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Form ID: 3259

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In addition some concerns are raised with regard to the sustainability of the option which involves providing housing growth along the A421. It is considered that this would promote reliance on the private car and will result in development that fails to meet national and local objectives to reduce climate change and improve air quality. Luton Council considers that housing and employment delivery options that can be directly served by the rail network should be given significant priority.

Form ID: 3260

Luton Council welcomes the opportunity to comment on the above consultation document. These comments are based only upon the documents which are available to review online which include the consultation document, sustainability appraisal scoping report, HELAA and site selection methodology. The main comments are in relation to housing need and the figures identified within the consultation paper. It is noted that a flexible approach has been adopted (given potential changes in Government legislation) within the consultation paper identifying housing requirement numbers of 800-1,305 dwelling per annum across the plan period. The minimum housing requirement is based upon the Government’s current standard method for assessing local housing need, which is currently under consultation to change. The Governments revised standard method currently out to consultation could potentially result in a figure within the range of the figures stated within the paper at 1,153 dwellings per annum. If the Bedford Local Plan does not meet its own housing need, Luton given its own constraints, will not be able to help to meet Bedford’s housing needs. The revised Local Plan will need to ensure that it is able to meet Bedford’s minimum annual housing requirement in accordance with Government guidance for the plan period.

Form ID: 3261

In terms of employment provision, comments are based only on the information currently available which does not include the Employment Land Study/Employment topic paper which is in the process of being drafted. It is noted that further employment sites are proposed as an option within the consultation paper but specific figures of requirements are not provided. This is positive, Luton would be unable to provide additional employment land to support the needs of other Boroughs. It is also evident that there are significant opportunities with the East-West rail link to provide well connected employment areas which will make a positive contribution to the local and regional economy.

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