MM012 - Page 34 After Paragraph 4.12 (new paragraph)

Showing comments and forms 1 to 24 of 24

Object

Proposed Main Modifications

Representation ID: 6687

Received: 11/01/2019

Respondent: Mr Robert Howard

Representation:

WY1, Little Wymondley Categorised as a village identified for growth is completely unsound. The development and modification are unsound. NHDC have not once mentioned the Wymondley Neighbourhood plan which is currently at Examination in Public stage. The Local Plan and modification are unsound.

Full text:

I object to Main Modification (MM 012).
Little Wymondley being categorised as a village identified for growth for the following reasons.


WY1, Little Wymondley Categorised as a village identified for growth is completely unsound. The development and modification are unsound.

1, the Office for National Statistics and government have made it clear that NHDC,s proposed development grown for NHDC is completely overestimated and is unsound. The development and modification are unsound.

I do not believe that NHDC have taken the findings of the ONS regarding the reduction of housing needs with the NHDC area seriously. NHDC do not need to build WY1 on green belt in Little Wymondley and WY1 should not be categorised a village identified for growth, the development and modification are unsound.

NHDC used the projections from 2014 to base the housing figures instead of the ONS 2016 projections. Therefore, NHDC have overestimated the housing need by 4000 dwellings. The housing figure should be lowered by 4000 which will prevent the need to build on the green belt within the smaller villages such as WY1 in Little Wymondley. Therefore, the modification is unsound.





2, developing WY1 which is approximately equivalent to an increase in the size of Little Wymondley of 80% simply is not sustainable development.
The development and modification are unsound.

3, the infrastructure cannot cope with the amount of traffic we have now and NHDC have not carried out any air quality measurements in the parish of Wymondley. The AQMA at the Three Moorhens needs to be extended along the A602 Wymondley Bypass.
Representation ID:
6686

Support / Object:
OBJECT

Section:
MM010 - Page 32 Policy SP2

Do you consider the DPD is Legally compliant?
No

Do you consider the DPD is Sound?
No

Does it comply with the duty to Co-operate?
No

Failed soundness tests:

Positively prepared
Justified
Effective
Consistent with national policy

Representation:
I object to Main Modification (MM 010 Policy SP2).
Little Wymondley being categorised as a village identified for growth for the following reasons.


WY1, Little Wymondley Categorised as a village identified for growth is completely unsound. The development and modification are unsound.

1, the Office for National Statistics and government have made it clear that NHDC,s proposed development grown for NHDC is completely overestimated and is unsound. The development and modification are unsound.

I do not believe that NHDC have taken the findings of the ONS regarding the reduction of housing needs with the NHDC area seriously. NHDC do not need to build WY1 on green belt in Little Wymondley and WY1 should not be categorised a village identified for growth, the development and modification are unsound.

NHDC used the projections from 2014 to base the housing figures instead of the ONS 2016 projections. Therefore, NHDC have overestimated the housing need by 4000 dwellings. The housing figure should be lowered by 4000 which will prevent the need to build on the green belt within the smaller villages such as WY1 in Little Wymondley. Therefore, the modification is unsound.





2, developing WY1 which is approximately equivalent to an increase in the size of Little Wymondley of 80% simply is not sustainable development.
The development and modification are unsound.

3, the infrastructure cannot cope with the amount of traffic we have now and NHDC have not carried out any air quality measurements in the parish of Wymondley. The AQMA at the Three Moorhens needs to be extended along the A602 Wymondley Bypass. The Wymondley Parish Neighbourhood Plan Committee (sub committee of the Wymondley Parish Council) along with the Friends of the Earth (FoE) have carried out air quality diffusion tube testing in November 2017 then 12 consecutive months starting in April 2018 and will reach completion in March 2019. The diffusion test tubes supplied by FoE are analysed by the same laboratory (GRADKO) as NHDC have used., using the DEFRA model.
Until NHDC do this then the development and modification are unsound.


4, the proposed new road leading to WY1 will be on a known flood risk area on Stevenage Road, this proposed development and modification are unsound.

5, NHDC has not proved that they have used up all brownfield site development areas and have not proved "very special circumstances" to remove WY1 from the current green belt status. Therefore, WY1, Little Wymondley should not be categorised as a village identified for growth. This proposed development and modification are unsound.

Summary:
WY1 does not represent sustainable development and there are no "very special circumstances" to remove WY1 from the green belt. WY1, Little Wymondley Categorised as a village identified for growth is completely unsound. The development and modification are unsound. NHDC have not once mentioned the Wymondley Neighbourhood plan which is currently at Examination in Public stage. The Local Plan and modification are unsound.

Changes:
Do not build WY1 on green belt in Little Wymondley. NHDC have not once mentioned the Wymondley Neighbourhood plan which is currently at Examination in Public stage. The Local Plan and modification are unsound.
Until NHDC do this then the development and modification are unsound.


4, the proposed new road leading to WY1 will be on a known flood risk area on Stevenage Road, this proposed development and modification are unsound.

5, NHDC has not proved that they have used up all brownfield site development areas and have not proved "very special circumstances" to remove WY1 from the current green belt status. Therefore, WY1, Little Wymondley should not be categorised as a village identified for growth. This proposed development and modification are unsound.

Object

Proposed Main Modifications

Representation ID: 6737

Received: 19/01/2019

Respondent: Mr Alan McMullen

Representation:

See Full Text below

Full text:

The following comments on the proposed submission North Hertfordshire District Council's Local Plan 2011 - 2031 as modified in November 2018 are in addition to the comments already made concerning the specific application for 167 dwellings on Land to the South of Heath Lane, Codicote
(18/02722/FP) (CD5 in Local Plan), those comments being appended at the end of this document.

Referring primarily to the new paragraph 4.xx between 4.12 and 4.13:
This states that five villages, Knebworth, Codicote, Ickleford, Little Wymondley and Barkway, have been identified as villages that can support higher levels of growth. Firstly, in respect of the first two villages the grounds cited for this are that they are: 'the two largest villages within North Hertfordshire and support a range of services, including a station at Knebworth'; that must mean that they are the villages most at risk of losing their character as villages and becoming small towns. Secondly, in respect of all five villages, paragraph 4.9 states that they will contribute about 11% to the total requirement of just under 16,000 new homes. But should it really be necessary to alter the character of these villages and intrude on the green belt around them when as paragraph 4.104 states: 'Land to the west of the A1(M) at Stevenage within North Hertfordshire has long been identified as a sustainable location for a substantial urban extension to the town. Given the history of this site, it is considered there is sufficient justification to remove this site from the Green Belt now and safeguard it for future use.' That paragraph goes on to state: 'This land is not allocated for development at the present time. No development will be permitted until a plan review determines that the site is required to meet long-term needs and remains (part of) the most appropriate solution.' Surely if that land is known to be a sustainable for a substantial development it would be preferable on any rational view to bring forward development there rather than in five villages which would provide fewer homes between them in any case.

Referring to paragraph 4.35:
This states in part: 'There are quite sizeable employment sites in villages such as Ashwell, Codicote, Kimpton, Little Wymondley and Weston which provide rural jobs and should be retained.' In the case of Codicote (and for all I know the others) the description 'sizeable' might be considered to be an exaggeration; what is certain is that the existing employment opportunities there would be miniscule in comparison to the number of new inhabitants that would be accommodated in the proposed housing development. Those new inhabitants seeking employment would perforce have to travel elsewhere to work. There is already a traffic problem on the roads, bus services are inadequate, there is no railway station at Codicote and the car parks at the two nearest stations (Welwyn North and Knebworth) are already too small to meet demand on weekdays.

Object

Proposed Main Modifications

Representation ID: 7056

Received: 11/03/2019

Respondent: Pirton Parish Council

Representation:

See attached

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 7094

Received: 06/03/2019

Respondent: CPRE Hertfordshire

Representation:

See attached

Full text:

See Attached

Object

Proposed Main Modifications

Representation ID: 7168

Received: 07/03/2019

Respondent: Codicote Parish Council

Representation:

See attached

Full text:

See attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 7304

Received: 27/03/2019

Respondent: Knebworth Parish Council

Agent: Mr Jed Griffiths

Representation:

See attached

Full text:

See attached

Support

Proposed Main Modifications

Representation ID: 7357

Received: 09/04/2019

Respondent: Welbeck Strategic Land IV LLP

Agent: DLP Planning Ltd

Representation:

Support the proposed additional paragraph as it identifies Little Wymondley as a suitable location based on its proximity to, and sustainable transport connections with, neighbouring towns.

Full text:

We support the proposed additional paragraph as it sets out a series of simple justifications for the understanding of the reader, explaining the broad rationale underlying the identification of the villages considered suitable to accommodate a higher level of planned growth. We believe that this justification is sufficient in detail within this part of the Plan, which should in any case be read in the round to understand why the allocation of sites in those specific locations are considered appropriate: conversely it is not necessary to provide a detailed exposition as to why individual settlements are included or excluded from consideration - where again the Plan should be read in its entirety. The additional wording is considered therefore sufficient to support the effectiveness of the Plan in providing context to the spatial strategy.

In that context we support MM012 insofar as it identifies Little Wymondley as a suitable location based on its proximity to, and sustainable transport connections with, neighbouring towns.

Object

Proposed Main Modifications

Representation ID: 7432

Received: 11/04/2019

Respondent: Ms Jennie Hawkins

Representation:

See attached.

Full text:

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 existingVillage, 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.

Object

Proposed Main Modifications

Representation ID: 7439

Received: 10/04/2019

Respondent: Janet Sunderland

Representation:

See attached.

Full text:

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.

Object

Proposed Main Modifications

Representation ID: 7446

Received: 09/04/2019

Respondent: Mr Robert Sunderland

Representation:

See attached.

Full text:

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.

Object

Proposed Main Modifications

Representation ID: 7453

Received: 08/04/2019

Respondent: Mr Robert Howard

Representation:

See attached.

Full text:

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

The Green Belt review update 2018 provides further confirmation that the area surrounding LittleWymondley, including the proposed development site WY1, makes a significant contribution to theGreen 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.

Support

Proposed Main Modifications

Representation ID: 7529

Received: 01/03/2019

Respondent: Taylor Wimpey North Thames

Agent: WYG

Representation:

See attached

Full text:

See Attached

Object

Proposed Main Modifications

Representation ID: 7574

Received: 10/04/2019

Respondent: Mrs Sandra Lewis

Representation:

See attached

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 7596

Received: 05/03/2019

Respondent: Ickleford Parish Council

Representation:

See attached

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 7721

Received: 10/04/2019

Respondent: Mr Julian Tribe

Representation:

See attached

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 7732

Received: 10/04/2019

Respondent: Mrs Kim Tulley-Martin

Representation:

See attached

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 7757

Received: 11/04/2019

Respondent: Mr and Mrs Robert and Lesley Bacon

Number of people: 2

Representation:

See attached

Full text:

We agree with the objections set out below. The air pollution in this area has been stated on many different occasions as over the EU standard reading. The traffic through the village at peak times is already reaching towards the maximum as there are more and more heavy vehicles that use the Stevenage Road instead of the by-pass. Any additional houses will only add to these problems.

Response from Residents of Wymondley Parish

NHDC Emerging Local Plan Consultation on Main Modifications 2019 - Objections/Comments

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.

Object

Proposed Main Modifications

Representation ID: 7867

Received: 08/04/2019

Respondent: Mrs Linda Brookes

Representation:

See attached representations

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 7928

Received: 11/04/2019

Respondent: CPRE Hertfordshire

Representation:

See attached

Full text:

See Attached

Object

Proposed Main Modifications

Representation ID: 8070

Received: 07/04/2019

Respondent: Miss Hayley Ward

Representation:

See attached representations

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 8092

Received: 09/04/2019

Respondent: Barkway Parish Council

Representation:

See attached

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 8104

Received: 10/04/2019

Respondent: Save Our Green Belt

Representation:

See attached

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 8115

Received: 08/04/2019

Respondent: Wymondley Parish Neighbourhood Plan Committee

Representation:

See attached

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 8172

Received: 10/04/2019

Respondent: Mr and Mrs Paul and Diane Kennedy

Number of people: 2

Representation:

See attached.

Full text:

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.