The second stage examination of the Luton Local Plan concluded at the end of September. The examination is a peer review with the purpose of identifying weaknesses in the plan and providing recommendations on how the plan can be modified to remedy any weakness. At the first stage Planning Inspector Mr Jeremy Yule decided Luton Borough Council had fulfilled its statutory obligation to cooperate with Central Bedfordshire Council.  Councillor Paul Castleman of Luton Borough Council and Councillor Sue Clark of Central Bedfordshire Council had signed a Statement of Common Ground (SOCG) in which Central Bedfordshire agreed to work towards meeting Luton’s unmet housing need. During the second stage the Inspector identified deficiencies in parts of the Luton Local Plan and concluded there was a significant amount of work still to be undertaken before he would approve it.

Deficiencies in the Luton Local Plan include at what locations in Central Bedfordshire Luton’s unmet housing need will be met and the impacts of meeting this on the Green Belt, the Chilterns Area of Outstanding Natural Beauty (AONB), transport infrastructure, schools, heritage assets and the natural environment across Luton and Central Bedfordshire. Luton’s unmet need is 9 300 houses and Central Bedfordshire’s need is13 200 houses.  Over the period covered by both Local Plans 31 000 houses will need to built in Luton and across Central Bedfordshire to meet the housing needs of Luton and Central Bedfordshire, and to encourage people to move to these places from elsewhere but principally from London.

During the second stage Highways England reported on the traffic impacts on the M1 and the roads feeding into it due to new housing and new employment located at Napier and Century Parks, Butterfield Green, Luton Airport and at unidentified locations across Central Bedfordshire. The impacts on the road network are increases in congestion, journey times and roadside pollution. Highways England traffic modelling identified roads including the M1 would be operating at 95% of their capacity at peak journey times. The inspector was concerned planners had not identified what changes to the road network will be necessary to mitigate these impacts and how they would be funded. For those people commuting via the M1 their journey time will lengthen as any mitigation would require Government to fund increases in M1 capacity if this were possible. Motorway capacity through Luton is currently constrained by existing housing and employment areas and will be further constrained by new housing and employment development.

The prospects of Central Bedfordshire and Luton delivering a road linking the M1 to the A6 and the A505 was discussed as this road could relieve some of the impacts of increases in traffic within Luton and Central Bedfordshire. The intention is for land North of Luton to be safeguarded for an A6 A505 link road as currently there are no plans for its delivery. Also funding for the M1 A6 link road is uncertain due to changes in the priorities of the South East England Local Enterprise Partnership (SEMLEP) because of the emergence of the National Infrastructure Commission’s (NIC) proposal for an Oxford – Milton Keynes – Cambridge ‘Growth Corridor’. The potential loss of a proportion of the M1 A6 link road funding due to the UK leaving the European Union is another cause of uncertainty. The ‘Growth Corridor’ could result in the expansion of Milton Keynes into the Marston Vale in North Central Bedfordshire, and proposes the widening of the A421 between Milton Keynes and Bedford, and the upgrading of the West-East railway in the Marston Vale and its extension through to Sandy and on to Cambridge.  The Marston Vale includes Councillor Sue Clark’s Ward of Cranfield & Marston Moretaine.

Historic England made it clear the impacts of the M1 A6 link road’s route together with new housing and employment development could not be mitigated as they affect nationally significant heritage assets at Drays Ditches, Stopsley Common and St Mary’s Church Lower Sundon. Natural England expressed its concern about the potential impact of large scale housing development abutting the Sundon Quarry Site of Special Scientific Interest (SSI). Although the Chiltern’s Conservation Board did not attend the examination it made a written representation criticising the impact of new housing and the M1 A6 link road on the Chilterns AONB. Questions raised during the examination about projections of Luton’s population growth revealed a shortfall in early years’ school places within the next few years that will worsen over the duration of the Luton Local Plan. Luton planners had failed to identify this potential shortfall and put in place plans to provide enough school places.

The outcome of the second stage is the Inspector’s recommendation that Luton and Central Bedfordshire Councils work together to produce a deliverable Growth Options Study (GOS) to be ready for examination during the first week of December and prior to consultation on Central Bedfordshire’s draft Local Plan at the end of December. Additionally if the Luton Local Plan is approved an early review of the plan, within a few years from its start, should take place to ensure the plan is delivering its objectives. The growth options strategy arising from the GOS will define areas of growth across Central Bedfordshire and set out the scale and nature of new development within these areas. During the examination Luton Borough Council indicated areas in Central Bedfordshire where it would like to see its unmet housing need located. Two of these areas are North Luton encompassing the Green Belt parishes of Chalton, Sundon and Streatley, and West of Luton in the Green Belt parish of Caddington & Slip End. Government Policy provides for a high level of protection to the Green Belt as building on it will only be permitted in exceptional circumstances. The Secretary of State Department of Communities and Local Government (DCLG) Sajid Javed MP has recently said the Green Belt is ‘sacrosanct’. This policy protection and political support for the Green Belt would have to be blatantly ignored by Central Bedfordshire Council if new development were to go ahead in the Central Bedfordshire Green Belt because meeting unmet sustainable housing need is not an exceptional reason for building on the Green Belt.

Recently Luton Borough Council legally challenged Central Bedfordshire Council on the grounds that it had approved development on its Green Belt North of Houghton Regis. However this legal challenge was probably disingenuous as the quid pro quo for Central Bedfordshire Council’s support for the Luton Local Plan is likely to be no further legal challenges to plans to build on the Green Belt North and West of Luton. Nevertheless the Luton Green Belt remains intact because Luton Borough Council has chosen not to ignore Government Green Belt policy and build on its Green Belt to meet its housing need.