ED224

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Further Main Modifications to NHDC Local Plan Examination (June 2021)

Objection to EAST OF LUTON (EOL) development
POLICY SP19
The Plan is NOT CONSISTENT with National Policy

Environmental pollution centers.org
Construction Sites Pollution
Proximity of Construction sites to homes may generate HOME POLLUTION consisting of -
Air Pollution
Water Pollution
Soil Pollution
Noise Pollution

Construction Pollution
1. Building Construction Pollution
2. Road Construction Pollution
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unfccc.int The Paris Agreement
www.theccc.org.uk
This agreement is a significant global legally binding, international treaty on climate change adapted on 4th November 2016. Its goal - to limit Global Warming.
An Adaption committee was formed -
UK Progression followed -

www.theccc.org.uk
Reducing UK Emissions: 2020 Progress
Report to Parliament contains - Tree Planting, Peatland restoration and Green infrastructure

NASA
climate.nasa.gov.
Climate Change Adaptation and Mitigation
Global Climate Change
Vital signs of the Planet/facts/articles/
SOLUTIONS
“Humanity is committed” to some level of climate change.
Q. How much climate change?
A. This will be determined by how our emissions continue. (In 2013, the daily level of carbon dioxide in the atmosphere surpassed 400 parts per million for the first time in human history)

Committing to climate change involves -
1. Reducing emissions of and stabilising the levels of heat trapping greenhouse gases in the atmosphere (“Mitigation”)

2. Adapting to the climate changes already in the pipeline (“Adaptation”)

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Therefore ‘Climate Change Emergency’ was declared on behalf of represented nations on 28th November 2019 (throughout the world.)
However, prior to this the UK officially declared a Climate Emergency 2nd May 2019, being the first country to declare this as being so.

November 2020
HM Government produced -
The Ten Point Plan for a Green Industrial Revolution
See its foreword from the Prime Minister
and from the Secretary of State for Business, Energy and Industrial Strategy

All points within this plan are ‘vital’ to this long term ‘project’ to achieve the final ‘figures’ in 2030
POINT 9 is PROTECT OUR NATIONAL ENVIRONMENT

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bbc.co.uk
14 Jan 2020
Luton Borough Council announced a ‘Climate Emergency’
luton.gov.uk
‘My Climate Action Plan’
Becoming a carbon neutral Borough by 2040
Version 1.3
(Updated April 2021)

ADEPT (Association of Directors of Environment, Economy, Planning and Transport) was formed -
It is a plan to recovery from Covid 19.
A roadmap on how to deliver STRONGER HEALTHIER
COMMUNITIES
Of their 5 immediate priorities No. 5 reads - Accelerate tree planting, peatland restoration, green spaces and other green infrastructures
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Luton Borough Local Plan /North Herts District Council Local Plan 2011-31
Luton Borough Council are showing what seems an illogical decision to destroy a landscape, an Area of natural beauty, part of the Chiltern Cycleway situated to the Eastern part of Luton (Wigmore, bordering North Herts). They are not adhering to Government compliance and their own committed, previously stated decisions and priorities.

Enabling re-creation of this old and valuable site is virtually impossible! Why obliterate something without need to, to have only to reproduce exactly the same elsewhere to replace it! (at the moment the EOL site offers above average environmental gain. With regard to pollution levels, it has been the areas only saving grace! It has taken years to form and develop, only to become obliterated in an instant!)
The land needs to survive in its entirety to provide a healthier existence in this, already unhealthy, polluted, non affluent area.
London Luton Airport is situated entirely in this area. Luton Borough Council committed to airport expansion plans prior to Covid. The DART rail development continues to be underway as we speak, and although plans may be delayed slightly, Luton Council are not discarding their aspirations of a much larger airport. Covid is delaying plans temporarily only. The Airport at the moment is thankfully quiet, pollution in all aspects are lower - but ‘normal service will be resumed’ in the near future!

NOTE:
Luton Borough Council it would seem, do not need to destroy this green belt land for the purpose of new homes.
Figures and in depth proof are being submitted to the Inspector for the final modifications of this Examination by 24th June 2021.
Luton Borough Council, have indeed managed to build and also sell a substantial amount of new homes on land that has appeared to have not ‘been previously available’. And it would also appear that there seems to be adequate land for new homes in the future.

THIS PLAN IS NOT CONSISTENT WITH NATIONAL POLICY.
IT IGNORES, GOVERNMENTAL POLICIES REGARDING CLIMATE CHANGE.
IT FAILS TO FOLLOW THE GOVERNMENTAL POLICIES REGARDING GREEN SPACE LOSS, AND THE PROTECTION OF THE NATIONAL ENVIRONMENT.
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(Pollution decrease is paramount to Luton as a whole. The Green belt land currently earmarked to the East of Luton is paramount for a healthier area.)

stop lae.org
Air Pollution Deaths in Luton

www.qmul.ac.uk
SMD - New research to study impact of air pollution on children’s brain development

www.national world.com
One in 20 deaths in England caused by air pollution - these are the worst affected

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

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We both strongly object to the Evidence Document ED224 based on the following information.

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 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.

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