MM304 - Page 184 Policy LG10 (ED146B)

Objection is made to this modification. In our representations on the pre-submission plan, Sport England specifically supported the requirement in this allocation for the loss of outdoor sports facilities to be justified and re-provision or contributions towards improvements to existing provision. The requirement was included in the policy following representations made by Sport England earlier in the local plan process. The approach in the policy was considered to broadly accord with Government planning policy on playing fields set out in paragraph 97 of the NPPF (paragraph 74 in the 2012 NPPF).

It should be emphasised that Sport England is not objecting to the principle of the residential allocation or seeking to protect the site from being developed in order to meet current or future community playing field needs. What is being sought is for the policy to require proportionate and appropriate mitigation for the permanent loss of the opportunity to meet current/future community playing pitch needs. The potential role that closed school playing fields can play in meeting playing pitch needs in general terms is set out on page 20 of the Council's Playing Pitch Strategy & Action Plan (December 2018) https://www.north-herts.gov.uk/home/planning/planning-policy/planning-strategies/sports-strategies which has been adopted by the Council and published since the local plan examination hearings. When the Council's strategy and action plan was being prepared in 2015/16, Sport England and the sports governing bodies (that represent grassroots community sport) did not seek the specific protection of this site for meeting the playing pitch deficiencies in the Letchworth area. This was partly because the site was proposed to be allocated for residential in the emerging local plan (and Sport England did not want to unnecessarily frustrate the Council from meeting its housing needs) and partly because there were alternative solutions for addressing the deficiencies in football, rugby and cricket pitch provision as set out in the action plan e.g. additional 3G artificial grass pitches and improvements to the quality of existing grass pitches . However, all of these alternatives will require significant funding to be realised. The pragmatic approach taken by Sport England and the sports governing bodies through the preparation of the strategy and action plan was that the allocation of this site would not be resisted if mitigation could be made in the form of financial contributions being secure towards the delivery of the alternative solutions identified in the action plan. The proposed modification would remove this requirement and the delivery of the solutions would then be more dependent on the community (including NHDC and clubs in the voluntary sector) finding the resources.

As accepted by the Council in Examination Document ED146B which explains the rationale for the modification, there are current and/or future deficiencies in football, cricket and rugby pitch provision in Letchworth so the site is not considered to be surplus to requirements in relation to paragraph 97 of the NPPF (paragraph 74 in the 2012 NPPF). While the strategy has not identified a requirement to bring the site back into use at present, this is because the alternatives are being focused on instead. However, there is no certainty that these alternative solutions will be delivered and developer contributions are expected to play a significant role in their delivery. If there was no requirement for this allocation (and others) to make re-provision in the form of contributions, then it is considered more likely that there would be a need to bring such sites back into use for meeting pitch needs when the strategy and action plan is next reviewed. In relation to new playing pitch provision provided on major new residential allocations (as set out in the Council's case in ED146B), there is no certainty that the playing fields proposed within these developments will be suitable for meeting the identified needs or will be delivered in a suitable timescale to meet such needs. Furthermore, it would be inappropriate in terms of planning policy to seek to use new playing pitches that are provided to meet the needs of new developments for addressing the current needs of existing communities.

Sport England understands the Inspector's concern that the site should not be allocated for residential if the requirement remains in the policy to justify the loss of the outdoor sports facilities as this offers uncertainty in terms of delivery and the site cannot be both protected for outdoor sport and allocated for development. Sport England would also not expect the former playing fields to be re-provided on an equivalent/better basis because the playing pitch strategy has identified alternative solutions for addressing needs. The proposal for addressing our concerns would therefore be for the policy to be modified along the following lines:

* Justification for the loss of outdoor sports facilities. Re-provision or contributions towards improvements to existing provision where appropriate. Appropriate contributions should be made towards improvements to existing outdoor sports facility provision;

This would address the issue of the loss of outdoor sports facilities having to be justified to allow the development to be delivered and would not require re-provision of the site which would be more onerous for the developer to deliver in view of the absence of suitable sites in the area. However, it would address the need for playing field mitigation which could be directed through developer contributions being used towards the delivery of priority projects which would address current and future playing pitch needs which in turn would justify the site not being retained for meeting these needs. It would also allow the policy to remain consistent with the NPPF because if the alternative solutions for addressing needs were delivered partly through the developer contributions then the site would be genuinely surplus to requirements in terms of meeting playing pitch needs.

I recently *starred* in The Comet with the difficulties crossing the road from Croft Lane onto Norton Road enroute to Norton St Nicholas School.

I do hope that me and my 3 small children are not going to be 'the KSI statistic' that sees the suitable crossing facilities in place.

Croft lane itself is just as dangerous as it has no footpath and is a narrow country lane. This is usually pretty safely negotiated though as it's a quiet road.

However, I have concerns about the LG10 consultation document which shows 42 dwellings (mostly 4 and 5 bed houses) being accessed from Croft Lane. I feel strongly that this access should be re-negotiated with the safety of all pedestrians in mind. This includes the regular dog walkers who use this route.

I took a picture of a vehicle that parked up to take pictures of the access gate last week. Ironic that this vehicle could not safely park to allow vehicles to pass, without having to mount the kerb.

How would one envisage large vehicles negotiating this road?

See Attached

We strongly object to the decision to include LG10 Former Norton School Playing Field (Croft Lane) (MM304) in the local plan and the modifications regarding it not being required for recreational usage.

● In the Local Plan modification report it was indicated that LG10's previous usage as a playing field was no longer required as there were other available sites in the town. However the detail of these additional sites was not specified in the modifications. We would like to be informed of these additional sites, as if they require residents to drive to them from Norton area this goes against the vision to reduce traffic across the town.
● Sport England have objected to LG10 as there is no up to date assessment of the playing field requirements in North Herts, so therefore it cannot be stated that there are a surplus. The development of LG10 could fulfil a necessary community need and the loss of this site would be contrary to Sport England playing field property and government planning policy - para 74 of NPFF.
● The village of Norton and surround is already set to lose a significant chunk of the beautiful Greenway, so the removal of the green space on LG10 is concerning. The attached aerial shot shows just how hemmed in the beautiful conservation area around Croft Lane is going to be, once all this proposed building takes place.
● We'd like to remind the decision makers at HCC that Letchworth Garden City was designed around the concept of green space, sustainable living and an alternative to the cramped conditions of London.
● Office of National Statistics has downgraded its forecast for new homes from 300k to 159k between now and 2040. And a local need reduction from 13k to 9k. When other councils are already reforecasting based on the ONS figures, why has the North Herts plan remained unchanged?
● Related to the above point, HCC have increased the amount of houses proposed on LG10 from the local plan amount of 37. We have no idea how many houses will end up on LG10 if it gets swept in at outline planning. We could very well be in a situation whereby we have a surplus of housing if the developments go ahead and the need has reduced. We damage our conservation area beyond repair and we lose much needed community space.
● Norton Road is very congested already so the proposals for LG4 and LG10 will result in an additional 90 houses (so potentially 180 additional cars) feeding onto Norton Road.
● The Croft Lane access onto Norton Road is hazardous as it is metres away from the also congested Green Lane. Traffic on Green Lane regularly tails back to the industrial estate and the junction onto Norton Road has unfortunately been the scene of several accidents on a regular basis. This area and road cannot handle any more additional traffic.
● The traffic bollards on Green Lane are knocked down on an almost weekly basis, and the bollards near Cashio Lane have also been knocked down. This is a supposedly safe point for school children to cross from Common Lane to walk to the Grange School and equally for school children crossing from Norton Road/Cashio Lane/Principal Court to get to St Nicholas School. It highlights that this is not a safe road.
● We believe that the land should be returned to its original usage as a playing field.
● This part of Letchworth is very much into sustainability with many residents who have vegetable patches, ponds and a desire to have solar panels. There are many ways that the field could benefit the community.
- The playing fields could be opened up as a Village Green
- To complement the above suggestion and tie in the land to the LGC vision maybe part of the field could be used for:
- Community allotment purposes
- Solar power panels on the land contributing to the national grid.

See Attached