MM010 - Page 32 Policy SP2

ED55 13 Dec 2017 Inspector's list of actions for NHDC arising from Week 3 of the hearing sessions (Matters 15, 16, 17, 19 and 20) (PDF, 55Kb)

Documents for Air Quality Session on Tuesday 23 January 2017
ED62 12 Jan 2018 NHDC Note to Inspector on Air Quaility (PDF, 4Mb)

ED69 June 16 NHDC Air Quality Annual Statistics Report 2016 (PDF, 3,403Kb)

ED70 June 17 NHDC Air Quality Annual Statistics Report 2017 (PDF, 3,704Kb)

ED97 2015 Luton Borough Council 2015 transport modelling evidence re Luton airport (PDF, 4,874Kb)

Back in Week 3 at Matter 17 - The Inspector's List of Actions (ED55) for NHDC asked the Council to prepare an air quality note for the first week of January prior to the "reserve air quality session" and include in it information relating to monitoring data.
ED62 as it was then prepared, however we find in nothing but outright lies when dealing with east of Luton.

ED62
5.37 Appendix 5 contains the air quality monitoring data that is collected by London-Luton Airport within the boundary of its airport.

Yet if you go to "Appendix 5" it is falsely titled "2016": "Table B: 2016 Nitrogen Dioxide Data (ug/m3) from London-Luton Airport Diffusion Tubes (Annual Mean Ave. AQO = 40ug/m3)"
The air quality monitoring data contained in Appendix 5 is totally out-of-date but they have tried to lie and disguise that fact by falsely entitling it "2016 Nitrogen Dioxide Data".
It is in fact 2015 data extracted from the 2016 Annual Air Status Report. This means that all the data is from the year 2015 and NOT 2016!!! In case it needs spelling out; that is four year old data -unforgivable when so much more recent data exists.
Every year the Local Authority must produce a report on its air quality. This report is called an "Annual Air Status Report".
They are compiled once a year and must be submitted to DEFRA.
They must then be published on the local authority's website.
The reports contain the air monitoring data from the year prior. For example "Annual Air Status Report 2017" contains the air monitoring data from January 2016 up until December 2016.
In its document ED62 North Hertfordshire District Council (NHDC) has failed to use the available up-to-date data from the Annual Air Status Report 2017 produced by Luton Borough Council (LBC) found here:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Environmental%20and%20Consumer%20Services/Pollution/2017-Air-Quality-Annual-Status-Report.pdf

Had it done so, it would have revealed the truth; that the area around the Airport, which is closest to the East of Luton Strategic Housing Site and negatively affected A505 road, has air pollution already breaching legal limits.
However LBC have failed in their legal duty to take the appropriate measures and declare Air Quality Management Areas (AQMAs) around these dangerous sites and NHDC has been more than happy to accommodate them not addressing the problem.
14 monitoring sites are already breaching legal limits.

6 further monitoring sites are about to breach legal limits; being merely 1 unit away from the illegal threshold of 40.

So a total of 20 sites are breaching or verging breach.

Yet only 7 of those breaching sites have been declared as Air Quality Management Areas in Luton.

Therefore 13 breaching sites still remain at illegal levels yet the Council has failed to declare any AQMAs for these problem zones.

HOW MANY MONITORING SITES ARE THERE IN TOTAL?

THERE ARE A TOTAL OF 60 AIR POLLUTION MONITORS RUN BY LBC OR ITS AIRPORT COMPANY LONDON LUTON AIPORT COMPANY LTD.
ONE THIRD OF THE 60 MONITORING UNITS ARE ABOVE OR EXTREMELY CLOSE TO ILLEGAL LIMITS.
That's huge.
ASR 2017 (LBC) - p.p.14-21 shows the breakdown of ownership and type/ whether they are automatic or non-automatic monitors.
Automatic Monitors:
Total number of Automatic Monitors run by Council (LBC) - 2
Total number of Automatic Monitors run by Airport (LLAL) - 1
Automatic Monitors - TOTAL 3

Non-Automatic Monitors:
Total number of Non-Automatic Monitors run by Council (LBC) - 41
Total number of Non-Automatic Monitors run by Airport (LLAL) - 16
Non-Automatic Monitors - TOTAL 57

However large areas of the town are not being monitored at all. There are many huge blind spots that are cause for alarm. Such as the Hitchin Road into Luton/ A505 - at Stopsley roundabout. Nowhere in Stopsley, Round Green and High Town is being monitored.
There should be pollution monitoring distributed fairly across the entire town. If fair air pollution monitoring is not being applied then there can certainly be serious basis for claims that discrimination against certain ethnic and social groups is taking place.
There should be no reason why some areas are getting concentrated air pollution monitoring whilst others are getting absolutely none whatsoever. Or why some areas with elevated NO2 levels are declared AQMAs whereas many more that have even greater elevated levels, are not.
The closest monitoring points to the Local Plan's East of Luton Strategic Site are the Luton Airport's Air pollution monitoring system and those of LBC at Eaton Green Rd.
These are definitely breaching and have been doing so for many years and yet no AQMAs have ever been declared. So the Inspector should take the responsibility that both incompetent councils have failed to, and demand that AQMAs be declared rather than neglected, in all of the following places.
We directly refute the following fictitious statement from the Council:
ED62 - 5.36 The data from the 'worst case' monitoring locations contained within the Tables show that the air quality to the East of Luton does not breach the relevant Air Quality Objective. Therefore, because of the absence of any other potentially significant sources of nitrogen dioxide and particulate matter in the area it was judged to be unnecessary to monitor for local air pollutants elsewhere in the area east of Luton.

No need to monitor local air pollutants elsewhere in the area..."because of the absence of any other potentially significant sources of nitrogen dioxide".... What complete and utter rubbish - see the many significant sources of nitrogen dioxide and particulate matter below from the readings in the Luton ASR 2017, which NHDC has not looked at!
These sites are in fact the closest to the NHDC East of Luton Site and they are illegally breaching as you can easily see: -
SITE ID SITE NAME
IF INSIDE AQMA/ OR NOT
ORDNANCE SURVEY REF
ADDRESS AND POSTAL CODE WARD (ZONE) SOUTH/ NORTH LUTON POLLUTANTS
-MEASURED If Tube collocated with a Continuous Analyser/ or not
YEARS & OVERAL BREACH LEVEL CONCLUDED BY LBC ASR

LN23 Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF CRAWLEY (A) SOUTH NO2 Tube NOT collocated with a Continuous Analyser
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36

LA02 Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 40
2016 - 40

LA05 Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 - 46
2016 - 43

LA14 Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR, AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2012 -39
2016 - 39

LA16 Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE AIRPORT/ WIGMORE NO2 Tube NOT collocated with a Continuous Analyser
2014 - 37
2016 - 41

The following claim is an out and out lie:
ED62 - 5.39
The data show that the annual mean average Air Quality Objective for nitrogen dioxide was not exceeded at a relevant receptor in 2016. This is the only recent data published by Luton Borough Council. The only two marginal exceedances were measured at an airside location and a kerbside location within the airport boundary and so a relevant receptor is not exposed nor is there a likelihood of exposure because of the absence of housing or an equivalent receptor within the airport boundary.

Firstly there were not "only two marginal exceedances".

Secondly "exceedances" are never marginal - but are serious, illegal and likely to only get progressively worse.

Thirdly five exceedances is a serious matter, and AQMAs must be immediately declared by law. This is not an option but an obligation.

The author/s of ED62 lie by citing the Beachwood Green monitors to be the "relevant receptor(s) in 2016" - when these are much farther away from the proposed site and far less relevant than the monitors in the affected area of east of Luton. Since the traffic and entrances to the proposed housing site are all expected to be from Luton via the Crawley Green/ Luton Roads - so the monitors there are obviously far more relevant. Yet the diagram given in ED62 doesn't show any of these east of Luton points. It has left out their existence altogether.

See below how ED62 only shows five "relevant" analysers - all in the Village of Breachwood Green:

ED62 - 5.38
The data show that the Air Quality Objectives for PM10 particulate matter have not been exceeded from the first year of monitoring (2004 first full year of data) to date.

ED62 - 5.6 Local Air Quality Monitoring Data for East of Luton
5.32 There is currently no monitoring of air quality in the area of the district identified as the East of Luton. Historically there were eight monitoring locations, of which seven were diffusion tubes and one was a site comprising two real-time analysers. The locations of the air quality monitoring points are shown in Figure 5.6.

ED62 5.32 also lies when it falsely claims there is no monitoring of air quality on the area of the district identified as the East of Luton.

Here is a map to illustrate the fact there are many monitors now collecting readings. Had NHDC looked at the ASR 2017 report they would know that.

The yellow triangle is where Breachwood Green is. This is where the Council claims is "the most relevant monitor to the East of Luton site" according to ED62. Except it clearly isn't "the most relevant" - because the black scribbly area is the actual location of EL1, EL2 and EL3 proposed housing site/ currently Green Belt. As you can see there are many other air pollution monitors - in the urban area, much closer to the development and closer to the people already living there! So why select the most remote/ Breachwood Green ones (yellow triangle)?

The red tags show the locations of all the other air pollution monitors.

Clearly Breachwood Green is in a rural location far away from any of that!

So these statements in ED62 are complete and utter rubbish; what are all of these breaches at east Luton monitoring stations shown below? - Scotch mist?!

These sites are the closest to the NHDC East of Luton Site and MANY ARE ALREADY illegally breaching as you can see: -
NO2
2012 - 31
2013 - 32
2014 - 32
2015 - 32
2016 - 36 LN23
Eaton Green Road 1
(Not inside AQMA)
XOS 511377 YOS 221814
Mistletoe Hill, Wigmore, Luton, East of England, LU2 9HF
2012 - 40
2016 - 40 LA02
Airport Approach Road
(Not inside AQMA)
XOS 511586 YOS 220978
Airport Way, Wigmore, Luton, East of England, LU2 9GP
2012 - 46
2016 - 43 LA05
Runway Apron
(Not inside AQMA)
XOS 511703 YOS 221320
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2012 -39
2016 - 39 LA14
Stand 60 Luton Airport
(Not inside AQMA)
XOS 511861 YOS 221579
Luton Airport, Airport Way, Wigmore, Luton, East of England, LU2 9LR
2014 - 37
2016 - 41 LA16
Set Down Area
(Not inside AQMA)
XOS 511954 YOS 221313
Bay D Arriva Local, Airport Way, Wigmore, Luton, East of England, LU2 9NE

Readings from 2016 clearly show NHDC is lying and the truth is that NOx and NO2 were at dangerously illegal levels in the east of Luton at the time of ED62 being concocted. Since they are already at elevated levels before development, they are obviously projected to breach yet stratospherically further after development. Any fool can figure that out.

The red scribbly area shows where the location of the Infrastructure Project of National Significance is going to be located - something which the North Herts Plan and Inspector have both miraculously failed to mention!

It is currently a lovely green park (called wigmore Valley Park and Wildlife Conservation Area), but the Luton Council has just granted itself planning permission to put a 95 hectare development on top of the park, including two dual carriageways leading to an urban estate plus car park.

Imagine what the air pollution levels are going to become as they cut down all of the trees and smother the whole area with their beloved concrete and invite thousands more cars into the area to suck oxygen and poison every living creature.

Pollution levels are going to go through the roof. They are already illegal as it is, and this will take them into the "killer" zone.

And that is just based on the first approved NSIP.

Do not forget though - that there is a second NSIP planned for the same red scribbly area!

Luton Council is in the process of ALSO preparing a Development Consent Order application for a new Terminal Two - also upon the furthest away red scribbly part - the bit closest to the NHDC border no less!!

So both Councils are hiding things from the Inspector and the Inspector will need to ask them some very probing questions, or else he is going to become a laughing stock - when the High Court asks why are there an entire two NSIPs missing from the Local Plan he's just approved!!?

CONCLUSION ON AIR POLLUTION MONITORING SITUATION:
In Part II is the work I have compiled using the 2017 Annual Air Status Report which NHDC has ignored throughout its homework. We are still waiting for ASR 2018 which is with DEFRA now.
I have taken all of my data from the ASR 2017 and listed every single monitoring site in the whole of Luton and then worked out which the ward it sits in using Luton Borough Council ward data plus ordnance survey tools such as gridreferencefinder.com. You can see my Part II of this document for the full list and addresses.
The fact is that one third of all 60 monitoring stations run by LBC are breaching, or verging illegal levels - indicating there to be a very serious air pollution problem already present in Luton.
This is not at all surprising considering the large deficit in greenspace that Luton's population already suffers as compared to that of the national average. It is this deficit which is already taking its toll and manifesting as higher than normal morbidity rates, higher than national average asthmas rates, ill-health, higher crime rates, rising psychiatric illness, lower levels of intelligence overall and rising rates of depression.
Building 2,100 houses and cramming them into an unsuitable space only degrades the situation further.
Presently this east of Luton Green Belt is the only relief which can partially salvage this dire situation - it is truly an indispensable Green Belt buffer zone for the east of Luton - which if removed would literally close off of an entire area and seal in thousands of residents - leaving them trapped like caged monkeys in a zoo - between an unwanted "Gatwick sized" Airport Expansion/ Nationally Significant Infrastructure Projects in the field directly connected/ next-door, and thousands of crappy houses rendering the air totally unbreathable and roads disgustingly crammed full day and night.
This would most obviously have hugely and devastatingly negative consequences for the health and well-being of all age-groups and is a direct act of violence and barbaric cruelty when looked at in this wider real-life context.
This is why the MM010 Policy SP2 is absolutely not acceptable and does not deserve the title "spatial distribution" at all. The Inspector should remove/ delete the allowance of 2,100 houses adjoining Luton, within the settlement boundaries of Mangrove Green and Cockernhoe full stop.

TEXT REMOVED

LUTON:
* Cockernhoe and east of Luton
* * MM221 - Page 150 paragraph 13.66 (ED144)
MM 010 32 Policy SP2 Policy SP2: Settlement Hierarchy and Spatial Distributionx
INSERTED:Between 2011 and 2031, the plan seeks to make provision for at least 15,950 new homes.
INSERTED:Approximately 80% DELETED:The majority of the District's INSERTED:housing development INSERTED:and the substantial majority of new employment, retail and other development will be located within INSERTED:the adjusted settlement boundaries of DELETED:or adjoining the following towns:
* Baldock INSERTED:(3,298 homes);
* Hitchin INSERTED:(1,679);
* Letchworth Garden City INSERTED:(2,167);
* Luton32 INSERTED:(2,100)
* Royston INSERTED:(1,797);
* Stevenage (including Great Ashby)32 INSERTED:(1,830); and
INSERTED:Approximately 11% of housing, along with supporting infrastructure and facilities will be delivered in five villages identified by this Plan for growth:
* INSERTED:Barkway (209)
* INSERTED:Codicote (367)
* INSERTED:Ickleford (210)
* INSERTED:Knebworth (736)
* INSERTED:Little Wymondley (306)
INSERTED:The remaining development will be dispersed across the District as set out below.
INSERTED:In Category A villages, DELETED:GINSERTED:general development will DELETED:also be allowed within the defined settlement boundaries of DELETED:the Category A villages of:
* Ashwell;
* DELETED:Barkway;
* Barley;
* Breachwood Green;
* Cockernhoe INSERTED:& Mangrove Green;
* DELETED:Codicote;
* Graveley;
* Hexton;
* DELETED:Ickleford;
* Kimpton;
* DELETED:Knebworth;
* DELETED:Little Wymondley;
* Lower Stondon32;
* Oaklands32;
* Offley;
* Pirton;
* Preston;
* Reed;
* Sandon;
* St Ippolyts INSERTED:& Gosmore;
* Therfield;
* Weston; and
* Whitwell.

Each Air Status Report (ASR) for Luton can be found on the Council website at:
https://www.luton.gov.uk/environment/environmental%20health/air_pollution_2/air%20quality/pages/pollution%20control%20-%20air_2.aspx
Home * Environment and planning * Environmental health * Air pollution * Air quality
Air Quality Strategy

We continuously monitor air pollutants and regularly review and assess air quality in the town.
The government has published an air quality strategy. Outlined in the strategy are air quality objectives for the pollutants the government considers are of most concern at present
In response to the strategy, we reviewed and assessed air quality in Luton and produced the following reports available to download below:
Downloads

2017 Air Quality Annual Status Report (ASR) ( 3.2 MB )

2016 Air Quality Annual Status Report (ASR) ( 2.6 MB )

2016 Air Quality Management Area (no 3) Order ( 1.3 MB )

2015 Updating and Screening Assessment (USA) ( 5.4 MB )

2015 Detailed Assessment ( 2.1 MB )

2014 Progress Report ( 4.5 MB )

2013 Progress Report ( 4.2 MB )

2012 Updating and Screening Assessment (USA) ( 2.9 MB )

2011 Progress Report ( 1.3 MB )

2010 Progress Report ( 1.3 MB )

2009 Updating and Screening Assessment (USA) ( 1 MB )

2008 Progress Report ( 432.5 kB )

2007 Progress report ( 336.2 kB )

2006 Updating and Screening Assesment (USA) ( 1.7 MB )

2005 Air Quality Management Order ( 3.7 MB )

2005 Progress Report, Local Air Quality Management ( 312.4 kB )

2004 Detailed and Further Assessment ( 5.1 MB )

2003 Air Quality Management Order ( 1.1 MB )

2003 Updating and Screening Assessment (USA) ( 2.2 MB )

2003 Review and Assessment (Stage 4) ( 2.4 MB )

Contact information

Environmental health
Luton Borough Council, Town Hall, George Street, Luton, Bedfordshire, LU1 2BQ
Tel: 01582 510330
Fax: 01582 546676
environmentalhealth@luton.gov.uk

See Attached

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See Attached

See Attached

Green Belt and "exceptional circumstances": Main Modification 023 (Policy SP5)

The Green Belt review update 2018 provides further confirmation that the area surrounding Little Wymondley, including the proposed development site WY1, makes a significant contribution to the Green Belt, yet the Main Modifications and Emerging Local Plan fails to explain the "exceptional circumstances" or "very special circumstances" that justify it's removal from the Green Belt. The only justification NHDC have given is that the site is available and that there is a need to build houses in their jurisdiction. The NPPF 2012 against which this NHDC Plan is being tested clearly states that housing need alone does not justify removing land from Green Belt. It is unrealistic that a Green Belt Review can in effect be in entirely re-written yet still arrive at exactly the same conclusion without modification of the Green Belt boundaries proposed for change.

Indeed in their supporting document for the Green Belt Review, HOU1 (Housing and Green Belt Background Paper, including the Housing and Settlement Hierarchy Background Paper, November 2014), NHDC state:

"The National Planning Policy Framework (NPPF) advises as follows:
If it is necessary to prevent development in a village primarily because of the important contribution which the open character of the village makes to the openness of the Green Belt, the village should be included in the Green Belt. "

This is partly why the village of Little Wymondley was excluded from development in the NHDC Local Plan 1996 and in the saved policies (2007) from this plan.

The modifications to the plan also extend the physical site size of WY1, as a result of a developer's request to build up to a geographical brow. This contour is not a natural physical element of the site, but manmade from the distribution of soil excavated from the bypass construction, which, I believe, may contain contaminated materials unrecorded from the early 20th century.

Additionally, the ONS household formation figures released recently indicate that NHDC have overestimated the number of houses needing to be built in their jurisdiction.

Brownfield sites in the district also seem to have not yet been exhausted, and it is my belief that these should be used in priority over Green Belt land.

Openness (Green Belt/Green Spaces): MM023

The NHDC main modifications to the plan reduces the openness of the area as a result of further extension, and does not take account of the sight-lines from the listed buildings identified in a land assessment survey conducted by NHDC, which is why the original site was considerably reduced in size initially. There has been no practical suggestion as to why the extension has now been permitted.

The NPPF 2012 states in Paragraph 97 (b) that "the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location;" - NHDC's plan and Main Modifications have no compensatory equivalent open space in the locality of Wymondley Parish, or the surrounding areas.

When looked at as a whole for this locality, NHDC's proposals for site WY1 (Little Wymondley), NS1 (1,700 dwellings near Graveley) and Stevenage Borough Council's proposals in their Local Plan for sites HO3 (abutting Graveley), EC1/4 & EC1/7 (industrial estates on the land adjacent to the A1(M) Junction 8 and on Little Wymondley village boundary at Chantry Lane), plus the additional live planning application (Application No 19/00123/FPM) for 133 dwellings on the land to west of A1(M) and south of Stevenage Road (Todds Green) (formerly part of the Wymondley Parish, until NHDC removed this when the parish applied for it's neighbourhood plan area), the rural character of the entire area around Wymondley Parish will be completely eroded, destroying the villages and creating an urbanised area - this is exactly the situation that the Green Belt protection was originally designed to prevent (urban sprawl).

Infrastructure/Traffic & Air Quality Issues:

The cumulative effects of all the above listed sites will also add unsustainable and unacceptable additional traffic movements in and around the parish of Wymondley. This added to the existing congestion issues, particularly around Junction 8 of the A1(M), and throughout the road network in the parish, will exacerbate existing air quality/pollution issues. Plus, the proposed expansion of London Luton Airport (work is proposed to start on a second terminal in mid-2020) from 18 million to 32 million passengers, will also lead to increased traffic from the A1(M) Junction 8 onto the A602 as a main route to the airport and increased air pollution.

Despite the Main Modification 119, Policy T1 of NHDC's Emerging Local Plan stating:
"planning permission will be granted provided that:
a. development would not lead to highway safety problems or cause unacceptable impacts upon the highway network and safety;
b. mechanisms to secure any necessary sustainable transport measures and / or improvements to the existing highway network are secured in accordance with Policy SP7 (SP7: The Council will require development proposals to make provision for infrastructure that is necessary in order to accommodate additional demands resulting from the development.)"
- no such consideration appears to have been applied in NHDC's allocation of sites for housing development in the Wymondley Parish area and its immediate neighbours.
Further, Main Modification 369 states: "Some minor roads leading to and from the villages within Wymondley parish may require other traffic management measures which will also need to be investigated and will be reflected in future iterations of the Infrastructure Development Plan. Mitigation could include environmental improvements to the village centre. The mitigation of these issues will be part of the wider package of measures identified through the wider consideration of network issues concerning A1(M) J8 and alternate routeings to this."

It is unacceptable to plan for these major developments now (WY1, NS1, HO3 etc.) without a robust infrastructure plan in place to accompany these and mitigate adverse impacts on air quality and climate change. It is also potentially dangerous to health, particularly to children. In SP7, MM033, it is suggested that people should "change their behaviour" and walk or cycle instead of using their cars - this is an unrealistic expectation, altruistic at best and is unreasonable, especially re: site WY1 where the resident's homes are some 4 miles from any town centre. It is certainly unreasonable to expect people to walk 4 miles to train stations to start their commutes to London (for whom the majority of these houses are seemingly being built), particularly in inclement weather.

NHDC's lack of infrastructure plan would appear out of touch with the core planning guidance on "sustainable development" as defined by the NPPF 2012 and Government Planning Guidance. Indeed, NHDC's Emerging Local Plan Strategic Policy SP1, paragraph 4.1 reflects the legal definitions sustainable development as "improving our lives today while not comprising our ability to do so in the future". SP1 also states that they grant planning permission for proposals that, individually or cumulatively: "provide the necessary infrastructure required to support an increasing population" and "secure any necessary mitigation measures necessary that reduce the impact of development, including on climate change".

The current Emerging Local Plan, Main Modifications and other neighbouring authorities' plans affecting the immediate locality of Wymondley Parish, are completely at odds with Policy SP1 for the reasons stated earlier. Put quite simply, humans need to breath clean air, and increasing vehicular movements, in an area where there is existing heavy traffic congestion and air pollution issues, cannot possibly be seen as "improving our lives today" or in the future. Breathing dangerously toxic air in the place that you live or work over a period of time shortens life expectancy as evidenced by Public Health England.

In the Main Modifications of NHDC's Emerging Local Plan Strategic Policy 7 includes a requirement

"for developers to include infrastructure plans for developments to address cumulative impacts that might arise across multiple developments and to avoid placing unreasonable additional burdens on the existing community or existing infrastructure"

- however, no such infrastructure plans have accompanied any plans for site WY1, or any other plans in the locality, suggesting that no developer has a plan, and it would appear NHDC also do not have a plan.

Total additional traffic from the combined sites could total more than 5,000 additional vehicles (or 10,000+ vehicle movements on a daily basis) in an area where the A1(M) and A602 are already at a standstill during peak commuting times. More standing traffic, standing for longer, will obviously increase air pollution levels - levels which are already in excess of the WHO and EU safe legal limits.

On the Bovis Homes plan for site WY1, the pedestrian and cycle access point in the private lane alongside the listed "Croft" dwelling is an agreed vehicular access to Ashwater House and the Lane incorporates a blind bend making it totally inadequate for the purpose suggested. Consequently the new residents of the WY1 development will find great difficulty with accessing sustainable transport links in the village or their own homes on the occasion of flooding.

OBJECTION TO: Change of Categorisation of Village: (Main Modification 010 & MM012)

The main modification 010 (SP02) now lists the village of Little Wymondley as a 'Growth Village' to disassociate it from a category A village, yet no public consultation has taken place in relation to this concept and the public are generally unaware that there are now five villages within the Local Plan that are destined to lose their 'Village' status. Nor has NHDC provided any justification for stating that Little Wymondley is now a village that "can support growth". There was no explanation during the NHDC local Plan Examination in Public. The examiner remarked that the local plan seemed unfair that some Category A villages were being expected to have a high level of growth (for Little Wymondley, this growth is 88%), while others had none. Instead of NHDC reviewing this unfairness, and re-distributing house allocations fairly and evenly, they have simply attempted to resolve this issue but changing the classification of 5 villages to "Growth villages" with little regard as to whether these villages could realistically contribute towards "sustainable" growth (i.e. the harm caused by the development does not outweigh the benefits of the development).

The Examination in Public (EiP) of NHDC's Local Plan provided a Memorandum of Understanding from NHDC with Bovis Homes to develop site WY1, despite the landowner confirming that it is now unlikely that Bovis Homes would be the final developer. Therefore deliverability of a readily available site is entirely questionable.
Air Quality:

The EiP introduced a heavily modified report stating, "planning permission would be refused in areas of poor Air Quality". It is assumed that this refers to Air Quality pollutant levels close to or exceeding the EU maximum allowable. At the EiP the QC representing the NHDC stated that the presence of an Air Quality Monitoring Area was recognised "which is why developments are being considered away from these areas". Recent monitoring results of the WY1 site area abutting the A602 carried out by the Wymondley Neighbourhood Plan Committee in co-ordination with Friends of the Earth, has established consistent readings following the correct DEFRA process and independently tested. These readings exceed the EU maximum allowable levels of air pollutants.

We welcome Main Modification 153 - Air Quality:
"The following are types of developments for which the Council would expect the submission of an air quality impact assessment: ...
- Anywhere else in the District, applications that are considered to be 'major' in scale for example: significantly increase vehicle movements, particularly heavy duty vehicles; . . .
- Or that: introduce humans to an area where air pollution is an issue, but where humans were previously not present."

However, this policy seems to have been ignored in large parts throughout the plan, especially in light of Main Modification 010 to Policy SP2 whereby Little Wymondley has been re-categorised as a "Growth Village" - the consideration of Main Modification 153 has not been applied to site WY1.
It also worth noting that the Transport Strategy of October 2017, written by Markides Associates Ltd (MA) on behalf of North Hertfordshire District Council (NHDC) to support the emerging Local Plan recognises there are severe issues:

"These historic towns and links to/from them [sic. roads through the villages] suffer from traffic congestion and some air quality problems. Their 'environmental capacity' to accommodate further traffic growth without detrimentally affecting the high quality of the local environment is limited, and a starting point should be managing traffic growth and avoiding significant increases in traffic through the towns where possible."
In the same report, it also acknowledged that the NHDC Local Plan will indeed increase traffic volume through the Parish of Wymondley. Section 3.44 of the same report also recognises that the roads in Wymondley Parish are "unsuitable" for volumes of traffic:
"Use of unsuitable roads by through traffic
3.44 As with most urban areas, there is some evidence that motorists are using unsuitable roads to avoid delays on congested routes. There are many locations where traffic volumes are probably unsuitable for the nature of the road, but the more 'strategic' routes noted in the modelling include:
* Routes through Great Wymondley, by which traffic can bypass delays on the A602 between Hitchin and Stevenage;
* The B197 through Graveley between Letchworth and Stevenage;
* Willow Lane in Hitchin, which can be used by east/west traffic to bypass delays on the A505/A602 route; and
* Stevenage Road [sic. in Little Wymondley], which can be used to bypass congestion on the A602 between Hitchin and Stevenage."
Despite their own Transport Strategy document highlighting the unsustainability of Wymondley Parish in terms of air quality and transport, NHDC are still including site WY1 in their emerging Local Plan and stating they will address the infrastructure issues "later" - this is simply unacceptable when the adverse impacts on people's life expectancy is so severe.

MM028 (policy SP6 "Sustainable Transport") states:
"We will deliver accessibility improvements and promote the use of sustainable transport modes insofar as reasonable and practicable. We will:
1. Comply with the NHDC Transport Strategy and the provisions of the Local Transport Plan and other supporting documents as relevant and considered necessary;
2. Encourage development in locations which enable sustainable journeys to be made to key services and facilities;
And yet NHDC have decided to add MORE houses to site WY1, which contradicts their own policy above.

Flood Risk:

Little Wymondley Village has suffered regular flooding incidents for more than a century as recorded by the McCloys report on behalf of the Hertfordshire County Council in 2015 following the severe flood event of 2014. There are 82 homes that will likely be affected and many residents along Stevenage Road, Little Wymondley, pay considerably high insurance premiums as a result of these regular events. Site plans emerging for the development of WY1 show a number of "lagoons" to collect surface water and these are sited higher than Stevenage Road with the potential to flood the homes below. No method to distribute the collected water elsewhere, or to drain it away from the lagoons, is stated within the developer's proposal. As the development at WY1 is proposed to be on higher ground than the existing Village, it will clearly contribute to increase flooding events for the existing residents.

The proposed and ONLY road to and from the proposed development at WY1 emerges in the worst flood zone within the Village. This area is detailed in the McCloys report and referred to regularly by the Environment Agency in other similarly located planning applications as a major flood zone.

Further, in assessing flood risk in HOU1 (Nov 2014), NHDC state:

4.65 These three sites [site 121 - now known as WY1] have a combined estimated capacity of 439 new homes. Removing these sites from consideration would not, by itself, prejudice the Council's ability to meet its Objectively Assessed Needs and it is therefore considered highly unlikely that these sites would be required. All three sites are within the Stevenage HMA and in the Green Belt.

Which does beg the question, why are NHDC pursuing this site when there are so many serious issues with it and it is not a large site in view of the total housing level required?

Education:

Little Wymondley currently has a primary school that holds an "outstanding" Ofsted capability. The increased size of Little Wymondley will require an increased FE size provision and a new site is offered by the proposed WY1 development. The proposed site at the south side of the proposed new development will place pupils and teaching staff, close to contaminated land, the known effects of overhead electricity pylons and alongside an illegal Air Quality area. As a consequence of the need for this provision, we request that the Schooling provision and its eventual site is decided upon BEFORE any permission is provided for a development in WY1.

Due to all the reasons given above, I believe that the NHDC Emerging Local Plan and Main modifications are not sound, or justified.