IC2 Burford Grange, Bedford Road

With reference to the local plan submission. Whereas I agree that houses have to be built, to this extent in such a small village where other areas are better equipped to take some of the strain is will completely ruin the village. We moved to the village for the Green space, local school and community spirit which sites IC1, IC2 and IC3 would destroy, all of these sites are on greenbelt land! IC3 would completely eliminate the historical heart of the village do links to the church, there is no need to move the school, plenty of children attend from outside the village so it can't be
that over subscribed.

The traffic on Bedford Road is out of hand as it is with sites IC1,2 and 3 would make matters far worse if that's possible let alone the pollution and not knowing what the neighbouring authorities are proposing the increase in traffic would be a disaster.

IC1,2,3 and LS1 sites are not sound for reasons above and more such as the constant flooding and lack of proper consultation.

Please reconsider the scale of development in this area before we become like Walsworth swallowed into merging towns with no boundaries, character or reason to stay/move here.

It has come to my attention that there are plans to develop the following sites in Ickleford for new housing:

IC1 - Duncots Close - 9 homes
IC2 - Burford Grange - 40 homes
IC3 - Bedford Road - 150 homes
LS1 - North Ickleford, near Lower Stondon - 120 homes

This development then represents a total increase of 319 new homes.

This email is to register my objections to the above plans on the following grounds:

. Ickleford is a small, ancient, rural and picturesque local village. Such a quantity of additional homes will overwhelm these valued and desirable characteristics.

. Proposing such a quantity of additional homes is unsound bearing in mind the impact this will have on local infrastructure such as the roads which already experience significant congestion and the consequent increase in pollution.

. Facilities in Ickleford and Hitchin such as the local railway station already struggle with current demand.

. For sites IC1, IC2 and IC3 the local plan is not sound because it conflicts with National Planning Policy Framework and conflicts with NHDC Strategic Objectives on Green Belt.

. For sites IC1 and IC3 this plan is not sound as there is evidence that the drainage and sewerage systems cannot even cope with the current demand.

. For site IC3 the proposal to relocate the school is not sound because it will destroy the sense of community and integrity of the village.

. Site IC2 is very close to the Oughton Head Nature Reserve and such further development of the area will have a detrimental impact on the wildlife that it seeks to protect.

. Such a significant building over of land increases the risk of flooding.

. This is a rural area and such a loss of space and land and the consequent increase in people and traffic will significantly and adversely impact this characteristic irrevocably destroying natural beauty and environment for wildlife.

Please consider these objections when you are reviewing these proposals.

I write this in a personal capacity, solely as a resident as Ickleford.

I believe that the local plan impacting Ickleford village has not been subject to proper legal consultation. It also contradicts NHDC policy on preserving historic villages.

On sites IC1, IC2 & IC3 the local plan is " Not Sound" as it also conflicts with National Planning Policy Framework and the NHDC Strategic Objectives on the Green Belt.

On site IC3 and LS1 the local plan is not legally compliant as there was no consultation on these sites.

Also on site IC3 relocating the school is "Not Sound" as it would destroy the centre of the village, contrary to the NHDC policy to protect historic villages.

I am writing to object the planning proposals for IC1,IC2,IC3 and LS1.
My objections are because the local plan is 'not sound' building on green belt, it conflicts with national planning policy framework.
For sites IC1 and IC3 - the local plan is not sound due to the main sewer not being able to cope with the current demand and conflicts With the local plan not to build in areas prone to flooding. The drain outside bowmans is often over flowing and cannot cope with heavy rain. I have seen it all bubbling out of the ground on many occasions.
Traffic for all these sites is again 'not sound', it does not account for increased traffic from central Bedfordshire. And on air quality and pollution is again not sound. I am concerned as I am an Ickleford resident and are bringing up three children, which is why I am most upset about the prospect of moving Ickleford village school. This is the heart of the village and is so picturesque. It is also vital for the children as they use the church and village hall which are all so close in proximity. Why not extend out to the back of the school!??? Compulsory purchase the horse field behind, there is plenty of scope to build onto the school that way, but to move it will be a shame to say the least.
I really hope you listen to the residents of Ickleford and you can come to a solution without moving the school.

I am writing to express my concern regarding the above plan and the impact on the local area in Ickleford for the proposed sites IC1, IC2, IC3, and LS1
* The sites for IC1, IC2 and IC3 are not sound because they conflict with National Planning Policy Framework and also the NHDC Strategic Objectives on Green Belt.
* The sites for IC1 and IC3 are Not Sound because the main sewer already cannot cope with current demand and IC1 and IC3 will add to this problem. Also conflicts with NHDC policy not to develop in areas that are already prone to flooding and reduce the risk of flooding in new development.
* The Local plan is not legally compliant due to prior consultation on sites IC3 and LS1.
* Traffic is already a problem through the village due to vehicles accessing Hitchin and Letchworth from Bedfordshire so for sites IC1, IC2, IC3 and LS1 the Local plan is Not Sound because there is not account for the extra traffic from Bedfordshire as well as from these extra developments.
* Additionally the extra traffic will also impact on air quality so the Local Plan is not sound for sites IC1, IC2, IC3 and LS1.
* To relocate the village school to site IC3 is NOT SOUND as it will have a huge impact on the historical character of Ickleford which conflicts with NHDC policy to protect and enhance the historic character of villages. The school is in the centre of the village, was built in 1848 and the frontage is Grade 2 listed; thus making it unique. It is rarely under subscribed in its present form. Surely an additional school in Hitchin, or extension of a current school say Oughton Head or Strathmore School would benefit those areas also.
* The Local Plan is not sound for sites IC1, IC2, IC3 and LS1 because NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan.

Site Reference No IC2 - 40 homes - Burford Grange

As local residents we would like to object to the plans for Site Reference IC2 as being 'Not Sound' for the following reasons:
* Building on green belt conflicts with the National Planning Policy Framework and with the NHDC Strategic Objectives on Green Belt
* Traffic will be considerably increased on an already busy road which is often blocked with queuing traffic. The plan conflicts with NHDC policy on transport
* Air Quality - the increase in traffic pollution conflicts with NHDC policy on air quality, particularly as traffic already queues in this area
* No co-ordination with neighbouring authorities - NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan, despite the proximity

Site Reference No IC3 - 150 homes - Bedford Road

As local residents we would like to object to the plans for Site Reference IC3 as being 'Not Sound' for the following reasons:
* Building on green belt conflicts with the National Planning Policy Framework and with the NHDC Strategic Objectives on Green Belt
* Sewerage and flooding - evidence shows that the main sewer cannot cope with current demand and IC3 would add a significant additional burden and it conflicts with NHDC policies not to develop in areas prone to flooding and to reduce the risk of flooding from new developments
* Lack of proper consultation - the Local Plan is Not Legally Compliant as NHDC did not allow prior consultation on this site
* Traffic will be considerably increased on an already busy road which is often blocked with queuing traffic. The plan conflicts with NHDC policy on transport
* Air Quality - the increase in traffic pollution conflicts with NHDC policy on air quality, particularly as traffic already queues in this area
* Relocation of the school - the impact on the village conflicts with NHDC policy to protect and enhance the historic character of villages
* No co-ordination with neighbouring authorities - NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan, despite the proximity

We look forward to receiving your acknowledgement and response.

Site IC1 Objection: Unsound

Unadequate sewage and drainage. There has been flooding in Duncots Close, Lower Green and Laurel Way, and sewerage on their lawns.

Site IC2 Objection: Unsound

By having a new development, the existing problem of traffic in Ickleford will increase.

Site IC3 Objection: Unsound

The proposed 150 new houses will worsen the sewerage problem in Ickleford and also worsen the flow of traffic.

Potential loss of school due to not being able to extend it.

I believe that the local plan impacting Ickleford village need reviewing.

My concerns are made in a personal capacity and centre on the lack of consultation and conflict with existing policy.

On sites IC1, IC2 & IC3 the local plan is " Not Sound" as it conflicts with National Planning Policy Framework and the NHDC Strategic Objectives on the Green Belt.

Also I believe Green Belt can only be used in "exceptional circumstances" and that has yet to be proven in this case.

On site IC3 and LS1 the local plan is not legally compliant as there was no consultation on these sites.

Also on site IC3 relocating the school is "Not Sound" as it would destroy the centre of the village, contrary to the NHDC policy to protect historic villages.

I formally object to the following proposed building locations:-

IC1 - Duncots Close
IC2 - Burford Grange
IC3 - Bedford Road
LS1 - North Ickleford, near Lower Stondon

IC1, IC2 and IC3 - Not Sound - as the building conflicts with both the National Policy Framework and the NHDC Strategic Objectives on Green Belt

IC1 and IC3 - Not Sound - as the main sewer cannot cope with current demand (historically the drains have backed up) and the plan conflicts with NHDC policies not to develop in areas prone to flooding, and to reduce the risk of flooding from new developments

IC3 and LS1 - Not Legally Compliant - since NHDC failed to allow prior consultation on these sites

IC1, IC2, IC3 and LS1 - Not Sound - since the NHDC modelling is flawed, not taking into account increased traffic from Central Bedfordshire, and it also conflicts with the NHDC policy on transport

IC1, IC2, IC3 and LS1 - Not Sound - since an increase in traffic pollution conflicts with the NHDC policy on air quality

IC3 - Not Sound - since the consequent impact on the village, regarding the proposed relocation of the school, conflicts with the NHDC policy "to protect and enhance the historic character of villages"

IC1, IC2, IC3 and LS1 - Not Sound - since NHDC have failed to take into account any impact associated with the Central Bedfordshire Local Plan

I am writing to protest about the proposed local plan for Noth Herts, specifically the 4 sites in Ickleford. The plan would completely change the whole character of the Village. The traffic is already bad in Bedford road and Arlesley road and such a development would make it worse. The scale of development in North Herts generally is inappropriate for the infrastructure.
Some of the development is on Green belt land which I thought you were not allowed to build on. A couple of the sites are near a river which might make flooding possible and would be difficult to insure.
The school in Ickleford is a much loved institution and there is no need to build a new one if the developments do not take place. The residents of Ickleford were not consulted about the proposed developments.

Having considered the draft NHDC Local Plan in respect to Ickleford I wish to express my objection to the proposals on the grounds set out below.

Building on the North Herts Green Belt
Three sites are proposed that require building on the Green Belt: IC1, IC2 and IC3. The NHDC Local Plan is Not Sound as such building would conflict with the National Planning Policy Framework on building in the Green Belt and it conflicts with the stated NHDC Strategic Objectives for the Green Belt in the area.

For site IC2 the building on the Green Belt will have the impact of reducing the width of the separation of Ickleford to Hitchin to a mere token. The purpose of the Green Belt in this area is to prevent the absorption of the village into the town. Retaining the identity of the village is surely an objective that NHDC will have and which will be totally compromised by allowing this development. Therefore this site must be rejected.

In addition, for IC2, the closing of the Green Belt will impact on the wildlife corridor that runs between the village and the town alongside the Oughtonhead Local Nature Reserve - which at this point is only approx. 25m wide. The adjoining strip of Green Belt is therefore essential to support the objectives of the nature reserve and the wildlife that relies on it.

Flooding
Flooding is an issue within Ickleford as the infrastructure cannot meet the demands placed on it especially during heavy rain. This impacts on sites IC1 and IC3. In addition, the sloping site of IC2 currently causes surface water run off which saturates adjoining properties after rain storms or prolonged or heavy rainfall at any time of year. Development on this land will inevitably make this worse to the point where significant damage will be done.

Because of the additional flooding risks that will result from development the Local Plan is Not Sound as it conflicts with NHDC policies not to increase the risk of flooding from new developments.

Traffic
The A600 through the village is a very busy road with queuing traffic at peak times. Taking 30 minutes to get into Hitchin town centre at these times is common. The additional housing proposed at sites IC2, IC3 and LS1 would cause a significant rise in traffic volumes to the point where it would result in grid-lock around the village and the north of Hitchin. For IC2 the ability to join the A600 from the site at peak times will be extremely difficult due to the volume of traffic. Residents in the area report that it can already take some minutes to join the road. With so many additional houses the prospect of new residents queuing just to leave the site is very real.

The problem is compounded by large scale developments already sanctioned in Central Bedfordshire which will result in a large amount of additional traffic using the A600.

The Local Plan is Not Sound as it fails to account for increased traffic arising from IC2, IC3 and LS1 as well as that from Central Bedfordshire, and therefore this conflicts with NHDC policy on transport.

Air quality
The increase in traffic stated above will increase pollution and reduce air quality. Therefore the Local Plan is Not Sound as increased traffic pollution conflicts with NHDC policy on air quality.


Recognising that some additional houses do need to be built, a possible alternative to the plan is for a more limited developments to take place. The aim should be to minimise the need to build on Green Belt, to not further overburden the water and sewerage infrastructure and to lessen the surface water flooding risk. A more limited development would also minimise the contribution to the current traffic issues.

Both IC2 and IC3 have a built on area within the sites. Overall the footprint of the house, garden and outbuildings for each is relatively small compared to the size of area proposed in the Local Plan. A number of houses could be built on the footprints without compromising the open Green Belt areas and would have a lesser impact on traffic and air pollution in the area. A limited development such as this might be able to be regarded as more sustainable from a flooding and surface water risk given the issues stated above. However, any of these sites being even partially developed will still have a negative impact on the whole village.

A similar small, incremental development, could be made on the site of Ickleford Manor. Though not part of the Local Plan, it is available for development.

LS1 needs to be considered in respect to the integration of the site into plans for Lower Stondon and the works already being planned for that town. Whilst technically in Ickleford, in practical terms, any new residents of the site will inevitably look to Lower Stondon and Central Bedfordshire for facilities and services. Given the employment opportunities in North Herts the traffic impact of the developments in the whole Lower Stondon area are of significant concern to Ickleford residents. However, on balance site LS1 has fewer disadvantages that IC1 and IC2.

I trust that these comments will assist you in making a decision on the Local Plan for Ickleford.

Yes I am prepared to attend and speak and I would like to attend any hearing. Also like to be informed of relevant dates and actions.
Herewith comments on the above plan

Site IC1 Objection. Unsound
In conflict with the following:-
1. Sewerage and Drainage: In conflict with NHDC Plan statement Ref. Page 37 Para.1.163. Anglian Water considers there is capacity in the relevant Sewerage Treatment works to support the growth required.
This statement is totally misleading as it does not consider the actual sewerage pipes capacity running through the Village.
Sewerage flooding at properties in Duncots Close, Laurel Way and Lower Green have all suffered sewerage on their lawns and a backup flow in their toilets. A recent meeting with Residents and Anglian Water identified that the pipe capacity is not sufficient to carry sewerage to the local Pumping Station.
2. NHDC Policy Ref. ENV4 states not to develop in areas prone to flooding and the reduce the risk of flooding from new developments.
Site IC2 Objection. Unsound.
In conflict with the following:-

1. No accurate traffic modelling, as unable to reflect growth in Central Beds, as their district Plan is not available yet.
At peak times traffic approaching Hitchin on the A600 already queues back 2miles from this site, the proposed 40 new houses will worsen this situation.
2. NHDC policies ENV 1,2 & 3. As this proposal will link Hitchin with Ickleford. eg. urban sprawl northwards from Hitchin to Ickleford.
3. Greenbelt............policies NPPF 80,87& 89.
Site IC3 Objection Unsound
In conflict with the following:-
1. Not Legal...... District Plan Page 8 ref.1.19 and NHDC statement of Community involvement updated xxx2015.
No consultation opportunity for Ickleford Parish Council and Residents. This site being a late entry.
2.Greenbelt ....NPPF 80,87&89.
3. Sewerage and Drainage. (As per IC1)
In discussion with Anglian Water, sewerage from this site would flow Eastwards to the centre of the Village and be another junction joining the already inadequate main pipes on Arlesey Rd.
4. Transport... No accurate traffic modelling, as unable to reflect growth in Central Beds, as their District plan is not available yet. At peak times traffic approaching Hitchin already queues back nearly 2 miles from this site,the proposed 150 new houses will worsen this situation.
Potential loss of school: The school is the heartbeat of the Village, for generations parents have gathered on the Village Green both in the mornings and afternoons leaving and collecting their children to and from school.
NHDC Ref. 1.160................The statement reads " that the existing school cannot be extended". Without any backup evidence. Local Knowledge and common sense says different.

I object to ICI, IC2,IC3 as not sound and conflict with NHDC strategic policies on Greenbelt and National Planning Policy Framework

I object to IC3 and LSI for no prior consultation - Not Legally Compliant -as NHDC did not allow prior consultation.

I object to sites ICI, IC2, IC3 and LSI as Not sound regarding no traffic surveys to allow from central beds traffic along Bedford road to further congest Hitchin traffic which is already problematic at peak hours.

Site IC3 is Not sound nor acceptable in terms of relocating a listed village school which is the heart and soul of a village which NHDC policy claims to protect and enhance the character of.

I finally object to sites IC1, IC2, IC3 and LSI as Not Sound as no impact or connection with central beds local plan has been made apparent.

The North Hertfordshire District Council (NHDC)Proposed Submission Local Plan lists four sites in Ickleford for additional housing:

IC1 (Duncots Close)-9 homes
IC2 (Burford Grange)-40 homes
IC3 (Bedford Road)-150 homes
LS1 (North Ickleford, near Lower Stondon)-120 homes

We wish to make you aware of the following objections that we have with regard these proposed developments:

1. The proximity of the proposed large development in 2019 of approximately 750 houses at the current site of RAF Henlow , Lower Stondon. This large scale development has not been taken into account in the proposed submission and the effect it will have on local infrastructure, see point 2.

Not Sound -

a) NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan.

2. The increase in traffic flow on Bedford Rd, A600 associated with both the construction of housing within Ickleford and the large development at RAF Henlow will have a detrimental effect on a transport system that is currently already at full capacity during rush hour. On working days the traffic on the A600 regularly queues from the Turnpike lane/A600 roundabout to Holme Farm. Traffic flow through Hitchin during rush hour also struggles - this is exacerbated by vehicles being forced to transit through Ickleford and Hitchin when travelling to Luton, the M1 or A1. Serious consideration should be given to a Hitchin Bypass to cope with the increased traffic from the proposed construction of housing at RAF Henlow alone.

Not Sound -

a) Conflicts with NHDC policy on transport.
b) Increased traffic pollution conflicts with NHDC policy on air quality.

3. The proposed relocation of the school would have a serious impact on the historic connection the school has enjoyed with the neighbouring church, St Katherines. The close tie to the church connects the school to members of the local community who otherwise would not have any involvement with the school. This fosters a local community spirit and gives Ickleford a distinct identity which its residents are rightly proud of.

Not Sound -

a) The consequent impact on the village conflicts with NHDC policy to protect and enhance the historic character of village.

4. Ickleford Primary School, a Grade 2 listed building, is within a conservation area as designated by NHDC. Closure of the school in its current location would have a negative impact on this area.

Ickleford Conservation area
Not Sound -

a) Conflicts with NHDC designated conservation area.

We would be grateful if the council would take our objections into consideration when reviewing this submission.

I am writing to you concerning the North Hertfordshire District Council Proposed Submission Local Plan. I object to sites IC1, IC2, IC3 and LS1 on the grounds listed below:
a) As far as I can see there has been no consultation regarding sites IC3 and LS1 - surely this is illegal, the local plan is not legally compliant .
b) The main sewer in Ickleford struggles to cope as it is. Development at sites IC1 and IC3 will severely exacerbate this problem. For this reason the local plan is not sound.
c) Sites IC1, IC2 and IC3 are on green belt land - it is there for a reason and planning to build on green belt is in conflict with National Planning Policy Framework - another reason why the plan is not sound.

Building on Green Belt.
Sites IC1, IC2, IC3. The local plan is not sound. We are losing too much green belt land for housing.
Sewerage & Flooding
Sites IC1 and IC3. The local plan is not sound. The main sewer cannot cope with current demands as it is; Walnut Way often has problems when the main sewer in Turnpike Lane gets blocked and the need is to call out Anglian Water for the drains to be cleared. The extra demand will increase the burden on the sewers.
Traffic
Sites IC1, IC2, IC3 and LS1, The local plan is not sound. The traffic along the Bedford Road is horrendous at the moment, once the new sites are in place the noise and pollution will increase, the queues of traffic will also increase. Consideration should also be for the extra traffic from Pirton's new houses and the crematorium. There are also discussions on the extra housing at Lower Stondon and Henlow on the RAF Camp.
Turnpike Lane traffic will increase dramatically; Ickleford is already a cut through to Letchworth and other Bedfordshire villages.
Would not a by-pass around Ickleford be a consideration to help ease the increase in traffic flow?
We also support the Ickleford Parish Council's objections to the proposed submission local plans.

See attached

We strongly object to the proposed local plan as it relates to Ickleford under the sites IC1, IC2, IC3 & LS1 for the following reasons.

Site IC1 Duncots Close

This particular site is totally UNSOUND for reasons relating to the Green Belt. NPPF Section 87 states inappropriate development is harmful to the Green Belt and should not be approved except in exceptional circumstances. There are no exceptional circumstances in this area, quite the contrary given the area is prone to severe flooding given its location in the Village, apart from sewerage and drainage problems not identified by Anglian water in the NHDC report. This authority have confirmed that the pumping station in the Village to be inadequate as is also the pipe capacity to handle the volumes that accumulate at this junction and serious remedial work is required to not only combat the existing problems, and would be seriously increased with added development. Ickleford is also listed as an Excluded Village in Policy 5 of the North Hertfordshire District Plan, and within this Policy the Council will normally permit development for housing only if the development is compatible with the maintenance and enhancement of village character, and the maintenance of Green Belt boundaries. The proposed development in this site fails this test and therefore UNSOUND. This site also leads onto one of the major roads through the Village, where the pavements are very narrow, it is a main pedestrian route for school children to the Village School, and where the 7.5 tonne lorry ban is not effective, thereby making it a very dangerous area for all users particularly pedestrians.


IC2 Burford Grange.

This site is also considered UNSOUND. With particular emphasis on the Green Belt implications. NPPF Section 80 states the Green Belt aims to check the unrestricted sprawl of large built-up areas to prevent neighbouring towns merging into one another and to assist in safe guarding the countryside from encroachment. NPPF Section 89 also states exceptions to building on the Green Belt might exist, such as limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan. We do not consider the suggested proposals for building on this site of Green Belt are either limited or in filling, and also NHDC has not provided any evidence that these are exceptional circumstances.. The last Conservative & Liberal Democrat Coalition Government, supported by the Government of 2016 indicated there were many brownfield sites totally capable of being used for development and so prevent the intrusion into the Green Belt
North Herts Green Belt Review in July 2016 misrepresents the value of the Ickleford Green Belt in preventing the merger of neighbouring towns. Ickleford Green Belt is a very important boundary in terms of preventing the merger with Hitchin, and also Henlow and Lower Stondon and it is imperative this remains as a protection of the historic character of a North Herts Village as defined in Environmental objectives 1.2 & 3.
This area is situated just off the main A600 road leading into Hitchin and metres from a busy junction, and any additional traffic would require a complete overhaul of the current road layout for safety reasons. High proportion of the traffic feeding into Hitchin comes from across the Bedfordshire borders, and whilst the Central Beds Plans are not available it is known that over 750 properties are to be built in Henlow, and further developments are likely in many of the other Villages in Bedfordshire making this road a total bottleneck then exists at present. The area also backs onto woodland and any new build would considerably disturb wildlife. The main water pipes from this side of the Village also feed into the centre where the IC1 problems exists and therefore constantly add to the existing sewerage and waste problems already documented and belatedly acknowledged by Anglian Water. Being part of the older end of the Village aged pipework exacerbates all of these problems..

IC3 Bedford Road.

The largest of the three sites identified, and as this one appears to be a late decision without any consultation with the Village is again UNSOUND. NPPF Section 80 relating to the Green Belt again stresses that the Green Belt aims to check the unrestricted sprawl of large built up areas to prevent neighbouring towns merging into one another and to assist in safeguarding the countryside from encroachment. This is particularly prevalent in this site given the countryside around and with much of the land being currently worked for farming. A letter seen from the Minister of State for housing dated 7th June 2016 states the Government has put in place the strongest protection for Green Belt and that boundaries should only be adjusted in exceptional circumstances through the Local Plan, and to my knowledge there are no exceptional circumstances here.
Environmental objectives figure prominently in this site as there is an indication that the Village School would need to be moved to within this site IC3. This would be travesty as the School forms part of the triangle "hub" the Church, Village Hall &existing Village School, and one of the main Environmental objectives, ENV2, is to protect and enhance the historic character of North Herts Villages, which this site would destroy. Also to consider moving the school would take this out of the Village hub, and with presumably increased size provide further problems for future intakes into the Secondary stream of Hitchin Schools.
As with Sites IC1 & IC2 Sewerage and Drainage remain a problem for the area and given the outrageous comments from Anglian Water, in the NHDC report, a full review would be required to determine the effect of any proposed new development given the anticipated size. The main sewer, pipes and Pumping station are inadequate now and would require considerable changes at substantial costs to ensure improvement of the services.
Finally the traffic issues that such a potential increase of housing could produce would be enormous. The overall projected increase of housing in IC1, IC2 & IC3 plus LS1 is an increase of 40% on current levels with the majority of likely traffic emanating from this site, IC3, onto an already main busy road entering Hitchin. At present long delays consistently occur at peak times and with a potential increase of 150 homes on this site, each having a minimum of 2 cars per house, which I gather is higher than the Department of Transports Study indicates, which I think questionable, would make this road impossible. Bearing in mind also the likely increase of vehicles from Bedfordshire, when their plans are published, with Henlow having a development of 750 houses, and further likely developments at Fairfield, Clifton and Shefford, this road at peak times would grind to a halt.
Hitchin already suffers considerable traffic stress as detailed in a recently published paper, Hertfordshire Transport Vision 2020, and further volumes such as this site could produce could only make this situation even worse. Traffic modelling prepared by AECOM in the North Hertfordshire Local Plan Model Testing document indicates figures from this development which cannot be acceptable, as they mention only a possible 63 trips in the morning and 33 in the afternoon which given the proposed number of houses and likely vehicles is not feasible

Site LS1 Lower Stondon.

This site was again a late addition and no opportunity given for consultation, and whilst there is no problem here with Green Belt, the main objection relates to the traffic problems associated with such a large development od 120 houses.
As with IC3 this development will lead onto the Bedford Road A600 just out of Bedfordshire, and again not knowing the implication of any traffic numbers from new estates in that County, the likelihood is that there will be substantial vehicle movements throughout the peak times and th impact on Ickleford will be a constant threat.

This takes us onto the other important objection overall to these four sites, the Air and noise pollution generated by all of the traffic movements in the areas involved. The number of houses proposed is 40% increase in the population of Ickleford and will obviously lead to a proportionate in car journeys, and this coupled with the likely increase from Bedfordshire, and taking into consideration much of this traffic will come via the A600 or Arlesey Road, many of the residents will be subject to environmental health impacts due to traffic pollutants. NHDC Policy D4 on air quality requires consideration to be given to potential impact on total air quality. This does not appear to have been done, and would seem to be based on flawed traffic transport modelling.

As residents of Ickleford for over 40 years we have seen considerable changes, but the Village has maintained its community and Village Character, and we and our family consider these proposed changes will decimate the Village, and we strongly object to IC1,IC2 & IC3 for the reasons stated. LS1 will not have the same direct effect and if development is required then this would be the only acceptable site.

The North Hertfordshire District Council (NHDC) Proposed Submission Local Plan lists four sites in Ickleford for additional housing:

IC1 (Duncots Close) - 9 homes
IC2 (Burford Grange) - 40 homes
IC3 (Bedford Road) - 150 homes
LS1 (North Ickleford, near Lower Stondon) - 120 homes

My objections and concerns are:
1. Building on Green Belt: for sites IC1, IC2 and IC3 - the Local Plan is 'Not Sound' for the following reasons: Conflicts with National Planning Policy Framework; Conflicts with NHDC Strategic Objectives on Green Belt
2. Sewerage & Flooding: for sites IC1 and IC3 - the Local Plan is 'Not Sound' for the following reasons: Evidence shows that the main sewer cannot cope with current demand; IC1 and IC3 will add to this burden. Conflicts with NHDC policies not to develop in areas prone to flooding, and to reduce the risk of flooding from new developments
3. Lack of proper consultation: for sites IC3 and LS1 - the Local Plan is 'Not Legally Compliant' for the following reason: NHDC did not allow prior consultation on these sites
4. Traffic: for sites IC1, IC2, IC3 and LS1 - the Local Plan is 'Not Sound' for the following reason: NHDC modeling is flawed as it does not account for increased traffic from Central Bedfordshire, and conflicts with NHDC policy on transport
5. Air quality: for sites IC1, IC2, IC3 and LS1 - the Local Plan is 'Not Sound' for the following reason: Increased traffic pollution conflicts with NHDC policy on air quality
6. Relocation of the School: for site IC3 - the Local Plan is 'Not Sound' for the following reason: The consequent impact on the village conflicts with NHDC policy to protect and enhance the historic character of villages
7. No coordination with neighbouring authorities: for sites IC1, IC2, IC3 and LS1 - the Local Plan is 'Not Sound' for the following reason: NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan

The North Hertfordshire District Council (NHDC) Proposed Submission Local Plan lists four sites in Ickleford for additional housing:

IC1 (Duncots Close) - 9 homes
IC2 (Burford Grange) - 40 homes
IC3 (Bedford Road) - 150 homes
LS1 (North Ickleford, near Lower Stondon) - 120 homes

My objections and concerns are:
1. Building on Green Belt: for sites IC1, IC2 and IC3 - the Local Plan is 'Not Sound' for the following reasons: Conflicts with National Planning Policy Framework; Conflicts with NHDC Strategic Objectives on Green Belt
2. Sewerage & Flooding: for sites IC1 and IC3 - the Local Plan is 'Not Sound' for the following reasons: Evidence shows that the main sewer cannot cope with current demand; IC1 and IC3 will add to this burden. Conflicts with NHDC policies not to develop in areas prone to flooding, and to reduce the risk of flooding from new developments
3. Lack of proper consultation: for sites IC3 and LS1 - the Local Plan is 'Not Legally Compliant' for the following reason: NHDC did not allow prior consultation on these sites
4. Traffic: for sites IC1, IC2, IC3 and LS1 - the Local Plan is 'Not Sound' for the following reason: NHDC modelling is flawed as it does not account for increased traffic from Central Bedfordshire, and conflicts with NHDC policy on transport
5. Air quality: for sites IC1, IC2, IC3 and LS1 - the Local Plan is 'Not Sound' for the following reason: Increased traffic pollution conflicts with NHDC policy on air quality
6. Relocation of the School: for site IC3 - the Local Plan is 'Not Sound' for the following reason: The consequent impact on the village conflicts with NHDC policy to protect and enhance the historic character of villages
7. No coordination with neighbouring authorities: for sites IC1, IC2, IC3 and LS1 - the Local Plan is 'Not Sound' for the following reason: NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan

Please accept this our response to the NHDC Proposed Submission Local Plan.

We would like to raise the following objections:

Impact on Green Belt
Site Reference Number: IC1, IC2 and IC3
Grounds: Not Sound
Reasons:
* The National Planning Policy Framework states that "A local planning authority should regard the construction of new buildings as inappropriate in Green Belt". Whilst an exception to this is limited infilling under policies set out in the Local Plan, an increase of 40% to the housing stock cannot reasonably been deemed as 'limited'
* The proposal to build on Green Belt land also conflicts with the NHDC's own Strategic Objectives

Impact on traffic levels
Site Reference Number: IC1, IC2, IC3 and LS1
Grounds: Not Sound
Reasons:
* The traffic flow from Ickleford down the Bedford Road and through Hitchin (Paynes Park) in the morning rush hour is already excessive. I work in Luton and it typically takes 30 mins. to drive the 9.1 miles to work, 20 mins. of which is spent just reaching the A505/A602 junction on the South side of Hitchin
* The proposed plan will put further strain on an already overloaded road network
* Furthermore, the NHDC traffic modelling doesn't account for the increased traffic from Central Bedfordshire
* Further increases to the traffic load are likely to have a detrimental impact on the ability of local employers to recruit and retain staff from the local area and reduce their attractiveness as employers of choice

Impact on air quality
Site Reference Number: IC1, IC2, IC3 and LS1
Grounds: Not Sound
Reasons:
* Related to the above, the NHDC has a statutory duty to review air quality in its area
* The National Planning Policy Framework identified air pollution as a material planning consideration and states that "the planning system should contribute to and enhance the natural and local environment by preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution..."

Impact on the local School
Site Reference Number: IC3
Grounds: Not Sound
Reasons:
* Ickleford was designated a Conservation Area by the NHDC in October 1979. This states that it is an area of special architectural or historic interest and should be protected as such
* A school has been present on the site of the current school in Ickleford since 1839 and the proposal to relocate the School from its current prominent position in a Grade 2 listed building is in direct conflict with this designation

Impact on access to healthcare
Site Reference Number: IC1, IC2 and IC3
Grounds: Not Sound
Reasons:
* Primary healthcare provision with the Hitchin area is already overwhelmed with demand. It can typically take upwards of three weeks to secure a routine GP appointment with one of the practices in central Hitchin
* Emergency admissions at the Lister Hospital in Stevenage are similarly strained
* The National Planning Policy framework "emphasises that Local Planning Authorities should ensure that local strategies to improve health and wellbeing, and provision of health infrastructure requirements are considered in Local and Neighbourhood Plans and in planning decision-making"

See attached

Your Proposed Submission Local Plan lists four sites in Ickleford for additional housing. We are greatly opposed to development of all four sites for the reasons listed below.

IC1 & IC2
The Local Plan is not sound as it conflicts with both the National Planning Policy Framework and the NHDC Strategic Objectives on Green Belt. Additionally, for site IC1 the Plan is not sound as evidence shows that the existing main sewer cannot cope with current demand and the plan also conflicts with NHDC policies to not develop in areas prone to flooding and to reduce the risk of flooding from new developments. The Local Plan contradicts NHDC's policy on air quality, as an increase in traffic pollution is inevitable as a result of construction and resident traffic. Furthermore the local plan is not sound as the NHDC modelling for traffic is flawed as it does not account for increased traffic from Central Bedfordshire and conflicts with the NHDC policy on transport. The Local Plan is not sound as NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan.

IC3
The proposed development IC3 of 150 homes on Bedford Road is of great concern. The Local Plan is not sound as it conflicts with both the National Planning Policy Framework and the NHDC Strategic Objectives on Green Belt. Additionally, the Plan is not sound as evidence shows that the existing main sewer cannot cope with current demand and the plan also conflicts with NHDC policies to not develop in areas prone to flooding and to reduce the risk of flooding from new developments. We also feel that the Local Plan is not legally compliant as NHDC did not allow prior consultation on these sites. The Local Plan contradicts NHDC's policy on air quality, as an increase in traffic pollution is inevitable as a result of construction and resident traffic. Furthermore the local plan is not sound as the NHDC modelling for traffic is flawed as it does not account for increased traffic from Central Bedfordshire and conflicts with the NHDC policy on transport. The Local Plan is not sound as NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan.

We are seriously opposed to the suggestion that the school will be relocated as a consequence of the IC3 development and needing more school places. The Local Plan is not sound as the relocation of the school will seriously conflict with NHDC's policy to protect and enhance the historic character of villages. Our village community is centred around the location of the church, the primary school and pre-school, the village hall and village shop. Moving the school will undermine this sense of community and have a detrimental effect on the character of the village. Ickleford will become another sprawling mass of housing with no centre to its village. Furthermore, the number of parents who will have to drive their children to school will greatly increase due to it no longer being located in the village centre.

LS1
We are opposed to the development of LS1 as the Local Plan is not legally compliant as NHDC did not allow prior consultation on these sites. The Local Plan contradicts NHDC's policy on air quality, as an increase in traffic pollution is inevitable as a result of construction and resident traffic. Furthermore the local plan is not sound as the NHDC modelling for traffic is flawed as it does not account for increased traffic from Central Bedfordshire and conflicts with the NHDC policy on transport. Finally the Local Plan is not sound as NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan.

Rather than adding to existing villages and undermining what a 'village' means, we feel new villages should be created with their own community and centre.

We are residents of Ickleford, and object to the Proposed Submission for additional housing in Ickleford on the following grounds:-
1. Building on Green Belt
We believe that the Local Plan is 'Not Sound' for sites IC1, IC2 and IC3 as it conflicts with the National Planning Policy Framework. It also conflicts with NHDC Strategic Objectives on Green Belt.
2. Sewerage and Flooding
We believe that the Local Plan is 'Not Sound' for sites IC1 and IC3 as the main sewer cannot cope with current demand; sites IC1 and IC3 will add to this burden. The Local Plan also conflicts with NHDC policies not to develop in areas prone to flooding, and to reduce the risk of flooding from new developments.
3. Lack of proper consultation
We believe that the Local Plan is 'Not Legally Compliant' for sites IC3 and LS1, as the NHDC did not allow prior consultation on these sites.
4. Traffic
We believe that the Local Plan is 'Not Sound' for sites IC1, IC2, IC3 and LS1, as we understand that the NHDC modelling is flawed, since it does not account for increased traffic from Central Bedfordshire, and conflicts with NHDC policy on transport.
5. Air quality
We believe that the Local Plan is 'Not Sound' for sites IC1, IC2, IC3 and LS1, as increased traffic pollution conflicts with NHDC policy on air quality.
6. Relocation of the School
We believe that the Local Plan is 'Not Sound' for site IC3, as the consequent impact on the village conflicts with NHDC policy to protect and enhance the historic character of villages. Ickleford's primary school is thriving and is at the heart of village life. The loss of the school would mean the destruction of Ickleford's historic character.
7. No coordination with neighbouring authorities
We believe that the Local Plan is 'Not Sound' for sites IC1, IC2, IC3 and LS1, as it appears to be the case that NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan.

For the above reasons, we therefore request that the Local Plan proposals for Ickleford are reviewed by the Planning Inspector.

I am writing to register my comments and objections to the Local Plan in relation to the proposed residential sites in Ickleford, sites IC1, IC2, IC3 and LS1.

IC1 (Duncots Close)

Whilst this site is within the Green Belt and is therefore in contravention of National Planning Policy Framework, in principle I would support small housing development here. The incursion into Green Belt is relatively minor and would bring the building line in line with the houses on adjacent Laurel Way. There is also a natural boundary with trees etc shielding the landscape impact of this proposed development from Duncots field.

However, I understand there are concerns over sewer capacity and flooding and any development would need to be sensitively done and be sympathetic to the conservation area. If these concerns can be properly allayed then I am broadly supportive of this site.

IC2 (Burford Grange)

I wish to strongly object to the allocation of site IC2 for the proposed residential allocation of 40 + houses.

I consider the allocation of this site to be Not Sound for a number of reasons.

This site sits within the Green Belt and as such would be in contravention of National Planning Policy and conflicts with NHDC Strategic Objectives on the Green Belt.

The strip of Green Belt within which IC2 sits provides a critical role separating Hitchin from Ickleford and is also environmentally sensitive being in close proximity to Oughtonhead Nature Reserve and providing protection into beautiful open countryside beyond.

I would like to take issue and highlight inaccuracies and errors in the appraisal of this site, which make the allocation Not Sound.

Firstly, within the Green Belt Review July 2016, this site is identified as sitting within the Green Belt subparcel Oughtonhead 12A (page 33 of report), which concludes on page 49 that it plays an important role in preventing expansion of Hitchin northwards. It also plays a significant role in safeguarding the countryside. Overall the report concludes it makes a Significant Contribution.

However, the assessment of 12A makes an error when it says it plays no role in preventing merger of neighbouring towns.

This is clearly wrong as this narrow stretch of green belt where IC2 sits plays a key role separating Hitchin from Ickleford. My conclusion is confirmed by the assessment of green belt sub sector 13c on page 50 (which contains the Ickleford Manor site diagonally opposite IC2 on the other side of the A600), which is noted as playing a key role separating Hitchin from Ickleford. The Green Belt review is therefore inconsistent and clearly the findings in relation to 12A and specifically the land that IC2 occupies is in error. The allocation is therefore Not Sound.

How can the council come to a different conclusion on two adjacent pieces of greenbelt land playing the same role separating Hitchin from Ickleford, the only difference being the sites are on different sides of the A600.

I would also highlight that when you then turn to the site specific consideration of IC2 within the Greenbelt review (ref. 40 on page 112) IC2 is then only classed as making a Moderate contribution to Geen Belt. This is inconsistent with the report finding of the site being within Subparcel 12A, which the report concludes makes a Significant Contribution and I personally think this micro location within Subparcel 12A is particularly important in separating Hitchin and Ickleford.


I would encourage the council and the Inspector to review this proposed site allocation closely and reject it. The Green Belt around Hitchin is at its narrowest in this area and the proposed development represents an unacceptable and substantial erosion of the Green Belt. The situation is exacerbated by the site's close proximity to the Oughtonhead Nature Reserve, where its immediate surrounds should be preserved in my opinion. There is a lovely walk along the River Oughton from the Bedford Road into Oughtonhead Common and the proposed development of IC2 would significantly detract from this. To say there is no landscape impact of this development is in my opinion incorrect.

I also want to highlight inaccuracies in the council's Environmental Sustainability Appraisal dated September 2016.

In the site matrix (Appendix 6, page 76), the site is correctly noted under 'Land Use' as greenfield and grade 3 agricultural land but then under 'Environmental Protection' it is incorrectly noted as an existing brownfield site. The vast majority of the site is open field and grazing land. Living nearby and walking along the river into Oughton Head, I regularly see birds of prey hunting over that site in the field and I am sure the field part of the site provides an important ecological resource. This aspect of the site sustainability review is therefore Not Sound.

I also take issue with the comments within 'Protect and enhance landscapes' where the report states "the landscape is common and the impact of development moderate'. As already mentioned, this development would significantly impact on the outlook and landscape from the River Oughton pathway, which currently benefits from open countryside views here. If suddenly the horizon outlook is 40 houses this would significantly detract from the landscape. The report notes that this is a Landscape Conservation Area and it should therefore be protected. Again I think the comments and proposed allocation are therefore Not Sound.

The report also says that the site has access to open space. Yes the site adjoins green fields but these are in private ownership and used for agricultural purposes. There is therefore actually no access to open space. Again the comment is Not Sound.

I fundamentally believe this is a very important strip of Green Belt that needs to be preserved. If it was allocated, I am very concerned this would set a precedent for further incursion into the Green Belt in this area. I hope you will reject this allocation.

As a final comment, if an allocation in this vicinity is deemed necessary or justified, which I sincerely hope will not be the case, I would request that consideration is given to only the currently built portion of the site being available for residential, leaving the current field and grazing land open green space. I have marked up a plan and aerial photo showing my suggested amendment as a fall back.

The Ickleford development boundary should be similarly amended to exclude the green field part of the site.

However, I would reiterate my position that IC2 should be rejected outright.

Site IC3 - Bedford Road

In principle, I do not object to some housing allocation on part of this land but not all of it. A portion of it seems to be large derelict greenhouses and to a degree could be viewed as brownfield land sitting within the Green Belt that could be put to a better use.

However, I am concerned about the scale of the proposed allocation of 150 houses and the lack of detailed consultation on this site which has been added late in the process. My concern is increased as the plan envisages the relocation of the primary school, which is a fundamental part of the character of the village. What would happen to the existing school site, redevelopment for more housing?? Again I am not totally averse to this possibility but greater consultation and detail is required and then if housing could be accommodated on the existing school site could the allocations on un-built, Green Belt land be scaled back or removed entirely.

I therefore object to this site on grounds of being 'Not Legally Compliant' due to lack of prior detailed consultation. However, the principle of some residential on part of this site is something I would be willing to support subject to more detail on the nature and scale and interrelationship with the primary school.

My personal suggestion would be to allocate land to the south of the Icknield Way path (with a landscape buffer) for residential and for the Green Belt, agricultural land to the north of the Icknield Way path to remain protected Green Belt.

I have attached a plan with my suggested amendments.


SITE LS1 - Lower Stondon

In principle, I support a residential allocation here. Whilst in a rural area, it is beyond and outside the Green Belt and is in relative scale with the village of Lower Stondon and adjoins an existing new housing development. An allocation here would not lead to an erosion of the fragile Green Belt gap between Ickleford and Hitchin and is therefore preferable in my view.


OTHER CONCERNS:

Traffic generation: The scale of the three proposed sites on the Bedford Road (IC2, IC3 and LS1 in Lower Stondon) in my opinion will lead to an unacceptable cumulative traffic effect on the A600 Bedford Road, which is already very busy and congested at peak times.

I understand that the traffic modelling which the council has used is flawed and therefore this places further doubt over the Soundness of the allocations in this area.

I would also comment that in addition to additional cars pulling out onto Bedford Road, a pedestrian crossing would be required from IC2 to the bus stop on the other side of the Bedford Road, which would cause further traffic tail backs so close to the roundabout. Another reason why IC2 should be rejected as not suitable for this scale of development.

I would also highlight the proposals at RAF Henlow further up the Bedford Road outside of the NHDC Local Plan area, which is set to close by 2020 and become up to 780 homes. This development will further add to the traffic pressure on the Bedford Road with a significant proportion of people travelling into Hitchin.

I understand that NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan, which would include developments such as RAF Henlow. As a result, due to lack of coordination with neighbouring authorities the allocation for sites IC1, IC2, IC3 and LS1 are potentially not sound and I think this is particularly the case for those developments along the Bedford Road. The cumulative traffic impact of all these allocations needs to be properly considered and the analysis is currently flawed.


OTHER SUGGESTIONS:

The plan also does not take account of potential other housing sites in Ickleford. The vacant Green Man pub could accommodate a small housing development, the already developed commercial area at Ickleford Manor could also accommodate a residential development and I also understand that certain areas of Bowman's Mill are to be taken out of operation and could possibly provide potential in the future.

In my opinion, a better solution to housing needs could be achieved in Ickleford utilising brownfield sites, some of which sit within the Green Belt, that would reduce the need to build over valuable virgin Green Belt, that once it is gone we can never get back.

Sewage and Flooding

IC1 and IC3 are 'Not Sound' because Ickleford has a Victorian underground system where storm water and sewage are combined in the same pipes. During heavy rain, sewage backs up into gardens and overflows from lavatories. Documentary evidence is in the Ickleford Annual Parish Meeting on 8th May 2014 where Anglian Water made a statement that the existing pipes do not permit larger pumps . Extract from the minutes section 3.3.2 'The impact level for the village has been raised within the company to ensure the situation is addressed as a priority'.

Building on Green Belt
IC1, IC2 and IC3 are 'Not Sound' because they are on Green Belt and this is in conflict with -
- NHDC Strategic Objectives
- National Planning Policy Framework
- The Conservative Party manifesto at the last General Election

Traffic
IC1, IC2, IC3 and LS1 are 'Not Sound' because -
-NHDC Traffic Modelling does not take into account, the increase in traffic from Central Bedfordshire
- of conflict with NHDC Transport Policy

Air Quality
IC1, IC2, IC3 and LS1 are 'Not Sound' because of conflict with NHDC Policy on Air Quality due to
- Reduction of Green Belt
- Increase in traffic

Relocation of Ickleford School
IC3 is 'Not Sound' because of conflict with -
- NHDC policy to protect and enhance the historic character of villages
- National Planning Policy Framework

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