, thus giving NHDC an excuse to continue to justify the need for the houses at EOL.

A review has been carried out using publically available information on Luton’s house building programme and housing requirements. This concludes, with fully supported evidence, that:

· because of significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan;

· an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;

· these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;

· the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;

· had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;

· all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds – the most important neighbouring local authority to Luton - was not a party to this Statement;

Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern as investigations have identified the accurate facts.

In summary the proposal to build on the greenbelt is based on out of date numbers. Greenbelt's can only be built on if there is a proven need for the housing which in this case there isn't.

The council carried out an independent review of the greenbelts in Luton (the greenbelt study) in 2014 that came to the conclusion "that the existing greenbelt areas in luton make substantial contributions to meeting greenbelt contributions as defined by the NPPF.

They are important areas of open land which should permanently remain free of inappropriate development so that they continue to function as greenbelt."

I OBJECT to the proposed building of 2,100 homes on the Green Belt surrounding Cockernhoe, Mangrove Green, Tea Green and Wandon End

I object to the North Herts District Council (NHDC) Local Plan of the proposed buildings on the GREENBELT, the proposal has been based on out of date evidence in document ED224.

ED224, defends the need for the development, known as “East of Luton” (EOL), but that has been based on HISTORICAL calculations.

The NHDC has included the EOL development in its Local Plan, but this is based on out-of-date information concerning Luton’s unmet housing needs.

Luton’s Local Plan was adopted in 2017 including a Policy LLP40 to Review its Local Plan commencing in 2019 and completing by mid-2021.

Luton has confirmed, this March, that the Review is at an early stage and it has no exact date when it will be finished. This is at least two years LATE. This failure to carry out the Review in due time means that the number of houses required and being built in Luton, and the resulting unmet need in the town, has not been formally updated, thus giving NHDC an excuse to continue to justify the need for the houses at EOL.

A review has been carried out using publically available information on Luton’s house building programme and housing requirements. This concludes, with fully supported evidence, that:

· because of significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan;

· an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;

· these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;

· the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;

· had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;

· all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;

Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern as investigations have identified the accurate facts.

In summary the proposal to build on the greenbelt is based on out of date numbers. Greenbelt's can only be built on if there is a proven need for the housing which in this case there isn't.

The council carried out an independent review of the greenbelts in Luton (the greenbelt study) in 2014 that came to the conclusion "that the existing greenbelt areas in Luton make substantial contributions to meeting greenbelt contributions as defined by the NPPF.

They are important areas of open land which should permanently remain free of inappropriate development so that they continue to function as greenbelt."

I object to the plans to build 2,100 houses on the Green Belt to the east of Luton ref ED224 for the following reasons.
• due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
• an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

We object to the North Herts DC Local Plan's proposed development of 2,100 homes EOL required solely to meet an unmet need from Luton of 9,300 homes calculated in 2017 as argued in ED224, for the following reasons:
. Valuable Green Belt land; no adequate exceptional circumstances
. Luton's house building is much higher than 2017 forecast, updated assessed needs are lower, unmet needs reduced to around 2,000
. Luton's unmet needs have already been more than covered by Central Beds as the designated 'best fit' neighbour; with many already in build
. Luton's failure to require adequate family housing from developers.

My husband and I wish to object to the proposed EOL housing development on the following grounds:
· due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
· an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
· these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
· the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
· had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
· all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
· Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

I wish to raise my objection to the proposed East of Luton housing development (ED224) in the strongest possible terms. My objection is based on the following points:
• Due to significantly increased grants of planning permission and public announcements, Luton will be building around 14700 houses through to 2031, compared to 8500 stated in the LBC Local Plan.
• An updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17800 through to 2031 would now be reduced to 16700.
• These two facts mean the unmet housing need from Luton drops to around 2000 (16700 - 14700), compared to 9300 (17800 - 8500) in the Luton Local Plan.
• The Luton Inspector - when giving the go ahead for the Luton Local Plan in 2017 – stated the ‘best fit’ for any unmet housing need was Central Beds which had committed to provide 7350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction.
• Had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL.
• All this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes, and the Crown Estate, sticking to the out-of-date numbers to continue to justify the EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not party to this Statement.
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern, but we believe our investigations have identified the accurate facts.
I would be grateful if you will ensure that the above points are fully taken into account and not allow these facts to be disregarded.

This is to register my objection to the North Herts District Council Local Plan's proposed development of 2,100 homes East of Luton.

These proposed homes are required solely to meet an unmet need from Luton of 9,300 homes, a figure calculated in 2017 (as argued in ED224). It has been shown by diligent and forensic work - carried out, documented and reported to the Plan Inspector by members of the local community - that these houses are no longer needed. Specifically:
• Luton Borough Council's house building has been much higher than its 2017 forecast.
• The updated assessed needs are now lower, with any unmet need now reduced to approximately 2,000 houses.
• Central Bedfordshire has been designated, and agreed, as the 'best fit' neighbour to whom Luton BC should turn first for any residual Luton need. To this end, Luton's unmet needs have already been more than covered by Central Beds, with many houses already being built.
• Luton BC itself has failed to require adequate family housing from developers. This is not an 'unmet need' which NHDC has any obligation to remedy.
Beyond the practical and incontrovertible facts above, a further crucial point to emphasise is that the proposed houses would be sited on extremely valuable Green Belt land. In light of the circumstances stated above, no exceptional circumstances exist to justify the desecration of this Green Belt land.

We object to the North Herts DC Local Plan's proposed development of 2,100 homes EOL required solely to meet an unmet need from Luton of 9,300 homes calculated in 2017 as argued in ED224, for the following reasons:

1. Valuable Green Belt land; no adequate exceptional circumstances.
2. Luton's house building is much higher than 2017 forecast, updated assessed needs are lower, unmet needs reduced to around 2,000
3. Luton's unmet needs have already been more than covered by Central Beds as the designated 'best fit' neighbour; with many already in build
4. Luton's failure to require adequate family housing from developers.

I object to the North Herts DC Local Plan's proposed development of 2,100 homes EOL required solely to meet an unmet need from Luton of 9,300 homes calculated in 2017 as argued in ED224, for the following reasons: •

Valuable Green Belt land; no adequate exceptional circumstances •

Luton's house building is much higher than 2017 forecast, updated assessed needs are lower, unmet needs reduced to around 2,000

Luton's unmet needs have already been more than covered by Central Beds as the designated 'best fit' neighbour; with many already in build

Luton's failure to require adequate family housing from developers.

I object to the NHDC Local Plan for the proposed building of 2,100 homes on the Green Belt surrounding Cockernhoe, Mangrove Green, Tea Green and Wandon End on the following grounds:
• because of significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan;
• an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• all this information is known to NHDC yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• there is no evidence that NHDC officials and Councillors have carried out due diligence on Luton’s housing figures.

I object to the proposed building of 2,100 homes on the Green Belt surrounding Cockernhoe, Mangrove Green, Tea Green and Wandon End for the following reasons. Evidence Document ED224 defends the need for the development known as “East of Luton” (EOL), based on historically calculated dwelling numbers, and is used by North Herts District Council (NHDC) in its Local Plan, however, ED224 is outdated. Luton Council has confirmed that it is currently reviewing its Local Plan so at present, there is no up to date information regarding the unmet housing need in Luton.

A painstaking review of publicly available information on Luton’s house building programme and housing requirements, made by local residents, has provided evidence that:

1. Because of significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031, compared to 8,500 as stated in the LBC Local Plan;

2. An updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;

3. These two facts mean that the unmet housing need from Luton drops to around 2,000 (16,700 - 14,700), compared to 9,300 (17,800 - 8,500) in the Luton Local Plan;

4. The Luton inspector - when giving the go-ahead for the Luton Local Plan in 2017 – stated that the ‘best fit’ for any unmet housing need was Central Beds, which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings. Hundreds of those houses are already built or under construction;

5. Had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;

6. All this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Bloor Homes and the Crown Estate, sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;

7. Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern, but we believe our investigations have identified the accurate facts.

Those of us residents of Cockernhoe, Mangrove Green and Wigmore who are campaigning against this development have carried out a painstaking review of publicly available information on Luton’s house building programme and housing requirements. This concludes, with fully supported evidence, that:
• due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
•an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 – stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.

I am writing to object to the North Herts District Council Local Plan’s proposed development of 2,100 homes, named East of Luton.

As you are probably aware, the way you have calculated the unmet need for Luton’s homes from Evidence Document ED224 is completely out of date and therefore totally inaccurate.

The reasons they are wrong are;

- Because of significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031, compared to 8,500 stated in the LBC Local Plan.
- An updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would be reduced to 16,700.
- These two facts mean the unmet housing need for Luton drops to around 2,000 compared to 9,300 in the Luton Local Plan.
- The Luton Inspector, when giving the go ahead for the Luton Local Plan in 2017, stated the ‘best fit’ for any unmet housing need was Central Bedfordshire which has committed to provide 7,350 dwellings. It has allocated 20 sites with capacity for at least 8,850 dwellings. Hundreds of those houses are already under construction.
- Had Luton carried out it’s Review on time, these figures would have already come to light, meaning the NHDC does not have to allow EOL.
- EOL will be building on the valuable green belt land of North Herts, with no exceptional circumstances.
- Lastly, there is no evidence that NHDC officials and Councillors have carried out any due diligence on Luton’s housing figures, which is obviously not good enough.

I know that NHDC is aware of all these facts, but you still continue to press ahead with something that the people of North Herts do not want.
It seems to me that North Herts District Councillors have forgotten the reason for their job, to make decisions and run a council on behalf of the residents of North Herts and building on North Herts green belt is not in the best interests of your residents and was not what we have just voted for.

I will conclude by, again, stating my unreserved objection to the East of Luton expansion and of NHDC allowing building on our green belt.

I objected to the building of houses on the Green Belt land to the east of Luton a few years ago and understand that this is now back on the radar, however I still wish to clearly state my objections to this and reference ED224 in my objections and my reasons are outlined below:
• due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
• an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;
• all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern but we believe our investigations have identified the accurate facts.