LG3 Land east of Kristiansand Way and Talbot Way

This is another example of building on the green belt. It is clear from the green belt plan of 173 that there has already been development on a piece of the green belt in this area. Clearly the Garden City Heritage Foundation are ignoring the principles of Ebenezer Howard and this cannot be allowed to continue in a World Recognized Garden City (the first one!) which is a clam to fame of our town and brings people from all over the world to see what we have. Norton village should also be protected, it isn't part of Letchworth.

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I wish to register my opposition to the plans for the LG1 and LG3 sites in Letchworth as part of the council's local plan.

I believe that the number of proposed dwellings would have an extremely detrimental effect on the local area and on Letchworth Garden City as a whole. Building on Green Belt is unacceptable as it flies in the face of Ebeneezer Howard's principals for a Garden City and current government advice. It seems very odd to destroy the key principals the first gardens city whilst the government plans to build new garden cities.

Both the LG1 and LG3 sites risk merging Letchworth with stotfold and Baldock respectively, LG1 will expand Letchworth to within 50m of the Bedfordshire border. Any proposed sites should avoid urban sprawl and therefore I believe that this is unacceptable.

Both sites (particularly LG1 ) will greatly increase the traffic in the area and therefore increase the amount of pollution in the area as well. Many of the roads in especially Norton road and Green lane are already at capacity during peak times.The proposed sites are about 1.5 miles (2.4 km) away from Letchworth Rail Station. As acknowledged in the COTTEE report this is outside of expected walking distances hence additional traffic will add to congestion suffered at peak times. The station also has no infrastructure to cope with the likely increase in cars.

With the infrastructure of the town as a whole it lacks the doctors and schools to support the developments and there is no mention of how this will be addressed within the plans.

The LG3 site it proposed to be built right next to the newly discovered Bronze Age Henge, a site of national significance this should be celebrated and enjoyed rather than surrounding it with houses.

There are many brownfield sites within north Hertfordshire which though may not be as profitable should be built on first. If further housing is required then proposals suggested by our local MPs should be pursued and a new garden city established this would enhance Letchworth legacy rather than the current plans which would destroy it.

I hope you take these objections seriously.

As a Letchworth resident I object to building on site LG3.
I also object strongly about building on this land. First it is green belt land and is situated in the wrong place for extensive housing of 120 homes. There is little infrastructure to support this site. The historical village of Norton needs further protection.

I wish to register my opposition to building on the LG1 and LG3 sites in Letchworth as part of the council's local plan.

I believe that the number of proposed dwellings (especially in LG1) would have an extremely detrimental effect on the local area and on Letchworth Garden City as a whole. Building on Green Belt is unacceptable as it flies in the face of Ebeneezer Howard's principals for a Garden City and current government advice.

There are a number of brownfield sites around the town that should be redeveloped and used in place of this valuable countryside. The Green Belt and Greenway are the jewel in Letchworth's crown and should be protected rather than destroyed.

In addition, the proposed development would take Letchworth to within a few metres of the border with Bedfordshire (LG1) and potentially merge the town with Stotfold, which is also currently expanding at a rapid rate. LG3 also sees Letchworth move even closer to Baldock, with only the A1 and a field dividing the two towns.

The local road network is already extremely congested during peak hours, especially the junction of Norton Way and Green Lane and these developments would only serve to exacerbate this situation. The COTTEE report that was commissioned by the Heritage Foundation states that
1. "Letchworth town centre is about 3km walk (40 mins) which, although outside standard walking distances, is not unreasonable as a walk to work for an adult or college student."

This clearly implies that most residents in the new developments will travel by car to the town centre or station as LG1 will be "outside standard walking distances". LG3 will also be around this distance from the station and the town centre with Talbot Way being 2.6km from the station.
There is also no provision in the plan for any more school places or access to health care. Existing services are already being stretched- how will local services provide for this substantial growth in the local population? Are there sufficient school places for the expected number of children or will we see families forced to travel further afield to access schools or hastily erected temporary classrooms?
I would urge North Herts council to protect Letchworth, the world's first garden city, and to consider alternatives such as a new Garden City, which is an option supported by local MPs, Stephen MacPartland, Sir Oliver Heald and Peter Lilley. (http://www.thecomet.net/news/mps_back_new_garden_city_as_alternative_to_council_s_north_herts_housing_blueprint_1_3936165)
The role of the council is to represent the people. Please listen to the opinions of the people you represent. Once the Green Belt has been built over, it is lost forever. Please do not remove the "green lungs" and also the heart of the Garden City.

General Comments

1. Historic Towns
I am disappointed and surprised that Letchworth Garden City is not included in your designation of historic towns. The world's first garden city is of national and international importance, much studied and visited by researchers and planners. It is valued too by residents.

2. Numbers
Where have the enormous numbers of required housing come from? Increases of this size cannot be justified for the extension of small settlements such as Letchworth. Many existing residents are beyond child bearing age, so will not be producing more children who require housing. Where will the new residents come from? Letchworth has now reached its planned maximum size of 32,000.

3. Green Belt
Letchworth's Green Belt is an integral part of the garden city. It is where the idea of a green belt was pioneered. It has been much copied around this country and is revered around the world. It is part of national legislation, a valuable and popular part of planning laws. It has been reaffirmed by the present government which states that green belt should not be built on just to meet housing numbers. Open space is needed as well as housing.

Specific Areas
1. LG1 Land north of the Grange Estate
This area is not suitable for a large number of houses, which will destroy the green belt leaving only a narrow one field strip between Letchworth and Stotfold. As well as preventing urban sprawl, this land is valuable for biodiversity.

2. LG3 Land north east of Kristiansand Way
Here the green belt provides separation between Letchworth and the village of Norton, which has a long history as a separate settlement and is valued as such. There are archaeological sites here which need investigation and should not be built on.

Policy SP5 Countryside and the Green Belt
Policy SPG15 Site LG1 North of Letchworth Garden City
Paragraph 13.215 LG3 Land East of Kristiansand Way and Talbot Way
Where a large areas of existing Metropolitan Green Belt North and East of Letchworth has been re-designated as residential development land and proposals for the use of these sites (LG1 and LG3) for housing development.
These policies are not Legally Compliant as the Sustainability Assessment does not form a suitable assessment of the sustainability of the council's proposals. The SA does not consider the undesignated heritage asset status of the Green Belt which was an integral part of the design of Letchworth, and the first designed Green Belt in England. The Green Belt is an important factor in the setting of the Heritage Asset which is the town of Letchworth.
These policies are not Sound as:
a) They are not positively prepared as they are not consistent with achieving sustainable development as set out in NPPF. 7 pg 2
"There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:"

"an environmental role- contributing to protecting and enhancing our natural, built and historic environment;......"
They are not justified or consistent with national policy as they do not comply with the following sections of NPPF:
a) 9 Protecting Green Belt Land
79 The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence.
80 The Green Belt serves five purposes:
to check the unrestricted sprawl of large built up areas
to prevent neighbouring towns merging into one another
to assist in safeguarding the countryside from encroachment
to preserve the setting and special character of historic towns
to assist in urban regeneration, by encouraging the recycling of derelict and other urban land."
The proposals in SP5, SP15 and para 13.215, to re-designate the Green Belt land north of Letchworth, do not recognise or conform to all of the above five purposes.
83"...Once established Green Belt boundaries should only be altered in exceptional circumstances..."
MP Brandon Lewis confirmed in his letter to Boris Johnson of January 2015, that the need to meet Housing Targets did not constitute exceptional circumstances.
"NPPF is clear that Green Belt should be given the highest protection in the planning system and is an environmental constraint which may impact on the ability of authorities to meet their housing need. This Department published guidance on 6 October 2014 which re-affirms that Green Belt boundaries should only be altered in exceptional cases, through the preparation or review of the Local Plan. The guidance also states that the housing need alone does not justify the harm done to Green Belt by inappropriate development when drawing up a Local Plan."
The exceptional circumstances have not been demonstrated and reasonable alternatives to the use of sites LG1 and LG3 have not been identified, described and evaluated before the choice was made. The sites included in the appraisal were only those which owners put forward and the Draft Sustainability Appraisal document sets out in para 5.2.1 that to be considered a site had to be available for development. No alternative sites which would not cause such harm to the significance of Letchworth and its Green Belt were sought.
b) 11 Conserving and enhancing the natural environment

109 " The planning system should contribute to and enhance the natural and local environment."
110 "...Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this framework."
The Green Belt Review Study, sets out a scoring process for the sites put forward by owners which aims to establish which sites make the most significant contribution to the Green Belt. This system is flawed in the following ways and therefore not justified or consistent with national policy:
a) It says on page 30, para 44. "Letchworth Garden City has a relatively strong relationship with the surrounding countryside, particularly to the south where there is a clearer connection to the original footprint of the town."
This statement is not justified, the "original footprint of the town" quoted is simply the first area developed, from Norton Road in the north to Baldock/Hitchin Road in the south. This was by no means the intended size of the Garden City, Howard designed it to have 32,000 residents, that number has only recently been achieved with the addition of the Grange, Jackmans, Lordship, Manor and Westbury Estates. The town's relationship with the surrounding countryside is equally as strong in the north as in the south.
The following quote from Ebenezer Howard's book, Garden Cities of Tomorrow 1902 is relevant:
"Garden City has, we will suppose, grown until it has reached 32,000. How shall it grow? How shall it provide for the needs of others who will be attracted by its numerous advantages? Shall it build on the zone of agricultural land which is around it and thus forever destroy its right to be called a "Garden City"? Surely not. This disastrous result would indeed take place if the land around the town were, as is the land around our present cities, owned by private individuals anxious to make a profit out of it. For then as the town filled up, the agricultural land would become ripe for building purposes, and the beauty and healthfulness of the town would be quickly destroyed. But the land around Garden City is, fortunately not in the hands of private individuals: it is in the hands of the people: and is to be administered not in the supposed interests of the few, but in the real interests of the whole community."
b) Page 25, Parcel 22, under heading "Preserve setting and special character of historic towns"
"Forms part of countryside between Letchworth and Stotfold in Beds. Performs a more limited function due to landform resulting in limited views of any historic towns".
This analysis is far too simple, the historic town of Letchworth, the world's first garden city, and its integral Green Belt is completely ignored. The built up boundaries of Letchworth are clearly visible and its surviving Green Belt still performs its original design function to allow residents access to the countryside and for the grade 2 agricultural land to be farmed, and to provide the countryside setting for the Garden City as envisaged by Howard.

c) Page 117 section 5.3. Assessment of Potential Development Sites Land East of Talbot Way, and Land North of Croft Lane.
These sites adjoin Norton Conservation Area and Norton should be assessed as a village whose built boundaries should not be extended (in the same way that Willian the village to the South of the town, has been assessed). The statement in the Local Plan 2011-2031 page 181 para 13.209, that Willian has not been absorbed into the Garden City whilst Norton has, is not correct, Norton retains 3 sides of the village in contact with the countryside and it is only the houses on the East side of Norton Road which link it to the Garden City. Willian has a similar link along Willian Road from Letchworth Gate.
d) Page 118 North Letchworth
We do not consider the assessment to be accurate, this potential development site has 3 sides (North, East and West) which do not have development adjacent, if this had been used for analysis, rather than how many sides have development adjacent, then this site would have scored more highly. The wildly different shape of sites means that this method of assessment is not accurate.
There is no mention in the NHDC Local Plan or any background documents, of the proposed 22.5 hectares of residential sites to the East of Hitchin Road, in Central Beds Draft Local Plan, (work has already started on some of the houses). These proposals will bring the proposed development of North Letchworth closer than 500m to this Central Beds development, which as an extension of the Fairfield development will almost link Letchworth and Fairfield. The effect on the Green Belt has not been taken into account and this should result in a higher score under Towns Merging heading. The proposed development would also reduce the Green Belt between Letchworth and Stotfold to 500m in places. It is evident that the development of this North Letchworth site would result in the unrestricted sprawl that Green Belt designation is designed to prevent. The issue of co-operation on strategic and cross-boundary issues is relevant here.
Under the heading of "Preserve setting of historic town" this analysis says "site not within or affecting setting of a conservation area of a historic town". This is not a correct assessment of the importance of Letchworth's Green Belt as an integral part of the town's design and an important factor in its setting. The significance of the historic town of Letchworth, the world's first Garden City, would be seriously harmed by the loss of this area of Green Belt. A higher score should have been given here.
There is no Heritage Assessment Document for Letchworth prepared as part of the Background Papers, although Baldock Hitchin etc. have such assessments. A well informed Heritage Assessment for Letchworth would have identified the special historic character and significance of the World's First Garden City and its Green Belt, the first designed Green Belt in England.

Whilst Letchworth has its designated heritage assets in the form of listed buildings and Conservation Areas, it is also of local heritage importance in its entirety, as designed, with its Green Belt. This has not been considered in this Local Plan exercise.

Policy SP17 Site HT1 Highover Farm Hitchin
This policy is not Sound as it is not consistent with national policy.
NPPF says that green belt should only be altered in exceptional circumstances. Here the green belt between Hitchin and Letchworth will be reduced to 500m if this development goes ahead. No exceptional circumstances have been demonstrated.
The development will result in the unrestricted sprawl that the green belt is designed to prevent.

The modifications we would like to see are the removal of LG1, LG3 and HT1 from the list of proposed development sites and an exercise to identify sites to provide the housing needed in locations which do not harm the significance of Letchworth Garden City and its Green Belt.

We would like to participate at the oral part of the examination.

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