Stage 1 of the Examination of Luton’s Local Plan starts a 10am on Tuesday the 19th July at the UK Carnival Centre in St Mary’s Road LU1 3JA

Here is a letter to the Planning Inspector who is conducting the Examination. It contains comments on Luton’s Local Plan.

Dear Mr Jeremy Youle

Stage 1 Examination Duty to Cooperate Sundon Parish Council Representation

The stated object of Stage 1 examination is Duty to Cooperate, in particular cooperation on housing, economy, transport, green belt and infrastructure. Sundon Parish Council is disappointed it has been unable to properly consider Duty to Cooperate as documents DTC 001b and DTC 001d cited in the Council’s answers to questions set out in their document ED003 are currently unavailable to the public on the Council’s website.

On cooperation on housing; clearly some discussions have taken place between the Council and Central Bedfordshire Council. However the outcomes of these discussions, if there are any, do not appear to have influenced the content of the Council’s Local Plan or Central Bedfordshire Council’s emerging Local Plan. Also within the Council’s Local Plan there is no obvious consideration of options that could increase Luton’s capacity for housing, such as regenerating its existing poor quality and overcrowded housing, using more ‘brownfield’ for housing rather than employment,or building upwards instead of outwards.

On cooperation on the economy; the Council’s Local Plan refers to Central Bedfordshire Council’s Sundon Rail Freight Interchange (RFI) as potential means of assisting the Council achieving its employment needs. However the map in Appendix 1 calls into question whether there will ever be a Sundon RFI as the map shows the RFI site ALP142 as Residential or Mixed Residential use.

On cooperation on the Green Belt; in ED003 the Council states the joint Green Belt study commissioned by it and Central Bedfordshire Council ‘in so far as it affects Luton is due for completion in the week beginning 1st August 2016’. Clearly Luton’s capacity to meet all of its housing need with the cooperation of Central Bedfordshire is still under consideration. Without knowing the outcome of this study an objective judgement cannot be made about whether the Council has effectively cooperated with Central Bedfordshire Council.

The impact of meeting any of Luton’s unmet housing need in Sundon Parish, if this were necessary, is profound as the Parish is within the Green Belt and the Chilterns Area of Outstanding Natural Beauty. The Parish Council is heartened by the statements of politicians regarding Green Belts, the protection given to Green Belts and AONB’s in the National Planning Policy Framework (NPPF) and Green Belt planning case law. The Parish Council appreciates the purposes of the Green Belt are to check the unrestricted sprawl of large built up areas, to assist in safeguarding the countryside from encroachment and to assist urban regeneration.

The Parish Council cites three letters from Brandon Lewis MP; Appendix 2 Appendix 3 Appendix 4 that support these protections.  According to these letters housing need alone is not a reason for building on Green Belt. In particular the letter in Appendix 2 supports the choice of a Council not to meet all of the housing need identified in a Strategic Housing Market Assessment (SHMA) due to Green Belt policy constraints. Also there is no apparent exceptional circumstance, i.e. no cooperation on infrastructure, for changing Green Belt boundaries, in either the Council’s Local Plan or Central Bedfordshire Council’s emerging Local Plan or in answers to questions you have put to the Council.

As it currently stands the Council’s Local Plan is incomplete because the Council does not have a 5 year land supply to underpin the delivery of its housing need.  Currently Central Bedfordshire Council does not have a 5 year land supply either; see the planning inspector’s judgement in Appendix 5. Also in this judgement comment is made on the deliverability of Local Plans containing Green Belt in its land supply.

As land around Luton is Green Belt it is very unlikely Central Bedfordshire Council will be able to deliver Luton’s unmet housing need, if it chooses to do so, without facing significant challenges. As any Local Plan involving building on Green Belt against Government policy intent increases the likelihood of legal challenges against it, increases the time it takes to deliver the plan, and therefore significantly impedes progress towards achieving the Government’s target of building 250 000 houses a year.

Finally it is obvious to Sundon Parish Council that Councils’ Duty to Cooperate has not yet concluded as Councils’ Local Plans are devoid of the outcomes of their cooperation. The Parish Council therefore concludes the examination of the Local Plan at this time is premature.

Yours sincerely

Michael Stonnell

Chair of Sundon Parish Council