99 Manton Drive Luton LU2 7DL 01582 724257 info@wastebook.

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TO BLOOR HOMES cc North Herts District Council Luton BC 21 Jun 2013 We object to this proposal. a) Need v Demand 7000 people objected to the inclusion in the Core Strategy of using this area for urban expansion. Many said that it would set a dangerous precedent, allowing more applications to follow, based not on need but on developers ambitions and here we are again. The applicant has not justified need, only demand. The driving purpose of developers is to build houses and supporting infrastructure to make money. They have little interest in need or social factors, apart from doing minimum to satisfy planning requirements. Luton is seriously overdeveloped & already suffering considerable social, economic and environmental problems, including rapidly diminishing green space for biodiversity and recreation, leading to poor quality of life, so the town should be considered full, and only a tiny amount of truly essential housing should be provided for those in temporary accommodation or those already within the town. There is considerable demand for cheap accommodation, but this should not be met. Tacked on to Lutons eastern boundary, this development to accommodate 2000 adults plus their children is a blatant addition to Lutons population burden. While we do not accept the need for any homes on this site, we think Bloor should commit on any local development to a higher proportion than 40% of affordable homes. Vauxhall and other employers have gone, and more brownfield sites have appeared in Luton. Parts of these should become public green spaces to begin to replace the towns deficit in green spaces, but other parts could help Luton with its housing requirements, and should take priority. Given the 4000 homes proposed in 2010 by Bloor and a consortium of other landowners, there is no guarantee that another scheme nearby will not be proposed soon which would make the likely damage from this scheme far worse.

b) Coalescence The development would cause the coalescence of the communities of Cockernhoe, Tea Green, Mangrove Green and Wandon End. This would destroy the individuality of these hamlets, and have a serious effect on the picturesque landscape of Lilley Bottom, which affords unobstructed views in all directions. Claims of enhancements to landscape could by no means counter the damage to landscape that would be done. Some families in these villages have lived there for generations, and helped to manage and protect the relationship between their communities, their countryside and heritage. This balance could be quickly swept away by the development proposed. Buffers between development and existing communities are inadequate. The fields that would be covered over are so close to Lutons border as to effectively be an urban extension, altering Lutons border. Such plans are against national Green Belt policy. It would create a national precedent which cannot be allowed, or it would open the way to a flood of further development on a wide area which has a distinct rural character.

The overwhelming majority of comments in 2010 referred to the need to preserve the integrity of these villages and countryside as an amenity for residents of Luton and N Herts.

c) Access to countryside Luton benefits hugely from the Green Belt surrounding it. The area to the east is probably the most important landscape, which many value highly for walking and cycling. Green Belt policy allows people living in Luton to access, close by, both clean air, and outstanding, beautiful countryside offering diverse amenity and recreational uses. The development proposed would not be a destination except for friends and relatives, so it would, for many, remove forever 67 acres of their nearest countryside, with its different character from the built-up area within Lutons boundaries. The entire development would appear to be within Green Belt. 1000 dwellings constitutes large scale development, generally forbidden under national Green Belt policy except under exceptional circumstances. Any development on Green Belt must benefit existing communities. This plan would push the Green Belt further away from Luton, causing immense and unacceptable damage. The claim of environmental sustainability is farcical.

d) Traffic Todays normal family with two working adults may be able to manage with one, but often demands, two cars. So this development would generate 2000 more vehicles using narrow lanes, plus many extra journeys by visitors. Some social infrastructure is proposed (one or two shops and a primary school which would bring the noise of shouting children to quiet homes but no medical facilities) so very little local employment would take place. Virtually all residents would be made reliant on car journeys to Luton or Hitchin, a major traffic generator. A new relief road is proposed from Chalk HillI to Luton road; and Lower Road and Darley Rd would be realigned. This would provide only a small degree of local relief. The development would increase congestion at Asda at Wigmore. Those entering both Luton and Hitchin on the A505 already experience serious hold-ups. A small addition to traffic levels could make this much worse, and the increase from this development would be substantial. Lutons peak hour traffic is already over-capacity. Stopsley and Wigmore already suffer from serious congestion on their key roads: it is hard already to reach Luton town centre, the station, airport, and the M1. The new development would add unacceptably large increases in traffic. A key policy of the East of England Plan was to reduce the need to travel. Many people in this Hertfordshire estate would wish to go to Hitchin, perhaps more than to Luton. The road at the north of this development, the nearest point to Hitchin and the A505, is Chalk Hill. This is single track with passing places, to which Bloor offers no alternative except extra passing places. The road through Tea Green is also unsuitable for the traffic that would be generated. This alone is a reason why the proposed development is unsustainable and unacceptable. Country lanes serving the above villages threatened by coalescence, and others such as Breachwood Green, Whitwell, Preston, Great Offley, Kimpton and Codicote would become rat runs. Increasing internet use means deliveries are made by vans and trucks to peoples homes. This would be hard from the Hitchin direction. Traffic from this development would bring greater congestion, noise and air pollution. This development would cause car reliance, adding to climate emissions, against national and regional policy, which under the Climate Act requires these to be reduced year on year. e) Quality of countryside and biodiversity This countryside, with several substantial areas of woodland, hedgerows, and fields, is rich in biodiversity. Landscape enhancement could not mitigate the damage this development would cause: it would cut across established wildlife corridors; levels of traffic and intrusion would

increase roadkill and reduce the viability of species of flora and fauna in the area. This would go against the Biodiversity Action Plan. To build on these fields would end long-held farming tenancies and affect livelihoods and food provision. The agricultural land in this area is of good quality, and should not be lost, given the need to feed increasing populations (which should be more widely and thinly distributed as small, sustainable extensions to existing communities). Improvements to existing woodland and new woodland planting incorporating woodland walks. This after green corridors to and from woods in and around the development area have been cut off and woods isolated into a biodiversity island, reducing their viability for flora and fauna. It is hard to see how biodiversity would be enhanced in Brick Kiln Wood by making it into an island surrounded by housing. Three options all show large areas of tree cover, but the masterplan just shows pale green, when woods are shown in dark green. There is an opportunity to create wildflower meadows. This is a chalky area in a dry part of the UK, so water supplies and drainage are serious concerns.

f) Buildings would not be energy neutral Bloor and other developers are unwilling to comply with government targets for designing new homes to be energy neutral by 2016. (This only need cost 5% extra per home, to provide sustainable energy use for future generations, the aim of the Climate Act.) Until they are, new homes designed to waste energy unnecessarily should not be permitted. For instance, solar PV and thermal roof panels should be standard, and community wind should be considered. It is hard enough for authorities to retrofit all the existing homes with insulation and renewables, without new homes making energy consumption and emissions worse.

We have signed the petition to North Herts Council at http://epetition.north-herts.public-i.tv/epetition_core/

Yours sincerely David Oakley-Hill and Julie Furnivall Luton Friends of the Earth