ED224

Despite all the following information being known by North Herts District Council (NHD), it signed a Statement of Common Ground in December 2020 (ED224).

• NHDC has included the EOL development in its Local Plan based on out of date information about Luton’s unmet housing needs. Luton confirmed in March that the review of their Local Plan (adopted in 2017) is still at an early stage when it was supposed to have been reviewed and updated by mid 2021. This means that Luton’s unmet housing need has not been updated.
• A thorough review of publicly available information on Luton’s house building programme and housing requirements has shown that Luton will be building c. 14,700 houses through to 2031 compared to the 8,500 stated in LBC’s Local Plan (an increase of 6,200)
• In August 2020, Opinion Research Services carried out an analysis of Luton’s housing needs at the request of the North Herts District Council’s Inspector. This showed that the previous housing requirement of 17,800 through to 2031 could now be reduced to 16,700 (a reduction of 1,100.)
• This means that Luton’s updated unmet housing need is now around 2,000 (16,700 need identified in the August 2020 ORS analysis minus the 14,700 with planning permission to 2031).
• Moreover, the Luton Inspector, when agreeing to the 2017 Luton Local Plan, stated that the ‘best fit’ for any unmet housing need was in Central Bedfordshire which has committed to 7,350 homes and actually has the capacity for at least 8,850. many of which are already built or under construction

I strongly object to NHDC including the proposed building of 2,100 houses in Green Belt surrounding the villages of Cockernhoe, Mangrove Green, Tea Green and Wandon End to meet Luton’s unmet housing need. As stated above, Luton can no longer demonstrate that there is an unmet need and their own inspector has stated that the preferred location for housing is in Central Bedfordshire which has the capacity.

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.

We have previously objected to your proposal to build 2100 homes on green belt land (East of Luton) and are disappointed to see that, despite all the arguments that have been put forward to dispute the need for these, your Evidence Document ED224 (the Statement of Common Ground between NHDC, Luton Borough Council and Crown Estates) of December 2020 continues to insist that the 2,100 houses proposed around Cockernhoe are necessary to help meet Luton's unmet needs.

It pains us to have to contact you yet again to point out to you that these homes are not necessary and because of this we must register our objection to your documentED224 for the following reasons:

Residents of Cockernhoe, Mangrove Green and Wigmore have carried out a painstaking review of publicly available information on Luton’s house building programme and housing requirements and conclude - 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 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 from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its planned Review, these figures would have come to light formally confirming 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;
• Finally, 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 causes extreme concern- but we believe our investigations have identified the accurate facts.
We hope that, on reflection, you will give this ill though-out proposal your urgent reconsideration.

I am writing to you as I believe that the final consultation has commenced on the North Herts District Council Local Plan, and I am very concerned about the suggestion that 2,100 home are required (according to Luton Borough Council) to be built on the green belt area, which is predominantly Crown Property bordering Luton and Cockernhoe, and taking in the area around Mangrove Green, Tea Green and Wandon End.
I live on the corner property within the Luton town boundary, next to where there is a planned roundabout on Luton Road designated to be the only residential access point on to the estate to the north of this area, and beside two planned soak-aways.
There are several concerns that I have regarding these plans. Firstly, I do not believe that sufficient regard has been given to the drainage for this estate – there have been numerous flooding incidents in the past six months, when that field was not cultivated, and water built up in the natural bowl at the bottom of the hill, and causing flooding to the road, and bridlepath (on both sides). This is before any concrete has been laid. The flooding was only resolved once the field was again cultivated, after I brought this matter to the attention of LBC.
My next point of concern is the amount of traffic that would be using this roundabout, and the fact that Luton Road/Crawley Green Road already has plenty of traffic, particularly through rush hours and on school days. There is also no consideration been given to the increase in the amount of traffic which will head both out and in on the country lanes behind Cockernhoe and Tea Green in order to access the A505 and Whitwell through Lilley Bottom Road.

Finally, the whole reasoning behind this development in the first place has now been thrown into doubt on two counts - that the LBC Local Plan figures used to argue the case were outdated almost from the start, as the facts below demonstrate:
• 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 I believe these investigations have identified the accurate facts.
In addition, since the pandemic it is quite obvious that LBC needs to re-assess much of the current office space in the town, as working practices are likely to be very different post pandemic, and many office buildings will be superfluous, and will need to be re-designated and redeveloped into residential properties.

I trust that you can understand my concerns and feel my annoyance that this planning application is still being considered after almost seven years of consultations, when many residents, like myself have argued against this reckless desire to build on wonderful green belt countryside, which has been a haven for many during the course of the pandemic.

We object to the EOL plans, the Evidence Document, ED224 from NHDC is based on out of date information concerning Luton,s unmet housing needs. Luton's Local Plan was adopted in 2017, included a Policy LLP40 to review it's Local Plan, Luton has confirmed this March this review is at an early stage and no exact date as to when it will be finished. It is at least two years late. Local Residents have carried out a review of publicly available information on Luton,s house building programme and housing requirements. The conclusion with fully supported Evidence is as follows,
due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. Compared to the 8500 stated in LBC Local Plan, these are on brownfield sites,
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,
these two facts mean the unmet housing need from Luton drops to about 2,000 (16,700 - 14,700), compared to 9,300 in the Luton Local Plan,
the Luton Inspector - when passing the Luton Local Plan in 2017, stated the 'best fit' for any unmet housing needs was Central Bedfordshire which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with a capacity of at least 8,850 dwellings from which to provide that help to Luton's unmet housing needs. Hundreds those houses have already been built or are under construction.
had Luton already carried out it's review, these figures would already come to light formally. This means NHDC does not need to allow the East of Luton development.
all of this is known to NHDC and yet it signed a Statement of Common Ground in December with Luton, Blood Homes and The Crown Estate, still using the out of date figure to justify it's plans for the EOL development. Central Bedfordshire Council the most important Local Authority was not involved with this Statement.
Furthermore, there is no evidence that NHDC officials or it's Councillors have carried out due diligence on Luton's housing figures. This is extremely concerning but we believe our investigation has identified the true and accurate facts.
So we most strongly object to the plan to build 2,100 houses to the East of Luton for these reasons.

We have submitted and posted our objection to Strategic Planning and Projects Group, North Hertfordshire District Council concerning The Threat to Wigmore Residents.
The following reasons for our objection are:-

*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 Beds as the designated “best fit” neighbour; with many already in build.

*Luton’s failure to require adequate family housing from developers.

Offley Parish Council wish to object to the North Herts DC Local Plan’s proposed development of 2,100 homes East of Luton 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 development. It is proposed to meet Luton's unmet housing needs. Luton's Local Plan of 2017 is currently being reviewed (Ref Policy LLP40) and Luton's housing needs will only be known on completion of the review. The EOL development is therefore based on outdated information, and should consider the following;
1. As a result of 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 Local Plan adopted in 2017
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 requirements of 17,800 through to 2031 is now reduced 16,700
3. The outcome of this is that the unmet housing need for 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 approval for the Luton Local Plan in 2017, stated the 'best fit' for any unmet housing need was Central Beds which has committed to provide 7,300 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,500 dwellings from which to satisfy that commitment. Hundreds of these houses are already built or are under construction
5. These figures will come out in the Review meaning that NHDC does not need to allow development at EOL
6. The above 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 based on outdated information to continue justifying its EOL plans. Central Beds, the most important neighbouring local authority to Luton, was not party to this statement
The lack of consideration given to the above facts by NHDC officials and Councillors suggests they have not applied due diligence in assessing Luton's current housing figures.

I object to the North Herts DC Local Plan’s proposed development of 2,100 homes East of Luton 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 North Herts DC Local Plan’s proposed development of 2,100 homes East of Luton 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 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 circumstance
• 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 designed ‘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 circumstance
- 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 designed ‘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 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 plans to build 2,100 houses on the green belt to the east of Luton. We 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.

We are writing to object to ED224 for the following reasons:

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.

We, the undersigned wish to make representation against Evidence Document 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;
• n 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 lodge my objection against ED224 and the Plan to build houses on the Green Belt round Cockernhoe and the East of Luton, as it is in no way necessary or in the best interests of local residents.
The local infrastructure cannot support this type of development and furthermore there is no proven need for it.
• 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 beseech you to reconsider, to fully research and to listen to and consider the very genuine concerns of local residents.

I object to the North Herts DC local plans 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 the 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.

We have previously submitted objections to the proposed East of Luton (EOL) plan and object to the latest documents, in particular ED224.
ED224 defends the need for the EOL development, which is proposed to satisfy a large proportion of Luton’s unmet housing needs, and is based on historically calculated dwelling numbers by Luton Borough Council (LBC) as explained below.
The fundamental issue is that North Herts District Council (NHDC) has included the EOL development in its Local Plan based on out-of-date information concerning Luton’s unmet housing needs. Luton’s Local Plan was adopted in 2017 and included Policy LLP40 to Review its Local Plan commencing in 2019 and completing by mid-2021.
We understand that LBC confirmed in March 2021 that the Review is at an early stage and it has no exact date when it will be finished. Thus, allowing for the same timescale, the Review will take another two years. This failure to carry out the Review in a timely manner means that the number of dwellings 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, unreasonably in our opinion, the need for the EOL development.
We believe that other campaigners* (referenced below) against the EOL development have carried out a detailed review of publicly available information on Luton’s house building programme and housing requirements. Our summary objections* are that that:
1. Due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 dwellings 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. Points (1) and (2) above 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 support. Hundreds of those dwellings are already built or under construction;
5. Had LBC carried out its Review as expected, these figures would have come to light formally meaning that NHDC may not need the 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 LBC, Bloor Homes and the Crown Estate, adhering 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. No doubt Covid will be blamed but that is not an excuse to make poor decisions. Any decision on EOL should be delayed until a thorough review of housing need has been carried out and all interested parties including Central Beds, signed up.
This is of extreme concern as a lack of diligence by LBC and NHDC could mean the potential loss of important Green Belt to development, and as we have stated in our previous objections, bringing wholesale destruction of Green Belt along the Beds/Herts boundary as far as Luton Airport, and pulling even more inhabitants within the noisy, contaminated airspace around the airport.

The Luton Local Plan LP6 suggests that homes of 3+ bedrooms should constitute 69.6% of all new dwellings and should constitute 49% of Affordable homes. ED224 states that even if EOL were to proceed in its current form there is still a huge shortfall in the provision of 3+ bedroom houses - so where are they going to come from?.

It is also notable that in document :
” Matter 10 Hearing Statement: Housing Allocations and the Settlement Boundaries: The Towns: Luton (Cockernhoe)
North Hertfordshire Local Plan Examination
On behalf of Bloor Homes
January 2018 Ref: 2012.002” there is no mention of the mix of the dwellings, only their total number.

ED224 tries to justify the lack of affordable housing built in Luton on the basis that brownfield developments would otherwise be non-viable (or were Permitted Development). This is unacceptable. LBC are the Planning Authority and could have imposed more affordable housing and more 3+ bedrooms if they really wanted. The truth is they consider greenfield sites to be cheaper and hence more attractive to developers such as Bloor. Even so, the current EOL plans do not appear to come close to achieving the ‘split’ that LP6 actually recommends, so how can this be said to fulfil unmet needs?.

*We refer to, and endorse wholeheartedly the detailed response to ED224 provided by David Dorman and Roy Parker dated 21st May 2021.

Please accept the following objections to the plans to build 2100 houses on the GREEN BELT to the East of Luton.

The information we offer below for a very important and crucial final representation concerns the Evidence Document ED224.
The fundamental point we make is that NHDC has included the EOL development in its Local Plan 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. ED224 defends the need for the development, known as “East of Luton” (EOL), based on historically calculated dwelling numbers by Luton as explained below. Let us remember that these houses are proposed solely to meet Luton’s unmet housing needs.

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.

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:

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 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;
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.

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 object to the North Herts DC Local Plans proposed development of 2,100 homes East of Luton, required solely to meet an unmet need from Luton of 9,300 homes calculated in 2017 as argued in ED244, 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 wish to lodge my objection 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 forecast in 2017, updated assessment needs are lower and unmet needs have reduced to around 2,000

- Luton's unmet needs have already been more than covered by Central Bedfordshire as the designated "best fit" neighbour, with many houses already in build

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

I and all members of my household wish to formally object to 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 North Herts DC Local Plan proposed development of 2,100 houses East of Luton required solely to meet an Unmet Need from Luton Borough Council of 9,300 houses calculated in 2017as argued in ED224, for the following reasons:-

• Valuable Green Belt land, it does not meet the criteria of Exceptional Circumstances.

• In recent years Luton’s housebuilding has been much higher than the 2017 prediction, updated needs are significantly less than forecast 4 years ago, the Unmet Need has been reduced to 2,000.

• Luton’s Unmet Needs have already been both accommodated within their boundary, and by Central Bedfordshire as the designated ‘Best Fit’ neighbour, with many already built, or in the process of being built.

• Luton’s failure to ensure an adequate supply of family housing from developers.

• There is no longer an Unmet Need!

As an Offley Parish Councillor I wish to object to the North Herts DC Local Plan proposed development of 2,100 houses East of Luton required solely to meet an Unmet Need from Luton Borough Council of 9,300 houses calculated in 2017as argued in ED224, for the following reasons:-

1. Valuable Green Belt land, it does not meet the criteria of Exceptional Circumstances.

2. In recent years Luton’s housebuilding has been much higher than the 2017 prediction, updated needs are significantly less than forecast 4 years ago, the Unmet Need has been reduced to 2,000.

3. Lutons Unmet Needs have already been both accommodated within their boundary, and by Central Bedfordshire as the designated ‘Best Fit’ neighbour, with many already built, or in the process of being built.

4. Luton’s failure to ensure an adequate supply of family housing from developers.

5. There is no longer an Unmet Need!

We object to the North Hers DC Local Plan's proposed development of 2100 homes East of Luton required solely to meet an unmet need from Luton of 9300 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 2000.
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.

We object to the North Herts DC Local Plan’s proposed development of 2100 homes East of Luton, 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 the 2017 forecast - updated assessed needs are lower and 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 plans 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 assessment 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 2,100 houses East of Luton required solely to meet the unmet need from Luton of 9,300 homes calculated in 2017 as argued in ED0224, for the following reasons:

• Luton's unmet housing needs have already been more than covered by Central Beds as the designated 'best fit' neighbour, with many already having been started to be built.
• Luton's housing building is much higher that in 2017 forecast, updated assessment suggests figure to be around 2,000
• Luton' plans to extend and grow Luton Airport have changed dramatically due to Covid and Luton Council's precarious financial position in relation to borrowing it has made to the airport. Therefore the need for additional housing will be affected in Luton.
• The loss of valuable Green Belt land, with no exceptional circumstances in order to allow this to happen.
• More houses, more carbon footprint and loss of what we now know even more due to Covid is the need for green open spaces.