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

I object to the North Herts District Council (NHDC) Local Plan of the proposed buildings on the GREENBELT, the proposal has been based on out of date evidence in document ED224.

ED224, defends the need for the development, known as “East of Luton” (EOL), but that has been based on HISTORICAL calculations.

The NHDC has included the EOL development in its Local Plan, but this is based on out-of-date information concerning Luton’s unmet housing needs.

Luton’s Local Plan was adopted in 2017 including a Policy LLP40 to Review its Local Plan commencing in 2019 and completing by mid-2021.

Luton has confirmed, this March, that the Review is at an early stage and it has no exact date when it will be finished. This is at least two years LATE. This failure to carry out the Review in due time means that the number of houses 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 the need for the houses at EOL.

A review has been carried out using publically available information on Luton’s house building programme and housing requirements. This concludes, with fully supported evidence, that:

· 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 stated in the LBC Local Plan;

· 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;

· these two facts 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;

· 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 help. Hundreds of those houses are already built or under construction;

· 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;

· all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, 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;

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 as investigations have identified the accurate facts.

In summary the proposal to build on the greenbelt is based on out of date numbers. Greenbelt's can only be built on if there is a proven need for the housing which in this case there isn't.

The council carried out an independent review of the greenbelts in Luton (the greenbelt study) in 2014 that came to the conclusion "that the existing greenbelt areas in luton make substantial contributions to meeting greenbelt contributions as defined by the NPPF.

They are important areas of open land which should permanently remain free of inappropriate development so that they continue to function as greenbelt."