Local Plan 2011-2031 Proposed Submission Draft

I wish to object to the NHDC local plan.
Firstly, in relation to the removal of land from Green Belt status, east of Luton for development of housing, to meet Luton's Unmet Need, this is not an exceptional circumstance because there is evidence that there is sufficient Brown Field Land to build the 2,100 dwellings, at the same density, within Luton's existing boundaries. An Unmet need is unlikely to outweigh the harm to the Green Belt unless there are very Special Circumstances (National Planning Policy Framework).
Secondly, the proposal is completely out of proportion. Currently there are 205 dwellings in Cockernhoe, Tea Green and Mangrove Green; an additional 2,100 dwellings will be an increase of 1025%. This increase represents over 14% of the total for the whole of NHDC Local Plan. These villages will cease to exist and their integrity will be lost.
Thirdly, there is no planned improvement to infrastructure in the NHDC Local Plan, neither into Luton nor to the two country lanes from Luton into North Hertfordshire. Potentially 2,100 houses will create 4,000-5,000 additional vehicle movements.
Fourthly, this is likely to be compounded by a massive increase in traffic owing to Luton Airport expansion, with regard to both projected passenger numbers of 22 million by 2030 and 7,000 new jobs. Luton Borough Council base their traffic modelling on an unbuilt link road to the A505 at Lilley. A Freedom of Information request states: This transport modelling includes the alignment of the proposed spine road through that development site and Luton Borough Council 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. Bloor Homes @Access and Masterplan slides see www.wanden park.co.uk (Newly constructed Relief Road linking Luton Road with Chalk Hill...). This suggests they expect a spine road to be built despite NHDC having no plans for this road development; however, NHDC state on page 72 of the NHDC Local Plan, para 4.222 - 'our assessments show that this level of development can be accommodated without a significant adverse impact on the wider networks of Luton and Hertfordshire. The views of North Herts and Luton are contradictory.
Lastly, Luton Borough Council have also proposed locating a new Airport Business Park and Century Park at Wandon End. This is a rural area near the airport accessed at present by narrow country lanes. Is the proposed spine road that is referred to above to service this new facility despite no provision by NHDC for a road. The NHDC Local Plan, Section Two: Spacial Strategy and Strategic Policies -c,iii states we will: provide the necessary infrastructure required to support an increasing population and c.iv states protect key elements of North Hertfordshire's environment including important landscapes, heritage assets and green infrastructure. The area of the proposed development is close to a designated AONB and if a spine road is built it will impact on this area as such a road would be likely to cut through it if it is to join to the A505 at the junction of Lilley. The loss of wildlife habitat and an amenity resource for both Luton residents, North Hertfordshire residents and from elsewhere is also a consequence of this plan.

I wish to object to the NHDC local plan.
Firstly, in relation to the removal of land from Green Belt status, east of Luton for development of housing, to meet Luton's Unmet Need, this is not an exceptional circumstance because there is evidence that there is sufficient Brown Field Land to build the 2,100 dwellings, at the same density, within Luton's existing boundaries. An Unmet need is unlikely to outweigh the harm to the Green Belt unless there are very Special Circumstances (National Planning Policy Framework).
Secondly, the proposal is completely out of proportion. Currently there are 205 dwellings in Cockernhoe, Tea Green and Mangrove Green; an additional 2,100 dwellings will be an increase of 1025%. This increase represents over 14% of the total for the whole of NHDC Local Plan. These villages will cease to exist and their integrity will be lost.
Thirdly, there is no planned improvement to infrastructure in the NHDC Local Plan, neither into Luton nor to the two country lanes from Luton into North Hertfordshire. Potentially 2,100 houses will create 4,000-5,000 additional vehicle movements.
Fourthly, this is likely to be compounded by a massive increase in traffic owing to Luton Airport expansion, with regard to both projected passenger numbers of 22 million by 2030 and 7,000 new jobs. Luton Borough Council base their traffic modelling on an unbuilt link road to the A505 at Lilley. A Freedom of Information request states: This transport modelling includes the alignment of the proposed spine road through that development site and Luton Borough Council 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. Bloor Homes @Access and Masterplan slides see www.wanden park.co.uk (Newly constructed Relief Road linking Luton Road with Chalk Hill...). This suggests they expect a spine road to be built despite NHDC having no plans for this road development; however, NHDC state on page 72 of the NHDC Local Plan, para 4.222 - 'our assessments show that this level of development can be accommodated without a significant adverse impact on the wider networks of Luton and Hertfordshire. The views of North Herts and Luton are contradictory.
Lastly, Luton Borough Council have also proposed locating a new Airport Business Park and Century Park at Wandon End. This is a rural area near the airport accessed at present by narrow country lanes. Is the proposed spine road that is referred to above to service this new facility despite no provision by NHDC for a road. The NHDC Local Plan, Section Two: Spacial Strategy and Strategic Policies -c,iii states we will: provide the necessary infrastructure required to support an increasing population and c.iv states protect key elements of North Hertfordshire's environment including important landscapes, heritage assets and green infrastructure. The area of the proposed development is close to a designated AONB and if a spine road is built it will impact on this area as such a road would be likely to cut through it if it is to join to the A505 at the junction of Lilley. The loss of wildlife habitat and an amenity resource for both Luton residents, North Hertfordshire residents and from elsewhere is also a consequence of this plan.