Townsend believes they have been so impressive that they should be clear of the drop zone.
However, Luton may have to rely on gifts from outside sources to stay up, such as points deductions for Nottingham Forest and Everton.
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Speaking to BBC Monday Night Club, Townsend stated: Yes, we would have taken being above the dotted line at the start of the season but I feel like we should be clear of the relegation zone.
"We shouldn't be in the conversation. Three-nil up against Bournemouth, lost four-three, two-all in the last minute against Villa, lost three-two, four-two up against Newcastle, draw four-four.
I don't know how to feel. I'm happy that we're above the relegation zone, but I'm a bit like, we could be doing so much better, we could be so much higher."