Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
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Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
FM 029
Representation ID: 8511
Received: 19/05/2021
Respondent: Mr David Dorman
The 8,500 quoted as the housing capacity of Luton through to 2031 is now more like 14,700 using up to date numbers. Luton's revised OAN of July 2020 shows a lower requirement of 14,700. Luton's unmet need through to 2031 is only 2,000 and not the 9,300 in the Luton Local Plan. Central Bedfordshire Council has allocated 20 sites with a capacity of 8,850 dwellings to meet Luton's unmet needs. Luton's failure to hold its required Review by mid-2021 under its Policy LLP40 would reveal this. NHDC does not need to build houses on Green Belt land at Cockernhoe.
The figure of 8,500 as Luton's house-building capacity is hopelessly outdated. Analysis of the 2019 SHLAA for house completions and projections on identified Luton sites through to 2031 show 10,903 dwellings. The Luton Planning & Development Control Committee has since then approved such a significant increase in building sites for completion prior to 2031, on sites not in the 2019 SHLAA, that the housing capacity of Luton is now 14,700. This coupled with the decrease in the Objectively Assessed Need for Luton identified by Opinion Research Services in July 2020 as now 16,700 and not the 17,800 in the Luton Local Plan means that the true unmet need from Luton is no more than 2,000 (16,700-14700). This unmet need is first of all to be directed towards Central Bedfordshire Council (CBC)as the 'best fit' and CBC has allocated 20 sites totalling 8,850 dwellings for this purpose, many now under construction. There is no unmet need required to be fulfilled by NHDC around Cockernhoe on significant Green Belt land. All this would have been revealed had Luton abided by the requirement in its Policy LLP40 to hold a Review of its Plan by mid-2021 - a Review on which work by Luton has only just started - two years late.
Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
MM 083 / FM 009
Representation ID: 8512
Received: 19/05/2021
Respondent: Mr David Dorman
Policy SP19 - Sites EL1, EL2 and EL3 - Sites East of Luton should be removed from this Local Plan as there is no unmet housing need from within Luton that will require any intervention from NHDC under the Duty to Co-operate. This is because the true and up to date unmet housing need from Luton is only 2,000 and Central Bedfordshire Council has allocated 20 sites with a capacity of 8,850 dwellings which more than meets this shortfall.
It goes without saying that references in this MM to Strategic Masterplanning of the SP19 site is also not required.
Policy SP19 - Sites EL1, EL2 and EL3 - Sites East of Luton should be removed from this Local Plan as there is no unmet housing need from within Luton that will require any intervention from NHDC under the Duty to Co-operate. This is because the true and up to date unmet housing need from Luton is only 2,000 and Central Bedfordshire Council has allocated 20 sites with a capacity of 8,850 dwellings which more than meets this shortfall.
It goes without saying that references in this MM to Strategic Masterplanning of the SP19 site is also not required.
Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
MM 035 / FM 057
Representation ID: 8513
Received: 19/05/2021
Respondent: Mr David Dorman
Delete point (a) ii as the 100 houses stated to be built within the Luton HMA are not required. These houses are part of the 2,100 dwellings earmarked for this Green Belt land solely to meet unmet needs from Luton and which are not required.
Delete point (b) entirely - these houses are not required as Luton's much smaller unmet needs will be met by Central Bedfordshire Council.
Delete point (c) - final bullet point referencing EL1, EL2 and EL3 for 2,100 homes - not needed.
Delete point (a) ii as the 100 houses stated to be built within the Luton HMA are not required. These houses are part of the 2,100 dwellings earmarked for this Green Belt land solely to meet unmet needs from Luton and which are not required.
Delete point (b) entirely - these houses are not required as Luton's much smaller unmet needs will be met by Central Bedfordshire Council.
Delete point (c) - final bullet point referencing EL1, EL2 and EL3 for 2,100 homes - not needed.
Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
MM 020 / FM 054
Representation ID: 8514
Received: 19/05/2021
Respondent: Mr David Dorman
The development 'East of Luton' (EOL) is not justified because the true unmet housing need from Luton is now no more than 2,000 through to 2031, with Central Bedfordshire Council having allocated 20 sites with the capacity for 8,850 dwellings to more than cover this reduced shortfall. With no need for NHDC to build houses at EOL solely to meet Luton's unmet needs, it follows there is also no need for an additional retail centre. In any event there is already a well-established retail centre less than half a mile away at Wigmore Shopping Centre in Luton.
The development 'East of Luton' (EOL) is not justified because the true unmet housing need from Luton is now no more than 2,000 through to 2031, with Central Bedfordshire Council having allocated 20 sites with the capacity for 8,850 dwellings to more than cover this reduced shortfall. With no need for NHDC to build houses at EOL solely to meet Luton's unmet needs, it follows there is also no need for an additional retail centre. In any event there is already a well-established retail centre less than half a mile away at Wigmore Shopping Centre in Luton.
Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
ED173
Representation ID: 8696
Received: 19/06/2021
Respondent: Mr David Dorman
See Attached - Detailed comments on Luton housebuilding profile, absence of exceptional circumstances, consideration of alternatives, sustainability appraisal and options presented by the Inspector
See Attached
Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
ED224
Representation ID: 9015
Received: 24/06/2021
Respondent: Mr David Dorman
See Attached
See Attached
Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
ED224
Representation ID: 9017
Received: 20/05/2021
Respondent: Mr David Dorman
Number of people: 2
See Attached
See Attached
Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
ED224
Representation ID: 9018
Received: 05/06/2021
Respondent: Mr David Dorman
Number of people: 2
This email is further to the joint representation and consultation binder containing Appendices from myself Mr Dorman and Mr Parker covering Examination Document ED224 - the Statement of Common Ground between NHDC, Luton Borough Council, Bloor Homes and the Crown Estate re Luton Housing Market Area which was sent on 20 May, 2021 and lodged formally by automated response on 21 May, 2021.
We now wish to lodge an Addendum to this representation which includes a letter sent by email and hard copy to Cllr. Paul Clark, NHDC's Executive Member for Planning and which contains matter very relevant to the subject. These documents are attached herewith. Any response from Cllr. Clark and our observations on that response will also be registered in due course for the Inspector's considerations.
See Attached
This email is further to the joint representation and consultation binder containing Appendices from myself Mr Dorman and Mr Parker covering Examination Document ED224 - the Statement of Common Ground between NHDC, Luton Borough Council, Bloor Homes and the Crown Estate re Luton Housing Market Area which was sent on 20 May, 2021 and lodged formally by automated response on 21 May, 2021.
We now wish to lodge an Addendum to this representation which includes a letter sent by email and hard copy to Cllr. Paul Clark, NHDC's Executive Member for Planning and which contains matter very relevant to the subject. These documents are attached herewith. Any response from Cllr. Clark and our observations on that response will also be registered in due course for the Inspector's considerations.
See Attached
Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
ED172
Representation ID: 9224
Received: 20/05/2021
Respondent: Mr David Dorman
Number of people: 2
See attached
See Attached
Object
Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031
ED172
Representation ID: 9232
Received: 24/06/2021
Respondent: Mr David Dorman
See attached
See Attached
