LA1 is proposed on Green Belt Land described as 'North Baldock Chalk Uplands' charactized by its remote and open landscape.

"The reference to areas of remoteness is fully supported. The feeling of tranquillity is also a perceptual aspect of the landscape that should be protected wherever possible. Tranquillity provides relief from urban areas and benefits health and wellbeing, protecting any pockets of tranquillity is especially important in close proximity to highly developed areas." (comment letter from Paul Donovan HCC Spatial Planning and the Economy Environment Department 3 Feb 15)

In 1902 Ebenezer Howard wrote in Garden Cities of Tomorrow: "Shall it build on the zone of agricultural land which is around it and thus forever destroy its right to be called a 'Garden City'? Surely not." LG1 as farmland is of vital importance in maintaining the green belt design of the world's first garden city. To erode this beyond the natural skyline boundary of the existing built up area would be a critical loss to Letchworth's integrity and therefore no developer could possibly satisfy Policy SP15 condition a,i "How the site will follow and implement Garden City principles", Replacing green belt by some new areas near Luton airport is no mitigation.

It is also difficult to imagine how any development at a density of c.35 dwellings per Ha can possibly "implement Garden City principles" in any case.

This high density housing at LA1 will be especially deliterious to views from afar, eg from North Road between Radwell and Baldock and from the water tower at the junction of the A1 and the Langford Road where Letchworth is currently out of view in its own valley. It will become highly visible, and be a ruinous encroachment on the rural aspect of Letchworth from the North and especially to Radwell and its Wildlife area.

NPPF and Government statements
The Planning Minister in March 2014 reaffirmed NPPF priorities saying "Unmet housing need is unlikely to outweigh harm to the green belt and other harm to constitute the very special circumstances justifying inappropriate development on a site within the Green Belt"

NPPF requires Councils to protect the green belt when preparing their Plans. Para 14 states that the extent to which assessed housing needs are met should reflect constraints such as Green Belt. Guidance 1 re-confirms this.

NPPF says "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belt are their openness and their permanence."

"The River Ivel catchment is a fast responding catchment meaning it is vulnerable to flash flooding following a significant rainfall event." (Central Beds report CB/FLO/15/09003)

Currently (and for the last 60 years since my family have lived here) Radwell has NOT suffered from flooding, but in wet winters it does come close to it.

The proposed developments in Letchworth plan to add c. 900 new homes, all of which are in the River Ivel catchment. This infers the development is likely to significantly affect Radwell and Stotfold through increased water flows both from runoff and sewage treatment outfall.

Apparently no Surface Water Management Plan (SWMP) study has been conducted despite the fact that Flooding regularly occurs in Stotfold. This happened as recently as July 2015 and again in June 2016 when extreme rain events in Letchworth (c. 25mm in 90 minutes) overwhelmed Pix Brook and flooded houses in Stotfold.

River flow at Radwell Mill has been measured to vary between 3.5 and 16 Megalitres(Ml)/day (oct 2015 - oct 2016, Affinity Water study).

Treated water:
In the absence of any alternative proposals, it is reasonable to assume the treated water from the development will be pumped over the hill to Letchworth sewage plant thereby exacerbating the existing flooding issues with Pix Brook in Stotfold.

Runoff:
"Developing a green field site may result in 10 times the runoff during extreme rainfall" (Woods-Ballard et al 2007). The policy mentions "Incorporate ordinary watercourses (and any appropriate measures) within comprehensive green infrastructure and / or SUDs approach" In this development the fall of the land is towards the Ivel at Radwell where we already have flooding issues from the land between the Norton Road and the Grange Estate. (The land drains were relaid in 2013 which resulted in the Norton Road being flooded and the ditch on the Radwell side of the Norton Road overflowing.) It is therefore easy to envisage that a development of this size is highly likely to lead to flooding in Radwell and other settlements (eg Stotfold) downstream.

25mm (c. 1 inch) of rainfall over 40 Ha is 10 Ml of water. The 5% runoff expected from the green field site would be 0.5 Ml, the runoff from the same area as residential development could be expected to be between 30% (3 Ml) and 60% (6Ml) representing a potential increase of between 2.5 Ml and 5.5 Ml of runoff in a single event. Besides increasing the flow in the Ivel by between 30% and 80% the existing ditches into the Ivel cannot possibly be expected to cope with this sort of increase in flow so flooding is to be expected.

Pollution:
Radwell lake is already deemed an area of "Wildlife and Nature policy 14" and we work hard to keep it nice. The massively increased runoff is likely to increase temperatures in our river, harming fish and other organisms; A sudden burst of runoff from a rainstorm can cause a fish-killing shock of hot water. Salt used to melt ice and snow on pavements and roads in the new developments will further contaminate our river.

Oil and other hard-to-monitor pollutants will get into our river from the newly developed areas. This already happened when the SuDS ponds associated with runoff from the A1(M) built in 1966 silted up after only 25 years of service and we began to see an occasional oil film (on one occasion a large quantity of it) polluting our river. Eventually the ponds were dredged at considerable expense because the silt was classified as hazardous waste.