ED224

I wish to object to the 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 will be destroyed that can never be recovered. There are no adequate exceptional circumstances for this. Brown field sites within the town should be used, or areas within the town centre which will become vacant due to the repercussions of Covid on retail. Green belt areas should always be protected.
2. Luton's house building is much higher than the 2017 forecast, updated assessed needs are lower, and unmet needs have been reduced to around 2000. These could be met by brown field sites, or using areas within the current town area.
3. Luton's unmet needs have already been more than covered by Central Beds a s the designated "best fit" neighbour; with many already in build.
4. Luton has failed to require adequate family housing/ social housing from the developer
5. Roads in the area are already gridlocked at times. Further housing will only exacerbate this problem.
Please acknowledge my objection and keep me updated re the outcome of this plan.

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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.

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 the NHDC Inspector, showed that the previous housing requirements of 17,800 through 2031 would now be reduced to 16,700.
3: these two facts mean the unmet housing need from Luton drops to around 2,00 (16,700-14,700),compared to 9,300 (17,800-8,500) in 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 was 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 are under construction.
5: had Luton carried out it's Review, these figures would have come to light formally meaning that NHDC does not need to allow Development at EOL.
6: all this information Isis known to NHDC and yet it signed 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.
7: Furthermore, there is no evidence at all that NHDC officials and council lots 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.

Due to the information received from these seven bullet points and the extra inconveniences i:e extra traffic and congestion of the Roads in the Wigmore area, I strongly object to the building of 2,100 new homes on the green belt surrounding Cockernoe, Tea Green, Mangrove Green and Wandon End.

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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:

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.

See Attached

See Attached

Please note my objection to the development of 2100 homes on Green Belt land to the east of Luton, 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’m writing with reference to document ED224 to state our objection 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 it is believed that investigations have identified the accurate facts.

On the basis of the above there appears to be no genuine reason for the proposed East of Luton development to proceed, especially as its premise appears to be based on out of date information and we therefore urge rejection of the plan.

I wish to object to the plans to build 2,100 houses on the Green Belt to the east of Luton and reference evidence document ED224. 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.
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 stubbornly continue to justify the need for the houses at EOL.
My points of objection are 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 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 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;
• 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;
• 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 that the unmet housing need from Luton drops to around 2,00 (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 dwelling. 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 is signed a Statement of Common Ground in December 2020 (ED224) with Luton, Blood 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 the Statement;
• Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, of 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 and reference evidence document ED224. 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.
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 stubbornly continue to justify the need for the houses at EOL.
My points of objection are 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 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 and reference evidence document ED224. 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.
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 stubbornly continue to justify the need for the houses at EOL.
My points of objection are 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 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 as a family of 4 are writing to formally object via email to state that we are totally against the plans to build 2,100 houses on the Green Belt to the east of Luton, re 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.

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I object to the North Herts District Council Local Plan proposed development of housing East of Luton.

This housing development is being proposed to allegedly "meet Luton's unmet housing need".

* The alleged Luton unmet housing need does NOT exist
- this stated need is based upon a totally ridiculous and non-updated forecast from 2017
- IF there is still any unmet Luton housing need, which I do not believe to be true any longer, then it would be more than covered by the building in excess of the original Luton Local Plan
- Central Bedfordshire are providing more houses than could possibly be needed for any possible Luton shortfall
* There is NO adequate exceptional circumstances to warrant building on the Green Belt
* There can be no excuse for building on the Green Belt just because Luton Borough Council has failed in its legal duty to update its own Local Plan.

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I object to North Herts District Councils East of Luton housing development plan (ED224) for the following reasons:

· North Herts District Council based the case for the East of Luton housing development based upon flawed information in regards to Luton Borough Councils 2017 Local Plan policy LLP40.

· Luton’s house building is far greater than it’s 2017 forecast in which unmet needs are now reduced to around 2,000

· Luton’s historic transient population changes as a result of the airport, Brexit, world and UK forecasted population number shifts.

· Central Beds District Council have provisioned Luton’s unmet housing needs.

· Destruction of valuable Green Belt land and insufficient data provided to support a Biodiversity Gain Plan.

I strongly object to the planned building of 2021 houses on Green Belt Land east of Luton ref ED224 for the follow 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.

In addition to myriad excellent points of objection already raised by ourselves and fellow residents of east Luton and its neighbouring North Hertfordshire villages at various stages of the consultation process, we are now objecting to this development on the grounds that it is unnecessary. Evidence Document 224 (hereafter ED224) defends the need for this development on the basis of proposed dwelling numbers historically calculated by Luton. However, research by the EOL Objectors group demonstrates that the information in ED224 is now obsolete.

NHDC 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. This included 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, have not been formally updated.

However, the EOL group's research, fully supported by evidence, demonstrates the following facts:
• 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 Bedfordshire - the most important neighbouring local authority to Luton - was not a party to this Statement. We wonder whether NHDC has done so in order to proceed with building a significant proportion of its Local Plan housing quota on the District's very fringes, relying on Luton's services whilst protecting towns and villages within the rest of the county?

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. Indeed, given the information set out above, we are dismayed that a public authority appears to be stubbornly persisting with destructive development on the green belt in the face of a drastic change of circumstances, and when alternative, more appropriate sites in Central Bedfordshire have already been identified. Again, we question the motivations behind the District Council's intransigence.

For the reasons set out above, Martyn, Tareena and I object in the strongest terms to the proposed EOL development. Further, formal research into the unmet housing need figures in ED224 must be undertaken by NHDC, to shed light on whether the figures upon which it is justifying the EOL development are accurate. If, as we suspect, they are not, the Inspector and the Council must think seriously about whether there is any longer a need for the proposed EOL development. Where NHDC is not willing to undertake this research, it must not proceed with the development until Luton's Policy LLP40 review is complete and accurate figures are available.

Objection to East of Luton EOL development (SP19)
I wish to 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 will be destroyed that can never be recovered. There are no adequate exceptional circumstances for this. Brownfield sites and other vacant areas within the town should be used. Green belt areas should always be protected and just this last week Prime Minister Johnson stated, on the radio, that there should be no building on green belt land.
2. Luton's house building is much higher than the 2017 forecast, updated assessed needs are lower, and unmet needs have been 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 has failed to require adequate family and social housing from the developers.
5. Further housing will only exacerbate the problem of the area’s gridlocked roads that develop during busy times.

Objection to East of Luton EOL development (SP19)

I wish to 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 will be destroyed that can never be recovered. There are no adequate exceptional circumstances for this. Brownfield sites and other vacant areas within the town should be used. Green belt areas should always be protected and just this last week Prime Minister Johnson stated, on the radio, that there should be no building on green belt land.
2. Luton's house building is much higher than the 2017 forecast, updated assessed needs are lower, and unmet needs have been 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 has failed to require adequate family and social housing from the developers.
5. Further housing will only exacerbate the problem of the area’s gridlocked roads that develop during busy times.

I wish 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.