ED224

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a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans.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.

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.

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.

For the reasons set out above, Julia, Geoffrey, Stephanie 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 Development (SP19)
We object to North Herts D C Local Plans proposed development of 2100 homes East of Luton required solely to meet a previously unmet need from Luton of 9,300 homes calculated in 2017 as argued in ED224 for the following reasons.

1 it is Valuable Green Belt land and no adequate exceptional circumstances exist

2 Luton’s house building greatly exceeds the 2017 forecast. Updated and assessed needs are now lower and unmet needs are 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.

5 Pollution levels already greatly exceed government requirements and any further development exasperates this further

6 Totally inadequate infrastructure to support any development.

I am writing to formally object, again, the proposal to build 2,100 houses on Green Belt to the east of Luton (EOL). I will not rehearse the reasons I gave in my originally submission, but they still stand.

I now understand that NHDC have included the EOL development in its Local Plan based on out-of-date data concerning Luton’s unmet housing needs. This calls into question the evidence submitted in document ED224.
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.
The 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..
I included my wife’s name on this email and request it be counted as two objections.

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I am emailing this objection letter following the final consultation on the North Herts District Council Local Plan which proposes the development of 2,100 homes on the Green Belt surrounding Cockernhoe, Mangrove Green, Tea Green and Wandon End.

The Evidence Document, reference ED224, defends the need for this development based on historically calculated dwelling numbers. My objection is as follows;
• Due to significantly increased grants of planning permission and public announcements, Luton will be building around 14,700 houses through to 2031, compared to the 8,500 stated in the LBC Local Plan.
• An updated analysis of Luton’s housing needs, carried out by the Opinion Research Services in Aug 2020 at the request of the NHDC Inspector, shows that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700.
• The above means the “unmet housing need” decreases to 2,000 (16,700-14,700) compared to the 9,300 stated in the Local Plan.
• The Luton Inspector approving the Local Plan in 2017 stated the best fit for unmet housing need was Central Beds which has committed to providing 7,350 dwellings. In fact it has allocated 20 sites with capacity for at least 8,850 dwellings, many of which are already built or under construction.
• Had LBC carried out its Review, these figures would have been highlighted meaning that NHDC does not need to allow development at east of Luton (EOL).
• Despite this available information, NHDC signed a Statement of Common Ground in December 2020 (ED224) sticking with the out-of-date numbers to justify EOL plans. Central Beds Council- the most important neighbouring local authority to Luton- was not party to this statement, despite being identified as the ‘best fit’ for the unmet housing need by the Luton Inspector in 2017.
• There is no evidence that NHDC officials have carried out adequate due diligence on Luton’s housing figures which is of extreme concern considering the development will cause a significant loss of valuable Green Belt land. The proposed development will cause irreversible damage to the local community and environment.

There are the obvious issues with the proposed development, namely the loss of habitat for many protected species including Red kite, Great crested newts, Redwing and many more which are protected under the Wildlife and Countryside Act 1981, as amended. This green hub of the community is threatened by the proposed development which thus threatens the wellbeing of the community. The coronavirus pandemic has shown us that is more important than ever to ensure communities have access to green space, not only for the obvious physical health but also for mental health.

The fundamental point I make, is that NHDC has included the EOL development in its Local Plan threatening the ever-so-important Green Belt land with no adequate exceptional circumstances, based on out-of-date information concerning Luton’s unmet housing needs.

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I refer to the proposed building of approximately 2,100 houses on the Green Belt around Cockernhoe, to the east of Luton known as “East of Luton” (EOL) which is currently under detailed examination of a Planning Inspector.

As a local resident I strongly object to this proposed development which has been put forward based on flawed and out-of-date data in relation to Luton's unmet housing requirements set out in NHDC's inaccurate evidence document ref: ED224. Please see below supporting 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.
Please consider the above representations in all fairness to the local residents of Cockenhoe and its neighbouring villages and districts.

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:

1. you are wanting to use valuable Green Belt land; no adequate exceptional circumstances;
2. 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;
3. 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;
4.the two above facts (2 and 3) 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;
5. 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;
6. 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;
7. 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; and
8. 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 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:

1. you are wanting to use valuable Green Belt land; no adequate exceptional circumstances;
2. 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;
3. 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;
4. the two above facts (2 and 3) 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;
5. 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;
6. 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;
7. 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; and
8. 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 investigations have identified the accurate facts.

We have been following the proposed building of 2100 homes on the green belt in our neighbourhood and am writing to agree with the findings of those residents who are campaigning against this development. They have substantial evidence to support 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 but we believe our investigations have identified the accurate facts.

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I object to the Norths Herts DC Local Plans proposed development of 2100 house 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.Lutons 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 builds already in process.
4. Luton's failure to require adequate family housing from developers.

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