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

We have previously submitted objections to the proposed East of Luton (EOL) plan and object to the latest documents, in particular ED224.
ED224 defends the need for the EOL development, which is proposed to satisfy a large proportion of Luton’s unmet housing needs, and is based on historically calculated dwelling numbers by Luton Borough Council (LBC) as explained below.
The fundamental issue is that North Herts District Council (NHDC) has included the EOL development in its Local Plan based on out-of-date information concerning Luton’s unmet housing needs. Luton’s Local Plan was adopted in 2017 and included Policy LLP40 to Review its Local Plan commencing in 2019 and completing by mid-2021.
We understand that LBC confirmed in March 2021 that the Review is at an early stage and it has no exact date when it will be finished. Thus, allowing for the same timescale, the Review will take another two years. This failure to carry out the Review in a timely manner means that the number of dwellings required and being built in Luton, and the resulting unmet need in the town, has not been formally updated, thus giving NHDC an excuse to continue to justify, unreasonably in our opinion, the need for the EOL development.
We believe that other campaigners* (referenced below) against the EOL development have carried out a detailed review of publicly available information on Luton’s house building programme and housing requirements. Our summary objections* are that that:
1. Due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 dwellings through to 2031, compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
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. Points (1) and (2) above mean 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 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 from which to provide that support. Hundreds of those dwellings are already built or under construction;
5. Had LBC carried out its Review as expected, these figures would have come to light formally meaning that NHDC may not need the 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 LBC, Bloor Homes and the Crown Estate, adhering 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. No doubt Covid will be blamed but that is not an excuse to make poor decisions. Any decision on EOL should be delayed until a thorough review of housing need has been carried out and all interested parties including Central Beds, signed up.
This is of extreme concern as a lack of diligence by LBC and NHDC could mean the potential loss of important Green Belt to development, and as we have stated in our previous objections, bringing wholesale destruction of Green Belt along the Beds/Herts boundary as far as Luton Airport, and pulling even more inhabitants within the noisy, contaminated airspace around the airport.

The Luton Local Plan LP6 suggests that homes of 3+ bedrooms should constitute 69.6% of all new dwellings and should constitute 49% of Affordable homes. ED224 states that even if EOL were to proceed in its current form there is still a huge shortfall in the provision of 3+ bedroom houses - so where are they going to come from?.

It is also notable that in document :
” Matter 10 Hearing Statement: Housing Allocations and the Settlement Boundaries: The Towns: Luton (Cockernhoe)
North Hertfordshire Local Plan Examination
On behalf of Bloor Homes
January 2018 Ref: 2012.002” there is no mention of the mix of the dwellings, only their total number.

ED224 tries to justify the lack of affordable housing built in Luton on the basis that brownfield developments would otherwise be non-viable (or were Permitted Development). This is unacceptable. LBC are the Planning Authority and could have imposed more affordable housing and more 3+ bedrooms if they really wanted. The truth is they consider greenfield sites to be cheaper and hence more attractive to developers such as Bloor. Even so, the current EOL plans do not appear to come close to achieving the ‘split’ that LP6 actually recommends, so how can this be said to fulfil unmet needs?.

*We refer to, and endorse wholeheartedly the detailed response to ED224 provided by David Dorman and Roy Parker dated 21st May 2021.