Local Plan 2011-2031 Proposed Submission Draft

I strongly object to the NHDC Local Plan 2011-2031.

Firstly, with regard to "Removing this land from Green Belt status to meet 'Luton's Unment Need". The National Planning Policy Framework document states that the Removal of Green Belt Status does not fit the Government's criteria of "Except in exceptional circumstances." Luton's Unmet Need is not an exceptional circumstance. It also states: "an Unmet Need is unlikely to outweigh the harm to the Green Belt unless there are very Special Circumstances."

There are already sufficient undeveloped Brown field sites in Luton to meet its Unmet Needs.

The Unmet Housing Need figure also shows inaccuracies. During Executive Meetings, LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment in order to re-examine once more the Unmet Housing Need figure assumptions. This was due to their estimated nature, with far-reaching consequences and drastic impact upon the area. Luton's Unmet Housing Need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.

The removal of this land from Green Belt Status as proposed by NHDC in their plan leaves this land unprotected and open to applications from developers.

Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport.

The Transport Assessments were not robust. The data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity; they were not carried out for long enough and some studies from Luton Borough Council assumed roads that did not even exist. Furthermore, Luton Borough Council base their traffic modelling on an unbuilt link road to the A505 at Lilley. A Freedom of Information request states: "This transport modelling includes the alignment of the proposed spine road through that development site and LBC have also assumed by 2031 that will be extended at its northern end to join the A505 near its junction with the road into Lilley". However, NHDC state on P27 of the NDHC Local Plan Para 4.222 - "Our assessments show that this level of development can be accommodated without a significant adverse impact on the wider highway networks of Luton and Hertfordshire".

Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.

The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.
If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate. In fact, the whole proposal is out of proportion. 2,100 homes is 14% of the total allocation of houses in the NHDC Local Plan; a 1,025% increase on the 205 houses in the three hamlets placing these - and the houses in Wigmore bordering the development - into the middle of an estate. With respect to Wigmore on its own, currently around 4,500 houses, again this proposal is at an unacceptably disproportionate level of expansion since 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.

Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.
Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.

There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.

Finally I mention the impact on wildlife. There are areas of woodland containing Bluebells - a protected plant species. There are Red Kites in the area - a protected bird species.