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

I am writing to you as I believe that the final consultation has commenced on the North Herts District Council Local Plan, and I am very concerned about the suggestion that 2,100 home are required (according to Luton Borough Council) to be built on the green belt area, which is predominantly Crown Property bordering Luton and Cockernhoe, and taking in the area around Mangrove Green, Tea Green and Wandon End.
I live on the corner property within the Luton town boundary, next to where there is a planned roundabout on Luton Road designated to be the only residential access point on to the estate to the north of this area, and beside two planned soak-aways.
There are several concerns that I have regarding these plans. Firstly, I do not believe that sufficient regard has been given to the drainage for this estate – there have been numerous flooding incidents in the past six months, when that field was not cultivated, and water built up in the natural bowl at the bottom of the hill, and causing flooding to the road, and bridlepath (on both sides). This is before any concrete has been laid. The flooding was only resolved once the field was again cultivated, after I brought this matter to the attention of LBC.
My next point of concern is the amount of traffic that would be using this roundabout, and the fact that Luton Road/Crawley Green Road already has plenty of traffic, particularly through rush hours and on school days. There is also no consideration been given to the increase in the amount of traffic which will head both out and in on the country lanes behind Cockernhoe and Tea Green in order to access the A505 and Whitwell through Lilley Bottom Road.

Finally, the whole reasoning behind this development in the first place has now been thrown into doubt on two counts - that the LBC Local Plan figures used to argue the case were outdated almost from the start, as the facts below demonstrate:
• 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 but I believe these investigations have identified the accurate facts.
In addition, since the pandemic it is quite obvious that LBC needs to re-assess much of the current office space in the town, as working practices are likely to be very different post pandemic, and many office buildings will be superfluous, and will need to be re-designated and redeveloped into residential properties.

I trust that you can understand my concerns and feel my annoyance that this planning application is still being considered after almost seven years of consultations, when many residents, like myself have argued against this reckless desire to build on wonderful green belt countryside, which has been a haven for many during the course of the pandemic.