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

In addition to myriad excellent points of objection already raised by ourselves and fellow residents of east Luton and its neighbouring North Hertfordshire villages at various stages of the consultation process, we are now objecting to this development on the grounds that it is unnecessary. Evidence Document 224 (hereafter ED224) defends the need for this development on the basis of proposed dwelling numbers historically calculated by Luton. However, research by the EOL Objectors group demonstrates that the information in ED224 is now obsolete.

NHDC included the EOL development in its Local Plan based on out-of-date information concerning Luton’s unmet housing needs.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. This included 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, have not been formally updated.

However, the EOL group's research, fully supported by evidence, demonstrates the following facts:
• Due to 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. These are all on brownfield sites;
• 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 Bedfordshire - the most important neighbouring local authority to Luton - was not a party to this Statement. We wonder whether NHDC has done so in order to proceed with building a significant proportion of its Local Plan housing quota on the District's very fringes, relying on Luton's services whilst protecting towns and villages within the rest of the county?

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. Indeed, given the information set out above, we are dismayed that a public authority appears to be stubbornly persisting with destructive development on the green belt in the face of a drastic change of circumstances, and when alternative, more appropriate sites in Central Bedfordshire have already been identified. Again, we question the motivations behind the District Council's intransigence.

For the reasons set out above, Martyn, Tareena and I object in the strongest terms to the proposed EOL development. Further, formal research into the unmet housing need figures in ED224 must be undertaken by NHDC, to shed light on whether the figures upon which it is justifying the EOL development are accurate. If, as we suspect, they are not, the Inspector and the Council must think seriously about whether there is any longer a need for the proposed EOL development. Where NHDC is not willing to undertake this research, it must not proceed with the development until Luton's Policy LLP40 review is complete and accurate figures are available.