Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

I object to the proposed building of 2,100 homes on the Green Belt surrounding Cockernhoe, Mangrove Green, Tea Green and Wandon End for the following reasons. Evidence Document ED224 defends the need for the development known as “East of Luton” (EOL), based on historically calculated dwelling numbers, and is used by North Herts District Council (NHDC) in its Local Plan, however, ED224 is outdated. Luton Council has confirmed that it is currently reviewing its Local Plan so at present, there is no up to date information regarding the unmet housing need in Luton.

A painstaking review of publicly available information on Luton’s house building programme and housing requirements, made by local residents, has provided evidence that:

1. Because of significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031, compared to 8,500 as stated in the LBC Local Plan;

2. An updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;

3. These two facts mean that the unmet housing need from Luton drops to around 2,000 (16,700 - 14,700), compared to 9,300 (17,800 - 8,500) in the Luton Local Plan;

4. The Luton inspector - when giving the go-ahead for the Luton Local Plan in 2017 – stated that the ‘best fit’ for any unmet housing need was Central Beds, which has committed to provide 7,350 dwellings. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings. Hundreds of those houses are already built or under construction;

5. Had Luton carried out its Review, these figures would have come to light formally meaning that NHDC does not need to allow development at EOL;

6. All this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Bloor Homes and the Crown Estate, sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;

7. Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This is of extreme concern, but we believe our investigations have identified the accurate facts.