IC3 Land at Bedford Road

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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I object to the inclusion in the draft local plan of housing site IC2 (Burford Grange, Ickleford) and part of housing site IC3 (Bedford Road, Ickleford). In both cases my objection is based on the argument that the site's inclusion is not based on proportionate evidence and is therefore not justified as described by paragraph 182 of the National Planning Policy Framework.

Site IC2

This site was first identified as a possible site for housing in 2013 when the council published its Housing Options paper. It was then called 'site 40' and it was categorised as a 'priority 3' site. In order to be included as a 'priority' site it was only necessary for sites to be physically capable of being developed by a willing owner and to be capable of making a profit (Housing Options para. 3.2). In other words, no planning judgement was involved. Planning judgement was only used to divide the 'priority' sites into categories: category 1 (those 'most likely to be acceptable'), category 2 (those that were 'moderately acceptable'), and category 3 (those 'least likely to be developed'). Priority 3 sites were therefore ones that were considered unsuitable in planning terms in varying degrees. Even sites that were totally unacceptable from a planning point of view were given a 'priority 3' ranking. I objected at the time, arguing that such a terminology was misleading because it implied that all sites with a 'priority' were regarded as being preferable to others - those over which they had a priority - when in fact all sites that had been put forward by owners were included provided that they were physically and financially capable of being developed.

The explanation for giving the site only a 'priority 3' classification was given in the SHLAA, the most recent of which had been published in December 2012. It was stated that developing this green belt site would 'erode the narrow gap between Ickleford and Hitchin'. (Maintaining the separation of settlements is, of course, a key green belt function.) That conclusion was not surprising. Ickleford is a separate village from its neighbouring town but that separation is fragile.

The distance between the nearest properties in Hitchin and those in Ickleford is only about 250m. The intervening land, of which Site IC2 forms a major part, accommodates just a very few houses in largish grounds. Having that break produces for both residents and all those travelling on Bedford Road - the main road between the two settlements - a sense of leaving one settlement before entering the other. That sense would be destroyed if this site were to be developed as a new housing estate. Ickleford would be perceived to be simply a part of Hitchin.

Only one other road links Ickleford to Hitchin - Old Hale Way (which becomes 'Arlesey Road' in Ickleford). On that road, too, there is a gap between the two settlements. The gap is similar to that on the Bedford Road, comprising a roughly 250m stretch of mainly undeveloped land. That gap is also important in maintaining the identity of the village as a separate settlement, and I note that there is no proposal to allocate housing there.

Of those two gaps which separate the village from Hitchin, the one in which the objection site lies is by far the more important. Bedford Road is an 'A' road (the A600) and is the main route between Hitchin (and Stevenage further south) and Bedford. It carries a huge amount of traffic, whereas Old Hale Way is just a residential street. For most people, therefore, the perception of Ickleford as comprising a distinct settlement and not being merely a part of Hitchin is critically dependent on maintaining Site IC2 as open land.

I assume that the reason why the council has changed its mind since the Housing Options paper was issued, and now proposes allocating Site IC2 for housing despite its earlier view that its development 'would erode the narrow gap between Ickleford and Hitchin' is that its allocation is necessitated by the demand for housing land. I am not arguing that the mere fact that Site IC2 lies in the green belt is sufficient to rule it out. It may be the case generally that the demand for housing in North Herts is such as to constitute exceptional circumstances justifying the redrawing of green belt boundaries. However, when the Housing Options paper was published Ickleford was envisaged to provide a total of just 9 dwellings, all of which were to be located on what is now Site IC1 (land to the rear of Duncots Close). The 48 dwellings then estimated to be possible on Site IC2 were obviously not required - or at least not sufficiently required as to justify the harm that would be done by eroding the green belt gap between the village and Hitchin.

It may be the case that since 2013 the perceived demand for housing has increased. However, I find it hard to believe that that increase has been sufficient to justify the enormous increase in housing provision demanded of Ickleford. The Proposed Submission local plan envisages no fewer than 319 houses being added to the village. In addition, since the Housing Options paper was issued, planning permission has been granted for 8 houses right in the centre of the village on the site of the former Green Man pub, and a planning application (which I have written to support) has been submitted for a development of 19 houses, again right in the centre of the village on the Ickleford Manor site. These sites (the latter if approved) cannot be dismissed as 'windfall' sites, irrelevant to the local plan process. They go towards meeting housing need. They are both 'previously developed' sites. Their contribution allows less acceptable sites, such as Site IC2, being dropped from the plan.

The additional housing sites in Ickleford - IC3 and LS1 - were added to the draft plan only at the most recent stage, when the Proposed Submission version was issued. They have therefore not been the subject of public consultation until now. Together, they would provide a total of 270 homes. In my opinion (and I comment in more detail below on Site IC3) their development, although regrettable and harmful to the countryside, would not be as harmful to the green belt as would the development of Site IC2 because they are not located in the gap between Ickleford and Hitchin. When the council was alerted to these sites it should have reconsidered whether it was still right to maintain Site IC2 as an allocated site. Had it done so, I believe that it would have concluded that Site IC2 should now be dropped.


Site IC3

This site straddles a public footpath which runs from the Bedford Road eastwards to the village playing field. The footpath's eastern half forms the northern boundary of the village's built up area. In my opinion the development of that part of the site which lies on the unbuilt southern side of the footpath would be acceptable, but to allow the built up part of the village to cross over to the northern side of the footpath would not. Development of the part of the site that lies south of the footpath could almost be regarded as infilling.

Allowing housing development to the north of the footpath would have two damaging effects. First, it would ruin a very pleasant walk. Instead of a walk with fields on at least one side, with the path forming a natural and obvious boundary to the village on the other, the walk would be reduced to a route through a new housing estate. Second, it would see an unacceptable degree of encroachment onto open countryside. While there is some development north of the path on the Bedford Road, it is not visible from the path itself and the view northwards from the path is one of open countryside. That would be totally ruined the whole of Site IC3 were developed.


Traffic

Bedford Road is very busy already. In the morning peak, and especially during school term time, there is always a long a queue of cars into Hitchin. Often the queue stretches all the way from the mini roundabout at the top of Turnpike Lane right to the town centre. I know that route intimately as I live on it, and for many years until I retired I used it daily to get to Hitchin train station to commute into London. Now, if I have an appointment at 9 am in Hitchin I have to leave the house before 8.30, and even then I often choose to go via the village centre, which is itself busy at that time.

In my opinion Bedford Road is not capable of accommodating any significant increase in traffic, either from Site IC2 or Site IC3. Development on Site LS1 would exacerbate the problem.


Appearance at the Public Examination

I do wish to appear at the public examination. However, if there are others who will be appearing who make the same points, not least Ickleford Parish Council, I would be happy to allow this written objection to suffice.