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Proposed Main Modifications

ED62 NHDC Note to Inspector on Air Quality

Representation ID: 7663

Received: 11/04/2019

Respondent: Amelia Curran

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

See attached representations

Full text:

ED55 13 Dec 2017 Inspector's list of actions for NHDC arising from Week 3 of the hearing sessions (Matters 15, 16, 17, 19 and 20) (PDF, 55Kb)

Documents for Air Quality Session on Tuesday 23 January 2017
ED62 12 Jan 2018 NHDC Note to Inspector on Air Quaility (PDF, 4Mb)

ED69 June 16 NHDC Air Quality Annual Statistics Report 2016 (PDF, 3,403Kb)

ED70 June 17 NHDC Air Quality Annual Statistics Report 2017 (PDF, 3,704Kb)

ED97 2015 Luton Borough Council 2015 transport modelling evidence re Luton airport (PDF, 4,874Kb)

Back in Week 3 at Matter 17 - The Inspector's List of Actions (ED55) for NHDC asked the Council to prepare an air quality note for the first week of January prior to the "reserve air quality session" and include in it information relating to monitoring data.
ED62 as it was then prepared, however we find in nothing but outright lies when dealing with east of Luton.

ED62
5.37 Appendix 5 contains the air quality monitoring data that is collected by London-Luton Airport within the boundary of its airport.

Yet if you go to "Appendix 5" it is falsely titled "2016": "Table B: 2016 Nitrogen Dioxide Data (ug/m3) from London-Luton Airport Diffusion Tubes (Annual Mean Ave. AQO = 40ug/m3)"
The air quality monitoring data contained in Appendix 5 is totally out-of-date but they have tried to lie and disguise that fact by falsely entitling it "2016 Nitrogen Dioxide Data".
It is in fact 2015 data extracted from the 2016 Annual Air Status Report. This means that all the data is from the year 2015 and NOT 2016!!! In case it needs spelling out; that is four year old data -unforgivable when so much more recent data exists.
Every year the Local Authority must produce a report on its air quality. This report is called an "Annual Air Status Report".
They are compiled once a year and must be submitted to DEFRA.
They must then be published on the local authority's website.
The reports contain the air monitoring data from the year prior. For example "Annual Air Status Report 2017" contains the air monitoring data from January 2016 up until December 2016.
In its document ED62 North Hertfordshire District Council (NHDC) has failed to use the available up-to-date data from the Annual Air Status Report 2017 produced by Luton Borough Council (LBC) found here:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Environmental%20and%20Consumer%20Services/Pollution/2017-Air-Quality-Annual-Status-Report.pdf

Had it done so, it would have revealed the truth; that the area around the Airport, which is closest to the East of Luton Strategic Housing Site and negatively affected A505 road, has air pollution already breaching legal limits.
However LBC have failed in their legal duty to take the appropriate measures and declare Air Quality Management Areas (AQMAs) around these dangerous sites and NHDC has been more than happy to accommodate them not addressing the problem.
14 monitoring sites are already breaching legal limits.

6 further monitoring sites are about to breach legal limits; being merely 1 unit away from the illegal threshold of 40.

So a total of 20 sites are breaching or verging breach.

Yet only 7 of those breaching sites have been declared as Air Quality Management Areas in Luton.

Therefore 13 breaching sites still remain at illegal levels yet the Council has failed to declare any AQMAs for these problem zones.

HOW MANY MONITORING SITES ARE THERE IN TOTAL?

THERE ARE A TOTAL OF 60 AIR POLLUTION MONITORS RUN BY LBC OR ITS AIRPORT COMPANY LONDON LUTON AIPORT COMPANY LTD.
ONE THIRD OF THE 60 MONITORING UNITS ARE ABOVE OR EXTREMELY CLOSE TO ILLEGAL LIMITS.
That's huge.
ASR 2017 (LBC) - p.p.14-21 shows the breakdown of ownership and type/ whether they are automatic or non-automatic monitors.
Automatic Monitors:
Total number of Automatic Monitors run by Council (LBC) - 2
Total number of Automatic Monitors run by Airport (LLAL) - 1
Automatic Monitors - TOTAL 3

Non-Automatic Monitors:
Total number of Non-Automatic Monitors run by Council (LBC) - 41
Total number of Non-Automatic Monitors run by Airport (LLAL) - 16
Non-Automatic Monitors - TOTAL 57

However large areas of the town are not being monitored at all. There are many huge blind spots that are cause for alarm. Such as the Hitchin Road into Luton/ A505 - at Stopsley roundabout. Nowhere in Stopsley, Round Green and High Town is being monitored.
There should be pollution monitoring distributed fairly across the entire town. If fair air pollution monitoring is not being applied then there can certainly be serious basis for claims that discrimination against certain ethnic and social groups is taking place.
There should be no reason why some areas are getting concentrated air pollution monitoring whilst others are getting absolutely none whatsoever. Or why some areas with elevated NO2 levels are declared AQMAs whereas many more that have even greater elevated levels, are not.
The closest monitoring points to the Local Plan's East of Luton Strategic Site are the Luton Airport's Air pollution monitoring system and those of LBC at Eaton Green Rd.
These are definitely breaching and have been doing so for many years and yet no AQMAs have ever been declared. So the Inspector should take the responsibility that both incompetent councils have failed to, and demand that AQMAs be declared rather than neglected, in all of the following places.
We directly refute the following fictitious statement from the Council:
ED62 - 5.36 The data from the 'worst case' monitoring locations contained within the Tables show that the air quality to the East of Luton does not breach the relevant Air Quality Objective. Therefore, because of the absence of any other potentially significant sources of nitrogen dioxide and particulate matter in the area it was judged to be unnecessary to monitor for local air pollutants elsewhere in the area east of Luton.

No need to monitor local air pollutants elsewhere in the area..."because of the absence of any other potentially significant sources of nitrogen dioxide".... What complete and utter rubbish - see the many significant sources of nitrogen dioxide and particulate matter below from the readings in the Luton ASR 2017, which NHDC has not looked at!
These sites are in fact the closest to the NHDC East of Luton Site and they are illegally breaching as you can easily see: -
SITE ID SITE NAME
IF INSIDE AQMA/ OR NOT
ORDNANCE SURVEY REF
ADDRESS AND POSTAL CODE WARD (ZONE) SOUTH/ NORTH LUTON POLLUTANTS
-MEASURED If Tube collocated with a Continuous Analyser/ or not
YEARS & OVERAL BREACH LEVEL CONCLUDED BY LBC ASR

LN23 Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF CRAWLEY (A) SOUTH NO2 Tube NOT collocated with a Continuous Analyser
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36

LA02 Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 40
2016 - 40

LA05 Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 46
2016 - 43

LA14 Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR, AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 -39
2016 - 39

LA16 Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2014 - 37
2016 - 41

The following claim is an out and out lie:
ED62 - 5.39
The data show that the annual mean average Air Quality Objective for nitrogen dioxide was not exceeded at a relevant receptor in 2016. This is the only recent data published by Luton Borough Council. The only two marginal exceedances were measured at an airside location and a kerbside location within the airport boundary and so a relevant receptor is not exposed nor is there a likelihood of exposure because of the absence of housing or an equivalent receptor within the airport boundary.

Firstly there were not "only two marginal exceedances".

Secondly "exceedances" are never marginal - but are serious, illegal and likely to only get progressively worse.

Thirdly five exceedances is a serious matter, and AQMAs must be immediately declared by law. This is not an option but an obligation.

The author/s of ED62 lie by citing the Beachwood Green monitors to be the "relevant receptor(s) in 2016" - when these are much farther away from the proposed site and far less relevant than the monitors in the affected area of east of Luton. Since the traffic and entrances to the proposed housing site are all expected to be from Luton via the Crawley Green/ Luton Roads - so the monitors there are obviously far more relevant. Yet the diagram given in ED62 doesn't show any of these east of Luton points. It has left out their existence altogether.

See below how ED62 only shows five "relevant" analysers - all in the Village of Breachwood Green:

ED62 - 5.38
The data show that the Air Quality Objectives for PM10 particulate matter have not been exceeded from the first year of monitoring (2004 first full year of data) to date.

ED62 - 5.6 Local Air Quality Monitoring Data for East of Luton
5.32 There is currently no monitoring of air quality in the area of the district identified as the East of Luton. Historically there were eight monitoring locations, of which seven were diffusion tubes and one was a site comprising two real-time analysers. The locations of the air quality monitoring points are shown in Figure 5.6.

ED62 5.32 also lies when it falsely claims there is no monitoring of air quality on the area of the district identified as the East of Luton.

Here is a map to illustrate the fact there are many monitors now collecting readings. Had NHDC looked at the ASR 2017 report they would know that.

The yellow triangle is where Breachwood Green is. This is where the Council claims is "the most relevant monitor to the East of Luton site" according to ED62. Except it clearly isn't "the most relevant" - because the black scribbly area is the actual location of EL1, EL2 and EL3 proposed housing site/ currently Green Belt. As you can see there are many other air pollution monitors - in the urban area, much closer to the development and closer to the people already living there! So why select the most remote/ Breachwood Green ones (yellow triangle)?

The red tags show the locations of all the other air pollution monitors.

Clearly Breachwood Green is in a rural location far away from any of that!

So these statements in ED62 are complete and utter rubbish; what are all of these breaches at east Luton monitoring stations shown below? - Scotch mist?!

These sites are the closest to the NHDC East of Luton Site and MANY ARE ALREADY illegally breaching as you can see: -
NO2
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36 LN23
Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF
2012 - 40
2016 - 40 LA02
Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP
2012 - 46
2016 - 43 LA05
Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2012 -39
2016 - 39 LA14
Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2014 - 37
2016 - 41 LA16
Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE

Readings from 2016 clearly show NHDC is lying and the truth is that NOx and NO2 were at dangerously illegal levels in the east of Luton at the time of ED62 being concocted. Since they are already at elevated levels before development, they are obviously projected to breach yet stratospherically further after development. Any fool can figure that out.

The red scribbly area shows where the location of the Infrastructure Project of National Significance is going to be located - something which the North Herts Plan and Inspector have both miraculously failed to mention!

It is currently a lovely green park (called wigmore Valley Park and Wildlife Conservation Area), but the Luton Council has just granted itself planning permission to put a 95 hectare development on top of the park, including two dual carriageways leading to an urban estate plus car park.

Imagine what the air pollution levels are going to become as they cut down all of the trees and smother the whole area with their beloved concrete and invite thousands more cars into the area to suck oxygen and poison every living creature.

Pollution levels are going to go through the roof. They are already illegal as it is, and this will take them into the "killer" zone.

And that is just based on the first approved NSIP.

Do not forget though - that there is a second NSIP planned for the same red scribbly area!

Luton Council is in the process of ALSO preparing a Development Consent Order application for a new Terminal Two - also upon the furthest away red scribbly part - the bit closest to the NHDC border no less!!

So both Councils are hiding things from the Inspector and the Inspector will need to ask them some very probing questions, or else he is going to become a laughing stock - when the High Court asks why are there an entire two NSIPs missing from the Local Plan he's just approved!!?

CONCLUSION ON AIR POLLUTION MONITORING SITUATION:
In Part II is the work I have compiled using the 2017 Annual Air Status Report which NHDC has ignored throughout its homework. We are still waiting for ASR 2018 which is with DEFRA now.
I have taken all of my data from the ASR 2017 and listed every single monitoring site in the whole of Luton and then worked out which the ward it sits in using Luton Borough Council ward data plus ordnance survey tools such as gridreferencefinder.com. You can see my Part II of this document for the full list and addresses.
The fact is that one third of all 60 monitoring stations run by LBC are breaching, or verging illegal levels - indicating there to be a very serious air pollution problem already present in Luton.
This is not at all surprising considering the large deficit in greenspace that Luton's population already suffers as compared to that of the national average. It is this deficit which is already taking its toll and manifesting as higher than normal morbidity rates, higher than national average asthmas rates, ill-health, higher crime rates, rising psychiatric illness, lower levels of intelligence overall and rising rates of depression.
Building 2,100 houses and cramming them into an unsuitable space only degrades the situation further.
Presently this east of Luton Green Belt is the only relief which can partially salvage this dire situation - it is truly an indispensable Green Belt buffer zone for the east of Luton - which if removed would literally close off of an entire area and seal in thousands of residents - leaving them trapped like caged monkeys in a zoo - between an unwanted "Gatwick sized" Airport Expansion/ Nationally Significant Infrastructure Projects in the field directly connected/ next-door, and thousands of crappy houses rendering the air totally unbreathable and roads disgustingly crammed full day and night.
This would most obviously have hugely and devastatingly negative consequences for the health and well-being of all age-groups and is a direct act of violence and barbaric cruelty when looked at in this wider real-life context.
This is why the MM010 Policy SP2 is absolutely not acceptable and does not deserve the title "spatial distribution" at all. The Inspector should remove/ delete the allowance of 2,100 houses adjoining Luton, within the settlement boundaries of Mangrove Green and Cockernhoe full stop.

TEXT REMOVED

LUTON:
* Cockernhoe and east of Luton
* * MM221 - Page 150 paragraph 13.66 (ED144)
MM 010 32 Policy SP2 Policy SP2: Settlement Hierarchy and Spatial Distributionx
INSERTED:Between 2011 and 2031, the plan seeks to make provision for at least 15,950 new homes.
INSERTED:Approximately 80% DELETED:The majority of the District's INSERTED:housing development INSERTED:and the substantial majority of new employment, retail and other development will be located within INSERTED:the adjusted settlement boundaries of DELETED:or adjoining the following towns:
* Baldock INSERTED:(3,298 homes);
* Hitchin INSERTED:(1,679);
* Letchworth Garden City INSERTED:(2,167);
* Luton32 INSERTED:(2,100)
* Royston INSERTED:(1,797);
* Stevenage (including Great Ashby)32 INSERTED:(1,830); and
INSERTED:Approximately 11% of housing, along with supporting infrastructure and facilities will be delivered in five villages identified by this Plan for growth:
* INSERTED:Barkway (209)
* INSERTED:Codicote (367)
* INSERTED:Ickleford (210)
* INSERTED:Knebworth (736)
* INSERTED:Little Wymondley (306)
INSERTED:The remaining development will be dispersed across the District as set out below.
INSERTED:In Category A villages, DELETED:GINSERTED:general development will DELETED:also be allowed within the defined settlement boundaries of DELETED:the Category A villages of:
* Ashwell;
* DELETED:Barkway;
* Barley;
* Breachwood Green;
* Cockernhoe INSERTED:& Mangrove Green;
* DELETED:Codicote;
* Graveley;
* Hexton;
* DELETED:Ickleford;
* Kimpton;
* DELETED:Knebworth;
* DELETED:Little Wymondley;
* Lower Stondon32;
* Oaklands32;
* Offley;
* Pirton;
* Preston;
* Reed;
* Sandon;
* St Ippolyts INSERTED:& Gosmore;
* Therfield;
* Weston; and
* Whitwell.

Each Air Status Report (ASR) for Luton can be found on the Council website at:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Home * Environment and planning * Environmental health * Air pollution * Air quality
Air Quality Strategy

We continuously monitor air pollutants and regularly review and assess air quality in the town.
The government has published an air quality strategy. Outlined in the strategy are air quality objectives for the pollutants the government considers are of most concern at present
In response to the strategy, we reviewed and assessed air quality in Luton and produced the following reports available to download below:
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

2016 Air Quality Management Area (no 3) Order ( 1.3 MB )

2015 Updating and Screening Assessment (USA) ( 5.4 MB )

2015 Detailed Assessment ( 2.1 MB )

2014 Progress Report ( 4.5 MB )

2013 Progress Report ( 4.2 MB )

2012 Updating and Screening Assessment (USA) ( 2.9 MB )

2011 Progress Report ( 1.3 MB )

2010 Progress Report ( 1.3 MB )

2009 Updating and Screening Assessment (USA) ( 1 MB )

2008 Progress Report ( 432.5 kB )

2007 Progress report ( 336.2 kB )

2006 Updating and Screening Assesment (USA) ( 1.7 MB )

2005 Air Quality Management Order ( 3.7 MB )

2005 Progress Report, Local Air Quality Management ( 312.4 kB )

2004 Detailed and Further Assessment ( 5.1 MB )

2003 Air Quality Management Order ( 1.1 MB )

2003 Updating and Screening Assessment (USA) ( 2.2 MB )

2003 Review and Assessment (Stage 4) ( 2.4 MB )

Contact information

Environmental health
Luton Borough Council, Town Hall, George Street, Luton, Bedfordshire, LU1 2BQ
Tel: 01582 510330
Fax: 01582 546676
environmentalhealth@luton.gov.uk

Object

Proposed Main Modifications

ED69 NHDC Air Quality Annual Statistics Report 2016

Representation ID: 7904

Received: 11/04/2019

Respondent: Amelia Curran

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

See attached representations

Full text:

ED55 13 Dec 2017 Inspector's list of actions for NHDC arising from Week 3 of the hearing sessions (Matters 15, 16, 17, 19 and 20) (PDF, 55Kb)

Documents for Air Quality Session on Tuesday 23 January 2017
ED62 12 Jan 2018 NHDC Note to Inspector on Air Quaility (PDF, 4Mb)

ED69 June 16 NHDC Air Quality Annual Statistics Report 2016 (PDF, 3,403Kb)

ED70 June 17 NHDC Air Quality Annual Statistics Report 2017 (PDF, 3,704Kb)

ED97 2015 Luton Borough Council 2015 transport modelling evidence re Luton airport (PDF, 4,874Kb)

Back in Week 3 at Matter 17 - The Inspector's List of Actions (ED55) for NHDC asked the Council to prepare an air quality note for the first week of January prior to the "reserve air quality session" and include in it information relating to monitoring data.
ED62 as it was then prepared, however we find in nothing but outright lies when dealing with east of Luton.

ED62
5.37 Appendix 5 contains the air quality monitoring data that is collected by London-Luton Airport within the boundary of its airport.

Yet if you go to "Appendix 5" it is falsely titled "2016": "Table B: 2016 Nitrogen Dioxide Data (ug/m3) from London-Luton Airport Diffusion Tubes (Annual Mean Ave. AQO = 40ug/m3)"
The air quality monitoring data contained in Appendix 5 is totally out-of-date but they have tried to lie and disguise that fact by falsely entitling it "2016 Nitrogen Dioxide Data".
It is in fact 2015 data extracted from the 2016 Annual Air Status Report. This means that all the data is from the year 2015 and NOT 2016!!! In case it needs spelling out; that is four year old data -unforgivable when so much more recent data exists.
Every year the Local Authority must produce a report on its air quality. This report is called an "Annual Air Status Report".
They are compiled once a year and must be submitted to DEFRA.
They must then be published on the local authority's website.
The reports contain the air monitoring data from the year prior. For example "Annual Air Status Report 2017" contains the air monitoring data from January 2016 up until December 2016.
In its document ED62 North Hertfordshire District Council (NHDC) has failed to use the available up-to-date data from the Annual Air Status Report 2017 produced by Luton Borough Council (LBC) found here:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Environmental%20and%20Consumer%20Services/Pollution/2017-Air-Quality-Annual-Status-Report.pdf

Had it done so, it would have revealed the truth; that the area around the Airport, which is closest to the East of Luton Strategic Housing Site and negatively affected A505 road, has air pollution already breaching legal limits.
However LBC have failed in their legal duty to take the appropriate measures and declare Air Quality Management Areas (AQMAs) around these dangerous sites and NHDC has been more than happy to accommodate them not addressing the problem.
14 monitoring sites are already breaching legal limits.

6 further monitoring sites are about to breach legal limits; being merely 1 unit away from the illegal threshold of 40.

So a total of 20 sites are breaching or verging breach.

Yet only 7 of those breaching sites have been declared as Air Quality Management Areas in Luton.

Therefore 13 breaching sites still remain at illegal levels yet the Council has failed to declare any AQMAs for these problem zones.

HOW MANY MONITORING SITES ARE THERE IN TOTAL?

THERE ARE A TOTAL OF 60 AIR POLLUTION MONITORS RUN BY LBC OR ITS AIRPORT COMPANY LONDON LUTON AIPORT COMPANY LTD.
ONE THIRD OF THE 60 MONITORING UNITS ARE ABOVE OR EXTREMELY CLOSE TO ILLEGAL LIMITS.
That's huge.
ASR 2017 (LBC) - p.p.14-21 shows the breakdown of ownership and type/ whether they are automatic or non-automatic monitors.
Automatic Monitors:
Total number of Automatic Monitors run by Council (LBC) - 2
Total number of Automatic Monitors run by Airport (LLAL) - 1
Automatic Monitors - TOTAL 3

Non-Automatic Monitors:
Total number of Non-Automatic Monitors run by Council (LBC) - 41
Total number of Non-Automatic Monitors run by Airport (LLAL) - 16
Non-Automatic Monitors - TOTAL 57

However large areas of the town are not being monitored at all. There are many huge blind spots that are cause for alarm. Such as the Hitchin Road into Luton/ A505 - at Stopsley roundabout. Nowhere in Stopsley, Round Green and High Town is being monitored.
There should be pollution monitoring distributed fairly across the entire town. If fair air pollution monitoring is not being applied then there can certainly be serious basis for claims that discrimination against certain ethnic and social groups is taking place.
There should be no reason why some areas are getting concentrated air pollution monitoring whilst others are getting absolutely none whatsoever. Or why some areas with elevated NO2 levels are declared AQMAs whereas many more that have even greater elevated levels, are not.
The closest monitoring points to the Local Plan's East of Luton Strategic Site are the Luton Airport's Air pollution monitoring system and those of LBC at Eaton Green Rd.
These are definitely breaching and have been doing so for many years and yet no AQMAs have ever been declared. So the Inspector should take the responsibility that both incompetent councils have failed to, and demand that AQMAs be declared rather than neglected, in all of the following places.
We directly refute the following fictitious statement from the Council:
ED62 - 5.36 The data from the 'worst case' monitoring locations contained within the Tables show that the air quality to the East of Luton does not breach the relevant Air Quality Objective. Therefore, because of the absence of any other potentially significant sources of nitrogen dioxide and particulate matter in the area it was judged to be unnecessary to monitor for local air pollutants elsewhere in the area east of Luton.

No need to monitor local air pollutants elsewhere in the area..."because of the absence of any other potentially significant sources of nitrogen dioxide".... What complete and utter rubbish - see the many significant sources of nitrogen dioxide and particulate matter below from the readings in the Luton ASR 2017, which NHDC has not looked at!
These sites are in fact the closest to the NHDC East of Luton Site and they are illegally breaching as you can easily see: -
SITE ID SITE NAME
IF INSIDE AQMA/ OR NOT
ORDNANCE SURVEY REF
ADDRESS AND POSTAL CODE WARD (ZONE) SOUTH/ NORTH LUTON POLLUTANTS
-MEASURED If Tube collocated with a Continuous Analyser/ or not
YEARS & OVERAL BREACH LEVEL CONCLUDED BY LBC ASR

LN23 Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF CRAWLEY (A) SOUTH NO2 Tube NOT collocated with a Continuous Analyser
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36

LA02 Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 40
2016 - 40

LA05 Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 46
2016 - 43

LA14 Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR, AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 -39
2016 - 39

LA16 Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2014 - 37
2016 - 41

The following claim is an out and out lie:
ED62 - 5.39
The data show that the annual mean average Air Quality Objective for nitrogen dioxide was not exceeded at a relevant receptor in 2016. This is the only recent data published by Luton Borough Council. The only two marginal exceedances were measured at an airside location and a kerbside location within the airport boundary and so a relevant receptor is not exposed nor is there a likelihood of exposure because of the absence of housing or an equivalent receptor within the airport boundary.

Firstly there were not "only two marginal exceedances".

Secondly "exceedances" are never marginal - but are serious, illegal and likely to only get progressively worse.

Thirdly five exceedances is a serious matter, and AQMAs must be immediately declared by law. This is not an option but an obligation.

The author/s of ED62 lie by citing the Beachwood Green monitors to be the "relevant receptor(s) in 2016" - when these are much farther away from the proposed site and far less relevant than the monitors in the affected area of east of Luton. Since the traffic and entrances to the proposed housing site are all expected to be from Luton via the Crawley Green/ Luton Roads - so the monitors there are obviously far more relevant. Yet the diagram given in ED62 doesn't show any of these east of Luton points. It has left out their existence altogether.

See below how ED62 only shows five "relevant" analysers - all in the Village of Breachwood Green:

ED62 - 5.38
The data show that the Air Quality Objectives for PM10 particulate matter have not been exceeded from the first year of monitoring (2004 first full year of data) to date.

ED62 - 5.6 Local Air Quality Monitoring Data for East of Luton
5.32 There is currently no monitoring of air quality in the area of the district identified as the East of Luton. Historically there were eight monitoring locations, of which seven were diffusion tubes and one was a site comprising two real-time analysers. The locations of the air quality monitoring points are shown in Figure 5.6.

ED62 5.32 also lies when it falsely claims there is no monitoring of air quality on the area of the district identified as the East of Luton.

Here is a map to illustrate the fact there are many monitors now collecting readings. Had NHDC looked at the ASR 2017 report they would know that.

The yellow triangle is where Breachwood Green is. This is where the Council claims is "the most relevant monitor to the East of Luton site" according to ED62. Except it clearly isn't "the most relevant" - because the black scribbly area is the actual location of EL1, EL2 and EL3 proposed housing site/ currently Green Belt. As you can see there are many other air pollution monitors - in the urban area, much closer to the development and closer to the people already living there! So why select the most remote/ Breachwood Green ones (yellow triangle)?

The red tags show the locations of all the other air pollution monitors.

Clearly Breachwood Green is in a rural location far away from any of that!

So these statements in ED62 are complete and utter rubbish; what are all of these breaches at east Luton monitoring stations shown below? - Scotch mist?!

These sites are the closest to the NHDC East of Luton Site and MANY ARE ALREADY illegally breaching as you can see: -
NO2
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36 LN23
Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF
2012 - 40
2016 - 40 LA02
Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP
2012 - 46
2016 - 43 LA05
Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2012 -39
2016 - 39 LA14
Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2014 - 37
2016 - 41 LA16
Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE

Readings from 2016 clearly show NHDC is lying and the truth is that NOx and NO2 were at dangerously illegal levels in the east of Luton at the time of ED62 being concocted. Since they are already at elevated levels before development, they are obviously projected to breach yet stratospherically further after development. Any fool can figure that out.

The red scribbly area shows where the location of the Infrastructure Project of National Significance is going to be located - something which the North Herts Plan and Inspector have both miraculously failed to mention!

It is currently a lovely green park (called wigmore Valley Park and Wildlife Conservation Area), but the Luton Council has just granted itself planning permission to put a 95 hectare development on top of the park, including two dual carriageways leading to an urban estate plus car park.

Imagine what the air pollution levels are going to become as they cut down all of the trees and smother the whole area with their beloved concrete and invite thousands more cars into the area to suck oxygen and poison every living creature.

Pollution levels are going to go through the roof. They are already illegal as it is, and this will take them into the "killer" zone.

And that is just based on the first approved NSIP.

Do not forget though - that there is a second NSIP planned for the same red scribbly area!

Luton Council is in the process of ALSO preparing a Development Consent Order application for a new Terminal Two - also upon the furthest away red scribbly part - the bit closest to the NHDC border no less!!

So both Councils are hiding things from the Inspector and the Inspector will need to ask them some very probing questions, or else he is going to become a laughing stock - when the High Court asks why are there an entire two NSIPs missing from the Local Plan he's just approved!!?

CONCLUSION ON AIR POLLUTION MONITORING SITUATION:
In Part II is the work I have compiled using the 2017 Annual Air Status Report which NHDC has ignored throughout its homework. We are still waiting for ASR 2018 which is with DEFRA now.
I have taken all of my data from the ASR 2017 and listed every single monitoring site in the whole of Luton and then worked out which the ward it sits in using Luton Borough Council ward data plus ordnance survey tools such as gridreferencefinder.com. You can see my Part II of this document for the full list and addresses.
The fact is that one third of all 60 monitoring stations run by LBC are breaching, or verging illegal levels - indicating there to be a very serious air pollution problem already present in Luton.
This is not at all surprising considering the large deficit in greenspace that Luton's population already suffers as compared to that of the national average. It is this deficit which is already taking its toll and manifesting as higher than normal morbidity rates, higher than national average asthmas rates, ill-health, higher crime rates, rising psychiatric illness, lower levels of intelligence overall and rising rates of depression.
Building 2,100 houses and cramming them into an unsuitable space only degrades the situation further.
Presently this east of Luton Green Belt is the only relief which can partially salvage this dire situation - it is truly an indispensable Green Belt buffer zone for the east of Luton - which if removed would literally close off of an entire area and seal in thousands of residents - leaving them trapped like caged monkeys in a zoo - between an unwanted "Gatwick sized" Airport Expansion/ Nationally Significant Infrastructure Projects in the field directly connected/ next-door, and thousands of crappy houses rendering the air totally unbreathable and roads disgustingly crammed full day and night.
This would most obviously have hugely and devastatingly negative consequences for the health and well-being of all age-groups and is a direct act of violence and barbaric cruelty when looked at in this wider real-life context.
This is why the MM010 Policy SP2 is absolutely not acceptable and does not deserve the title "spatial distribution" at all. The Inspector should remove/ delete the allowance of 2,100 houses adjoining Luton, within the settlement boundaries of Mangrove Green and Cockernhoe full stop.

TEXT REMOVED

LUTON:
* Cockernhoe and east of Luton
* * MM221 - Page 150 paragraph 13.66 (ED144)
MM 010 32 Policy SP2 Policy SP2: Settlement Hierarchy and Spatial Distributionx
INSERTED:Between 2011 and 2031, the plan seeks to make provision for at least 15,950 new homes.
INSERTED:Approximately 80% DELETED:The majority of the District's INSERTED:housing development INSERTED:and the substantial majority of new employment, retail and other development will be located within INSERTED:the adjusted settlement boundaries of DELETED:or adjoining the following towns:
* Baldock INSERTED:(3,298 homes);
* Hitchin INSERTED:(1,679);
* Letchworth Garden City INSERTED:(2,167);
* Luton32 INSERTED:(2,100)
* Royston INSERTED:(1,797);
* Stevenage (including Great Ashby)32 INSERTED:(1,830); and
INSERTED:Approximately 11% of housing, along with supporting infrastructure and facilities will be delivered in five villages identified by this Plan for growth:
* INSERTED:Barkway (209)
* INSERTED:Codicote (367)
* INSERTED:Ickleford (210)
* INSERTED:Knebworth (736)
* INSERTED:Little Wymondley (306)
INSERTED:The remaining development will be dispersed across the District as set out below.
INSERTED:In Category A villages, DELETED:GINSERTED:general development will DELETED:also be allowed within the defined settlement boundaries of DELETED:the Category A villages of:
* Ashwell;
* DELETED:Barkway;
* Barley;
* Breachwood Green;
* Cockernhoe INSERTED:& Mangrove Green;
* DELETED:Codicote;
* Graveley;
* Hexton;
* DELETED:Ickleford;
* Kimpton;
* DELETED:Knebworth;
* DELETED:Little Wymondley;
* Lower Stondon32;
* Oaklands32;
* Offley;
* Pirton;
* Preston;
* Reed;
* Sandon;
* St Ippolyts INSERTED:& Gosmore;
* Therfield;
* Weston; and
* Whitwell.

Each Air Status Report (ASR) for Luton can be found on the Council website at:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Home * Environment and planning * Environmental health * Air pollution * Air quality
Air Quality Strategy

We continuously monitor air pollutants and regularly review and assess air quality in the town.
The government has published an air quality strategy. Outlined in the strategy are air quality objectives for the pollutants the government considers are of most concern at present
In response to the strategy, we reviewed and assessed air quality in Luton and produced the following reports available to download below:
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

2016 Air Quality Management Area (no 3) Order ( 1.3 MB )

2015 Updating and Screening Assessment (USA) ( 5.4 MB )

2015 Detailed Assessment ( 2.1 MB )

2014 Progress Report ( 4.5 MB )

2013 Progress Report ( 4.2 MB )

2012 Updating and Screening Assessment (USA) ( 2.9 MB )

2011 Progress Report ( 1.3 MB )

2010 Progress Report ( 1.3 MB )

2009 Updating and Screening Assessment (USA) ( 1 MB )

2008 Progress Report ( 432.5 kB )

2007 Progress report ( 336.2 kB )

2006 Updating and Screening Assesment (USA) ( 1.7 MB )

2005 Air Quality Management Order ( 3.7 MB )

2005 Progress Report, Local Air Quality Management ( 312.4 kB )

2004 Detailed and Further Assessment ( 5.1 MB )

2003 Air Quality Management Order ( 1.1 MB )

2003 Updating and Screening Assessment (USA) ( 2.2 MB )

2003 Review and Assessment (Stage 4) ( 2.4 MB )

Contact information

Environmental health
Luton Borough Council, Town Hall, George Street, Luton, Bedfordshire, LU1 2BQ
Tel: 01582 510330
Fax: 01582 546676
environmentalhealth@luton.gov.uk

Object

Proposed Main Modifications

ED70 NHDC Air Quality Annual Statistics Report 2017

Representation ID: 7905

Received: 11/04/2019

Respondent: Amelia Curran

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

See attached representations

Full text:

ED55 13 Dec 2017 Inspector's list of actions for NHDC arising from Week 3 of the hearing sessions (Matters 15, 16, 17, 19 and 20) (PDF, 55Kb)

Documents for Air Quality Session on Tuesday 23 January 2017
ED62 12 Jan 2018 NHDC Note to Inspector on Air Quaility (PDF, 4Mb)

ED69 June 16 NHDC Air Quality Annual Statistics Report 2016 (PDF, 3,403Kb)

ED70 June 17 NHDC Air Quality Annual Statistics Report 2017 (PDF, 3,704Kb)

ED97 2015 Luton Borough Council 2015 transport modelling evidence re Luton airport (PDF, 4,874Kb)

Back in Week 3 at Matter 17 - The Inspector's List of Actions (ED55) for NHDC asked the Council to prepare an air quality note for the first week of January prior to the "reserve air quality session" and include in it information relating to monitoring data.
ED62 as it was then prepared, however we find in nothing but outright lies when dealing with east of Luton.

ED62
5.37 Appendix 5 contains the air quality monitoring data that is collected by London-Luton Airport within the boundary of its airport.

Yet if you go to "Appendix 5" it is falsely titled "2016": "Table B: 2016 Nitrogen Dioxide Data (ug/m3) from London-Luton Airport Diffusion Tubes (Annual Mean Ave. AQO = 40ug/m3)"
The air quality monitoring data contained in Appendix 5 is totally out-of-date but they have tried to lie and disguise that fact by falsely entitling it "2016 Nitrogen Dioxide Data".
It is in fact 2015 data extracted from the 2016 Annual Air Status Report. This means that all the data is from the year 2015 and NOT 2016!!! In case it needs spelling out; that is four year old data -unforgivable when so much more recent data exists.
Every year the Local Authority must produce a report on its air quality. This report is called an "Annual Air Status Report".
They are compiled once a year and must be submitted to DEFRA.
They must then be published on the local authority's website.
The reports contain the air monitoring data from the year prior. For example "Annual Air Status Report 2017" contains the air monitoring data from January 2016 up until December 2016.
In its document ED62 North Hertfordshire District Council (NHDC) has failed to use the available up-to-date data from the Annual Air Status Report 2017 produced by Luton Borough Council (LBC) found here:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Environmental%20and%20Consumer%20Services/Pollution/2017-Air-Quality-Annual-Status-Report.pdf

Had it done so, it would have revealed the truth; that the area around the Airport, which is closest to the East of Luton Strategic Housing Site and negatively affected A505 road, has air pollution already breaching legal limits.
However LBC have failed in their legal duty to take the appropriate measures and declare Air Quality Management Areas (AQMAs) around these dangerous sites and NHDC has been more than happy to accommodate them not addressing the problem.
14 monitoring sites are already breaching legal limits.

6 further monitoring sites are about to breach legal limits; being merely 1 unit away from the illegal threshold of 40.

So a total of 20 sites are breaching or verging breach.

Yet only 7 of those breaching sites have been declared as Air Quality Management Areas in Luton.

Therefore 13 breaching sites still remain at illegal levels yet the Council has failed to declare any AQMAs for these problem zones.

HOW MANY MONITORING SITES ARE THERE IN TOTAL?

THERE ARE A TOTAL OF 60 AIR POLLUTION MONITORS RUN BY LBC OR ITS AIRPORT COMPANY LONDON LUTON AIPORT COMPANY LTD.
ONE THIRD OF THE 60 MONITORING UNITS ARE ABOVE OR EXTREMELY CLOSE TO ILLEGAL LIMITS.
That's huge.
ASR 2017 (LBC) - p.p.14-21 shows the breakdown of ownership and type/ whether they are automatic or non-automatic monitors.
Automatic Monitors:
Total number of Automatic Monitors run by Council (LBC) - 2
Total number of Automatic Monitors run by Airport (LLAL) - 1
Automatic Monitors - TOTAL 3

Non-Automatic Monitors:
Total number of Non-Automatic Monitors run by Council (LBC) - 41
Total number of Non-Automatic Monitors run by Airport (LLAL) - 16
Non-Automatic Monitors - TOTAL 57

However large areas of the town are not being monitored at all. There are many huge blind spots that are cause for alarm. Such as the Hitchin Road into Luton/ A505 - at Stopsley roundabout. Nowhere in Stopsley, Round Green and High Town is being monitored.
There should be pollution monitoring distributed fairly across the entire town. If fair air pollution monitoring is not being applied then there can certainly be serious basis for claims that discrimination against certain ethnic and social groups is taking place.
There should be no reason why some areas are getting concentrated air pollution monitoring whilst others are getting absolutely none whatsoever. Or why some areas with elevated NO2 levels are declared AQMAs whereas many more that have even greater elevated levels, are not.
The closest monitoring points to the Local Plan's East of Luton Strategic Site are the Luton Airport's Air pollution monitoring system and those of LBC at Eaton Green Rd.
These are definitely breaching and have been doing so for many years and yet no AQMAs have ever been declared. So the Inspector should take the responsibility that both incompetent councils have failed to, and demand that AQMAs be declared rather than neglected, in all of the following places.
We directly refute the following fictitious statement from the Council:
ED62 - 5.36 The data from the 'worst case' monitoring locations contained within the Tables show that the air quality to the East of Luton does not breach the relevant Air Quality Objective. Therefore, because of the absence of any other potentially significant sources of nitrogen dioxide and particulate matter in the area it was judged to be unnecessary to monitor for local air pollutants elsewhere in the area east of Luton.

No need to monitor local air pollutants elsewhere in the area..."because of the absence of any other potentially significant sources of nitrogen dioxide".... What complete and utter rubbish - see the many significant sources of nitrogen dioxide and particulate matter below from the readings in the Luton ASR 2017, which NHDC has not looked at!
These sites are in fact the closest to the NHDC East of Luton Site and they are illegally breaching as you can easily see: -
SITE ID SITE NAME
IF INSIDE AQMA/ OR NOT
ORDNANCE SURVEY REF
ADDRESS AND POSTAL CODE WARD (ZONE) SOUTH/ NORTH LUTON POLLUTANTS
-MEASURED If Tube collocated with a Continuous Analyser/ or not
YEARS & OVERAL BREACH LEVEL CONCLUDED BY LBC ASR

LN23 Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF CRAWLEY (A) SOUTH NO2 Tube NOT collocated with a Continuous Analyser
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36

LA02 Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 40
2016 - 40

LA05 Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 46
2016 - 43

LA14 Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR, AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 -39
2016 - 39

LA16 Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2014 - 37
2016 - 41

The following claim is an out and out lie:
ED62 - 5.39
The data show that the annual mean average Air Quality Objective for nitrogen dioxide was not exceeded at a relevant receptor in 2016. This is the only recent data published by Luton Borough Council. The only two marginal exceedances were measured at an airside location and a kerbside location within the airport boundary and so a relevant receptor is not exposed nor is there a likelihood of exposure because of the absence of housing or an equivalent receptor within the airport boundary.

Firstly there were not "only two marginal exceedances".

Secondly "exceedances" are never marginal - but are serious, illegal and likely to only get progressively worse.

Thirdly five exceedances is a serious matter, and AQMAs must be immediately declared by law. This is not an option but an obligation.

The author/s of ED62 lie by citing the Beachwood Green monitors to be the "relevant receptor(s) in 2016" - when these are much farther away from the proposed site and far less relevant than the monitors in the affected area of east of Luton. Since the traffic and entrances to the proposed housing site are all expected to be from Luton via the Crawley Green/ Luton Roads - so the monitors there are obviously far more relevant. Yet the diagram given in ED62 doesn't show any of these east of Luton points. It has left out their existence altogether.

See below how ED62 only shows five "relevant" analysers - all in the Village of Breachwood Green:

ED62 - 5.38
The data show that the Air Quality Objectives for PM10 particulate matter have not been exceeded from the first year of monitoring (2004 first full year of data) to date.

ED62 - 5.6 Local Air Quality Monitoring Data for East of Luton
5.32 There is currently no monitoring of air quality in the area of the district identified as the East of Luton. Historically there were eight monitoring locations, of which seven were diffusion tubes and one was a site comprising two real-time analysers. The locations of the air quality monitoring points are shown in Figure 5.6.

ED62 5.32 also lies when it falsely claims there is no monitoring of air quality on the area of the district identified as the East of Luton.

Here is a map to illustrate the fact there are many monitors now collecting readings. Had NHDC looked at the ASR 2017 report they would know that.

The yellow triangle is where Breachwood Green is. This is where the Council claims is "the most relevant monitor to the East of Luton site" according to ED62. Except it clearly isn't "the most relevant" - because the black scribbly area is the actual location of EL1, EL2 and EL3 proposed housing site/ currently Green Belt. As you can see there are many other air pollution monitors - in the urban area, much closer to the development and closer to the people already living there! So why select the most remote/ Breachwood Green ones (yellow triangle)?

The red tags show the locations of all the other air pollution monitors.

Clearly Breachwood Green is in a rural location far away from any of that!

So these statements in ED62 are complete and utter rubbish; what are all of these breaches at east Luton monitoring stations shown below? - Scotch mist?!

These sites are the closest to the NHDC East of Luton Site and MANY ARE ALREADY illegally breaching as you can see: -
NO2
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36 LN23
Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF
2012 - 40
2016 - 40 LA02
Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP
2012 - 46
2016 - 43 LA05
Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2012 -39
2016 - 39 LA14
Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2014 - 37
2016 - 41 LA16
Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE

Readings from 2016 clearly show NHDC is lying and the truth is that NOx and NO2 were at dangerously illegal levels in the east of Luton at the time of ED62 being concocted. Since they are already at elevated levels before development, they are obviously projected to breach yet stratospherically further after development. Any fool can figure that out.

The red scribbly area shows where the location of the Infrastructure Project of National Significance is going to be located - something which the North Herts Plan and Inspector have both miraculously failed to mention!

It is currently a lovely green park (called wigmore Valley Park and Wildlife Conservation Area), but the Luton Council has just granted itself planning permission to put a 95 hectare development on top of the park, including two dual carriageways leading to an urban estate plus car park.

Imagine what the air pollution levels are going to become as they cut down all of the trees and smother the whole area with their beloved concrete and invite thousands more cars into the area to suck oxygen and poison every living creature.

Pollution levels are going to go through the roof. They are already illegal as it is, and this will take them into the "killer" zone.

And that is just based on the first approved NSIP.

Do not forget though - that there is a second NSIP planned for the same red scribbly area!

Luton Council is in the process of ALSO preparing a Development Consent Order application for a new Terminal Two - also upon the furthest away red scribbly part - the bit closest to the NHDC border no less!!

So both Councils are hiding things from the Inspector and the Inspector will need to ask them some very probing questions, or else he is going to become a laughing stock - when the High Court asks why are there an entire two NSIPs missing from the Local Plan he's just approved!!?

CONCLUSION ON AIR POLLUTION MONITORING SITUATION:
In Part II is the work I have compiled using the 2017 Annual Air Status Report which NHDC has ignored throughout its homework. We are still waiting for ASR 2018 which is with DEFRA now.
I have taken all of my data from the ASR 2017 and listed every single monitoring site in the whole of Luton and then worked out which the ward it sits in using Luton Borough Council ward data plus ordnance survey tools such as gridreferencefinder.com. You can see my Part II of this document for the full list and addresses.
The fact is that one third of all 60 monitoring stations run by LBC are breaching, or verging illegal levels - indicating there to be a very serious air pollution problem already present in Luton.
This is not at all surprising considering the large deficit in greenspace that Luton's population already suffers as compared to that of the national average. It is this deficit which is already taking its toll and manifesting as higher than normal morbidity rates, higher than national average asthmas rates, ill-health, higher crime rates, rising psychiatric illness, lower levels of intelligence overall and rising rates of depression.
Building 2,100 houses and cramming them into an unsuitable space only degrades the situation further.
Presently this east of Luton Green Belt is the only relief which can partially salvage this dire situation - it is truly an indispensable Green Belt buffer zone for the east of Luton - which if removed would literally close off of an entire area and seal in thousands of residents - leaving them trapped like caged monkeys in a zoo - between an unwanted "Gatwick sized" Airport Expansion/ Nationally Significant Infrastructure Projects in the field directly connected/ next-door, and thousands of crappy houses rendering the air totally unbreathable and roads disgustingly crammed full day and night.
This would most obviously have hugely and devastatingly negative consequences for the health and well-being of all age-groups and is a direct act of violence and barbaric cruelty when looked at in this wider real-life context.
This is why the MM010 Policy SP2 is absolutely not acceptable and does not deserve the title "spatial distribution" at all. The Inspector should remove/ delete the allowance of 2,100 houses adjoining Luton, within the settlement boundaries of Mangrove Green and Cockernhoe full stop.

TEXT REMOVED

LUTON:
* Cockernhoe and east of Luton
* * MM221 - Page 150 paragraph 13.66 (ED144)
MM 010 32 Policy SP2 Policy SP2: Settlement Hierarchy and Spatial Distributionx
INSERTED:Between 2011 and 2031, the plan seeks to make provision for at least 15,950 new homes.
INSERTED:Approximately 80% DELETED:The majority of the District's INSERTED:housing development INSERTED:and the substantial majority of new employment, retail and other development will be located within INSERTED:the adjusted settlement boundaries of DELETED:or adjoining the following towns:
* Baldock INSERTED:(3,298 homes);
* Hitchin INSERTED:(1,679);
* Letchworth Garden City INSERTED:(2,167);
* Luton32 INSERTED:(2,100)
* Royston INSERTED:(1,797);
* Stevenage (including Great Ashby)32 INSERTED:(1,830); and
INSERTED:Approximately 11% of housing, along with supporting infrastructure and facilities will be delivered in five villages identified by this Plan for growth:
* INSERTED:Barkway (209)
* INSERTED:Codicote (367)
* INSERTED:Ickleford (210)
* INSERTED:Knebworth (736)
* INSERTED:Little Wymondley (306)
INSERTED:The remaining development will be dispersed across the District as set out below.
INSERTED:In Category A villages, DELETED:GINSERTED:general development will DELETED:also be allowed within the defined settlement boundaries of DELETED:the Category A villages of:
* Ashwell;
* DELETED:Barkway;
* Barley;
* Breachwood Green;
* Cockernhoe INSERTED:& Mangrove Green;
* DELETED:Codicote;
* Graveley;
* Hexton;
* DELETED:Ickleford;
* Kimpton;
* DELETED:Knebworth;
* DELETED:Little Wymondley;
* Lower Stondon32;
* Oaklands32;
* Offley;
* Pirton;
* Preston;
* Reed;
* Sandon;
* St Ippolyts INSERTED:& Gosmore;
* Therfield;
* Weston; and
* Whitwell.

Each Air Status Report (ASR) for Luton can be found on the Council website at:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Home * Environment and planning * Environmental health * Air pollution * Air quality
Air Quality Strategy

We continuously monitor air pollutants and regularly review and assess air quality in the town.
The government has published an air quality strategy. Outlined in the strategy are air quality objectives for the pollutants the government considers are of most concern at present
In response to the strategy, we reviewed and assessed air quality in Luton and produced the following reports available to download below:
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

2016 Air Quality Management Area (no 3) Order ( 1.3 MB )

2015 Updating and Screening Assessment (USA) ( 5.4 MB )

2015 Detailed Assessment ( 2.1 MB )

2014 Progress Report ( 4.5 MB )

2013 Progress Report ( 4.2 MB )

2012 Updating and Screening Assessment (USA) ( 2.9 MB )

2011 Progress Report ( 1.3 MB )

2010 Progress Report ( 1.3 MB )

2009 Updating and Screening Assessment (USA) ( 1 MB )

2008 Progress Report ( 432.5 kB )

2007 Progress report ( 336.2 kB )

2006 Updating and Screening Assesment (USA) ( 1.7 MB )

2005 Air Quality Management Order ( 3.7 MB )

2005 Progress Report, Local Air Quality Management ( 312.4 kB )

2004 Detailed and Further Assessment ( 5.1 MB )

2003 Air Quality Management Order ( 1.1 MB )

2003 Updating and Screening Assessment (USA) ( 2.2 MB )

2003 Review and Assessment (Stage 4) ( 2.4 MB )

Contact information

Environmental health
Luton Borough Council, Town Hall, George Street, Luton, Bedfordshire, LU1 2BQ
Tel: 01582 510330
Fax: 01582 546676
environmentalhealth@luton.gov.uk

Object

Proposed Main Modifications

ED97 Luton Borough Council 2015 transport modelling evidence re Luton Airport

Representation ID: 7906

Received: 11/04/2019

Respondent: Amelia Curran

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

See attached representations

Full text:

ED55 13 Dec 2017 Inspector's list of actions for NHDC arising from Week 3 of the hearing sessions (Matters 15, 16, 17, 19 and 20) (PDF, 55Kb)

Documents for Air Quality Session on Tuesday 23 January 2017
ED62 12 Jan 2018 NHDC Note to Inspector on Air Quaility (PDF, 4Mb)

ED69 June 16 NHDC Air Quality Annual Statistics Report 2016 (PDF, 3,403Kb)

ED70 June 17 NHDC Air Quality Annual Statistics Report 2017 (PDF, 3,704Kb)

ED97 2015 Luton Borough Council 2015 transport modelling evidence re Luton airport (PDF, 4,874Kb)

Back in Week 3 at Matter 17 - The Inspector's List of Actions (ED55) for NHDC asked the Council to prepare an air quality note for the first week of January prior to the "reserve air quality session" and include in it information relating to monitoring data.
ED62 as it was then prepared, however we find in nothing but outright lies when dealing with east of Luton.

ED62
5.37 Appendix 5 contains the air quality monitoring data that is collected by London-Luton Airport within the boundary of its airport.

Yet if you go to "Appendix 5" it is falsely titled "2016": "Table B: 2016 Nitrogen Dioxide Data (ug/m3) from London-Luton Airport Diffusion Tubes (Annual Mean Ave. AQO = 40ug/m3)"
The air quality monitoring data contained in Appendix 5 is totally out-of-date but they have tried to lie and disguise that fact by falsely entitling it "2016 Nitrogen Dioxide Data".
It is in fact 2015 data extracted from the 2016 Annual Air Status Report. This means that all the data is from the year 2015 and NOT 2016!!! In case it needs spelling out; that is four year old data -unforgivable when so much more recent data exists.
Every year the Local Authority must produce a report on its air quality. This report is called an "Annual Air Status Report".
They are compiled once a year and must be submitted to DEFRA.
They must then be published on the local authority's website.
The reports contain the air monitoring data from the year prior. For example "Annual Air Status Report 2017" contains the air monitoring data from January 2016 up until December 2016.
In its document ED62 North Hertfordshire District Council (NHDC) has failed to use the available up-to-date data from the Annual Air Status Report 2017 produced by Luton Borough Council (LBC) found here:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Environmental%20and%20Consumer%20Services/Pollution/2017-Air-Quality-Annual-Status-Report.pdf

Had it done so, it would have revealed the truth; that the area around the Airport, which is closest to the East of Luton Strategic Housing Site and negatively affected A505 road, has air pollution already breaching legal limits.
However LBC have failed in their legal duty to take the appropriate measures and declare Air Quality Management Areas (AQMAs) around these dangerous sites and NHDC has been more than happy to accommodate them not addressing the problem.
14 monitoring sites are already breaching legal limits.

6 further monitoring sites are about to breach legal limits; being merely 1 unit away from the illegal threshold of 40.

So a total of 20 sites are breaching or verging breach.

Yet only 7 of those breaching sites have been declared as Air Quality Management Areas in Luton.

Therefore 13 breaching sites still remain at illegal levels yet the Council has failed to declare any AQMAs for these problem zones.

HOW MANY MONITORING SITES ARE THERE IN TOTAL?

THERE ARE A TOTAL OF 60 AIR POLLUTION MONITORS RUN BY LBC OR ITS AIRPORT COMPANY LONDON LUTON AIPORT COMPANY LTD.
ONE THIRD OF THE 60 MONITORING UNITS ARE ABOVE OR EXTREMELY CLOSE TO ILLEGAL LIMITS.
That's huge.
ASR 2017 (LBC) - p.p.14-21 shows the breakdown of ownership and type/ whether they are automatic or non-automatic monitors.
Automatic Monitors:
Total number of Automatic Monitors run by Council (LBC) - 2
Total number of Automatic Monitors run by Airport (LLAL) - 1
Automatic Monitors - TOTAL 3

Non-Automatic Monitors:
Total number of Non-Automatic Monitors run by Council (LBC) - 41
Total number of Non-Automatic Monitors run by Airport (LLAL) - 16
Non-Automatic Monitors - TOTAL 57

However large areas of the town are not being monitored at all. There are many huge blind spots that are cause for alarm. Such as the Hitchin Road into Luton/ A505 - at Stopsley roundabout. Nowhere in Stopsley, Round Green and High Town is being monitored.
There should be pollution monitoring distributed fairly across the entire town. If fair air pollution monitoring is not being applied then there can certainly be serious basis for claims that discrimination against certain ethnic and social groups is taking place.
There should be no reason why some areas are getting concentrated air pollution monitoring whilst others are getting absolutely none whatsoever. Or why some areas with elevated NO2 levels are declared AQMAs whereas many more that have even greater elevated levels, are not.
The closest monitoring points to the Local Plan's East of Luton Strategic Site are the Luton Airport's Air pollution monitoring system and those of LBC at Eaton Green Rd.
These are definitely breaching and have been doing so for many years and yet no AQMAs have ever been declared. So the Inspector should take the responsibility that both incompetent councils have failed to, and demand that AQMAs be declared rather than neglected, in all of the following places.
We directly refute the following fictitious statement from the Council:
ED62 - 5.36 The data from the 'worst case' monitoring locations contained within the Tables show that the air quality to the East of Luton does not breach the relevant Air Quality Objective. Therefore, because of the absence of any other potentially significant sources of nitrogen dioxide and particulate matter in the area it was judged to be unnecessary to monitor for local air pollutants elsewhere in the area east of Luton.

No need to monitor local air pollutants elsewhere in the area..."because of the absence of any other potentially significant sources of nitrogen dioxide".... What complete and utter rubbish - see the many significant sources of nitrogen dioxide and particulate matter below from the readings in the Luton ASR 2017, which NHDC has not looked at!
These sites are in fact the closest to the NHDC East of Luton Site and they are illegally breaching as you can easily see: -
SITE ID SITE NAME
IF INSIDE AQMA/ OR NOT
ORDNANCE SURVEY REF
ADDRESS AND POSTAL CODE WARD (ZONE) SOUTH/ NORTH LUTON POLLUTANTS
-MEASURED If Tube collocated with a Continuous Analyser/ or not
YEARS & OVERAL BREACH LEVEL CONCLUDED BY LBC ASR

LN23 Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF CRAWLEY (A) SOUTH NO2 Tube NOT collocated with a Continuous Analyser
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36

LA02 Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 40
2016 - 40

LA05 Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 46
2016 - 43

LA14 Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR, AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 -39
2016 - 39

LA16 Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2014 - 37
2016 - 41

The following claim is an out and out lie:
ED62 - 5.39
The data show that the annual mean average Air Quality Objective for nitrogen dioxide was not exceeded at a relevant receptor in 2016. This is the only recent data published by Luton Borough Council. The only two marginal exceedances were measured at an airside location and a kerbside location within the airport boundary and so a relevant receptor is not exposed nor is there a likelihood of exposure because of the absence of housing or an equivalent receptor within the airport boundary.

Firstly there were not "only two marginal exceedances".

Secondly "exceedances" are never marginal - but are serious, illegal and likely to only get progressively worse.

Thirdly five exceedances is a serious matter, and AQMAs must be immediately declared by law. This is not an option but an obligation.

The author/s of ED62 lie by citing the Beachwood Green monitors to be the "relevant receptor(s) in 2016" - when these are much farther away from the proposed site and far less relevant than the monitors in the affected area of east of Luton. Since the traffic and entrances to the proposed housing site are all expected to be from Luton via the Crawley Green/ Luton Roads - so the monitors there are obviously far more relevant. Yet the diagram given in ED62 doesn't show any of these east of Luton points. It has left out their existence altogether.

See below how ED62 only shows five "relevant" analysers - all in the Village of Breachwood Green:

ED62 - 5.38
The data show that the Air Quality Objectives for PM10 particulate matter have not been exceeded from the first year of monitoring (2004 first full year of data) to date.

ED62 - 5.6 Local Air Quality Monitoring Data for East of Luton
5.32 There is currently no monitoring of air quality in the area of the district identified as the East of Luton. Historically there were eight monitoring locations, of which seven were diffusion tubes and one was a site comprising two real-time analysers. The locations of the air quality monitoring points are shown in Figure 5.6.

ED62 5.32 also lies when it falsely claims there is no monitoring of air quality on the area of the district identified as the East of Luton.

Here is a map to illustrate the fact there are many monitors now collecting readings. Had NHDC looked at the ASR 2017 report they would know that.

The yellow triangle is where Breachwood Green is. This is where the Council claims is "the most relevant monitor to the East of Luton site" according to ED62. Except it clearly isn't "the most relevant" - because the black scribbly area is the actual location of EL1, EL2 and EL3 proposed housing site/ currently Green Belt. As you can see there are many other air pollution monitors - in the urban area, much closer to the development and closer to the people already living there! So why select the most remote/ Breachwood Green ones (yellow triangle)?

The red tags show the locations of all the other air pollution monitors.

Clearly Breachwood Green is in a rural location far away from any of that!

So these statements in ED62 are complete and utter rubbish; what are all of these breaches at east Luton monitoring stations shown below? - Scotch mist?!

These sites are the closest to the NHDC East of Luton Site and MANY ARE ALREADY illegally breaching as you can see: -
NO2
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36 LN23
Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF
2012 - 40
2016 - 40 LA02
Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP
2012 - 46
2016 - 43 LA05
Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2012 -39
2016 - 39 LA14
Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2014 - 37
2016 - 41 LA16
Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE

Readings from 2016 clearly show NHDC is lying and the truth is that NOx and NO2 were at dangerously illegal levels in the east of Luton at the time of ED62 being concocted. Since they are already at elevated levels before development, they are obviously projected to breach yet stratospherically further after development. Any fool can figure that out.

The red scribbly area shows where the location of the Infrastructure Project of National Significance is going to be located - something which the North Herts Plan and Inspector have both miraculously failed to mention!

It is currently a lovely green park (called wigmore Valley Park and Wildlife Conservation Area), but the Luton Council has just granted itself planning permission to put a 95 hectare development on top of the park, including two dual carriageways leading to an urban estate plus car park.

Imagine what the air pollution levels are going to become as they cut down all of the trees and smother the whole area with their beloved concrete and invite thousands more cars into the area to suck oxygen and poison every living creature.

Pollution levels are going to go through the roof. They are already illegal as it is, and this will take them into the "killer" zone.

And that is just based on the first approved NSIP.

Do not forget though - that there is a second NSIP planned for the same red scribbly area!

Luton Council is in the process of ALSO preparing a Development Consent Order application for a new Terminal Two - also upon the furthest away red scribbly part - the bit closest to the NHDC border no less!!

So both Councils are hiding things from the Inspector and the Inspector will need to ask them some very probing questions, or else he is going to become a laughing stock - when the High Court asks why are there an entire two NSIPs missing from the Local Plan he's just approved!!?

CONCLUSION ON AIR POLLUTION MONITORING SITUATION:
In Part II is the work I have compiled using the 2017 Annual Air Status Report which NHDC has ignored throughout its homework. We are still waiting for ASR 2018 which is with DEFRA now.
I have taken all of my data from the ASR 2017 and listed every single monitoring site in the whole of Luton and then worked out which the ward it sits in using Luton Borough Council ward data plus ordnance survey tools such as gridreferencefinder.com. You can see my Part II of this document for the full list and addresses.
The fact is that one third of all 60 monitoring stations run by LBC are breaching, or verging illegal levels - indicating there to be a very serious air pollution problem already present in Luton.
This is not at all surprising considering the large deficit in greenspace that Luton's population already suffers as compared to that of the national average. It is this deficit which is already taking its toll and manifesting as higher than normal morbidity rates, higher than national average asthmas rates, ill-health, higher crime rates, rising psychiatric illness, lower levels of intelligence overall and rising rates of depression.
Building 2,100 houses and cramming them into an unsuitable space only degrades the situation further.
Presently this east of Luton Green Belt is the only relief which can partially salvage this dire situation - it is truly an indispensable Green Belt buffer zone for the east of Luton - which if removed would literally close off of an entire area and seal in thousands of residents - leaving them trapped like caged monkeys in a zoo - between an unwanted "Gatwick sized" Airport Expansion/ Nationally Significant Infrastructure Projects in the field directly connected/ next-door, and thousands of crappy houses rendering the air totally unbreathable and roads disgustingly crammed full day and night.
This would most obviously have hugely and devastatingly negative consequences for the health and well-being of all age-groups and is a direct act of violence and barbaric cruelty when looked at in this wider real-life context.
This is why the MM010 Policy SP2 is absolutely not acceptable and does not deserve the title "spatial distribution" at all. The Inspector should remove/ delete the allowance of 2,100 houses adjoining Luton, within the settlement boundaries of Mangrove Green and Cockernhoe full stop.

TEXT REMOVED

LUTON:
* Cockernhoe and east of Luton
* * MM221 - Page 150 paragraph 13.66 (ED144)
MM 010 32 Policy SP2 Policy SP2: Settlement Hierarchy and Spatial Distributionx
INSERTED:Between 2011 and 2031, the plan seeks to make provision for at least 15,950 new homes.
INSERTED:Approximately 80% DELETED:The majority of the District's INSERTED:housing development INSERTED:and the substantial majority of new employment, retail and other development will be located within INSERTED:the adjusted settlement boundaries of DELETED:or adjoining the following towns:
* Baldock INSERTED:(3,298 homes);
* Hitchin INSERTED:(1,679);
* Letchworth Garden City INSERTED:(2,167);
* Luton32 INSERTED:(2,100)
* Royston INSERTED:(1,797);
* Stevenage (including Great Ashby)32 INSERTED:(1,830); and
INSERTED:Approximately 11% of housing, along with supporting infrastructure and facilities will be delivered in five villages identified by this Plan for growth:
* INSERTED:Barkway (209)
* INSERTED:Codicote (367)
* INSERTED:Ickleford (210)
* INSERTED:Knebworth (736)
* INSERTED:Little Wymondley (306)
INSERTED:The remaining development will be dispersed across the District as set out below.
INSERTED:In Category A villages, DELETED:GINSERTED:general development will DELETED:also be allowed within the defined settlement boundaries of DELETED:the Category A villages of:
* Ashwell;
* DELETED:Barkway;
* Barley;
* Breachwood Green;
* Cockernhoe INSERTED:& Mangrove Green;
* DELETED:Codicote;
* Graveley;
* Hexton;
* DELETED:Ickleford;
* Kimpton;
* DELETED:Knebworth;
* DELETED:Little Wymondley;
* Lower Stondon32;
* Oaklands32;
* Offley;
* Pirton;
* Preston;
* Reed;
* Sandon;
* St Ippolyts INSERTED:& Gosmore;
* Therfield;
* Weston; and
* Whitwell.

Each Air Status Report (ASR) for Luton can be found on the Council website at:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Home * Environment and planning * Environmental health * Air pollution * Air quality
Air Quality Strategy

We continuously monitor air pollutants and regularly review and assess air quality in the town.
The government has published an air quality strategy. Outlined in the strategy are air quality objectives for the pollutants the government considers are of most concern at present
In response to the strategy, we reviewed and assessed air quality in Luton and produced the following reports available to download below:
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

2016 Air Quality Management Area (no 3) Order ( 1.3 MB )

2015 Updating and Screening Assessment (USA) ( 5.4 MB )

2015 Detailed Assessment ( 2.1 MB )

2014 Progress Report ( 4.5 MB )

2013 Progress Report ( 4.2 MB )

2012 Updating and Screening Assessment (USA) ( 2.9 MB )

2011 Progress Report ( 1.3 MB )

2010 Progress Report ( 1.3 MB )

2009 Updating and Screening Assessment (USA) ( 1 MB )

2008 Progress Report ( 432.5 kB )

2007 Progress report ( 336.2 kB )

2006 Updating and Screening Assesment (USA) ( 1.7 MB )

2005 Air Quality Management Order ( 3.7 MB )

2005 Progress Report, Local Air Quality Management ( 312.4 kB )

2004 Detailed and Further Assessment ( 5.1 MB )

2003 Air Quality Management Order ( 1.1 MB )

2003 Updating and Screening Assessment (USA) ( 2.2 MB )

2003 Review and Assessment (Stage 4) ( 2.4 MB )

Contact information

Environmental health
Luton Borough Council, Town Hall, George Street, Luton, Bedfordshire, LU1 2BQ
Tel: 01582 510330
Fax: 01582 546676
environmentalhealth@luton.gov.uk

Object

Proposed Main Modifications

MM010 - Page 32 Policy SP2

Representation ID: 7907

Received: 11/04/2019

Respondent: Amelia Curran

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

See attached representations

Full text:

ED55 13 Dec 2017 Inspector's list of actions for NHDC arising from Week 3 of the hearing sessions (Matters 15, 16, 17, 19 and 20) (PDF, 55Kb)

Documents for Air Quality Session on Tuesday 23 January 2017
ED62 12 Jan 2018 NHDC Note to Inspector on Air Quaility (PDF, 4Mb)

ED69 June 16 NHDC Air Quality Annual Statistics Report 2016 (PDF, 3,403Kb)

ED70 June 17 NHDC Air Quality Annual Statistics Report 2017 (PDF, 3,704Kb)

ED97 2015 Luton Borough Council 2015 transport modelling evidence re Luton airport (PDF, 4,874Kb)

Back in Week 3 at Matter 17 - The Inspector's List of Actions (ED55) for NHDC asked the Council to prepare an air quality note for the first week of January prior to the "reserve air quality session" and include in it information relating to monitoring data.
ED62 as it was then prepared, however we find in nothing but outright lies when dealing with east of Luton.

ED62
5.37 Appendix 5 contains the air quality monitoring data that is collected by London-Luton Airport within the boundary of its airport.

Yet if you go to "Appendix 5" it is falsely titled "2016": "Table B: 2016 Nitrogen Dioxide Data (ug/m3) from London-Luton Airport Diffusion Tubes (Annual Mean Ave. AQO = 40ug/m3)"
The air quality monitoring data contained in Appendix 5 is totally out-of-date but they have tried to lie and disguise that fact by falsely entitling it "2016 Nitrogen Dioxide Data".
It is in fact 2015 data extracted from the 2016 Annual Air Status Report. This means that all the data is from the year 2015 and NOT 2016!!! In case it needs spelling out; that is four year old data -unforgivable when so much more recent data exists.
Every year the Local Authority must produce a report on its air quality. This report is called an "Annual Air Status Report".
They are compiled once a year and must be submitted to DEFRA.
They must then be published on the local authority's website.
The reports contain the air monitoring data from the year prior. For example "Annual Air Status Report 2017" contains the air monitoring data from January 2016 up until December 2016.
In its document ED62 North Hertfordshire District Council (NHDC) has failed to use the available up-to-date data from the Annual Air Status Report 2017 produced by Luton Borough Council (LBC) found here:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Environmental%20and%20Consumer%20Services/Pollution/2017-Air-Quality-Annual-Status-Report.pdf

Had it done so, it would have revealed the truth; that the area around the Airport, which is closest to the East of Luton Strategic Housing Site and negatively affected A505 road, has air pollution already breaching legal limits.
However LBC have failed in their legal duty to take the appropriate measures and declare Air Quality Management Areas (AQMAs) around these dangerous sites and NHDC has been more than happy to accommodate them not addressing the problem.
14 monitoring sites are already breaching legal limits.

6 further monitoring sites are about to breach legal limits; being merely 1 unit away from the illegal threshold of 40.

So a total of 20 sites are breaching or verging breach.

Yet only 7 of those breaching sites have been declared as Air Quality Management Areas in Luton.

Therefore 13 breaching sites still remain at illegal levels yet the Council has failed to declare any AQMAs for these problem zones.

HOW MANY MONITORING SITES ARE THERE IN TOTAL?

THERE ARE A TOTAL OF 60 AIR POLLUTION MONITORS RUN BY LBC OR ITS AIRPORT COMPANY LONDON LUTON AIPORT COMPANY LTD.
ONE THIRD OF THE 60 MONITORING UNITS ARE ABOVE OR EXTREMELY CLOSE TO ILLEGAL LIMITS.
That's huge.
ASR 2017 (LBC) - p.p.14-21 shows the breakdown of ownership and type/ whether they are automatic or non-automatic monitors.
Automatic Monitors:
Total number of Automatic Monitors run by Council (LBC) - 2
Total number of Automatic Monitors run by Airport (LLAL) - 1
Automatic Monitors - TOTAL 3

Non-Automatic Monitors:
Total number of Non-Automatic Monitors run by Council (LBC) - 41
Total number of Non-Automatic Monitors run by Airport (LLAL) - 16
Non-Automatic Monitors - TOTAL 57

However large areas of the town are not being monitored at all. There are many huge blind spots that are cause for alarm. Such as the Hitchin Road into Luton/ A505 - at Stopsley roundabout. Nowhere in Stopsley, Round Green and High Town is being monitored.
There should be pollution monitoring distributed fairly across the entire town. If fair air pollution monitoring is not being applied then there can certainly be serious basis for claims that discrimination against certain ethnic and social groups is taking place.
There should be no reason why some areas are getting concentrated air pollution monitoring whilst others are getting absolutely none whatsoever. Or why some areas with elevated NO2 levels are declared AQMAs whereas many more that have even greater elevated levels, are not.
The closest monitoring points to the Local Plan's East of Luton Strategic Site are the Luton Airport's Air pollution monitoring system and those of LBC at Eaton Green Rd.
These are definitely breaching and have been doing so for many years and yet no AQMAs have ever been declared. So the Inspector should take the responsibility that both incompetent councils have failed to, and demand that AQMAs be declared rather than neglected, in all of the following places.
We directly refute the following fictitious statement from the Council:
ED62 - 5.36 The data from the 'worst case' monitoring locations contained within the Tables show that the air quality to the East of Luton does not breach the relevant Air Quality Objective. Therefore, because of the absence of any other potentially significant sources of nitrogen dioxide and particulate matter in the area it was judged to be unnecessary to monitor for local air pollutants elsewhere in the area east of Luton.

No need to monitor local air pollutants elsewhere in the area..."because of the absence of any other potentially significant sources of nitrogen dioxide".... What complete and utter rubbish - see the many significant sources of nitrogen dioxide and particulate matter below from the readings in the Luton ASR 2017, which NHDC has not looked at!
These sites are in fact the closest to the NHDC East of Luton Site and they are illegally breaching as you can easily see: -
SITE ID SITE NAME
IF INSIDE AQMA/ OR NOT
ORDNANCE SURVEY REF
ADDRESS AND POSTAL CODE WARD (ZONE) SOUTH/ NORTH LUTON POLLUTANTS
-MEASURED If Tube collocated with a Continuous Analyser/ or not
YEARS & OVERAL BREACH LEVEL CONCLUDED BY LBC ASR

LN23 Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF CRAWLEY (A) SOUTH NO2 Tube NOT collocated with a Continuous Analyser
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36

LA02 Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 40
2016 - 40

LA05 Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 46
2016 - 43

LA14 Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR, AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 -39
2016 - 39

LA16 Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2014 - 37
2016 - 41

The following claim is an out and out lie:
ED62 - 5.39
The data show that the annual mean average Air Quality Objective for nitrogen dioxide was not exceeded at a relevant receptor in 2016. This is the only recent data published by Luton Borough Council. The only two marginal exceedances were measured at an airside location and a kerbside location within the airport boundary and so a relevant receptor is not exposed nor is there a likelihood of exposure because of the absence of housing or an equivalent receptor within the airport boundary.

Firstly there were not "only two marginal exceedances".

Secondly "exceedances" are never marginal - but are serious, illegal and likely to only get progressively worse.

Thirdly five exceedances is a serious matter, and AQMAs must be immediately declared by law. This is not an option but an obligation.

The author/s of ED62 lie by citing the Beachwood Green monitors to be the "relevant receptor(s) in 2016" - when these are much farther away from the proposed site and far less relevant than the monitors in the affected area of east of Luton. Since the traffic and entrances to the proposed housing site are all expected to be from Luton via the Crawley Green/ Luton Roads - so the monitors there are obviously far more relevant. Yet the diagram given in ED62 doesn't show any of these east of Luton points. It has left out their existence altogether.

See below how ED62 only shows five "relevant" analysers - all in the Village of Breachwood Green:

ED62 - 5.38
The data show that the Air Quality Objectives for PM10 particulate matter have not been exceeded from the first year of monitoring (2004 first full year of data) to date.

ED62 - 5.6 Local Air Quality Monitoring Data for East of Luton
5.32 There is currently no monitoring of air quality in the area of the district identified as the East of Luton. Historically there were eight monitoring locations, of which seven were diffusion tubes and one was a site comprising two real-time analysers. The locations of the air quality monitoring points are shown in Figure 5.6.

ED62 5.32 also lies when it falsely claims there is no monitoring of air quality on the area of the district identified as the East of Luton.

Here is a map to illustrate the fact there are many monitors now collecting readings. Had NHDC looked at the ASR 2017 report they would know that.

The yellow triangle is where Breachwood Green is. This is where the Council claims is "the most relevant monitor to the East of Luton site" according to ED62. Except it clearly isn't "the most relevant" - because the black scribbly area is the actual location of EL1, EL2 and EL3 proposed housing site/ currently Green Belt. As you can see there are many other air pollution monitors - in the urban area, much closer to the development and closer to the people already living there! So why select the most remote/ Breachwood Green ones (yellow triangle)?

The red tags show the locations of all the other air pollution monitors.

Clearly Breachwood Green is in a rural location far away from any of that!

So these statements in ED62 are complete and utter rubbish; what are all of these breaches at east Luton monitoring stations shown below? - Scotch mist?!

These sites are the closest to the NHDC East of Luton Site and MANY ARE ALREADY illegally breaching as you can see: -
NO2
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36 LN23
Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF
2012 - 40
2016 - 40 LA02
Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP
2012 - 46
2016 - 43 LA05
Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2012 -39
2016 - 39 LA14
Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2014 - 37
2016 - 41 LA16
Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE

Readings from 2016 clearly show NHDC is lying and the truth is that NOx and NO2 were at dangerously illegal levels in the east of Luton at the time of ED62 being concocted. Since they are already at elevated levels before development, they are obviously projected to breach yet stratospherically further after development. Any fool can figure that out.

The red scribbly area shows where the location of the Infrastructure Project of National Significance is going to be located - something which the North Herts Plan and Inspector have both miraculously failed to mention!

It is currently a lovely green park (called wigmore Valley Park and Wildlife Conservation Area), but the Luton Council has just granted itself planning permission to put a 95 hectare development on top of the park, including two dual carriageways leading to an urban estate plus car park.

Imagine what the air pollution levels are going to become as they cut down all of the trees and smother the whole area with their beloved concrete and invite thousands more cars into the area to suck oxygen and poison every living creature.

Pollution levels are going to go through the roof. They are already illegal as it is, and this will take them into the "killer" zone.

And that is just based on the first approved NSIP.

Do not forget though - that there is a second NSIP planned for the same red scribbly area!

Luton Council is in the process of ALSO preparing a Development Consent Order application for a new Terminal Two - also upon the furthest away red scribbly part - the bit closest to the NHDC border no less!!

So both Councils are hiding things from the Inspector and the Inspector will need to ask them some very probing questions, or else he is going to become a laughing stock - when the High Court asks why are there an entire two NSIPs missing from the Local Plan he's just approved!!?

CONCLUSION ON AIR POLLUTION MONITORING SITUATION:
In Part II is the work I have compiled using the 2017 Annual Air Status Report which NHDC has ignored throughout its homework. We are still waiting for ASR 2018 which is with DEFRA now.
I have taken all of my data from the ASR 2017 and listed every single monitoring site in the whole of Luton and then worked out which the ward it sits in using Luton Borough Council ward data plus ordnance survey tools such as gridreferencefinder.com. You can see my Part II of this document for the full list and addresses.
The fact is that one third of all 60 monitoring stations run by LBC are breaching, or verging illegal levels - indicating there to be a very serious air pollution problem already present in Luton.
This is not at all surprising considering the large deficit in greenspace that Luton's population already suffers as compared to that of the national average. It is this deficit which is already taking its toll and manifesting as higher than normal morbidity rates, higher than national average asthmas rates, ill-health, higher crime rates, rising psychiatric illness, lower levels of intelligence overall and rising rates of depression.
Building 2,100 houses and cramming them into an unsuitable space only degrades the situation further.
Presently this east of Luton Green Belt is the only relief which can partially salvage this dire situation - it is truly an indispensable Green Belt buffer zone for the east of Luton - which if removed would literally close off of an entire area and seal in thousands of residents - leaving them trapped like caged monkeys in a zoo - between an unwanted "Gatwick sized" Airport Expansion/ Nationally Significant Infrastructure Projects in the field directly connected/ next-door, and thousands of crappy houses rendering the air totally unbreathable and roads disgustingly crammed full day and night.
This would most obviously have hugely and devastatingly negative consequences for the health and well-being of all age-groups and is a direct act of violence and barbaric cruelty when looked at in this wider real-life context.
This is why the MM010 Policy SP2 is absolutely not acceptable and does not deserve the title "spatial distribution" at all. The Inspector should remove/ delete the allowance of 2,100 houses adjoining Luton, within the settlement boundaries of Mangrove Green and Cockernhoe full stop.

TEXT REMOVED

LUTON:
* Cockernhoe and east of Luton
* * MM221 - Page 150 paragraph 13.66 (ED144)
MM 010 32 Policy SP2 Policy SP2: Settlement Hierarchy and Spatial Distributionx
INSERTED:Between 2011 and 2031, the plan seeks to make provision for at least 15,950 new homes.
INSERTED:Approximately 80% DELETED:The majority of the District's INSERTED:housing development INSERTED:and the substantial majority of new employment, retail and other development will be located within INSERTED:the adjusted settlement boundaries of DELETED:or adjoining the following towns:
* Baldock INSERTED:(3,298 homes);
* Hitchin INSERTED:(1,679);
* Letchworth Garden City INSERTED:(2,167);
* Luton32 INSERTED:(2,100)
* Royston INSERTED:(1,797);
* Stevenage (including Great Ashby)32 INSERTED:(1,830); and
INSERTED:Approximately 11% of housing, along with supporting infrastructure and facilities will be delivered in five villages identified by this Plan for growth:
* INSERTED:Barkway (209)
* INSERTED:Codicote (367)
* INSERTED:Ickleford (210)
* INSERTED:Knebworth (736)
* INSERTED:Little Wymondley (306)
INSERTED:The remaining development will be dispersed across the District as set out below.
INSERTED:In Category A villages, DELETED:GINSERTED:general development will DELETED:also be allowed within the defined settlement boundaries of DELETED:the Category A villages of:
* Ashwell;
* DELETED:Barkway;
* Barley;
* Breachwood Green;
* Cockernhoe INSERTED:& Mangrove Green;
* DELETED:Codicote;
* Graveley;
* Hexton;
* DELETED:Ickleford;
* Kimpton;
* DELETED:Knebworth;
* DELETED:Little Wymondley;
* Lower Stondon32;
* Oaklands32;
* Offley;
* Pirton;
* Preston;
* Reed;
* Sandon;
* St Ippolyts INSERTED:& Gosmore;
* Therfield;
* Weston; and
* Whitwell.

Each Air Status Report (ASR) for Luton can be found on the Council website at:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Home * Environment and planning * Environmental health * Air pollution * Air quality
Air Quality Strategy

We continuously monitor air pollutants and regularly review and assess air quality in the town.
The government has published an air quality strategy. Outlined in the strategy are air quality objectives for the pollutants the government considers are of most concern at present
In response to the strategy, we reviewed and assessed air quality in Luton and produced the following reports available to download below:
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

2016 Air Quality Management Area (no 3) Order ( 1.3 MB )

2015 Updating and Screening Assessment (USA) ( 5.4 MB )

2015 Detailed Assessment ( 2.1 MB )

2014 Progress Report ( 4.5 MB )

2013 Progress Report ( 4.2 MB )

2012 Updating and Screening Assessment (USA) ( 2.9 MB )

2011 Progress Report ( 1.3 MB )

2010 Progress Report ( 1.3 MB )

2009 Updating and Screening Assessment (USA) ( 1 MB )

2008 Progress Report ( 432.5 kB )

2007 Progress report ( 336.2 kB )

2006 Updating and Screening Assesment (USA) ( 1.7 MB )

2005 Air Quality Management Order ( 3.7 MB )

2005 Progress Report, Local Air Quality Management ( 312.4 kB )

2004 Detailed and Further Assessment ( 5.1 MB )

2003 Air Quality Management Order ( 1.1 MB )

2003 Updating and Screening Assessment (USA) ( 2.2 MB )

2003 Review and Assessment (Stage 4) ( 2.4 MB )

Contact information

Environmental health
Luton Borough Council, Town Hall, George Street, Luton, Bedfordshire, LU1 2BQ
Tel: 01582 510330
Fax: 01582 546676
environmentalhealth@luton.gov.uk

Object

Proposed Main Modifications

MM221 - Page 150 paragraph 13.66 (ED144)

Representation ID: 7908

Received: 11/04/2019

Respondent: Amelia Curran

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

See attached representations

Full text:

ED55 13 Dec 2017 Inspector's list of actions for NHDC arising from Week 3 of the hearing sessions (Matters 15, 16, 17, 19 and 20) (PDF, 55Kb)

Documents for Air Quality Session on Tuesday 23 January 2017
ED62 12 Jan 2018 NHDC Note to Inspector on Air Quaility (PDF, 4Mb)

ED69 June 16 NHDC Air Quality Annual Statistics Report 2016 (PDF, 3,403Kb)

ED70 June 17 NHDC Air Quality Annual Statistics Report 2017 (PDF, 3,704Kb)

ED97 2015 Luton Borough Council 2015 transport modelling evidence re Luton airport (PDF, 4,874Kb)

Back in Week 3 at Matter 17 - The Inspector's List of Actions (ED55) for NHDC asked the Council to prepare an air quality note for the first week of January prior to the "reserve air quality session" and include in it information relating to monitoring data.
ED62 as it was then prepared, however we find in nothing but outright lies when dealing with east of Luton.

ED62
5.37 Appendix 5 contains the air quality monitoring data that is collected by London-Luton Airport within the boundary of its airport.

Yet if you go to "Appendix 5" it is falsely titled "2016": "Table B: 2016 Nitrogen Dioxide Data (ug/m3) from London-Luton Airport Diffusion Tubes (Annual Mean Ave. AQO = 40ug/m3)"
The air quality monitoring data contained in Appendix 5 is totally out-of-date but they have tried to lie and disguise that fact by falsely entitling it "2016 Nitrogen Dioxide Data".
It is in fact 2015 data extracted from the 2016 Annual Air Status Report. This means that all the data is from the year 2015 and NOT 2016!!! In case it needs spelling out; that is four year old data -unforgivable when so much more recent data exists.
Every year the Local Authority must produce a report on its air quality. This report is called an "Annual Air Status Report".
They are compiled once a year and must be submitted to DEFRA.
They must then be published on the local authority's website.
The reports contain the air monitoring data from the year prior. For example "Annual Air Status Report 2017" contains the air monitoring data from January 2016 up until December 2016.
In its document ED62 North Hertfordshire District Council (NHDC) has failed to use the available up-to-date data from the Annual Air Status Report 2017 produced by Luton Borough Council (LBC) found here:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Environmental%20and%20Consumer%20Services/Pollution/2017-Air-Quality-Annual-Status-Report.pdf

Had it done so, it would have revealed the truth; that the area around the Airport, which is closest to the East of Luton Strategic Housing Site and negatively affected A505 road, has air pollution already breaching legal limits.
However LBC have failed in their legal duty to take the appropriate measures and declare Air Quality Management Areas (AQMAs) around these dangerous sites and NHDC has been more than happy to accommodate them not addressing the problem.
14 monitoring sites are already breaching legal limits.

6 further monitoring sites are about to breach legal limits; being merely 1 unit away from the illegal threshold of 40.

So a total of 20 sites are breaching or verging breach.

Yet only 7 of those breaching sites have been declared as Air Quality Management Areas in Luton.

Therefore 13 breaching sites still remain at illegal levels yet the Council has failed to declare any AQMAs for these problem zones.

HOW MANY MONITORING SITES ARE THERE IN TOTAL?

THERE ARE A TOTAL OF 60 AIR POLLUTION MONITORS RUN BY LBC OR ITS AIRPORT COMPANY LONDON LUTON AIPORT COMPANY LTD.
ONE THIRD OF THE 60 MONITORING UNITS ARE ABOVE OR EXTREMELY CLOSE TO ILLEGAL LIMITS.
That's huge.
ASR 2017 (LBC) - p.p.14-21 shows the breakdown of ownership and type/ whether they are automatic or non-automatic monitors.
Automatic Monitors:
Total number of Automatic Monitors run by Council (LBC) - 2
Total number of Automatic Monitors run by Airport (LLAL) - 1
Automatic Monitors - TOTAL 3

Non-Automatic Monitors:
Total number of Non-Automatic Monitors run by Council (LBC) - 41
Total number of Non-Automatic Monitors run by Airport (LLAL) - 16
Non-Automatic Monitors - TOTAL 57

However large areas of the town are not being monitored at all. There are many huge blind spots that are cause for alarm. Such as the Hitchin Road into Luton/ A505 - at Stopsley roundabout. Nowhere in Stopsley, Round Green and High Town is being monitored.
There should be pollution monitoring distributed fairly across the entire town. If fair air pollution monitoring is not being applied then there can certainly be serious basis for claims that discrimination against certain ethnic and social groups is taking place.
There should be no reason why some areas are getting concentrated air pollution monitoring whilst others are getting absolutely none whatsoever. Or why some areas with elevated NO2 levels are declared AQMAs whereas many more that have even greater elevated levels, are not.
The closest monitoring points to the Local Plan's East of Luton Strategic Site are the Luton Airport's Air pollution monitoring system and those of LBC at Eaton Green Rd.
These are definitely breaching and have been doing so for many years and yet no AQMAs have ever been declared. So the Inspector should take the responsibility that both incompetent councils have failed to, and demand that AQMAs be declared rather than neglected, in all of the following places.
We directly refute the following fictitious statement from the Council:
ED62 - 5.36 The data from the 'worst case' monitoring locations contained within the Tables show that the air quality to the East of Luton does not breach the relevant Air Quality Objective. Therefore, because of the absence of any other potentially significant sources of nitrogen dioxide and particulate matter in the area it was judged to be unnecessary to monitor for local air pollutants elsewhere in the area east of Luton.

No need to monitor local air pollutants elsewhere in the area..."because of the absence of any other potentially significant sources of nitrogen dioxide".... What complete and utter rubbish - see the many significant sources of nitrogen dioxide and particulate matter below from the readings in the Luton ASR 2017, which NHDC has not looked at!
These sites are in fact the closest to the NHDC East of Luton Site and they are illegally breaching as you can easily see: -
SITE ID SITE NAME
IF INSIDE AQMA/ OR NOT
ORDNANCE SURVEY REF
ADDRESS AND POSTAL CODE WARD (ZONE) SOUTH/ NORTH LUTON POLLUTANTS
-MEASURED If Tube collocated with a Continuous Analyser/ or not
YEARS & OVERAL BREACH LEVEL CONCLUDED BY LBC ASR

LN23 Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF CRAWLEY (A) SOUTH NO2 Tube NOT collocated with a Continuous Analyser
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36

LA02 Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 40
2016 - 40

LA05 Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 46
2016 - 43

LA14 Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR, AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 -39
2016 - 39

LA16 Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2014 - 37
2016 - 41

The following claim is an out and out lie:
ED62 - 5.39
The data show that the annual mean average Air Quality Objective for nitrogen dioxide was not exceeded at a relevant receptor in 2016. This is the only recent data published by Luton Borough Council. The only two marginal exceedances were measured at an airside location and a kerbside location within the airport boundary and so a relevant receptor is not exposed nor is there a likelihood of exposure because of the absence of housing or an equivalent receptor within the airport boundary.

Firstly there were not "only two marginal exceedances".

Secondly "exceedances" are never marginal - but are serious, illegal and likely to only get progressively worse.

Thirdly five exceedances is a serious matter, and AQMAs must be immediately declared by law. This is not an option but an obligation.

The author/s of ED62 lie by citing the Beachwood Green monitors to be the "relevant receptor(s) in 2016" - when these are much farther away from the proposed site and far less relevant than the monitors in the affected area of east of Luton. Since the traffic and entrances to the proposed housing site are all expected to be from Luton via the Crawley Green/ Luton Roads - so the monitors there are obviously far more relevant. Yet the diagram given in ED62 doesn't show any of these east of Luton points. It has left out their existence altogether.

See below how ED62 only shows five "relevant" analysers - all in the Village of Breachwood Green:

ED62 - 5.38
The data show that the Air Quality Objectives for PM10 particulate matter have not been exceeded from the first year of monitoring (2004 first full year of data) to date.

ED62 - 5.6 Local Air Quality Monitoring Data for East of Luton
5.32 There is currently no monitoring of air quality in the area of the district identified as the East of Luton. Historically there were eight monitoring locations, of which seven were diffusion tubes and one was a site comprising two real-time analysers. The locations of the air quality monitoring points are shown in Figure 5.6.

ED62 5.32 also lies when it falsely claims there is no monitoring of air quality on the area of the district identified as the East of Luton.

Here is a map to illustrate the fact there are many monitors now collecting readings. Had NHDC looked at the ASR 2017 report they would know that.

The yellow triangle is where Breachwood Green is. This is where the Council claims is "the most relevant monitor to the East of Luton site" according to ED62. Except it clearly isn't "the most relevant" - because the black scribbly area is the actual location of EL1, EL2 and EL3 proposed housing site/ currently Green Belt. As you can see there are many other air pollution monitors - in the urban area, much closer to the development and closer to the people already living there! So why select the most remote/ Breachwood Green ones (yellow triangle)?

The red tags show the locations of all the other air pollution monitors.

Clearly Breachwood Green is in a rural location far away from any of that!

So these statements in ED62 are complete and utter rubbish; what are all of these breaches at east Luton monitoring stations shown below? - Scotch mist?!

These sites are the closest to the NHDC East of Luton Site and MANY ARE ALREADY illegally breaching as you can see: -
NO2
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36 LN23
Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF
2012 - 40
2016 - 40 LA02
Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP
2012 - 46
2016 - 43 LA05
Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2012 -39
2016 - 39 LA14
Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2014 - 37
2016 - 41 LA16
Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE

Readings from 2016 clearly show NHDC is lying and the truth is that NOx and NO2 were at dangerously illegal levels in the east of Luton at the time of ED62 being concocted. Since they are already at elevated levels before development, they are obviously projected to breach yet stratospherically further after development. Any fool can figure that out.

The red scribbly area shows where the location of the Infrastructure Project of National Significance is going to be located - something which the North Herts Plan and Inspector have both miraculously failed to mention!

It is currently a lovely green park (called wigmore Valley Park and Wildlife Conservation Area), but the Luton Council has just granted itself planning permission to put a 95 hectare development on top of the park, including two dual carriageways leading to an urban estate plus car park.

Imagine what the air pollution levels are going to become as they cut down all of the trees and smother the whole area with their beloved concrete and invite thousands more cars into the area to suck oxygen and poison every living creature.

Pollution levels are going to go through the roof. They are already illegal as it is, and this will take them into the "killer" zone.

And that is just based on the first approved NSIP.

Do not forget though - that there is a second NSIP planned for the same red scribbly area!

Luton Council is in the process of ALSO preparing a Development Consent Order application for a new Terminal Two - also upon the furthest away red scribbly part - the bit closest to the NHDC border no less!!

So both Councils are hiding things from the Inspector and the Inspector will need to ask them some very probing questions, or else he is going to become a laughing stock - when the High Court asks why are there an entire two NSIPs missing from the Local Plan he's just approved!!?

CONCLUSION ON AIR POLLUTION MONITORING SITUATION:
In Part II is the work I have compiled using the 2017 Annual Air Status Report which NHDC has ignored throughout its homework. We are still waiting for ASR 2018 which is with DEFRA now.
I have taken all of my data from the ASR 2017 and listed every single monitoring site in the whole of Luton and then worked out which the ward it sits in using Luton Borough Council ward data plus ordnance survey tools such as gridreferencefinder.com. You can see my Part II of this document for the full list and addresses.
The fact is that one third of all 60 monitoring stations run by LBC are breaching, or verging illegal levels - indicating there to be a very serious air pollution problem already present in Luton.
This is not at all surprising considering the large deficit in greenspace that Luton's population already suffers as compared to that of the national average. It is this deficit which is already taking its toll and manifesting as higher than normal morbidity rates, higher than national average asthmas rates, ill-health, higher crime rates, rising psychiatric illness, lower levels of intelligence overall and rising rates of depression.
Building 2,100 houses and cramming them into an unsuitable space only degrades the situation further.
Presently this east of Luton Green Belt is the only relief which can partially salvage this dire situation - it is truly an indispensable Green Belt buffer zone for the east of Luton - which if removed would literally close off of an entire area and seal in thousands of residents - leaving them trapped like caged monkeys in a zoo - between an unwanted "Gatwick sized" Airport Expansion/ Nationally Significant Infrastructure Projects in the field directly connected/ next-door, and thousands of crappy houses rendering the air totally unbreathable and roads disgustingly crammed full day and night.
This would most obviously have hugely and devastatingly negative consequences for the health and well-being of all age-groups and is a direct act of violence and barbaric cruelty when looked at in this wider real-life context.
This is why the MM010 Policy SP2 is absolutely not acceptable and does not deserve the title "spatial distribution" at all. The Inspector should remove/ delete the allowance of 2,100 houses adjoining Luton, within the settlement boundaries of Mangrove Green and Cockernhoe full stop.

TEXT REMOVED

LUTON:
* Cockernhoe and east of Luton
* * MM221 - Page 150 paragraph 13.66 (ED144)
MM 010 32 Policy SP2 Policy SP2: Settlement Hierarchy and Spatial Distributionx
INSERTED:Between 2011 and 2031, the plan seeks to make provision for at least 15,950 new homes.
INSERTED:Approximately 80% DELETED:The majority of the District's INSERTED:housing development INSERTED:and the substantial majority of new employment, retail and other development will be located within INSERTED:the adjusted settlement boundaries of DELETED:or adjoining the following towns:
* Baldock INSERTED:(3,298 homes);
* Hitchin INSERTED:(1,679);
* Letchworth Garden City INSERTED:(2,167);
* Luton32 INSERTED:(2,100)
* Royston INSERTED:(1,797);
* Stevenage (including Great Ashby)32 INSERTED:(1,830); and
INSERTED:Approximately 11% of housing, along with supporting infrastructure and facilities will be delivered in five villages identified by this Plan for growth:
* INSERTED:Barkway (209)
* INSERTED:Codicote (367)
* INSERTED:Ickleford (210)
* INSERTED:Knebworth (736)
* INSERTED:Little Wymondley (306)
INSERTED:The remaining development will be dispersed across the District as set out below.
INSERTED:In Category A villages, DELETED:GINSERTED:general development will DELETED:also be allowed within the defined settlement boundaries of DELETED:the Category A villages of:
* Ashwell;
* DELETED:Barkway;
* Barley;
* Breachwood Green;
* Cockernhoe INSERTED:& Mangrove Green;
* DELETED:Codicote;
* Graveley;
* Hexton;
* DELETED:Ickleford;
* Kimpton;
* DELETED:Knebworth;
* DELETED:Little Wymondley;
* Lower Stondon32;
* Oaklands32;
* Offley;
* Pirton;
* Preston;
* Reed;
* Sandon;
* St Ippolyts INSERTED:& Gosmore;
* Therfield;
* Weston; and
* Whitwell.

Each Air Status Report (ASR) for Luton can be found on the Council website at:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Home * Environment and planning * Environmental health * Air pollution * Air quality
Air Quality Strategy

We continuously monitor air pollutants and regularly review and assess air quality in the town.
The government has published an air quality strategy. Outlined in the strategy are air quality objectives for the pollutants the government considers are of most concern at present
In response to the strategy, we reviewed and assessed air quality in Luton and produced the following reports available to download below:
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

2016 Air Quality Management Area (no 3) Order ( 1.3 MB )

2015 Updating and Screening Assessment (USA) ( 5.4 MB )

2015 Detailed Assessment ( 2.1 MB )

2014 Progress Report ( 4.5 MB )

2013 Progress Report ( 4.2 MB )

2012 Updating and Screening Assessment (USA) ( 2.9 MB )

2011 Progress Report ( 1.3 MB )

2010 Progress Report ( 1.3 MB )

2009 Updating and Screening Assessment (USA) ( 1 MB )

2008 Progress Report ( 432.5 kB )

2007 Progress report ( 336.2 kB )

2006 Updating and Screening Assesment (USA) ( 1.7 MB )

2005 Air Quality Management Order ( 3.7 MB )

2005 Progress Report, Local Air Quality Management ( 312.4 kB )

2004 Detailed and Further Assessment ( 5.1 MB )

2003 Air Quality Management Order ( 1.1 MB )

2003 Updating and Screening Assessment (USA) ( 2.2 MB )

2003 Review and Assessment (Stage 4) ( 2.4 MB )

Contact information

Environmental health
Luton Borough Council, Town Hall, George Street, Luton, Bedfordshire, LU1 2BQ
Tel: 01582 510330
Fax: 01582 546676
environmentalhealth@luton.gov.uk

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