LS1 Land at Bedford Road

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

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

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

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

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

The proposed LS1 North Ickleford (near Lower Stondon) 120 home development falls foul on a number of key factors. They are detailed below.

LS1 in the context of other proposed developments
It is not possible to decouple the proposed LS1 development (North Hertfordshire) with those under consideration in neighbouring Lower Stondon (Central Bedfordshire). The proposed LS1 site is within c.500m of the proposed 100 home development on Welbeck land in Lower Stondon AND within c.300m of the proposed 800+ home development on ex-Ministry of Defence land at RAF Henlow. A total of c.1,020+ homes in addition to existing developments being undertaken adjacent to Station Road in Lower Stondon, and more along the A507 corridor into Central Bedfordshire - numbers unknown.

With particular reference to issues relating to the A600 carriageway between Lower Stondon and Hitchin (including Ickleford) it is not possible to decouple the proposed LS1 development from the proposed IC2 (Burford Grange) and IC3 (Bedford Road) developments within Ickleford.

Conclusion. In my view there has been inadequate local consultation in relation to the proposed LS1 development, and/or the cumulative effects of the IC1, IC2, IC3 and LS1 developments, and proposed developments in Central Bedfordshire along the A600 Bedford Road corridor. It is therefore 'not legally compliant'.

A600 Bedford to Hitchin road
The heavily used A600 is the ONLY direct carriageway heading south from the proposed LS1 development into the small market town of Hitchin - itself a known bottleneck during key periods of the day and the connect town to A1 access - as well as Luton. On ANY given day, in particular but not exclusively at rush-hour pinch points, the southbound A600 often features tailbacks from the Hitchin one-way system at Bedford Road/Paynes Park up to and beyond Old Ramerick Manor Farm and further into Lower Stondon - a distance of c.2.5 to 3 miles plus.

For example: Any incident on the A602 south of Hitchin and/or southbound A1 carriageway close to Hitchin will under normal circumstances result in the above scenario - likewise any incident in Hitchin and/or Ickleford. Any incidence of precipitation (fog included) particularly during the 7am - 9.00am window will more often than not extend traffic beyond the stated 3 miles. Any temporary and/or protracted roadworks will also have a detrimental effect.

The A600 stretch between Lower Stondon (and further north) to Ickleford in the south (c.2.5 miles) has a chequered safety record - one which has been woefully underappreciated by 'system says no' analysis based on street 'average accounting' monitors, non-existent site visits and/or consultation, and equally misleading analysis based on road safety algorithms - both at NHDC and Central Bedfordshire.

There have been two recent fatalities (one particularly tragic relating to a pedestrian and widely reported) and a series of incidents particular to the junctions of the A600/Holwell Turn, the A600 and the private roads for Old Ramerick Manor Farm and Holwellbury, and the speed limit transition northbound into the margins of Lower Stondon - all close or directly adjacent to the proposed LS1 development. Mere tinkering with speed limits has historically failed to adequately correct what is a locally known (local authority blind) as clear and present danger.

The A600 between Lower Stondon and Ickleford also has additional dangers and stress points.
- It is the preferred choice for users of pantechnicons between and servicing Hitchin and Bedford, 24 hours a day.
- The A600 services 4 arable farms (plus additional working farms requiring access to the A600 from Holwell and Pirton). In particular Old Ramerick Manor Farm and its associated ingress and egress point from the Bedford Road, opposite Holwellbury and entirely adjacent to my property and the proposed LS1 development. At key times of the farming calendar heavy farm machinery either on the carriageway (much of which is 60mph rated) and/or seeking ingress (and worse still egress onto the A600) is a clear at present danger.
- The A600 services a number of homes, a majority of which are within the 60mph zone - all suffering from dangers and considerable difficulties of egress onto the A600 at peak times.
- The A600 also services a number of businesses including a local construction business adjacent to the proposed LS1 site, a number of public serving nurseries, a fencing business and a Biffa waste disposal centre - all have shown evidence of requiring the ingress and egress from the A600 - including some on-road loading.
- The A600 is also a popular pedestrian route from Lower Stondon to the Public Footpaths close to Old Ramerick Manor Cottages (this has and will increase markedly), as well as being a nominated route for Duke of Edinburgh participants. The footpaths the entire length of the A600 between Lower Stondon and Ickleford are unsubstantial and inadequate - in the extreme!

Conclusion. During 20+ years as a resident I have NOT ONCE been directly consulted about a strategy for road traffic volume management and/or safety measures on the A600 despite being on record (NHCD, Central Bedfordshire, Hertfordshire Police) for raising issues relating to road safety post the pedestrian fatality adjacent to No 1, Old Ramerick Manor Cottages, SG5 3SB. Fixed monitoring devices and analysis based on algorithms have been, and continue to be misleading and/or unsatisfactory.

I am NOT aware of any bi-partisan consultation and/or analysis between Central Bedfordshire and NHDC on the effects the increase in traffic from Central Bedfordshire has on NHDC policy to transport. Referring to the NHDC Infrastructure Delivery Plan 2011-2031 (September 2016) - Point 5.107 it is stated that key areas of Hitchin are ALREADY at 100% traffic capacity at peak times.

The A600 (and I'd suggest the traffic management within Ickleford and Hitchin per se) is to most eyes incapable of sustaining this level of development without a clearly-defined, evidence-based process of consultation, reviews, proposals and iterations - with resultant needs-sensitive measures.

Particular to No's 1 and 2 Old Ramerick Manor Cottages, SG5 3SB
No's 1 and 2 Old Ramerick Manor Cottages, SG5 3SB are sited directly adjacent to the A600 (opposite Holwellbury) and the proposed site LS1 site. Ingress and egress to the properties is via a private road shared with No's 3 and 4 Old Ramerick Manor Cottages, No's 1, 2, 3 and 4 of the newly constructed Old Ramerick Manor Barns, the listed Old Ramerick Manor and Old Ramerick Manor Farm. The private road is also an extensively utilised public footpath.

Conclusion: Over and above a general increase in public footpath footfall and noise consistent with the construction and eventual habitation of c.120 homes, it should be noted that No's 1 and 2 Old Ramerick Manor Cottages SG53SB benefit from certain covenants which must be protected - in particular the right to discharge run-off water from our joint septic tank, into the area designated as the proposed LS1 site.

You will notice for balance that I have not detailed any 'softer' considerations relating to property values and/or macro or micro environmental impacts. Ends.

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

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

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

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

Not Sound -

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

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

Not Sound -

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

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

Not Sound -

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

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

Ickleford Conservation area
Not Sound -

a) Conflicts with NHDC designated conservation area.

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

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

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

See attached

See attached

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

Site IC1 Duncots Close

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


IC2 Burford Grange.

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

IC3 Bedford Road.

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

Site LS1 Lower Stondon.

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

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

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

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

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

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

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

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

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

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

We would like to raise the following objections:

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

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

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

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

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

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

See attached

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 emailing to submit objections to the proposals concerning IC1, IC2 & IC3 based on conflicts between the Local Plan and NHDC/national policies.

My concerns are:
* That all the sites listed above, the local plan in 'not sound' as it conflicts with National Planning Policy framework and conflicts with NHDC Strategic Objectives on Green Belt
* 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. This is one of the aspects I feel most strongly against- my son has just started at the Primary School and I feel that the upheaval of all the school children for the relocation of the school would be detrimental to their wellbeing and education. It would also destroy ties with the local St Katharine's Church, and stop the children being able to walk over for activities such as services. I feel this is an important part of teaching the school's core values, and would be a great shame for the children to lose character building activities they get so much enjoyment out of. It would also make it extremely difficult to have one child at the school and one at pre-school, and increase traffic through the village for school drop offs and pick ups.
* I feel that the build of site IC3 would negatively affect our home life and ability to enjoy the countryside around us. We are in the middle of a build at the end of Wyatt Close, and the contractors regularly start noisy work (illegally) before 8am despite our complaining directly to them. Given that this is a small build compared to the scope of proposed build, we can only imagine the noise disruption we will experience in the early morning, as the contractors obviously do not respect the regulations in place to protect local residents.
* 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, I have heard incidents of sewage spilling into residents' properties just on the current demand; IC1 and IC3 will add to this burden. It also conflicts with NHDC policies not to develop in areas prone to flooding, and to reduce the risk of flooding from new developments
* There has been a 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
* 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
* 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
* 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 look forward to hearing your responses.

See attachment

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.

See attached