MM367 - Page 213 Policy WY1 (ED148B)

The road leading to the proposed development site of WY1 from Stevenage Road is in a known flood area and has a high risk of flooding again, making WY1 inaccessible during a flood Therefore, Little Wymondley should not be categorised as a village identified for growth. The development and modification are unsound.

Support proposed amendments to 3rd bullet point relating to flood risk and consultation being required with both HCC and SBC.
Support proposed additional bullet relating to transport assessment and improving accessibility for non-motorised highway users.

We note and broadly support the Modifications to Policy WY1 having regard to the discussions undertaken at the Examination. Specifically, we note the Inspector's requested actions as set out in ED96 and the Council's proposed responses in ED148B.

Bullet 3
Specifically, we consider that the Modification to the wording of bullet 3 makes sufficiently clear that the solutions necessary to avoid exacerbating flood risk and to address an appropriate surface water drainage regime are not bound by a requirement also to redress the propensity for flooding within the existing built up area of Little Wymondley - which lies upstream of the potential discharge points of the allocated site - but that such solutions should not compound existing issues.

We do not object to the reference to consulting the Lead Local Flood Authority notwithstanding that this shall be a matter of course as part of any planning application, but note that no reference is made to any consultation with the Environment Agency who are responsible from flooding arising from "main rivers" and are also likely to be a consultee on any development proposal.

However, notwithstanding the actions recorded as necessary in ED96, we do question why the policy should be modified to require consultation with Stevenage Borough Council which has no jurisdiction over flood risk matters even within the boundary of its own authority and whose administrative area lies entirely upstream of Little Wymondley and the Ash Brook into which it is anticipated that surface water flows will be directed. We note in this context that the Stevenage Borough Council's own website directs all matters concerning flooding and flood risk to the County Council (as LLFA) and to the Environment Agency and that the website makes clear that the Borough Council itself is only responsible for "the drainage of the roads and pedestrian areas within the town centre and for flooding on areas of land in the Council's ownership" (http://www.stevenage.gov.uk/about-the-council/156034/41316/). Moreover, the Flood Alleviation Feasibility Study August 2015 commissioned by Hertfordshire County Council did not include any reference to, or obvious input by, Stevenage Borough Council - notwithstanding that it considers the Ash Brook catchment within the Borough Council's area.

We therefore suggest that reference to Stevenage Borough Council, who demonstrably have no jurisdiction or expertise in the matter of flooding, be removed from the Policy as clearly any consultation will not be able to be effectively addressed by that Authority. We would not object to reference to consultation with the Environment Agency being substituted albeit this will, as with the LLFA, be expected to be undertaken as a matter of course.

Bullet 5
We agree the addition of a new bullet 5 in order to make clear that any application will need to consider the traffic impacts on Stevenage Road as it passes through the village, which considers non-motorised access opportunities, and which addresses the issue of potential severance between the north and south of the village. In this respect we consider that any perception of severance may depend on the solution to primary education provision noted in bullet 1 but we do not object to the identification of the issue as necessary to be considered in any application.

Bullet 11
Whilst we do not see in ED96 reference to the need to undertake a Contaminated Land Preliminary Risk Assessment for the site, having regard to the discussion at the EiP and to our client's knowledge of the site, we do not object to the additional bullet point where it supports the effectiveness of the Plan.

The revised plan still does not offer any new evidence to address the issue of building on Green Belt Land. The Plan still contains no evidence to justify special circumstance to allow Green Belt development.
One of the main functions of Green Belt is to prevent coalescence between towns and villages. It is 'where it is now' that is vital, it cannot arbitrarily be re-located elsewhere and still perform the same function.
LITTLE WYMONDLEY SITE WY1
To re-designate Little Wymondley as a growth village with no public consultation is a clear omission on the part if NHDC and is totally inappropriate given that other local authorities have followed a process of public consultation.
The scale of the proposed development WY1 is inappropriate given that the residents have clearly stated in their responses to the Neighbourhood Plan Survey that up to 50 houses could be accommodated in the parish without having a significant impact on the already overstretched transport infrastructure. The proposed development also does not take into account the accumulative impact on transport infrastructure of the adjoining local authority i.e. Stevenage Borough Council and its housing plans and proposed retail and commercial sites adjacent to the parish.
The site itself WY1 has only one access/exit for vehicular traffic on to Little Wymondley High Street, an area of high risk if flooding, as well documented data proves.
A high proportion of the flood water that travels along the High Street originates on the adjacent farm land and cannot be effectively be diverted elsewhere.
At times of flooding this could well result in no access or exit from the proposed site.
The site WY1 is also adjacent to the A602 the corridor that has consistently registered above legal limits of air pollution during the last year.
The proposed plans for WY1 shows a new primary school sited close to this persistent source of air borne pollution, is this wise?
To conclude, WY1 is not a suitable site for development because it is on Green Belt land, is adjacent to a known source of pollution, is at risk of being affected by flooding which has no guaranteed solution. It is on a scale not wanted by residents and would impact on an already saturated local road network.

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