Local Plan 2011-2031 Proposed Submission Draft

I object to the NHDC Local Plan 2011-2031 at this Regulation 19 stage. I want to change parts of this Local Plan. I want to participate in the Examination fully.
The plan is unsound. I object to the part of North Hertfordshire Local Plan 2011-2031, which allocates 2,105 dwellings on Land East of Luton.

This plan is not positively prepared, deliverable, justified, effective or consistent with national policy.

The Traffic Surveys have not been carried out to acceptable standards and also the results of this survey showed a negligible or nil effect on local congestion when the results and thus the underpinning of the proposal were based on a road that doesn't exist and hasn't even been proposed.

Unsound Reasoning and Incorrect, Inadequate Transportation Studies
There have been a series of Executive Meetings spanning several years up until the current time. LBC has repeatedly discussed points of concern and has concluded the lack of infrastructure and inadequate road network, to be a major and unresolved obstruction point.
Luton was consulted by North Herts District Council three times since 2013 on house building plans East of Luton, in each case Labour run LBC said they wanted either NO HOUSES or MORE. Their reason is that unless there are no less than 5,000 houses, they cannot justify or afford to build a new road from the A505 to the airport and on to the M1 junction 10.
So LBC WANT MORE houses not fewer. Their view is it's MORE or nothing. If it is ONLY 2,105 dwellings then they don't want them.
Most recently, the "2016.07.20. Summary of LBC Decisions/ Cllr David Franks" provides a brief summary of what has been decided by LBC. Their entire case rests on the need to finance a new road which could not be funded by smaller developments. Hence they are looking for a new road from the A505 to the airport and on to M1 junction 10. Yet even if this new road could be achieved it would simplify the journey from the new development to the airport and to the M1 motorway but do nothing to help families from the new homes to get into Luton town centre, to local employment areas, to medical facilities or to schools.
However bearing in mind that the whole of Wigmore is approximately 4,500 houses, building 5000 houses would be asking to build a part of the town LARGER than actual Wigmore itself. This is doubling the size on the area on land. And this is on Hertfordshire's land. They cannot fit 5,000 dwellings on this land.
The Transportation Network
Consider these comments taken from LBC executive meetings:

"With regard to the housing options east of Luton, we urged that any proposals must provide for adequate supporting community and transport infrastructure. This is particularly important in terms of the A505 and also the Luton corridor (serving the airport, Wigmore area and key regeneration sites connected by Vauxhall Way, Eaton Green Road, Crawley Green Road from the M1 Junction 10a) which are already badly affected by peak hour congestion." [Letter dated 10 Jun 2013, Cllr Sian Timoney addressed Cllr T. Brindley Executive Member NHDC about "Luton Local Plan Cross Boundary Issues" [Brindley Letter from Sian Timoney].
"22. The proposal for the major strategic development to the south west of Hitchin would have both benefits and drawbacks for Luton. On the plus side it would dramatically improve road access to Luton from the east, delivering a continual dual carriageway road on to the A1 (M) and beyond. Luton would also welcome the opportunity that such a scheme might offer to provide for the needs of Luton residents which cannot be delivered within Luton. However, on the negative side, the improved road access will undoubtedly put additional traffic pressure onto the A505 within Luton which is already suffering from severe congestions during peak periods." [Minutes of LBC Executive Meeting/ Agenda Item Number: 23 Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen]
"23. While the current development proposals for the East of Luton site provide a local centre, the main retail draw will be Luton and there is expected to be a significant increase in traffic around the Wigmore Asda. Previous proposals for development of the land in this location provided for a more comprehensive scheme which included a bypass that took airport/M1 traffic off the Vauxhall Way corridor and provided some mitigation for the development. The current proposals will not provide such infrastructure. The scope of transport impact appraisal relating to the East of Luton site is currently being agreed between the Council and relevant consultants. It is expected to cover Eaton Green Road, Crawley Green Road, Vauxhall Way, Airport Way, M1J10a and peripheral roads." [Minutes of LBC Executive Meeting/ Agenda Item Number: 23 Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen]
The development plan for Land East of Luton is like a big balloon, with one solitary entry and exit point only - that's the Luton Road leading into Crawley Green Road. If each house has two cars, that would generate 4210 extras cars travelling along that one road.

I object to the NHDC Local Plan 2011-2031. I want to change parts of this Local Plan. I want to participate in the Examination fully.
Infrastructure and Roads requests from LBC
Very specific requests at Executive levels, formed the basis for LBC's formal response to NHDC's Local Plan Consulation.
On 25 March 2013, LBC asked NHDC to:-

"4. Adequately model the impacts and necessary supporting infrastructure, should any
sites progress to the east of Luton. This will ensure that development is of a scale to be sustainable and help to resolve severe congestion:
* on the A505;
* around the Wigmore Asda area;
* along the east Luton corridor serving the airport, Vauxhall Way, Airport Way and
M1J10a;
* along Eaton Green Road, Crawley Green Road and other peripheral roads;
* Work closely with Luton on any cross boundary Community Infrastructure Levy matters"
[Executive Meeting-Luton Borough Council's Response to North Hertfordshire - New Local Plan Further Consultation: Housing Additional Location Options - July 2013]

NHDC Local Plan has not met these requests.
LBC also formally requests:
"16. However, North Herts is urged to ensure that a strategic approach is taken to examine the potential developments. They should secure sustainable communities supported by strategic infrastructure, including transportation, which integrates new and existing communities, links district and town centres, shopping, services and employment areas and tackles traffic congestion."
[Executive Meeting-Luton Borough Council's Response to North Hertfordshire - New Local Plan Further Consultation: Housing Additional Location Options - July 2013]
The NHDC Local Plan does not meet these requests either.
"Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government" is a document that provides guidance on the content and preparation of Transport Assessments (TAs) and Transport Statements (TSs).

It should be read in conjunction with, and in the context of, relevant Government policies, in particular those relating to transport and planning.

The TAs and TSs for this Local Plan are totally inadequate for numerous reasons. They are not robust nor founded upon a credible evidence base. The reasons for this are, but not limited to, the following.

Alarmingly LBC has undertaken transport modelling to support the preparation of its Local Plan and created an imaginary road that does not exist!

"5.1 National planning policy as set out in PPS1, PPS11 and PPS12 emphasises the requirement for development plans to be founded on 'a robust and credible evidence base'. [PPS 11 (para. 2.49); PPS12 (para. 4.24)]"

"5.2 Development plans will only be credible, authoritative and deliverable if transport
considerations are fully factored into their development from the outset."

In a Freedom of Information Request relating to the transportation studies for East Luton development as conducted so far, LBC states it's Transport Modelling assumes this road that does not exist:

"Luton Borough Council (LBC) has undertaken transport modelling to support the preparation of its Local Plan which includes the development east of Luton which, under the Duty to Cooperate, includes 2100 homes in North Hertfordshire to the east of the town. 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. This is just a high level operational assessment and, as more detailed design of the transport network associated with that development is progressed, a more detailed operational assessment based on current and future traffic conditions will be undertaken as part of the Transport Assessments and Sustainable Travel Plans as proposals for development of that site are brought forward."
[FOIR #6-REPLY-(LBCRef923239) Traffic Assessments North Herts Local Plan & Luton Local Plan-21Sept2016]

LBC admits their and NHDC's studies are based on totally different basic premises. Whilst LBC used an imaginary exit and entry road, to change the entire outcome of it's TA, NHDC did not include the imaginary road:

"The main difference compared to the LBC report (see response 1 above) is that North Hertfordshire's assessment did not include the new road between the A505 and the northern end of the spine road through the development site." [FOIR #6-REPLY-(LBCRef923239) Traffic Assessments North Herts Local Plan & Luton Local Plan-21Sept2016]

There is, and never has been a proposed new road in North Herts. The basis of the transport infrastructure relies on the existing Tarmac historic single track lanes in N Herts, i.e. Chalk Hill and Stoney Lane.

Maybe LBC need to do another Transportation Modelling study that also doesn't include this non-existent road, then it will be more in line with reality. That reality being heavy traffic congestion building up along Wigmore, Crawley Green, Eaton Green and Stockingstone roads.

More importantly, there is no reference to the devastating effect on the inadequate existing roads into Luton, Luton Airport, Train stations, and the M.1.

The Crown Estate application, shows no intention of linking to a new "spine" road, so should it not fail on this alone?

Guidance of Transport Assessment and Environment Ignored

"Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government" lists many issues that haven't been addressed by the Local Plan:

"Environment
4.38 The environment issues that should be assessed include:
* nuisance to people caused by transport-related noise and vibration generated by the development;
* the emission of greenhouse gases as a result of the transport implications of the development and the impact of changes in local air quality on people;
* the transport-related impacts of the development on areas of designated landscape
importance;
* whether the site is in an air quality management zone or is likely to cause a breach of current legislation;
* the transport-related impact of the development on areas of nature conservation or
biodiversity and Earth heritage interests (such as geology) where they interact with
roads;
* heritage of historic resources where they interact with development-generated transport
and/or proposed mitigation measures;
* the transport-related impact of the development on the townscape;
* appraisal of the transport-related impacts of the development on the water
environment;
* the impact of the transport implications of the development on physical fitness;
* journey ambience."

4.39 The potential for environmental impacts that would breach a statutory limit should be addressed. LHAs and the HA have a statutory duty to prevent a breach of statutory limits (e.g. air quality) due to incremental change of volumes of vehicular traffic on their networks.

Have LBC and NHDC conducted air quality assessments in the development area or carried out any noise pollution studies.

LBC said: "LBC has not undertaken any detailed assessments of Crawley Green/ Luton Road. Luton Road is situated in North Hertfordshire District Councils Area who may be able to advise regarding this location."
[Freedom of Information Request #3-REPLY-(LBC Ref# 910229)Traffic Special Needs School -5Jul2016].

"Environmental Protection has not carried out any noise pollution studies along Crawley Green Road. Luton Road as per question 11 is outside the borough boundary and part of North Hertfordshire District Council.
[Freedom of Information Request #3-REPLY-(LBC Ref# 910229)Traffic Special Needs School -5Jul2016].

Furthermore, there has been a big change since the Local Plan Transport Studies were conducted. Heavy goods vehicles have since been re-routed by NHDC, to along the Luton Road and Crawley Green Road. So the TAs now also fall short of another standard too:

"Traffic data and traffic forecast
4.18 The assessment should include recent counts (normally surveyed within the last three
years) for peak period turning movements at critical junctions. In certain instances, for
example, where there is known to be a significant level of heavy goods vehicles (HGV)
traffic, a classified count2 should be provided." [Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government]

"Environment
4.38 The environment issues that should be assessed include:
* nuisance to people caused by transport-related noise and vibration generated by the development;
* the emission of greenhouse gases as a result of the transport implications of the development and the impact of changes in local air quality on people;
* the transport-related impacts of the development on areas of designated landscape
importance;
* whether the site is in an air quality management zone or is likely to cause a breach of current legislation;
* the transport-related impact of the development on areas of nature conservation or
biodiversity and Earth heritage interests (such as geology) where they interact with
roads;
* heritage of historic resources where they interact with development-generated transport and/or proposed mitigation measures;
* the transport-related impact of the development on the townscape;
* appraisal of the transport-related impacts of the development on the water
environment;
* the impact of the transport implications of the development on physical fitness;
* journey ambience.

4.39 The potential for environmental impacts that would breach a statutory limit should be addressed. LHAs and the HA have a statutory duty to prevent a breach of statutory limits (e.g. air quality) due to incremental change of volumes of vehicular traffic on their networks."

The number of TA assessment years in respect of capacity analysis for transport network, is not consistent with the size, scale and completion schedule of the other four huge developments going on in the same vicinity of this site. Plans that are already approved are London Luton Airport Expansion, Napier Park and Butterfield Green Business Estate. And verging approval is Powercourt. This is too much for one side of the town to absorb. And it is impossible to predict the consequences upon the transportation systems of these four massive projects alone. All of these developments are considered more vital to LBC's economy than the Land East of Luton. It is necessary therefore to prioritize, and accept development in order to be sustainable must be paced and calculated.

"ASSESSMENT YEARS
4.45 The assessment year(s) in respect of capacity analysis for the transport network should be consistent with the size, scale and completion schedule of the proposed development, and that of other major developments in the vicinity of the site, as well as planned improvements to the transport system.
4.46 The appropriate horizon assessment year should be agreed with the relevant authorities during pre-application consultations.

4.47 In addition to the opening year, one or two further assessment years should be considered.
For the local transport network, a development should be assessed with regard to the LDF, and for a period of no less than five years after the date of registration of a planning application. Should the development take place over a longer period, it would be appropriate to extend the length of the assessment period. The development proposal should be supported by an acceptable TA, carried out in accordance with the GTA. This will help to ensure that the transport impacts of the development are more accurately applied to a situation where all committed local transportation infrastructure improvements are in place."
[Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government]
However in our case this should be reread reversely as "The development proposal should be supported by an acceptable TA, carried out in accordance with the GTA. This will help to ensure that the transport impacts of the development are more accurately applied to a situation where all committed local transportation infrastructure deteriorations are in place."

Traffic Assessments and the Tardis Factor

Literally bumper to bumper, there is only literally physically space to have 4,291 moving average cars bumper to bumper non-stop in one hour on Luton Crawley Green Road. That is non-stop, bumper to bumper however. This would mean a tail-back mostly all the way up the road on a permanent basis during peak times. It doesn't include Heavy Vehicles which also use that road.

What would happen if tomorrow car owning people of the proposed new development, took their cars out onto Luton Road and Crawley Road and into drove into Wigmore Lane in the rush hours?

Vague Traffic Assessments by AECOM

The published data from the Traffic assessments appear to be vague and inconsistent.

We have obtained AECOM's North Hertfordshire District Council Preferred Option Housing Assessment - Transport Modelling Report 2014 - Update 2 (71 pages)

And also the later AECOM study "Hertfordshire County Council Transport Planning Contract, Job No: 60279140 - 160" East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council) dated 24/02/16 (20 pages)

Seeking Earlier Versions of "Hertfordshire County Council Transport Planning Contract, Job No: 60279140 - 160" East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council) dated 24/02/16 (20 pages)

Regarding the later study Job No: 60279140 - 160/ East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council) there were serious changes made to the first and second versions that passed between council and AECOM, before NHDC settled on a final version. The document passed between AECOM to NHDC several times between parties, at NHDC's request alterations were made. Both parties will have record of this on their email company correspondence at systems level.

Parts where changed, then further parts changed at NHDC's request. We ask the Inspector to obtain these two earlier drafts of East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council). There were two previous drafts which passed between NHDC and AECOM before this final version.

It is important that we see what information was taken out, and then see if it needs putting back in again.

The newer AECOM Transport Modelling Assessment dated 24 Feb 2016 claims to be "an initial modelling assessment". However there is also a much earlier one by AECOM dated 7 Jan 2015. So we know it is not the "initial assessment" exactly. The earlier one would be the initial assessment. The earlier one was much, much longer however. It was 71 pages in total. The later one has shrunk down to just 20 pages. We think the later TA should be longer than 20 pages and more thorough.

Alarmingly, we think that the Traffic Assessments might not all completely agree with one another.

Transportation, Air Pollution and Child Health

Children are more susceptible to the brain damaging effects of heavy metals than adults.
There are two schools on this congested road - Richmond Hill Special Needs School and Wigmore Primary School.

It is unsafe to expose the children to this degree of heavy toxicity in the atmosphere. You have not consulted either school for their recommendations regarding health and safety impacts for pupils.

The children in Richmond Hill are already suffering a range of disabilities, and the plan is ignoring the damaging effects on disadvantaged children. It is fact that outdoor air pollution is responsible for 20 times more early deaths than the number of people killed on our roads.

The children at Richmond Hill have challenges, disorders and learning difficulties; many which are genetic. They require a healthy non-toxic environment which does not antagonise the various consequences of these disorders and learning difficulties further.

The exhaust fumes along this road collect in the air and you can smell them.

The exhaust fumes plus the jet fuel from the airport is choking and I am concerned about the health effects for myself and my children.

This pollution is unpleasant and dangerous for residents' health, especially childrens'.

No air particulate studies have been done on this road or surrounding areas by either Luton Borough Council or North Herts District Council. This neglect is by their own admission in replies to Freedom of Information Requests [see Appendix: Freedom of Information Request#6-REPLY-(LBCRef923239) Traffic Assessments North Herts Local Plan & Luton Local Plan-21Sept2016].
So they do not know if it is currently within legal limits or above legal limits now. They cannot accurately assume if air quality will be inside legal limits after the building of a new expanded airport.

Remember that legal limits are not necessarily healthy limits. When air particulates are in the upwards zones already, they do not need to be made worse.

Unsafe Entry Roads

The Luton and Crawley Roads are already extremely congested, too narrow, next to two schools and have many residences directly on either side. This will be like making people suddenly live next to a motorway, when they initially purchased/ chose to live here due to it being a quiet, neat, beautiful semi-rural area.

Both schools have access points and entrances upon this one access road.

It is already extremely dangerous as cars race around the corner, and there is no crossing anywhere near either school.

It becomes even more dangerous during winter, when nights and mornings are darker so drivers can't easily see.

Airport Expansion and Air and Noise Pollution Consequences

The Local Plan doesn't address that the London Luton Airport will be expanding and what this will mean for the residents, roads and infrastructure around this whole area.

The government approved plans to expand London Luton Airport to nearly double its capacity from 10 million to 18 million passengers a year.

The air and noise pollution will hit even higher levels once the pending expansion occurs. What will they become? What are the projections? Are the studies covering a wide enough area? It is not enough to simply measure air quality and sound pollution only within the Airport's boundaries - when it affects a much wider district.

The air and noise pollution will not be absorbed by more buildings, so in this part of town authorities should be concentrating upon balancing the impact of airport expansion by planting more greenery, not masking it with more concrete.

The Serious Matter of Traffic Congestion on the Wider Network

The airport will also create a huge quantity of traffic, which will create impact in several directions into the Luton Road's connected networks - Eaton Green Road, the A505, Airport Way, Wigmore Lane, into Stopsley, Crawley and even Stockingstone Road. The site next to Hampton by Hilton London Airport behind Vauxhall known as Napier Park site, is already allocated and also going to generate yet more traffic to add into the estimations that should have been included in the traffic studies, but which were not.

Because traffic studies are not an exact science and only estimates/ approximations are used, they need to actually see what happens to the traffic networks AFTER the airport has been expanded and is running. Only then will they know what the true traffic situation will be after the airport expands. Also since Napier Park is a development which is going ahead, this must also be integrated in the plan. The Airport expansion traffic plus the Napier Park traffic may create more than heavy enough load to absorb.

Mistakes can and do happen if left unchecked. Anyone who first went to Dubai twenty years ago, will know that, what once was a ten minute drive from Deira to Jumeirah, is now a forty to fifty minute wait in traffic. Ten minutes became fifty minutes in just a decade. Beware, it can and does happen. It is already happening though however according to the local people in the Wigmore area. How will 18 million passengers get into and out of this "relaunched" airport?

But it gets even worse, because Luton airport is planned to grow to 22 million passengers by 2030.

The airport has seen huge growth over the recent years adding to the already stretched road network. This growth in traffic has not been taken into account in the traffic surveys carried out, which renders them completely inaccurate.

The Fatality Risk of Birdstrike & SUDS

The drainage of that land is terrible and it has a tendency to waterlog. Therefore they have suggested SUDs, yet the appearance of these things are contrived and inappropriate. The dangers of these in relation to birdstrike risks, have been entirely ignored.

Declassifying Greenbelt not Justifiable

The "New Neighbourhood Planning and Infrastructure Bill 2016" states that it supports the Government's aim to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. The land designated for development East of Luton is Green Belt. The reasons for including this land does not meet the "Very Special Circumstances" required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Policy Framework, Paragraph 83).
The land for these homes is allocated as a 'reserve' (in other words, last resort), and therefore should not form part of the main housing distribution plan. Only if this main plan fails in some way should this reserve area even be considered. However Luton has not exhausted all of the options within it's own boundaries.
There are many reasonable alternatives. There is no train connection into the city this East Luton side of town. How will the city commuters get to work? Other sites have much better transport connections than here.

It is a lie that that there are 1950 homes (the remaining 155 being for Herts needs) that "cannot be physically accommodated within Luton". There ARE enough alternative available/ purchasable NON-GREEN BELT plots inside Luton's own boundaries to meet it's housing needs.

There are several alternatives for Luton's unmet needs that have since come to light; example; plans for residential units have been made AFTER NHDC Local Plan displayed initial calculation and allocation based on Luton's unmet needs. So this unmet need has since changed. So the plan also needs to change to reflect that the unmet housing need that has now been lessened by these new allocations within Luton's own boundaries.

New Allocations, after the writing of NHDC Local Plan, are as follows:

a) 234,138.38m2 next to Hampton by Hilton London Airport behind Vauxhall. This Napier Park site, is already allocated for commercial purposes. However, recently LBC announced that 625 units would be for residential purposes. This reduces "Luton's Unmet Housing need claim" on Hertfordshire's land by 625.
b) 58,264.24m2 M1 Junction 10 to M1. This is the site of the current football club. When the new larger football club is operational in 2021, is the plan for it states, then this site will be available. This reduces the remaining "Luton's Unmet Housing need claim" on Hertfordshire's land, since they will be able to fits thousands of units in this site. The location is also compatible with the cross-sectional breakdown of housing needs, as displayed in Luton's Strategic Housing Management Assessment report.
c) 145,311.15m2 Chaul End Vauxhall Car Park, on greenbelt but as an "infill". - This site has been allocated already. Does the allocation include any residential units? If so they too need to be deducted from Luton's claimed "Unmet Housing Need figure".

Alternative allocations are as follows:

d) 22,009.77m2 at Gypsy Lane/ Kimpton Road Car Parks and Scrubland is an alternative. Although it's considered an industrial zone, it could be re-zoned. Or if it can't be re-zoned the plans for a soft industrial site upon Wigmore Valley Park could be switched to here. Then instead of using Wigmore Valley Park for soft industry, could residential units be placed here instead?
e) Butterfield Green Business Estate - If LBC suddenly found room for 625 extra units on Napier Park, then why can't they also give a little section of the large Butterfield green site to residential units too?
f) 19,781.58m2 Hatters Way demolished site - is an industrial site which could be re-zoned. If not re-zoned it could be used for soft industry and thus free up the Wigmore Valley Park's soft industrial allocation.
g) 289,812.695m2 Dallow Road next to M1.
h) 83,130.63m2 M1 Junction 10 is where they are intending to place a football club and shopping centre. This of course will also lead to additional traffic problems, especially on match days when thousands of people drive into town and try to park their cars.
i) 517,700.94m2 Dunstable Chalk Hill. Dunstable is actually in need of regeneration. This is an opportunity to place regeneration in a place that actually needs it, instead of placing degeneration in a place that doesn't want it.
j) Kennelworth Road - A potential housing site, interdependent upon the stadium of Powercourt.
k) Bushwood - 5,500 residential homes of a range of types and tenures supporting a diverse population could be placed here according to the Bushwood Master Plan [Available at: http://bushwood.info/docs/Bushwood-Masterplan.pdf]. Ten years ago the developer was all ready to build but the plan though fairly far advanced, was put on hold. They had even placed two tunnels between junctions 10 and 11 of the M1. These were put there at the time of building the M1. These tunnels could be used to provide connection points to any development at Bushwood, since they still exist today; one is currently being used by a farmer and the other tunnel is part of a bridle way near - they are near Chaul End and Caddington. The Developer was all ready to begin building here. Unlike land East of Luton, Bushwood has excellent access points in and out from the M1, which it is right next to, and it has train stations nearby to enable populations to commute.

Therefore to destroy the Green Belt next to East Luton is not a necessity at all.

Green Belt Next to Areas of Outstanding Natural Beauty

Land East of Luton is next to two Areas of Outstanding Natural Beauty. Putteridge Bury (AONB) is on one side and then Lilley (AONB) is on the other. The EL development would obscure and radically alter the view of these two AONBs.

Urban Sprawl

The purpose of the Green Belt is to stop urban sprawl; this stretch off Green Belt is already so narrow and if taken away there will be absolutely no separation between Luton and Hertfordshire at all.

The boundaries would have to be moved, which will create it's own new problems.

They are already taking away Green Belt land with the Butterfield Green Business Estate - so the area is already going to be losing that.

The NHDC Local Plan says a site MASTERPLAN for all three sites EL1, EL2, and EL3 must be submitted and approved before the submission of any detailed matters (p.40). So why was Crown Estates permitted to submit one isolated planning application [PA 16/02014/1 for 660 dwellings East of Luton] prematurely BEFORE the Local Plan itself has even been inspected or approved?! It seems that the developers and council are speculating and too confident that the many serious doubts around the soundness of this Local Plan will be overlooked and ushered through.

The East of Luton and West of Cockernhoe communities now question transparency and fairness, since we are unhappy at this premature application, which ignores the MASTERPLAN. Was it a tactical move to divert and disperse our efforts to object previously?

Conservation

The rare wildlife in the Brickkiln Wood will not survive this encroachment upon their habitats. Neither will the humans ultimately survive the attack on their habitat. Already many local residents are thinking of selling up and moving away, since they cannot envisage a life in this area after losing their Green Belt and the character of the area that they love. This Local Plan and it's looming consequences has been spoiling quality of life for lots of people. Many people including myself, have been putting off making any home improvements and feel unsettled since this development has been proposed, since they believe that life cannot go on here were this to go ahead. It is no exaggeration to say that the local people are actually extremely distressed. I describe that seriously and accurately. It is affecting the population's quality of life, they are so worried.

There is an extremely high number of tree preservation orders on this area - higher than nearly all other areas considered. This indicates the ancient and mature nature of this particular Green Belt area.

Archaeological Heritage and Shrinking Later Studies

There are many archaeological sites strewn across the area, and it is noticeable that in older archaeological studies many more sites are mentioned than in the council's newer studies. I would therefore like to see the old studies revisited and those sites missing in the newer studies need to be added back into the newer studies. And I ask why are there so many archaeological sites documented in much earlier archaeological studies commissioned by NHDC, as well as private ones, which are no longer documented on the newer archaeological studies? The archaeological heritage didn't diminish, so let's re-examine and make sure that the later studies are as thorough as the earlier ones.

Unacceptable and Disproportionate Alteration of the Character of an Area

If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.

Wigmore consists of about 4500 houses, so the size of this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it on the side of it all over again.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village.

Infrastructure - Schools and Education Services Undeliverable

From the "Minutes of LBC Executive Meeting/ Agenda Item Number: 23
Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen":

"24. Discussions on previous plans for the land assumed that secondary school provision would be met at Ashcroft High. Such assumptions will need to be re-tested. If there is surplus capacity at Ashcroft, school buses may be required to mitigate further transport impact."
The nearest Secondary school on the Herts side are: Zero. There are no secondary schools on the Herts side nearby.
The nearest Secondary schools on the Luton side are just: Ashcroft High School and Putteridge High School.
How many extra school children and of what ages will 2,105 new houses typically generate?
The matter of providing infrastructure and costing for mandatory state run education services has not been factored in at all, and on this point the Local Plan is not deliverable and therefore not effective.
Recycling Oversubscribed Schools in Plans

Regarding developer plans "The Crown Estate Land West of Cockernhoe Illustrative Emergency Access Mangrove Road [KH 24/08/2015 A Access relocated in response to updated Site Boundary/ JM KH 25/08/2015]"
Upon their map they have actually presented the three schools, as the already over-subscribed Someries, Wigmore and Cockernhoe primary schools.

Is this the extent of Crown's Education Infrastructure solution? Isn't flooding two already full-up schools with 800 new children, actually making an infrastructure problem?
Social Infrastructure Undeliverable
The current level of social infrastructure can barely support the existing community in that area as it is. So far the councils themselves plus the two developers, have put forward plans for this area, which are totally inadequate to support their proposals in this capacity. There is no detail as to how they will deliver and pay for the basic services.
Infrastructure - Rubbish Collection Services Unaddressed
Rubbish Collection Services are not detailed or deliverable in this Local Plan.
How much will it cost to provide extra rubbish collections on a regular basis on a continual basis per annum? What will be the total cost until the end of the Local Plan, and beyond that? Who will pay for these? Will it be NHDC or LBC? Or will it be charged as additional Council Tax levied onto Herts residents or else Luton residents? This has not been addressed.
Who will carry out the extra rubbish collections? How many tonnes of extra rubbish will have to be removed annually? What is the costing for 2105 or more extra houses? Will it NHDC or LBC that will carry out the labour? Do they have the capacity and labour power in their departments to do this extra work?
Infrastructure - General Practitioner Services Unaddressed
How can health services at most basic level be provided to this extra segment of population? How many extra people would be resident in 2105 new dwellings, and in what capacity and to what quality will they need to be given these services?
How much will it cost to provide extra GP services on a continual basis per annum? What will be the total cost until the end of the Local Plan, and beyond that? What GP surgery will the extra residents go to? Will they build a new surgery to service this new population? How much will the building of and running of a new GP Surgery cost? Who will build and pay for it? Will it be NHDC or LBC? Or will it be levied as additional Council Tax to Herts residents or else Luton residents? This has not been addressed. How will costs be divided - if the population due to be serviced is within the Herts Borough, but in reality the other Borough is expected to provide the services due to it's proximity to the new estate? Which County will pay for this, and how will they figure this ongoing extra cost into their budget? Which services will lose out to make up for it?
The current ones in the area are already over-subscribed and the length of waiting times for appointments is already unsatisfactory. Current residents cannot be expected to lose the quality of their health services yet further. Is it justifiable to diminish the quality of public services in this area, yet still charge people the same, or more for them (via Council and other taxes)?
Infrastructure - Emergency Health Services Unaddressed
The Local Plan doesn't address earlier health budget deficits at all or think how they will address them rather than add to them.
Infrastructure - Water Pressure, Sewage and Thames Valley Concerns
In Luton Water Cycle Strategy, September 2015
[https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Local%20Plan/Climate%20change/CC%20005.pdf]

Point 3.2.4 says "The Water Framework Directive recognises the potential impacts on water bodies from new development as a pressure that must be addressed."

"The area north of Houghton Regis (which falls within the study area) is covered by the Anglian RBMP. The Anglian River Basin Management Plan (December 2009) identifies Luton as one of the three largest Growth Areas which will see a substantial amount of new development in the next 15-20 years, particularly in areas identified for growth or regeneration. Pressures from the cumulative impacts of planned development, especially those on water resources and water quality mean that actions will be required to achieve good ecological status and ensure that there is no deterioration.
Refer to the RBMP document for more details." [p.8]
Infrastructure - Police and Security Services Unaddressed
The Police budget is already stretched. Many crimes are being left un-investigated due to lack of resources.
Will NHDC or LBC provide adequate resources and budget as a result of the proposed housing development? If the population due to be serviced is within the Herts Borough, but in reality the other Borough is expected to provide the services due to it's proximity to the new estate, has it been agreed which County will pay for this, and how will they figure this ongoing extra cost into their budget?
Changing the Character of an Area and Removal of Vital Green Space
Luton currently has 30% too little greenery for a town of this size.

The community uses the green space here for leisure activities such as walking their dogs, exercise, taking children to play, people ride their horses along the bridal path, enjoy hiking, jogging or simply the views throughout the seasons.

This development will rob many thousands of local people of this simple but valuable and life-enriching treasure.

It is absolutely the view of the community that this development doesn't fit in with it's surroundings. It will uglify the whole area. There are also flats mentioned in the Plans, and this area does not have flats so this is inconsistent.

Wigmore Valley Park is already going to be taken away and placed outside of the Wigmore area. Therefore the people of this area would no longer have any green space and leisure areas other than this bridle path and Green Belt zone. If you take this away too, there will be nothing!

This is an unacceptable level of development forced upon this area, and it would alter it's character too drastically and too quickly for it's population and infrastructure to absorb.

This will have negative health consequences for the community as a whole.

Duty Not to Cooperate

Councils don't always pool their ideas and strategies seamlessly. We have seen many blind-spots occurring where duty to cooperate, gets interpreted as duty to blame the other council. This seems to be the mechanism at work, when it comes to things they don't like.

"27. It will be for North Hertfordshire to fully assess and model the appropriateness of their potential spatial strategy in terms of infrastructure (e.g. A1M capacity junctions 6 and 8) and sustainability (landscape, wildlife, economy and community impacts). However, Luton Borough Council's position is that North Hertfordshire should also make provision for a likely level of unmet need arising within Luton. Currently, the estimated capacity of the borough is believed to be around 6,200 dwellings over the plan period (2011-2031) compared to a trend migration requirement of 10,900 dwellings."
[Minutes of LBC Executive Meeting/ Agenda Item Number: 23
Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen].

So LBC is relying on North Hertfordshire to fully assess Luton's transport systems. However Hertfordshire is saying that Luton should be responsible for it's transportation systems. There are many lackings in the Transport Assessments. I don't actually see any mention of Wigmore networks, nor Stopsley, Crawley, or Stockingstone Road. Yet all would be impacted.
"28. The scale of provision will be dependent on cooperation with other neighbouring authorities including Central Bedfordshire. It will also depend on infrastructure capacity serving the east of the borough (e.g. the peak congestion experienced on the A505 and eastern corridor serving the airport) and any improvements that could be secured on the local network and in terms of community infrastructure."
[Minutes of LBC Executive Meeting/ Agenda Item Number: 23
Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen].

Empty Housing Un-utilised

Despite widespread anxiety about a shortage of housing supply, there are 610,123 empty homes in England, according to the government. Of these, 205,821 have been unoccupied for six months or more, the official definition of "long-term" emptiness. In September last year, Scotland had 31,884 long-term empty properties as of 2 Dec 2015. I understand that there are over 650 empty houses vacant in Luton.

Brexit
The NHDC Local Plan has not given any information about how Brexit will impact migration rates. It claims uncertainty. Yet on the contrary it considers itself able to predict future traffic data, for up to four new major traffic generating projects!
The migration assumptions and projections used to calculate unmet housing needs are going to change.
Inadequate Retail Facilities

In one East Luton development plan it has suggested that Westway shops could meet it's retail needs. However Westway is only four tiny shops: a chip shop, tiny beauty salon, hardware shop, and tiny corner store. These shops cannot provide for 5,052 people's retail requirements. The Local Plan says that there must be 250m2 (net) class A1 convenience retail provision (p.40).

Please send me a receipt for my objection. I was unable to upload it onto your system because you have a 3000 character limitation.

I object to the NHDC Local Plan 2011-2031 at this Regulation 19 stage. I want to change parts of this Local Plan. I want to participate in the Examination fully.
The plan is unsound. I object to the part of North Hertfordshire Local Plan 2011-2031, which allocates 2,105 dwellings on Land East of Luton.

This plan is not positively prepared, deliverable, justified, effective or consistent with national policy.

The Traffic Surveys have not been carried out to acceptable standards and also the results of this survey showed a negligible or nil effect on local congestion when the results and thus the underpinning of the proposal were based on a road that doesn't exist and hasn't even been proposed.

Unsound Reasoning and Incorrect, Inadequate Transportation Studies
There have been a series of Executive Meetings spanning several years up until the current time. LBC has repeatedly discussed points of concern and has concluded the lack of infrastructure and inadequate road network, to be a major and unresolved obstruction point.
Luton was consulted by North Herts District Council three times since 2013 on house building plans East of Luton, in each case Labour run LBC said they wanted either NO HOUSES or MORE. Their reason is that unless there are no less than 5,000 houses, they cannot justify or afford to build a new road from the A505 to the airport and on to the M1 junction 10.
So LBC WANT MORE houses not fewer. Their view is it's MORE or nothing. If it is ONLY 2,105 dwellings then they don't want them.
Most recently, the "2016.07.20. Summary of LBC Decisions/ Cllr David Franks" provides a brief summary of what has been decided by LBC. Their entire case rests on the need to finance a new road which could not be funded by smaller developments. Hence they are looking for a new road from the A505 to the airport and on to M1 junction 10. Yet even if this new road could be achieved it would simplify the journey from the new development to the airport and to the M1 motorway but do nothing to help families from the new homes to get into Luton town centre, to local employment areas, to medical facilities or to schools.
However bearing in mind that the whole of Wigmore is approximately 4,500 houses, building 5000 houses would be asking to build a part of the town LARGER than actual Wigmore itself. This is doubling the size on the area on land. And this is on Hertfordshire's land. They cannot fit 5,000 dwellings on this land.
The Transportation Network
Consider these comments taken from LBC executive meetings:

"With regard to the housing options east of Luton, we urged that any proposals must provide for adequate supporting community and transport infrastructure. This is particularly important in terms of the A505 and also the Luton corridor (serving the airport, Wigmore area and key regeneration sites connected by Vauxhall Way, Eaton Green Road, Crawley Green Road from the M1 Junction 10a) which are already badly affected by peak hour congestion." [Letter dated 10 Jun 2013, Cllr Sian Timoney addressed Cllr T. Brindley Executive Member NHDC about "Luton Local Plan Cross Boundary Issues" [Brindley Letter from Sian Timoney].
"22. The proposal for the major strategic development to the south west of Hitchin would have both benefits and drawbacks for Luton. On the plus side it would dramatically improve road access to Luton from the east, delivering a continual dual carriageway road on to the A1 (M) and beyond. Luton would also welcome the opportunity that such a scheme might offer to provide for the needs of Luton residents which cannot be delivered within Luton. However, on the negative side, the improved road access will undoubtedly put additional traffic pressure onto the A505 within Luton which is already suffering from severe congestions during peak periods." [Minutes of LBC Executive Meeting/ Agenda Item Number: 23 Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen]
"23. While the current development proposals for the East of Luton site provide a local centre, the main retail draw will be Luton and there is expected to be a significant increase in traffic around the Wigmore Asda. Previous proposals for development of the land in this location provided for a more comprehensive scheme which included a bypass that took airport/M1 traffic off the Vauxhall Way corridor and provided some mitigation for the development. The current proposals will not provide such infrastructure. The scope of transport impact appraisal relating to the East of Luton site is currently being agreed between the Council and relevant consultants. It is expected to cover Eaton Green Road, Crawley Green Road, Vauxhall Way, Airport Way, M1J10a and peripheral roads." [Minutes of LBC Executive Meeting/ Agenda Item Number: 23 Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen]
The development plan for Land East of Luton is like a big balloon, with one solitary entry and exit point only - that's the Luton Road leading into Crawley Green Road. If each house has two cars, that would generate 4210 extras cars travelling along that one road.

I object to the NHDC Local Plan 2011-2031. I want to change parts of this Local Plan. I want to participate in the Examination fully.
Infrastructure and Roads requests from LBC
Very specific requests at Executive levels, formed the basis for LBC's formal response to NHDC's Local Plan Consulation.
On 25 March 2013, LBC asked NHDC to:-

"4. Adequately model the impacts and necessary supporting infrastructure, should any
sites progress to the east of Luton. This will ensure that development is of a scale to be sustainable and help to resolve severe congestion:
* on the A505;
* around the Wigmore Asda area;
* along the east Luton corridor serving the airport, Vauxhall Way, Airport Way and
M1J10a;
* along Eaton Green Road, Crawley Green Road and other peripheral roads;
* Work closely with Luton on any cross boundary Community Infrastructure Levy matters"
[Executive Meeting-Luton Borough Council's Response to North Hertfordshire - New Local Plan Further Consultation: Housing Additional Location Options - July 2013]

NHDC Local Plan has not met these requests.
LBC also formally requests:
"16. However, North Herts is urged to ensure that a strategic approach is taken to examine the potential developments. They should secure sustainable communities supported by strategic infrastructure, including transportation, which integrates new and existing communities, links district and town centres, shopping, services and employment areas and tackles traffic congestion."
[Executive Meeting-Luton Borough Council's Response to North Hertfordshire - New Local Plan Further Consultation: Housing Additional Location Options - July 2013]
The NHDC Local Plan does not meet these requests either.
"Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government" is a document that provides guidance on the content and preparation of Transport Assessments (TAs) and Transport Statements (TSs).

It should be read in conjunction with, and in the context of, relevant Government policies, in particular those relating to transport and planning.

The TAs and TSs for this Local Plan are totally inadequate for numerous reasons. They are not robust nor founded upon a credible evidence base. The reasons for this are, but not limited to, the following.

Alarmingly LBC has undertaken transport modelling to support the preparation of its Local Plan and created an imaginary road that does not exist!

"5.1 National planning policy as set out in PPS1, PPS11 and PPS12 emphasises the requirement for development plans to be founded on 'a robust and credible evidence base'. [PPS 11 (para. 2.49); PPS12 (para. 4.24)]"

"5.2 Development plans will only be credible, authoritative and deliverable if transport
considerations are fully factored into their development from the outset."

In a Freedom of Information Request relating to the transportation studies for East Luton development as conducted so far, LBC states it's Transport Modelling assumes this road that does not exist:

"Luton Borough Council (LBC) has undertaken transport modelling to support the preparation of its Local Plan which includes the development east of Luton which, under the Duty to Cooperate, includes 2100 homes in North Hertfordshire to the east of the town. 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. This is just a high level operational assessment and, as more detailed design of the transport network associated with that development is progressed, a more detailed operational assessment based on current and future traffic conditions will be undertaken as part of the Transport Assessments and Sustainable Travel Plans as proposals for development of that site are brought forward."
[FOIR #6-REPLY-(LBCRef923239) Traffic Assessments North Herts Local Plan & Luton Local Plan-21Sept2016]

LBC admits their and NHDC's studies are based on totally different basic premises. Whilst LBC used an imaginary exit and entry road, to change the entire outcome of it's TA, NHDC did not include the imaginary road:

"The main difference compared to the LBC report (see response 1 above) is that North Hertfordshire's assessment did not include the new road between the A505 and the northern end of the spine road through the development site." [FOIR #6-REPLY-(LBCRef923239) Traffic Assessments North Herts Local Plan & Luton Local Plan-21Sept2016]

There is, and never has been a proposed new road in North Herts. The basis of the transport infrastructure relies on the existing Tarmac historic single track lanes in N Herts, i.e. Chalk Hill and Stoney Lane.

Maybe LBC need to do another Transportation Modelling study that also doesn't include this non-existent road, then it will be more in line with reality. That reality being heavy traffic congestion building up along Wigmore, Crawley Green, Eaton Green and Stockingstone roads.

More importantly, there is no reference to the devastating effect on the inadequate existing roads into Luton, Luton Airport, Train stations, and the M.1.

The Crown Estate application, shows no intention of linking to a new "spine" road, so should it not fail on this alone?

Guidance of Transport Assessment and Environment Ignored

"Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government" lists many issues that haven't been addressed by the Local Plan:

"Environment
4.38 The environment issues that should be assessed include:
* nuisance to people caused by transport-related noise and vibration generated by the development;
* the emission of greenhouse gases as a result of the transport implications of the development and the impact of changes in local air quality on people;
* the transport-related impacts of the development on areas of designated landscape
importance;
* whether the site is in an air quality management zone or is likely to cause a breach of current legislation;
* the transport-related impact of the development on areas of nature conservation or
biodiversity and Earth heritage interests (such as geology) where they interact with
roads;
* heritage of historic resources where they interact with development-generated transport
and/or proposed mitigation measures;
* the transport-related impact of the development on the townscape;
* appraisal of the transport-related impacts of the development on the water
environment;
* the impact of the transport implications of the development on physical fitness;
* journey ambience."

4.39 The potential for environmental impacts that would breach a statutory limit should be addressed. LHAs and the HA have a statutory duty to prevent a breach of statutory limits (e.g. air quality) due to incremental change of volumes of vehicular traffic on their networks.

Have LBC and NHDC conducted air quality assessments in the development area or carried out any noise pollution studies.

LBC said: "LBC has not undertaken any detailed assessments of Crawley Green/ Luton Road. Luton Road is situated in North Hertfordshire District Councils Area who may be able to advise regarding this location."
[Freedom of Information Request #3-REPLY-(LBC Ref# 910229)Traffic Special Needs School -5Jul2016].

"Environmental Protection has not carried out any noise pollution studies along Crawley Green Road. Luton Road as per question 11 is outside the borough boundary and part of North Hertfordshire District Council.
[Freedom of Information Request #3-REPLY-(LBC Ref# 910229)Traffic Special Needs School -5Jul2016].

Furthermore, there has been a big change since the Local Plan Transport Studies were conducted. Heavy goods vehicles have since been re-routed by NHDC, to along the Luton Road and Crawley Green Road. So the TAs now also fall short of another standard too:

"Traffic data and traffic forecast
4.18 The assessment should include recent counts (normally surveyed within the last three
years) for peak period turning movements at critical junctions. In certain instances, for
example, where there is known to be a significant level of heavy goods vehicles (HGV)
traffic, a classified count2 should be provided." [Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government]

"Environment
4.38 The environment issues that should be assessed include:
* nuisance to people caused by transport-related noise and vibration generated by the development;
* the emission of greenhouse gases as a result of the transport implications of the development and the impact of changes in local air quality on people;
* the transport-related impacts of the development on areas of designated landscape
importance;
* whether the site is in an air quality management zone or is likely to cause a breach of current legislation;
* the transport-related impact of the development on areas of nature conservation or
biodiversity and Earth heritage interests (such as geology) where they interact with
roads;
* heritage of historic resources where they interact with development-generated transport and/or proposed mitigation measures;
* the transport-related impact of the development on the townscape;
* appraisal of the transport-related impacts of the development on the water
environment;
* the impact of the transport implications of the development on physical fitness;
* journey ambience.

4.39 The potential for environmental impacts that would breach a statutory limit should be addressed. LHAs and the HA have a statutory duty to prevent a breach of statutory limits (e.g. air quality) due to incremental change of volumes of vehicular traffic on their networks."

The number of TA assessment years in respect of capacity analysis for transport network, is not consistent with the size, scale and completion schedule of the other four huge developments going on in the same vicinity of this site. Plans that are already approved are London Luton Airport Expansion, Napier Park and Butterfield Green Business Estate. And verging approval is Powercourt. This is too much for one side of the town to absorb. And it is impossible to predict the consequences upon the transportation systems of these four massive projects alone. All of these developments are considered more vital to LBC's economy than the Land East of Luton. It is necessary therefore to prioritize, and accept development in order to be sustainable must be paced and calculated.

"ASSESSMENT YEARS
4.45 The assessment year(s) in respect of capacity analysis for the transport network should be consistent with the size, scale and completion schedule of the proposed development, and that of other major developments in the vicinity of the site, as well as planned improvements to the transport system.
4.46 The appropriate horizon assessment year should be agreed with the relevant authorities during pre-application consultations.

4.47 In addition to the opening year, one or two further assessment years should be considered.
For the local transport network, a development should be assessed with regard to the LDF, and for a period of no less than five years after the date of registration of a planning application. Should the development take place over a longer period, it would be appropriate to extend the length of the assessment period. The development proposal should be supported by an acceptable TA, carried out in accordance with the GTA. This will help to ensure that the transport impacts of the development are more accurately applied to a situation where all committed local transportation infrastructure improvements are in place."
[Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government]
However in our case this should be reread reversely as "The development proposal should be supported by an acceptable TA, carried out in accordance with the GTA. This will help to ensure that the transport impacts of the development are more accurately applied to a situation where all committed local transportation infrastructure deteriorations are in place."

Traffic Assessments and the Tardis Factor

Literally bumper to bumper, there is only literally physically space to have 4,291 moving average cars bumper to bumper non-stop in one hour on Luton Crawley Green Road. That is non-stop, bumper to bumper however. This would mean a tail-back mostly all the way up the road on a permanent basis during peak times. It doesn't include Heavy Vehicles which also use that road.

What would happen if tomorrow car owning people of the proposed new development, took their cars out onto Luton Road and Crawley Road and into drove into Wigmore Lane in the rush hours?

Vague Traffic Assessments by AECOM

The published data from the Traffic assessments appear to be vague and inconsistent.

We have obtained AECOM's North Hertfordshire District Council Preferred Option Housing Assessment - Transport Modelling Report 2014 - Update 2 (71 pages)

And also the later AECOM study "Hertfordshire County Council Transport Planning Contract, Job No: 60279140 - 160" East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council) dated 24/02/16 (20 pages)

Seeking Earlier Versions of "Hertfordshire County Council Transport Planning Contract, Job No: 60279140 - 160" East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council) dated 24/02/16 (20 pages)

Regarding the later study Job No: 60279140 - 160/ East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council) there were serious changes made to the first and second versions that passed between council and AECOM, before NHDC settled on a final version. The document passed between AECOM to NHDC several times between parties, at NHDC's request alterations were made. Both parties will have record of this on their email company correspondence at systems level.

Parts where changed, then further parts changed at NHDC's request. We ask the Inspector to obtain these two earlier drafts of East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council). There were two previous drafts which passed between NHDC and AECOM before this final version.

It is important that we see what information was taken out, and then see if it needs putting back in again.

The newer AECOM Transport Modelling Assessment dated 24 Feb 2016 claims to be "an initial modelling assessment". However there is also a much earlier one by AECOM dated 7 Jan 2015. So we know it is not the "initial assessment" exactly. The earlier one would be the initial assessment. The earlier one was much, much longer however. It was 71 pages in total. The later one has shrunk down to just 20 pages. We think the later TA should be longer than 20 pages and more thorough.

Alarmingly, we think that the Traffic Assessments might not all completely agree with one another.

Transportation, Air Pollution and Child Health

Children are more susceptible to the brain damaging effects of heavy metals than adults.
There are two schools on this congested road - Richmond Hill Special Needs School and Wigmore Primary School.

It is unsafe to expose the children to this degree of heavy toxicity in the atmosphere. You have not consulted either school for their recommendations regarding health and safety impacts for pupils.

The children in Richmond Hill are already suffering a range of disabilities, and the plan is ignoring the damaging effects on disadvantaged children. It is fact that outdoor air pollution is responsible for 20 times more early deaths than the number of people killed on our roads.

The children at Richmond Hill have challenges, disorders and learning difficulties; many which are genetic. They require a healthy non-toxic environment which does not antagonise the various consequences of these disorders and learning difficulties further.

The exhaust fumes along this road collect in the air and you can smell them.

The exhaust fumes plus the jet fuel from the airport is choking and I am concerned about the health effects for myself and my children.

This pollution is unpleasant and dangerous for residents' health, especially childrens'.

No air particulate studies have been done on this road or surrounding areas by either Luton Borough Council or North Herts District Council. This neglect is by their own admission in replies to Freedom of Information Requests [see Appendix: Freedom of Information Request#6-REPLY-(LBCRef923239) Traffic Assessments North Herts Local Plan & Luton Local Plan-21Sept2016].
So they do not know if it is currently within legal limits or above legal limits now. They cannot accurately assume if air quality will be inside legal limits after the building of a new expanded airport.

Remember that legal limits are not necessarily healthy limits. When air particulates are in the upwards zones already, they do not need to be made worse.

Unsafe Entry Roads

The Luton and Crawley Roads are already extremely congested, too narrow, next to two schools and have many residences directly on either side. This will be like making people suddenly live next to a motorway, when they initially purchased/ chose to live here due to it being a quiet, neat, beautiful semi-rural area.

Both schools have access points and entrances upon this one access road.

It is already extremely dangerous as cars race around the corner, and there is no crossing anywhere near either school.

It becomes even more dangerous during winter, when nights and mornings are darker so drivers can't easily see.

Airport Expansion and Air and Noise Pollution Consequences

The Local Plan doesn't address that the London Luton Airport will be expanding and what this will mean for the residents, roads and infrastructure around this whole area.

The government approved plans to expand London Luton Airport to nearly double its capacity from 10 million to 18 million passengers a year.

The air and noise pollution will hit even higher levels once the pending expansion occurs. What will they become? What are the projections? Are the studies covering a wide enough area? It is not enough to simply measure air quality and sound pollution only within the Airport's boundaries - when it affects a much wider district.

The air and noise pollution will not be absorbed by more buildings, so in this part of town authorities should be concentrating upon balancing the impact of airport expansion by planting more greenery, not masking it with more concrete.

The Serious Matter of Traffic Congestion on the Wider Network

The airport will also create a huge quantity of traffic, which will create impact in several directions into the Luton Road's connected networks - Eaton Green Road, the A505, Airport Way, Wigmore Lane, into Stopsley, Crawley and even Stockingstone Road. The site next to Hampton by Hilton London Airport behind Vauxhall known as Napier Park site, is already allocated and also going to generate yet more traffic to add into the estimations that should have been included in the traffic studies, but which were not.

Because traffic studies are not an exact science and only estimates/ approximations are used, they need to actually see what happens to the traffic networks AFTER the airport has been expanded and is running. Only then will they know what the true traffic situation will be after the airport expands. Also since Napier Park is a development which is going ahead, this must also be integrated in the plan. The Airport expansion traffic plus the Napier Park traffic may create more than heavy enough load to absorb.

Mistakes can and do happen if left unchecked. Anyone who first went to Dubai twenty years ago, will know that, what once was a ten minute drive from Deira to Jumeirah, is now a forty to fifty minute wait in traffic. Ten minutes became fifty minutes in just a decade. Beware, it can and does happen. It is already happening though however according to the local people in the Wigmore area. How will 18 million passengers get into and out of this "relaunched" airport?

But it gets even worse, because Luton airport is planned to grow to 22 million passengers by 2030.

The airport has seen huge growth over the recent years adding to the already stretched road network. This growth in traffic has not been taken into account in the traffic surveys carried out, which renders them completely inaccurate.

The Fatality Risk of Birdstrike & SUDS

The drainage of that land is terrible and it has a tendency to waterlog. Therefore they have suggested SUDs, yet the appearance of these things are contrived and inappropriate. The dangers of these in relation to birdstrike risks, have been entirely ignored.

Declassifying Greenbelt not Justifiable

The "New Neighbourhood Planning and Infrastructure Bill 2016" states that it supports the Government's aim to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. The land designated for development East of Luton is Green Belt. The reasons for including this land does not meet the "Very Special Circumstances" required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Policy Framework, Paragraph 83).
The land for these homes is allocated as a 'reserve' (in other words, last resort), and therefore should not form part of the main housing distribution plan. Only if this main plan fails in some way should this reserve area even be considered. However Luton has not exhausted all of the options within it's own boundaries.
There are many reasonable alternatives. There is no train connection into the city this East Luton side of town. How will the city commuters get to work? Other sites have much better transport connections than here.

It is a lie that that there are 1950 homes (the remaining 155 being for Herts needs) that "cannot be physically accommodated within Luton". There ARE enough alternative available/ purchasable NON-GREEN BELT plots inside Luton's own boundaries to meet it's housing needs.

There are several alternatives for Luton's unmet needs that have since come to light; example; plans for residential units have been made AFTER NHDC Local Plan displayed initial calculation and allocation based on Luton's unmet needs. So this unmet need has since changed. So the plan also needs to change to reflect that the unmet housing need that has now been lessened by these new allocations within Luton's own boundaries.

New Allocations, after the writing of NHDC Local Plan, are as follows:

a) 234,138.38m2 next to Hampton by Hilton London Airport behind Vauxhall. This Napier Park site, is already allocated for commercial purposes. However, recently LBC announced that 625 units would be for residential purposes. This reduces "Luton's Unmet Housing need claim" on Hertfordshire's land by 625.
b) 58,264.24m2 M1 Junction 10 to M1. This is the site of the current football club. When the new larger football club is operational in 2021, is the plan for it states, then this site will be available. This reduces the remaining "Luton's Unmet Housing need claim" on Hertfordshire's land, since they will be able to fits thousands of units in this site. The location is also compatible with the cross-sectional breakdown of housing needs, as displayed in Luton's Strategic Housing Management Assessment report.
c) 145,311.15m2 Chaul End Vauxhall Car Park, on greenbelt but as an "infill". - This site has been allocated already. Does the allocation include any residential units? If so they too need to be deducted from Luton's claimed "Unmet Housing Need figure".

Alternative allocations are as follows:

d) 22,009.77m2 at Gypsy Lane/ Kimpton Road Car Parks and Scrubland is an alternative. Although it's considered an industrial zone, it could be re-zoned. Or if it can't be re-zoned the plans for a soft industrial site upon Wigmore Valley Park could be switched to here. Then instead of using Wigmore Valley Park for soft industry, could residential units be placed here instead?
e) Butterfield Green Business Estate - If LBC suddenly found room for 625 extra units on Napier Park, then why can't they also give a little section of the large Butterfield green site to residential units too?
f) 19,781.58m2 Hatters Way demolished site - is an industrial site which could be re-zoned. If not re-zoned it could be used for soft industry and thus free up the Wigmore Valley Park's soft industrial allocation.
g) 289,812.695m2 Dallow Road next to M1.
h) 83,130.63m2 M1 Junction 10 is where they are intending to place a football club and shopping centre. This of course will also lead to additional traffic problems, especially on match days when thousands of people drive into town and try to park their cars.
i) 517,700.94m2 Dunstable Chalk Hill. Dunstable is actually in need of regeneration. This is an opportunity to place regeneration in a place that actually needs it, instead of placing degeneration in a place that doesn't want it.
j) Kennelworth Road - A potential housing site, interdependent upon the stadium of Powercourt.
k) Bushwood - 5,500 residential homes of a range of types and tenures supporting a diverse population could be placed here according to the Bushwood Master Plan [Available at: http://bushwood.info/docs/Bushwood-Masterplan.pdf]. Ten years ago the developer was all ready to build but the plan though fairly far advanced, was put on hold. They had even placed two tunnels between junctions 10 and 11 of the M1. These were put there at the time of building the M1. These tunnels could be used to provide connection points to any development at Bushwood, since they still exist today; one is currently being used by a farmer and the other tunnel is part of a bridle way near - they are near Chaul End and Caddington. The Developer was all ready to begin building here. Unlike land East of Luton, Bushwood has excellent access points in and out from the M1, which it is right next to, and it has train stations nearby to enable populations to commute.

Therefore to destroy the Green Belt next to East Luton is not a necessity at all.

Green Belt Next to Areas of Outstanding Natural Beauty

Land East of Luton is next to two Areas of Outstanding Natural Beauty. Putteridge Bury (AONB) is on one side and then Lilley (AONB) is on the other. The EL development would obscure and radically alter the view of these two AONBs.

Urban Sprawl

The purpose of the Green Belt is to stop urban sprawl; this stretch off Green Belt is already so narrow and if taken away there will be absolutely no separation between Luton and Hertfordshire at all.

The boundaries would have to be moved, which will create it's own new problems.

They are already taking away Green Belt land with the Butterfield Green Business Estate - so the area is already going to be losing that.

The NHDC Local Plan says a site MASTERPLAN for all three sites EL1, EL2, and EL3 must be submitted and approved before the submission of any detailed matters (p.40). So why was Crown Estates permitted to submit one isolated planning application [PA 16/02014/1 for 660 dwellings East of Luton] prematurely BEFORE the Local Plan itself has even been inspected or approved?! It seems that the developers and council are speculating and too confident that the many serious doubts around the soundness of this Local Plan will be overlooked and ushered through.

The East of Luton and West of Cockernhoe communities now question transparency and fairness, since we are unhappy at this premature application, which ignores the MASTERPLAN. Was it a tactical move to divert and disperse our efforts to object previously?

Conservation

The rare wildlife in the Brickkiln Wood will not survive this encroachment upon their habitats. Neither will the humans ultimately survive the attack on their habitat. Already many local residents are thinking of selling up and moving away, since they cannot envisage a life in this area after losing their Green Belt and the character of the area that they love. This Local Plan and it's looming consequences has been spoiling quality of life for lots of people. Many people including myself, have been putting off making any home improvements and feel unsettled since this development has been proposed, since they believe that life cannot go on here were this to go ahead. It is no exaggeration to say that the local people are actually extremely distressed. I describe that seriously and accurately. It is affecting the population's quality of life, they are so worried.

There is an extremely high number of tree preservation orders on this area - higher than nearly all other areas considered. This indicates the ancient and mature nature of this particular Green Belt area.

Archaeological Heritage and Shrinking Later Studies

There are many archaeological sites strewn across the area, and it is noticeable that in older archaeological studies many more sites are mentioned than in the council's newer studies. I would therefore like to see the old studies revisited and those sites missing in the newer studies need to be added back into the newer studies. And I ask why are there so many archaeological sites documented in much earlier archaeological studies commissioned by NHDC, as well as private ones, which are no longer documented on the newer archaeological studies? The archaeological heritage didn't diminish, so let's re-examine and make sure that the later studies are as thorough as the earlier ones.

Unacceptable and Disproportionate Alteration of the Character of an Area

If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.

Wigmore consists of about 4500 houses, so the size of this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it on the side of it all over again.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village.

Infrastructure - Schools and Education Services Undeliverable

From the "Minutes of LBC Executive Meeting/ Agenda Item Number: 23
Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen":

"24. Discussions on previous plans for the land assumed that secondary school provision would be met at Ashcroft High. Such assumptions will need to be re-tested. If there is surplus capacity at Ashcroft, school buses may be required to mitigate further transport impact."
The nearest Secondary school on the Herts side are: Zero. There are no secondary schools on the Herts side nearby.
The nearest Secondary schools on the Luton side are just: Ashcroft High School and Putteridge High School.
How many extra school children and of what ages will 2,105 new houses typically generate?
The matter of providing infrastructure and costing for mandatory state run education services has not been factored in at all, and on this point the Local Plan is not deliverable and therefore not effective.
Recycling Oversubscribed Schools in Plans

Regarding developer plans "The Crown Estate Land West of Cockernhoe Illustrative Emergency Access Mangrove Road [KH 24/08/2015 A Access relocated in response to updated Site Boundary/ JM KH 25/08/2015]"
Upon their map they have actually presented the three schools, as the already over-subscribed Someries, Wigmore and Cockernhoe primary schools.

Is this the extent of Crown's Education Infrastructure solution? Isn't flooding two already full-up schools with 800 new children, actually making an infrastructure problem?
Social Infrastructure Undeliverable
The current level of social infrastructure can barely support the existing community in that area as it is. So far the councils themselves plus the two developers, have put forward plans for this area, which are totally inadequate to support their proposals in this capacity. There is no detail as to how they will deliver and pay for the basic services.
Infrastructure - Rubbish Collection Services Unaddressed
Rubbish Collection Services are not detailed or deliverable in this Local Plan.
How much will it cost to provide extra rubbish collections on a regular basis on a continual basis per annum? What will be the total cost until the end of the Local Plan, and beyond that? Who will pay for these? Will it be NHDC or LBC? Or will it be charged as additional Council Tax levied onto Herts residents or else Luton residents? This has not been addressed.
Who will carry out the extra rubbish collections? How many tonnes of extra rubbish will have to be removed annually? What is the costing for 2105 or more extra houses? Will it NHDC or LBC that will carry out the labour? Do they have the capacity and labour power in their departments to do this extra work?
Infrastructure - General Practitioner Services Unaddressed
How can health services at most basic level be provided to this extra segment of population? How many extra people would be resident in 2105 new dwellings, and in what capacity and to what quality will they need to be given these services?
How much will it cost to provide extra GP services on a continual basis per annum? What will be the total cost until the end of the Local Plan, and beyond that? What GP surgery will the extra residents go to? Will they build a new surgery to service this new population? How much will the building of and running of a new GP Surgery cost? Who will build and pay for it? Will it be NHDC or LBC? Or will it be levied as additional Council Tax to Herts residents or else Luton residents? This has not been addressed. How will costs be divided - if the population due to be serviced is within the Herts Borough, but in reality the other Borough is expected to provide the services due to it's proximity to the new estate? Which County will pay for this, and how will they figure this ongoing extra cost into their budget? Which services will lose out to make up for it?
The current ones in the area are already over-subscribed and the length of waiting times for appointments is already unsatisfactory. Current residents cannot be expected to lose the quality of their health services yet further. Is it justifiable to diminish the quality of public services in this area, yet still charge people the same, or more for them (via Council and other taxes)?
Infrastructure - Emergency Health Services Unaddressed
The Local Plan doesn't address earlier health budget deficits at all or think how they will address them rather than add to them.
Infrastructure - Water Pressure, Sewage and Thames Valley Concerns
In Luton Water Cycle Strategy, September 2015
[https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Local%20Plan/Climate%20change/CC%20005.pdf]

Point 3.2.4 says "The Water Framework Directive recognises the potential impacts on water bodies from new development as a pressure that must be addressed."

"The area north of Houghton Regis (which falls within the study area) is covered by the Anglian RBMP. The Anglian River Basin Management Plan (December 2009) identifies Luton as one of the three largest Growth Areas which will see a substantial amount of new development in the next 15-20 years, particularly in areas identified for growth or regeneration. Pressures from the cumulative impacts of planned development, especially those on water resources and water quality mean that actions will be required to achieve good ecological status and ensure that there is no deterioration.
Refer to the RBMP document for more details." [p.8]
Infrastructure - Police and Security Services Unaddressed
The Police budget is already stretched. Many crimes are being left un-investigated due to lack of resources.
Will NHDC or LBC provide adequate resources and budget as a result of the proposed housing development? If the population due to be serviced is within the Herts Borough, but in reality the other Borough is expected to provide the services due to it's proximity to the new estate, has it been agreed which County will pay for this, and how will they figure this ongoing extra cost into their budget?
Changing the Character of an Area and Removal of Vital Green Space
Luton currently has 30% too little greenery for a town of this size.

The community uses the green space here for leisure activities such as walking their dogs, exercise, taking children to play, people ride their horses along the bridal path, enjoy hiking, jogging or simply the views throughout the seasons.

This development will rob many thousands of local people of this simple but valuable and life-enriching treasure.

It is absolutely the view of the community that this development doesn't fit in with it's surroundings. It will uglify the whole area. There are also flats mentioned in the Plans, and this area does not have flats so this is inconsistent.

Wigmore Valley Park is already going to be taken away and placed outside of the Wigmore area. Therefore the people of this area would no longer have any green space and leisure areas other than this bridle path and Green Belt zone. If you take this away too, there will be nothing!

This is an unacceptable level of development forced upon this area, and it would alter it's character too drastically and too quickly for it's population and infrastructure to absorb.

This will have negative health consequences for the community as a whole.

Duty Not to Cooperate

Councils don't always pool their ideas and strategies seamlessly. We have seen many blind-spots occurring where duty to cooperate, gets interpreted as duty to blame the other council. This seems to be the mechanism at work, when it comes to things they don't like.

"27. It will be for North Hertfordshire to fully assess and model the appropriateness of their potential spatial strategy in terms of infrastructure (e.g. A1M capacity junctions 6 and 8) and sustainability (landscape, wildlife, economy and community impacts). However, Luton Borough Council's position is that North Hertfordshire should also make provision for a likely level of unmet need arising within Luton. Currently, the estimated capacity of the borough is believed to be around 6,200 dwellings over the plan period (2011-2031) compared to a trend migration requirement of 10,900 dwellings."
[Minutes of LBC Executive Meeting/ Agenda Item Number: 23
Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen].

So LBC is relying on North Hertfordshire to fully assess Luton's transport systems. However Hertfordshire is saying that Luton should be responsible for it's transportation systems. There are many lackings in the Transport Assessments. I don't actually see any mention of Wigmore networks, nor Stopsley, Crawley, or Stockingstone Road. Yet all would be impacted.
"28. The scale of provision will be dependent on cooperation with other neighbouring authorities including Central Bedfordshire. It will also depend on infrastructure capacity serving the east of the borough (e.g. the peak congestion experienced on the A505 and eastern corridor serving the airport) and any improvements that could be secured on the local network and in terms of community infrastructure."
[Minutes of LBC Executive Meeting/ Agenda Item Number: 23
Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen].

Empty Housing Un-utilised

Despite widespread anxiety about a shortage of housing supply, there are 610,123 empty homes in England, according to the government. Of these, 205,821 have been unoccupied for six months or more, the official definition of "long-term" emptiness. In September last year, Scotland had 31,884 long-term empty properties as of 2 Dec 2015. I understand that there are over 650 empty houses vacant in Luton.

Brexit
The NHDC Local Plan has not given any information about how Brexit will impact migration rates. It claims uncertainty. Yet on the contrary it considers itself able to predict future traffic data, for up to four new major traffic generating projects!
The migration assumptions and projections used to calculate unmet housing needs are going to change.
Inadequate Retail Facilities

In one East Luton development plan it has suggested that Westway shops could meet it's retail needs. However Westway is only four tiny shops: a chip shop, tiny beauty salon, hardware shop, and tiny corner store. These shops cannot provide for 5,052 people's retail requirements. The Local Plan says that there must be 250m2 (net) class A1 convenience retail provision (p.40).

Please send me a receipt for my objection. I was unable to upload it onto your system because you have a 3000 character limitation.