Local Plan 2011-2031 Proposed Submission Draft

I am writing to object to aspects of the proposed Local Plan which relate to the East of Luton development around Cockernhoe and Mangrove Green.
Green Belt
The land in question is protected Green Belt. Reading through the National Planning Policy Framework (NPPF) it states that:
A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:
* buildings for agriculture and forestry;
* provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it;
* the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building;
* the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces;
* limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan;
* limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.
The requirement for fulfilling Luton's unmet housing need by constructing 2,100 houses, vastly overwhelming the 205 houses in the villages it will surround, is clearly substantially beyond "limited infilling" and therefore does not fit these criteria. It will also essentially mean that these villages cease to exist and become part of Luton.
According to the NPPF, "inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances". The above points make clear that the development proposed in the Local Plan is categorised as inappropriate above.
The NPPF also states that "'very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations". It also states that "Green Belt boundaries should only be altered in exceptional circumstances". I cannot see how fulfilling Luton's Unmet Need is sufficient to fit these criteria when alternative, less harmful options, exist including undeveloped Brownfield sites within Luton itself which have been identified during previous planning consultations.

Transport Infrastructure
A significant concern is the road infrastructure to support this development. The Local Plan Proposal just mentions that "principal access to be taken from Luton Road and integrated into Luton's existing highway network via Crawley Green Road". There is no mention of access in the other direction to Hitchin where the route would be via single track country roads.
The roads both towards Hitchin and the A1 as well as Luton and the M1 already struggle with current traffic levels, especially during rush hour. The surrounding narrow country lanes are used as rat runs for people trying to avoid the Luton traffic and are becoming dangerous at peak times.
These problems will only increase with the planned extension of Luton Airport and building of a substantial number of houses.
A Freedom of Information request has uncovered that "This transport modeling 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". This would presumably be the route towards Hitchin but is omitted in the current proposal and would have a very significant impact on the surrounding countryside.
The statements in the Local Plan Proposal about the required changes to the road network and that "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." is therefore incorrect and misleading. It will also have a far larger impact than the statement in the proposal "Built development contained within the Breachwood Ridge and avoiding adverse impacts on the wider landscape of the Lilley Valley or the Chilterns AONB as informed by detailed landscape assessments" would appear to indicate.

In summary, I believe this proposal:
* does not satisfy the required circumstances to remove Green Belt land
* includes a disproportionate number of houses which will destroy the villages they will surround essentially subsuming them into Luton
* ignores the significant impact on local transport infrastructure and seeks to mislead by not mentioning the additional highway link to the A505 at Lilley which any analysis has been based on. This will impact even more Green Belt land as well as an Area of Outstanding Natural Beauty (contrary to the statements made in the proposal). It also exacerbates the already struggling infrastructure heading into both Hitchin and Luton which is no way remediated by either the disclosed or undisclosed assumptions.

I urge you to reject this unsound proposal and that a more appropriate, viable and transparent option is put forwards.