IC3 Land at Bedford Road

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 several grounds, as listed below:
1) There is a conflict between NHDC policy on air quality and the increased traffic pollution that will follow as a result of development at sites IC1, IC2, IC3 and LS1 - for this reason I would argue that the local plan is not sound.
2) It is NHDC policy to protect and enhance the historic character of villages - how could you propose to relocate our much loved village school? To do so will tear the heart out of Ickleford village and our close community. The local plan is not sound as the impact of development at site IC3, damage to our community and the character of our village, is in conflict with NHDC policy - PROTECT and ENHANCE the historic character of villages!
3) Development on sites IC1, IC2 and IC3 is in direct conflict with NHDC Strategic Objectives on Green Belt and also conflicts with the National Policy Planning Framework - these conflicts mean that the Local Plan is not sound.
4) The Local Plan is not legally compliant regarding site IC3 as NHDC did not allow prior consultation on this site - this is an outrageous omission and our community is ready to oppose this development every step of the way.

As residents in Ickleford for many years, these proposals disappoint my wife & I immensely, the historic village will be turned into a town with the 319 properties being proposed.

As anyone given thought to how this village which has won time after time, awards for best kept village, etc. would be able to cope with this development, to mention just a few, the traffic is already a major problem, and will get much worse, the village has 1 small shop, no post office, the sewage/drainage system cannot cope as it is, we have been the victims ourselves due to the aged pipe networks & pumping station, which cannot deal with the present flows let alone another 319 properties.
The historic & listed village school would appear to have to be relocated, because of the influx of additional pupils.

This proves 1 basic point, The Lack of Proper Consultation, which on its own is not Legally Compliant, not to mention coordination with neighbouring authorities, i.e. Central Bedfordshire.

Ickleford is a beautiful village, surrounded by green belt, farms, picturesque cottages, and common land, the Local Plan for sites IC1,IC2,& IC3 conflicts with the National Planning Policy framework, also with NHDC Strategic Objectives on Green Belt.

We strongly object to ALL sites mentioned above, for the reasons given, all the sites are NOT Sound,& Conflict with Policy or Strategic Objectives. And would urge the council to reconsider ALL the proposals.

I have serious and genuine concerns regarding North Hertfordshire District Council's (NHDC) Proposed Submission Local Plan.
The sites in Ickleford for proposed development by NHDC for additional housing are I understand:

IC1 (Duncots Close) - 9 homes

IC2 (Burford Grange) - 40 homes

IC3 (Bedford Road) - 150 homes

LS1 (North Ickleford, near Lower Stondon) - 120 homes

I am submitting objections to sites IC1, IC2 and IC3, and express concerns about site
LS1, based on conflicts between the Local Plan and NHDC/national policies.
These 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.

I have several deep concerns about the effects on Ickleford if the following proposals are agreed.
My objections and concerns are as follows:

1) Building on Green Belt Land
IC1, IC2 and IC3. The local plan is not sound because it conflicts with the NHDC strategic objectives on Green Belt, and also it conflicts with National Planning Policy Framework.
2) Sewerage and Flooding
IC1 and IC3. The local plan is not sound because:
Conflict with NHDC policies not to develop on flood prone areas, and to reduce the risk of flooding from new developments.
Evidence shows the main sewer currently cannot cope with demand as it is, IC1and IC3 will make things even worse.
3) Lack of proper consultation
NHDC did not allow prior consultation on sites IC3 and LS1 so the local plan is Not Legally Compliant.
4) Traffic
The local plan is Not Sound for sites IC1, IC2, IC3 and LS1 for the reason that NHDC modelling is flawed as it doesn't account for an increase in traffic from Central Beds, and conflicts with NHDC policy on transport.
5) Air Quality
The Local Plan is Not Sound for sites IC1, IC2 IC3 and LS1 as increased traffic and ensuing pollution conflicts with NHDC policy on air quality.
6) Relocation of Ickleford School
The local plan is Not Sound for site IC3 because the impact on the village of moving the school conflicts with NHDC policy on protecting and enhancing the historic character of villages.
7) No Co-ordination with other Local Authorities The local plan is Not Sound for sites IC1, IC2, IC3 and LS1 because NHDC has not taken into account any impact upon the Central Bedfordshire Local Plan.

Sites IC1, IC2, IC3 not sound
Building on green belt this conflicts with national policy framework and NHDC objectives on green belt

IC1, IC3 not sound
main sewer could not cope with demand and conflicts with NHDC not to develop in areas prone to flooding and to reduce risk of flooding.

IC3, LS1 not sound
NHDC did not have consultation for these sites

IC1,IC2, IC3 and LS1 not sound
this is flawed and it does not account for increased traffic. Bedford Road and Traffic is already appalling and so this conflicts with NHDC policy on transport.

IC1, IC2, IC3, LS1 not sound
increased traffic conflicts with NHDC on air quality

IC3 not sound
Relocation of school does not take into account the historic character of the village. The danger for children getting to the new school with increased traffic from new developments. This is not sound

IC1, IC2, IC3, LS1 not sound

The NHDC has not accounted on the impact to central Bedfordshire councils local plan.

We are writing to object to the NHDC Proposed Submission Local Plan ('the Local Plan') as it relates to the following proposed sites:

IC1 (Duncots Close, Ickleford)
IC2 (Burford Grange, Ickleford)
IC3 (Bedford Road, Ickleford)
LS1 (North Ickleford).

Our objections are as follows:

1.For sites IC1, IC2 and IC3, the Local Plan is NOT SOUND because it conflicts with the National Planning Policy Framework and the NHDC Strategic Objectives on Green Belt land.
2.For sites IC3 and LS1, the Local Plan is NOT LEGAL as there was not 'early or meaningful engagement with the local neighbourhood' contrary to the National Planning Policy Framework. In fact there was no engagement and the first time the neighbourhood knew these sites were being considered for development was when the draft Local Plan was published a few weeks ago.
3.For sites IC1, IC2, IC3 and LS1, the Local Plan is NOT SOUND as the NHDC modelling used to estimate traffic flows does not account for increased traffic from Central Bedfordshire, in particular resulting from the closure of nearby RAF Henlow and the redevelopment of that large site to provide around 700 new homes. It can be expected that many of the residents of that recently announced development will travel along the A600 to Hitchin to access businesses in Hitchin, Stevenage or Luton (or beyond) or to commute by rail into London from Hitchin. Even without that development, the proposed additional homes at IC3 and LS1 will place an unreasonable burden on the traffic flow as the A600 approaches Ickleford at the mini-roundabout junction with Turnpike Lane. There appears to be no viable mitigation for this traffic flow such as a by-pass.
4.For sites IC3 and LS1, the Local Plan is NOT SOUND as NHDC has not accounted for any impact associated with the Central Bedfordshire Local Plan and/or the proposed redevelopment of RAF Henlow which has only recently been announced.

See attachment

We object to development of IC 1,IC2, 1C3, for the following reasons , the local plan is not sound because it clashes with
Green Belt Policy and NHDC strategy, also because the sewer would not cope with such a massive development , NHDC
Did not allow prior consultation on the sites. There is already far to much traffic through the village and along the A600,
especially at peak times. As for the relocation of the school, this would destroy the nature of the heart of our lovely village
of which the school is an essential part.

We object to development of IC 1,IC2, 1C3, for the following reasons , the local plan is not sound because it clashes with
Green Belt Policy and NHDC strategy, also because the sewer would not cope with such a massive development , NHDC
Did not allow prior consultation on the sites. There is already far to much traffic through the village and along the A600,
especially at peak times. As for the relocation of the school, this would destroy the nature of the heart of our lovely village
of which the school is an essential part.

We object to development of IC 1,IC2, 1C3, for the following reasons , the local plan is not sound because it clashes with
Green Belt Policy and NHDC strategy, also because the sewer would not cope with such a massive development , NHDC
Did not allow prior consultation on the sites. There is already far to much traffic through the village and along the A600,
especially at peak times. As for the relocation of the school, this would destroy the nature of the heart of our lovely village
of which the school is an essential part.

Development on Green Belt

The Parish Council believes that inclusion of this site, which is located on Green Belt land, means that the Local Plan is not consistent with national policy for the following reasons:

1. The Local Plan proposes development on Green Belt around Ickleford at three sites; IC1, IC2 and IC3. 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 safeguarding the countryside from encroachment'. NPPF Section 87 states 'Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.' NPPF Section 89 states exceptions to building on 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 believe that the overall proposals for building on Green Belt in Ickleford are either 'limited' or 'infilling', nor has NHDC provided a compelling case to suggest that these are exceptional circumstances.

2. The letter (attached) from the Minister of State for Housing and Planning dated 7th June 2016 is unequivocal on the subject of the Green Belt: 'Government has put in place strongest protection for Green Belt ... boundaries should be adjusted only in exceptional circumstances, through the Local Plan process and with the support of local people' (our italics). As representatives of the residents of Ickleford we are confident in stating that these incursions into the Green Belt do not have the support of local people.

We believe that inclusion of this site, which is located on Green Belt land, means that the Local Plan has not been positively prepared for the following reasons:

1. North Hertfordshire Green Belt Review (July 2016) misrepresents the value of the Ickleford Green Belt in preventing the merging of neighbouring towns; this is given a low ranking of 1. However, the Ickleford Green Belt plays an important role in preventing the merger of Hitchin and Letchworth, and also that of Hitchin and Henlow/ Stondon.

2. Ickleford is listed as an 'Excluded' village in policy 5 of the North Hertfordshire District Local Plan No.2 with Alterations. Within this policy, it is noted that that 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 developments at IC1, IC2 and IC3 fail the above test.

Environmental Objectives

The Draft Sustainability Appraisal of North Hertfordshire Proposed Submission Local Plan cites a number of Environmental Objectives:

* ENV1 - Direct development towards the most sustainable locations which seek to maintain the existing settlement pattern
* ENV2 - Protect and enhance the historic character of North Hertfordshire villages
* ENV3 - Protect, maintain and enhance the historic and natural environment, its network of open spaces and rural landscapes

The Parish Council believes the Local Plan has not been positively prepared in relation to the following environmental objectives:

1. To increase the housing stock of a village by 40% (the net effect of IC1, IC2, IC3 and LS1), with minimal local resources and poor public transport links contravenes ENV1; this is not sustainable and does not maintain the existing settlement pattern.

2. Ickleford Primary School is part of the historic core of the village. Along with the Grade 1 Church with which it is aligned as a Church of England Voluntary Controlled school, and the Village Hall, it forms the 'golden triangle' focus for the village. The proposed relocation of the school as part of the Local Plan therefore contravenes ENV2.

We consider that the Local Plan has not been positively prepared and is not justified in relation to the following environmental objective:

1. The excessive development proposed for Ickleford damages our historic and natural environment and our open and rural spaces, and therefore contravenes ENV3.

Sewerage and drainage

The Parish Council believes that the Local Plan has not been positively prepared for the following reason:

1. 13.163 of the Local Plan cites Anglian Water as indicating 'that there is capacity at the relevant treatment works to support the level of growth proposed' in Ickleford. However, the critical issue of sewerage pipe capacity has not been addressed. Over the past decade, there has been an increasing incidence of flooding and sewerage overflow in IC1 and surrounding streets. Discussions initiated by Ickleford Parish Council with Anglian Water have indicated that the main sewer through the village, into which both IC1 and IC3 would feed, cannot cope with current demand. In addition, the increased likelihood of severe rainfall associated with climate change will escalate the frequency and severity of flooding already experienced in IC1.

The Parish Council believes that the Local Plan is not consistent with national policy for the following reasons:

1. The NPPF Planning Guidelines are clear that sites for development should be 'as far as reasonably possible, located where the risk of flooding (from all sources) is lowest'. This is clearly not the case for IC1.

2. The Royal Town Planning Institute lists capacity of physical infrastructure, e.g. in the public drainage systems as a material planning consideration. This has been disregarded in the Local Plan for IC1 and IC3.

3. NPPF Sections 99 and 100 state 'Local Plans should take account of climate change over the longer term, including factors such as flood risk' and 'Inappropriate development in areas at risk of flooding should be avoided'. These objectives have been disregarded in respect of IC1.

Traffic

Traffic throughout the District is acknowledged as being already problematic. Table 17 of the Draft Sustainability Appraisal states: 'The density of traffic on the principal road network is high and increasing but the rural nature of the District makes the provision of sustainable travel modes more challenging'.

We consider that the Local Plan has not been positively prepared for the following reasons:

1. 13.158 of the Local Plan indicates no specific mitigation works required for the Ickleford road network according to NHDC transport modelling. We believe this to be flawed. Extensive current and proposed development is planned within the neighbouring authority of Central Bedfordshire, against which Ickleford abuts. For example, the town or Arlesey (4 km north of Ickleford) is earmarked for approximately 1,000 new dwellings, and the site at RAF Henlow (2km north of Ickleford) will close by 2020 with 780 new dwellings being proposed for the site. The attached Department for Transport National Travel Survey NTS9902 indicates 1.31 vehicles per household in the East of England in 2014/15, and a rural town/ fringe figure 19% higher than the average. For just these two sites, an additional 2774 additional vehicles (1.31 +19% = 1.56 per household x 1780) can reasonably be predicted. A significant number of these will flow through Ickleford (A600 and Arlesey Road/ Turnpike Lane), adding to an already-strained road network.

We believe that the definition of traffic problems used by NHDC is too conservative. Thus, the Local Plan Transport Modelling Report - Draft July 2016 states: 'A problem with network operation was defined as a location where the model shows there are still more than 100 vehicles queuing at the end of the AM or PM peak hour.' A more realistic definition would identify more traffic problem sites, possibly including some in Ickleford.

2. In addition, Central Bedfordshire has yet to publish its Local Plan, but it is inevitable that the latter will recommend yet further housing, traffic from which will affect Ickleford. Moreover, Table 34 of the Draft Sustainability Appraisal acknowledges this: 'Given the early stage of the [Central Bedfordshire] Plan preparation process, it is not possible to identify specific cumulative impacts'. This is particularly problematic for a village such as Ickleford which is adjacent to the county/ authority boundary.

These major traffic factors have been overlooked, and therefore, we believe NHDC transport modelling to be fundamentally flawed.

IC2 and IC3 are unsound because developments of that size could not be justified on these sites due to the adverse impact of the additional traffic on the road system when combined with traffic from Central Bedfordshire.

3. The Appraisal Framework of the Draft Sustainability Appraisal suggests that developments should 'avoid exacerbating local traffic congestion'. The traffic modelling prepared by AECOM in the North Hertfordshire Local Plan Model Testing document attempts to quantify the increase in traffic resulting from the Local Plan. We do not believe these figures are credible. For example, for IC3 the proposed 150 additional dwellings are projected to lead to an additional 63 trips in the morning and an additional 33 trips in the afternoon - see above data on projected vehicles per household based on Department for Transport NTS9902. Therefore, we do not believe the objective of the Draft Sustainability Appraisal can be met.

Air and noise pollution associated with increased traffic

The Parish Council believes that the Local Plan has not been positively prepared for the following reasons:

1. A 40% increase in the population of Ickleford will lead to a similar rise in car journeys. This will be dwarfed by the overall increases in traffic associated with the wider NHDC Local Plan, and the likely increases associated with the embryonic Central Bedfordshire Local Plan. The majority of Ickleford residents live within 25 metres of the two village thoroughfares (A600 and Arlesey Road/ Turnpike Lane), and will be subject to likely environmental health impacts due to traffic pollutants.

2. NHDC Policy D4 on air quality requires consideration to be given to potential impact on local air quality. This does not appear to have been done, and even if it had, it would likely be based on the flawed transport modelling mentioned above.

3. The Appraisal Framework of the Draft Sustainability Appraisal suggests that developments should achieve good air quality and reduce ambient noise, especially from traffic. We do not believe either of these objectives can be met. Importantly, Table 17 of the Draft Sustainability Appraisal supports our assertion: 'Noise from air and road transport has a significant effect on quality of life in the District. Proposed developments will have significant additional impacts'.

We consider that the Local Plan is not consistent with national policy for the following reason:

1. The NPPF (Para 124) states 'Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the cumulative impacts on air quality from individual sites in local areas.'

Lack of prior consultation

1. The Parish Council believes the Local Plan is not legally compliant as sites IC3 and LS1 were added to the Proposed Submission Local Plan at a very late stage. Therefore, there was no opportunity for public consultation on these sites.

This development was not part of the initial consultation. The development is on green belt land some of which is open land used for farming. The size of the development coupled with the proposal to move the school would change the character of Ickleford which is a historic village with several listed buildings including the school and church centred around a village green.

Overall the Council's view that it is sensible to increase the size of a village like Ickleford by 40% (IC1, IC2, IC3, LC1) while it is not appropriate to recommend any development in smaller villages seems flawed. The council's argument seems to be that Ickleford has the infrastructure (school, shop, pubs and church) to support more houses while a smaller village does not. However the council is proposing so many houses that the primary school is too small and would need to be moved - better to build houses in a village without a school so that a new school can be built where there is no school. The same is true of shops; increasing the population of a village without a shop increases the viability of a shop - more useful to all of the inhabitants.

Conflicts with national planning policy

Conflicts with NHDC strategic objectives on greenbelt

Evidence shows the sewer cannot cope with current demand

Conflicts with NHDC policies not to develop in areas prone to flooding

NHDC didn't allow prior consultation on these sites

NHDC modelling is flawed as it does not account for increased traffic from central beds and conflicts with NHDC transport policy

Increased traffic conflicts with NHDC policy on air quality

The impact on the village conflicts with the NHDC policy to protect/enhance the character of villages

NHDC have not allowed for any impact associated with the central beds local plan

Whilst I agree with all the points raised in this regard by Ickleford Parish council, I would like to make specific representation in regard to the suggestion of closing the current school and building a new 2 entrant school on the proposed site.

I recognise that there is a requirement to build new homes and that North Hertfordshire will be required to take a share of these.

However, I believe that homes should be integrated with, and benefit from, the village that they may be added to.

For some villages, they have a central point which may be a church, a pub, a village hall that represents the 'heart of the village'. In the case of Ickleford the church doesn't even have a toilet, the village hall is always booked and we have three pubs. The centrepoint, the place where our main community events happen and where you will find congregations of people interacting with each other, building relationships, enabling a village community rather than a shared area to live, is our school.

From the social events such as Christmas and summer fayres, school events such as plays, sports days etc. to classes, the school is a focal point for much that is good about Ickleford.

If you do not consider the objections on practical and environmental grounds enough to change the plans, I would urge you to reconsider closing the school.

Build a new one entrant school at the north of the village, expand a local primary on Old Hale Way, build on the area north of The Priory school but please do not close the current school as that land will just be built on at some point and we may retain the title of a village, but the essence of what makes Ickleford a village will be lost. We will become just a collection of houses on the north edge of Hitchin - a suburb of a town.

Please consider our points carefully as we should be building vibrant sustainable communities, not destroying the work that has been done in this regard over many years.

Not sound for the following reasons:
Conflicts with National Planning Policy Framework.
Conflicts with NHDC Strategic Objectives on Green Belt.
Flooding danger - main sewer cannot cope with current demand, further burdens on it from more development could be disastrous. Conflicts with NHDC policies not to develop in areas prone to flooding, and to reduce the risk of flooding from new developments.
'Not legally compliant' because NHDC did not allow prior consultation on this site.
Traffic - NHDC modelling is flawed as it does not account for increased traffic from Central Beds and conflicts with NHDC policy on transport - increased traffic pollution conflicts with NHDC policy on air quality.
Proposed relocation of the school - consequent impact on the village conflicts with NHDC policy to protect and enhance the historic character of villages.
Lack of coordination with neighbouring authorities, NHDC have not accounted for any impact associated with Central Beds Local Plan.

As a resident of Ickleford, I would like to express my concerns about sites IC1, IC2, IC3 and LS1.

1) Building on Green Belt land
In relation to sites IC1, IC2 and IC3, I believe that the Local Plan to be "Not Sound" for the following reasons:
*It conflicts with National Planning Policy Framework
*It conflicts with NHDC objectives on Green Belt
2) Sewerage and Flooding
Regarding sites IC1 and IC3, I think the Local Plan is also "Not Sound", because:
*Evidence shows that the man sewer cannot even cope with current demand -- so IC1 and IC3 will only add to this burden
*It conflicts with NHDC policies not to develop in areas prone to flooding, and to reduce the risk of flooding from new developments
3) Air quality
For all four of these sites, I believe the Local Plan is "Not Sound" for the following reason:
*Increased traffic pollution conflicts with NHDC policy on air quality
4) Relocation of Ickleford School
With regard to site IC3, the Local Plan is "Not Sound" for this reason:
*The consequent impact on the village conflicts with NHDC policy to protect and enhance the historic character of villages
*The existing school, Ickleford Primary School, was buildt in 1848, and the front part of the school is a Grade 2 listed building

I hope you will take these concerns into consideration.

We wish to object to the above Local Plans for the following reasons:-

* Not Sound as building would be on Green Belt Land - IC1 IC2 & IC3
* Not Sound as insufficient sewerage and flooding provisions IC1 and IC3
* Not legally complaint as no prior consultation - IC3
* Grave concerns regarding increased traffic through the village impacting on school activity and Local Residents IC1 IC2 IC3 & LS1

We urgency request that the above plans are reviewed.

I am a resident of Ickleford Village in Hertfordshire and would like to lodge my own personal objections to the planned additional housing in Ickleford:

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

Which I feel strongly is an amount of housing that the infrastructure of Ickleford and the surrounding area of Hitchin where we have our G.P. surgeries and secondary schools will not be able to sustain.

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.

Ickleford is a beautiful village surrounded by green fields on the borders of Lower Stondon/Arlesey - Befordshire. This is enjoyed by many families and groups as a countryside area for walking/running and exercise, also walking their pets. The removal of this Green Belt area and adding additional housing will be against our hopes to keep green belt countryside free.

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.

With the current difficulties the whole country is experiencing with flooding issues, which then require already stretched services who have to rescue elderly and vulnerable people, requires the use of many government departments to clear the devastation that flooding causes to properties is already a massive burden in this country, and problem that appears to be becoming more and more of a difficult issue. I feel to add to this knowingly is totally unacceptable.

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.

I feel the above comment is self-explanatory and disgraceful if it is 'Not Legally Compliant'. I do wonder why this happened as I am sure there would have been many objections, which I assume for planning purposes is easier to avoid.

4. Traffic
For sites IC1, IC2, IC3 and LS1 - The Local Plan is 'not Sound' for the following reasons:
- NHDC modelling is flawed as it does not account for increased traffic from Central Bedfordshire, and conflicts with NHDC policy on transport.

I have lived in the village for 21 years and brought up our three children here. It already has an excessive amount of traffic driving through the village each day. When taking our children through the village to the local school we often took our lives in our hands because of the narrow pavements and excessive speed of the cars going through the main road. The addition of traffic slowing measures has helped, but I cannot see that adding the amount of housing suggested will help this situation at all. Most people have at least one car per household if not two, and sometimes more. They will all add to the congestion around the school when they leave their premises each day and compromise further the safety of the children trying to access the school.

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.

I feel although I am not an expert on Air Pollution, it is blatantly obvious more housing and added car use in the village must add to Air Pollution which is a worldwide issue, if this conflicts with the NHDC policy on air quality surely this is inappropriate.

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.

The village of Ickleford has an amazing historical background and I have always thought that the local school is part of this and situated next to our beautiful church. There are links between the school and the church, and other organizations like the local Scouting and Brownie and Guides Groups. If the school were to be relocated purely because of the building of a new 150 home housing estate this would be devastating to the community of Ickleford. It is also blatantly obvious that the current school would never be able to cope with such an increase in the population of Ickleford.

OUR MAJOR CONCERN: If the school is relocated could you tell me would the existing school field then be granted permission for another huge amount of housing as our back garden is adjoined to the current school field?

7. No Co-Ordination 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.

I am not sure why this has not happened but surely it should have been considered.

I would like to say as a resident I am really concerned about the impact the planned housing will have on the village of Ickleford, its school, the traffic increase, we currently use G.P. surgeries in Hitchin and they struggle to cope with their patient numbers. I am worried how much the situation will deteriorate with 319 additional homes in the village. The local secondary schools in Hitchin are highly in demand and surely also will struggle to accommodate the planned new housing. I feel there is currently no increase in supporting community infrastructure, if anything just financial cut backs, closures of school etc. - how can this current suggested additional housing be appropriate?

I look forward to hearing from you with your comments on the above. If there is any way this concern can be forwarded to the relevant committees I would be more than grateful.

I strongly object to the proposed local plan in so far as it relates to Ickleford, by which I mean sites IC1, IC2, IC3 and LS1, for the following principal reasons:

1. It flies in the face of HMG's own Planning Practice Guidance and in particular paragraphs 79, 80, 83, 85 and 87. HMG attaches great importance to the Green Belt, the basic and fundamental aim being to prevent urban sprawl and to prevent the merging of neighbouring towns. The Guidance continues that established green belt should only be altered in very exceptional circumstances. The massive deleterious effect of the proposals upon the village of Ickleford should be clear to any impartial observer, and it is clear that the circumstances are not "very exceptional". In the circumstances the proposal is not sound.

2. Ickleford is a low-lying village which is already the subject of potential flood problems. In July this year one brief rainstorm caused my garden to flood because there is inadequate sewerage and water drainage. Last year properties at the lower end of the village had sewage backing up their lavatories and at a subsequent meeting with representatives of NHDC and Anglian Water it was admitted that the pumping station at Lower Green and the capacity of the pipes were both inadequate. Improvement of the pumping capacity was considered pointless because the pipe capacity throughout the whole of the village would have to be increased [which was considered "impracticable"]. There is already planning permission for additional houses on the site of the Green Man public house and any further housing would be disastrous unless major pipe enlargement works were conducted throughout the whole area and improvements made to the pumping station. This work would have to be undertaken and concluded before any housing development took place. In the circumstances the proposal is not sound.

3. Traffic through Ickleford is already causing difficulties, mainly by reason of new housing in South Bedfordshire [Fairfield, Stotfold, Arlesey and Stondon] and it is well known that Hitchin and, indeed the centre of Ickleford , are frequently gridlocked at busy times. A further 319 homes would cause impossible difficulties without the construction of a bye pass or bye passes, which in turn would doubtless be constructed [if at all] on Green Belt land! In the circumstances the proposal is unpractical and unsound.

4. It has already been tacitly admitted that the proposed development would destroy the character of the village, the centre of which [both physically and emotionally] is the school, church and village hall. The suggestion that the school would have to be moved to a site outside the confines of the village speaks volumes and no further comment should be necessary. The effect on the village renders the proposal unsound.

The submission smacks of a "panic" approach to an admittedly difficult situation caused by HMG's requirement to produce a plan by a specific date but there is no indication of any considered or sensible attempt to address the issues. The appearance is of a hurried decision simply to pluck enough ground, anywhere, to enable to Council to satisfy "the numbers". If the submission were put into effect the result would be a flagrant disavowal of HMG's own criteria.

TRAFFIC

Two of the three routes converging directly on Hitchin from the north pass through Ickleford.

Both already become congested at peak periods, so that without a major upgrading of the road system the proposed housing development at sites IC1, IC2, IC3 and LS1 would inevitably increase that congestion.
Contributing further to such an effect would be traffic coming from similar developments already proposed for Mid-Bedfordshire.

From the Local Plan Technical Review 2.4 we learn that there is currently no COMET run that illustrates the impact of the scale of growth from the local plan housing requirements for any of the 10 District Councils in Hertfordshire. 5.4 draws attention to the required evidence also being dependent on growth in adjacent authorities (e.g. Bedfordshire in this case) which appears to be as uncertain as that of NHDC and the other Hertfordshire Districts. 5.17 states that the county wide model will show the key corridors and linkages between the urban areas where public transport and sustainable modes should be promoted, but in no part of the subsequent summary is any estimate given as to the likely time it will take to pull all this work together to form a plan for Ickleford that is worthy of public consultation.

If a consultation is nevertheless imminent our response must be that the grounds for this are Not Sound as Ickleford cannot be expected to suffer the consequences of a decision that would ignore the mass of facts already evident locally or likely to form part of the planners'
broader vision.

Re: Plans for Ickleford IC1, IC2, IC3, LS!

I would like to state my support for the Ickleford Parish Council's objections to sites IC!, IC2, & IC3.
I believe the are not sound for following reasons :
The main sewer through the village is already at capacity & in extreme wet conditions gets full which causes "back up" to drainage pipes from roads leading into the main Arlesey Road. This is known to Anglia Water & tankers regularly attend to pump sewerage / drainage water from the pumping stations by Cadwell Bridge & Laurel Way, however this does not help in very wet conditions when flooding is experienced in several areas. Anglia Water in their comments in the plan state that their treatment Centre can cope---this might be true but the actual pipework through the village taking sewerage etc to the Treatment Centre certainly can't . Additional housing would only add to the problems.

I believe as do most people in the village that the school ( which is partly listed) is the centre of the village & to move this is not justified. If ever expansion was needed then a seperate annexe should be considered for certain ages

Other aspects such as Traffic & Building on Green Belt I agree with Ickleford Parish Council's response, but my main objections are as stated above. We do realise that some building is necessary but the infrastructure must be also in place.

I write to you as a resident of Ickleford in regard to the NHDC Local Plan for additional housing in and around Ickleford.

As a younger home owner and resident of Ickleford I recognise the urgent need for additional housing in the London Commuter belt, with this in mind I still feel that the proposal is ill thought through and unsound for the following reason.

1) Duncots Close (location of IC1) is small cut-d-sac with no pavements - pedestrians have to walk on the road to access the houses. The situation as is, is already a serious safety hazard. Any additional housing in this area as proposed under IC1 will increase traffic and poses a very serious safety hazard to the residents and other pedestrians. Due to the positioning of houses it appears impossible to provide suitable pavements.
Summary: Objection of the grounds of safety.

2) For site IC1, IC2 and IC3 the Local plan is not sound as it is in conflict with eh National Planning Policy Framework and conflicts with the NHDC Strategic Objectives on Green Belt land.

3) Duncots Close (location for IC1) has already suffered with sewerage draining issues as the main sewer cannot cope with the demand. The proposed IC1 and IC3 will increase this demand and will increase risk of flooding for the local residents.

4) 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) 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 may the planning inspector review the proposal for Ickleford with the above comments in mind?

All sites IC1 IC2 IC3 LS1 are not suitable for this area due to traffic and pollution concerns they are also to be built on Green Belt which conflicts with NHDC Strategic Objectives.

i am emailing you about the plans for houses in Ickleford

IC1, I do not think this is a good site to build on, it is meadow land to the back which dose flood depending on how much rain we have, the roads around there also flood so any more concrete in the area will make this problem worse. the traffic in the are is bad during rush hour.

IC2, i can not believe this has even got to planning, the A600, Bedford road dose not need any more traffic on it, the road is bumper to bumper every morning you only need one little problem and then the whole road system stops, this is the green belt and it is right on the local river and conservation site, the road floods here as it is at the bottom of a hill, the drains here are full all the time, i know this as i walk my dogs here, the road is continually having to be repaired as there are so many lorries go over the drain covers and smash up the road. i have seen this area in really server rain storms, i have seen the manhole covers on the path forced OPEN and water coming up like a fountain, very dangerous and people have to walk through this. putting 40 houses on an area that is very wet anyway and all the extra concert on this area will cause more flooding. there is a heron that lives at this point of the river and a king fisher that i see, this is also an area where the black squirrel live.

IC3 150 houses, if you say an average of 2 cars per home, that's 300 cars trying to get on to a very busy road A600 every morning, this is also on an area of green belt, the school is over subscribed every year as are all schools in the area so where are these children meant to go to school, we are losing so many services so a new school is way down the list, the infrastructure in the area can not take this amount of extra needs. its not a good idea.

LS1 this again is on green belt, again there will be more traffic on the roads.

i grew up in Ickleford, as did my mother and my 2 children, they will never be able to buy there own homes here as the prices are now so high but squeezing 319 in such a small space is crazy. we know why the building companies want to shoe horne these houses here as its in Hertfordshire, so they can charge more than 5 miles down the road in Bedfordshire. its obvious these people sit in an office looking at maps and when they see a green space they shout ' fill it ' with out any consideration on the impact of people already living there, the services and quality of life not only for residents already living there but for the new people that move in to these houses, you would be looking at potentially 1000 more people living in a small village, there will be more commuters and you cant get a seat as it is, the road area around the station from 3.30 on wards is crazy, it will get worse. i know we need more homes and its not the ' not in my yard' objection, its the fact there are TOO many, especially for a small village and the area they want to build on, if these are allowed Ickleford would soon be an area of Hitchin and would totally lose it's identity as a village.

OBJECTIONS TO THE LOCAL PLAN FOR ICKLEFORD

SITES IC1, IC2, 1C3, LS1

GENERAL OBJECTIONS
The local plan proposes 319 new homes (on top of the 27 new homes already part of the Planning Process). These additional 346 homes would be out of all proportion to the current Ickleford village which comprises just 850 dwellings - the number of dwellings would represent an increase of 40% in the housing stock

Such a significant increase in the number of dwellings/residents would fundamentally and materially alter the nature of the village. It would also put further strain on local roads and sewerage systems as well as on local schooling.

Most of the proposed developments are on Green Belt land.

Ickleford is listed as an "Excluded village in policy 5 of the North Hertfordshire District Local Plan (no 2 with Alterations). This notes that 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". Our firm view is that the Local Plan clearly fails to meet either of these criteria.
SPECIFIC OBJECTIONS
Because of the additional education capacity required by the major proposed increase in homes, the Plan proposes to move the local village primary school away from its key site in the centre of the village to a location at IC3. This, to us and we believe to most residents, is utterly inappropriate and totally unacceptable.

The current school, built in 1848, has a Listed frontage and is the main focal point within the village. It is situated on the village Green and has strong links with the nearby church.

With its position on the Green, it has for over a century and a half been an ideal gathering place for parents and pupils at the beginning and end of each school day. Pupils love playing and chasing eachother on the Green and, in the Autumn, collecting conkers. Maypole dancing on its front lawn is also a well-established tradition for its pupils, as is the walk across the Green to the nearby Church for Harvest Festival and for Xmas Carols. This is all an integral part of the heart and soul of the village.

The relocation of the village school would have a significant and material adverse effect on the historic soul and character of Ickleford and we firmly believe it should be resisted at all costs.

Objection

IC3 Bedford Road, Ickleford

My objection to IC3 planning at Bedford Road is that I am long standing tenant of the rural estates, I farm in the parish of Ickleford and live in the property of Five Oaks Bedford Road which comes into IC3 planning for Ickleford. I have farmed this land for 45 years which is my business and livelihood.
If this planning does go ahead the property of five oaks which myself and my wife have lived in for 45 years, we will be made homeless as my life tenancy agreement will cease.
My reason for the objection to this planning of IC3 is the infrastructure of the A600 Bedford road cannot take the amount of traffic we have today let alone another 300 cars on this main route to Hitchin and Bedford, as there has been a proposed site at Lower Stondon LS1 and also to take into consideration for the proposal site of RAF Henlow were as 700 homes will be built as from 2020 this will add to more traffic chaos.
At this site there is abundant wild life e.g. Barns owl, deer etc., myself object to this planning as a part of taking good agricultural land out of production which is part of my business.
We as local residents of Ickleford have not been consulted on this proposed site of IC3 as my wife was approached by local residents regarding IC3 was going to be built on, myself and my wife was not notified by NHDC or Rural Estates that was on the agenda.
At IC3 there no sewage mains which runs into sewage farm as we have septic tanks which have to be emptied via a contractor if this proposed building goes ahead the sewage which will be produced on following IC1 and IC3 sites which will add to this burden. The surface water which will be created by this proposed site will be drained into the local river Oughton which is part maintained by IDB and NHDC should consult the IDB.
The local school in the centre of the village is in no position to take extra children in the evidence of IC3 and IC2 as the school is at full capacity and cannot take anymore.
I object to this planning on IC3 as there is a bridleway runs alongside agricultural land which comes out on to the A600 Bedford Road there is used by a huge amount of walkers and horse riders that use this bridleway to gain access to bridleways that head towards Pirton and Oughtonhead common as this is the safest route to get onto the bridleways, this crossing point was put in for the safety of the general public and horse riders.
To bring another access out onto the A600 towards Hitchin or Bedford regarding IC3 is not safe in my opinion and is a potential accident site. I also think that the roundabout at the top of Turnpike lane would need to be massively increased in size to take the extra volume of traffic.

These are my objections to the proposed development site of IC3 Ickleford.

We were extremely disappointed to hear rather suddenly of the proposed plan to develop our lovely village of Ickleford. Residents had been aware of proposals IC1 and IC2, but with the sudden addition of IC3 we are all left in shock. Residents were not consulted on this additional site which in my mind cannot be legal.

Ickleford is a small village on the outskirts of Hitchin with a lovely "village" school [...] We specifically chose to live in Ickleford for the very reason to live in a "village". The school is centrally located on the village green near to the church, village shop and village hall; a triangle which binds the hub of the village and the local community. We currently walk to school across fields, one of the reasons we chose to move to the village to give our children a better life. The school is closely connected to the church, and the children have the opportunity to walk across to the church to celebrate festivities such as Harvest Festival, Easter and Christmas. The majority of the families whose children attend the school are of the Church of England faith. Moving the school to the Bedford Road, along with doubling the number of pupils will make trips to the church near on impossible.
Those children (and families) will lose their connection with the church and the historic character of the village as the school will amalgmate pupils from the village along with others from Hitchin with no affiliation to the church and it;s beliefs.

The proposal to build an additional 150 houses concerns us greatly [...We] get stuck in the traffic that builds up on the Bedford Road leading down from Lower Stondon and have witnessed traffic delays of up to 30 minutes even after 9am from Ickleford to Hicthin (Paynes Park). These additional 150 houses (IC3) PLUS 120 in Lower Stondon (LS1) will no doubt cause an increased bottleneck of traffic all trying to make their way through Hitchin to the A1(M) and other routes leading south adding to the turmoil and grief of all who use these roads. If the Primary school is relocated, then the majority of Ickleford residents (from the Lower Green end) will have to drive to school adding to this traffic. We do not feel that the proposed local plan with regards to the increased burden on traffic is sound and has not been accurately researched.

In summary, we do not feel that proposal IC3 has been thoroughly thought through in conjunction with IC1 and IC2 - this in total adds nearly 346 dwellings to Ickleford (a potential of a 40% increase which is not in proportion for the size of the village).
Such a massive increase in the number of dwellings/ residents will fundamentally alter the nature of the village. The larger villages and towns in NHDC are better able to absorb the increase in housing without altering the basic character. It is clear that the impact on quality of life for residents of the Plan is profound.

I am emailing regarding the proposed housing sites in Ickleford. We live in Ickleford and are concerned about the proposals for the following reasons.

We are a small historic village where community life focuses in the heart of the village. We fear that relocation of the school (sites IC3) will loose community spirit from the village. The green today is enjoyed by families every day - removal of the school will be a real shame to all that live here and the town will become a busy 'drive through' and conflicts with NHDC policy to protect and enhance the historic character of villages. It was a real shock to hear of this development plan at a recent meeting - a lack of consultation from NHDC and is not legally compliant.

Expanding the village by building on Burford Grange (site IC2) will mean Ickleford will become consumed by North Hitchin. The boundary of one field is a small but very important buffer of greenbelt land as well as a flood plain - building here will put a lot of demand on sewage, flooding and wildlife. The Bedford Road is already a fast and dangerous road with inadequate pavements and crossings. Building on Bedford Road (IC3) also will put huge demand on the the small round about on Turnpike Lane which already causes major congestion issues entering the village - increased traffic here would be a major problem. Pollution, noise and air quality will be affected and for these reasons are 'not sound' and conflicts with NHDC policy on transport.

There are many areas in the centre of Hitchin and Hertfordshire that could be built on and infilled rather than destroying our historic village. The industrial area on Bury Mead Road has masses of derelict industrial buildings - surely these would be of interest before building on unspoilt land?!

I'm writing to object about the elements of the proposed local plan relating to Ickleford, as follows:

Building on green belt land
This applies to sites IC1, IC2 & IC3 as it conflicts with the National Planning Policy Framework AND with the NHDC's own Strategic Objectives re. the Green Belt.

Sewerage & Flooding
This applies to sites IC1 and IC3 as the evidence suggest that the current main sewer cannot cope with the existing demand & these sites will add to that problem. This is also counter to the NHDC's own policy not to develop on land prone to flooding.

Lack of proper consultation
This applies to sites IC3 and LS1, as the plan is not legally compliant, since the NHDC have not allowed prior consultation on these sites.

Traffic
This applies to sites IC1, IC2, IC3 and LS1 as the NHDC's modelling is flawed because it does not account for increased traffic from Central Bedfordshire, and conflicts with the NHDC's policy on transport.

Air quality
This applies to sites IC1, IC2, IC3 and LS1 as the increased traffic pollution that will result conflicts with the NHDC's policy on air quality .

Relocation of the School
This applies to site IC3 - as an ex. Governor of the School my view is that the proposed relocation will impact Ickleford severely, which conflicts with NHDCs policy to protect and enhance the historic character of villages.

No coordination with neighbouring authorities
This applies to sites IC1, IC2, IC3 and LS1 as the NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan.

I do hope that my views will be considered when the Plan is debated, as I believe the current proposals will be disasterous for Ickleford.

I am writing to state my objections to the proposed sites developments in Ickleford for the following reasons:

sites IC1 and IC3 on the grounds of being not sound as evidence has shown that the main sewer cannot already cope with current demand and also sites are prone to flooding which will be exacerbated by further housing developments.

I am also objecting to sites IC1, IC2,IC3 and LS1 as being not sound in terms of traffic as the modelling does not take into account the additional traffic from central Bedfordshire housing increases and conflicts with NHDC policy on transport