RY8 Land at Lumen Road

Regarding the consultancy process for the local development plan, please find below my representation. I would like to start by saying that in principle, I am fully supportive of the need to increase housing stock within the area however I would like to raise two comments in relation to proposed local plan and its impact on Royston.

Firstly, it is my firm belief that the redevelopment of brown field sites should be prioritised over the development of any new sites. Take, for example the site on Lumen Road (RY8) that has been derelict for many years. Unfortunately any progress towards redevelopment has been difficult to determine often due to closed council sessions. I appreciate that there is a concern that the site is potentially contaminated however I would assume that it would make sense (morally and ethically if nothing else) to decontaminate the land and convert it to residential use rather than leave it as a contaminated, derelict eyesore that encourages vandalism and other anti social activities. Everyone gains as decontaminating the land would clearly benefit the wider community making the area a better area to live.

The second point relates to certain of the significant employment and residential sites proposed. The plan describes a significant employment opportunity on the north west of Royston - RY9 - and two significant housing proposals on the east side of town - RY2 (330 homes) and RY10 (300 homes) - on the opposite side of town. Given the locations of these sites and together with the location of the rail station, it is reasonable to assume that one consequence of this would be a significant increase in cross-town traffic. These two residential sites alone represent an almost 10% increase in housing compared to the 2011 census number of 6800 dwellings and the increase in volume of traffic would be expected to be similar. There are only a very limited number of routes to get from one side of town to the other with people preferring to use either the route through the town centre, or rat-runs predominantly consisting of Mill Road, Queens Road and Stamford Avenue, rather than using the A505 bypass. The areas described (Mill Road, Queens Road and Stamford Avenue) are residential areas and should not be considered as major conduits to aid traffic flow. These residential areas are already blighted by traffic and excessive speeding (with the very limited speed restriction humps on Mill Road being virtually pointless) and if anything, efforts should be in place to reduce or control traffic flow rather than increase it.
To the best of my knowledge, no studies have been presented to determine the impact of having employment and residential areas on the opposite side of Royston will have on the local roads - with Aecom transport studies not extending as far as Royston. There is apparently a COMET study of traffic flow in Royston however details of the study (methodology and results) have not been provided as part of the Supporting evidence. Some limited data is available through the supporting document (Local Plan Transport Technical Review (Odyssey Markrides 2016) which suggests several roads with volumes over capacity during peak times including through the town centre. This will only serve to force even more traffic through "rat-runs". Currently, it is not clear whether the impact on side roads and residential roads was considered in the study. Regardless, I would emphasise that as part of any development strategy, measures should be included to ensure that traffic flow these areas (Mill Road, Queens Road and Stamford Avenue) are not adversely affected by the proposals in question.

Finally, the document describes a vision to make North Hertfordshire an attractive and vibrant place where people will want to live. This is an admirable vision however I believe this can only be achieved if the existing residents views are taken into account during the consultancy.

See attached

Thank you for the opportunity to comment on the North Hertfordshire Proposed Submission Local Plan. The following response is submitted on behalf of Anglian Water.

I would be grateful if you could confirm that you have received this response.

Policy SP7: Infrastructure requirements and developer contributions (legally compliant - yes and sound - yes)

Anglian Water is generally supportive of Policy SP7 as it states that planning permission will only be granted if it can be demonstrated that development proposals make provision for infrastructure that is necessary to accommodate the additional demands resulting from the development.

Policy SP9: Design and sustainability (legally compliant - yes and sound - yes)

It is noted that Policy SP9 includes a requirement for residential development to meet the optional water efficiency standard (110 litres per person per day). We would support the optional water efficiency standard being applied within the North Hertfordshire Local Plan area.

Policy SP11: Natural resources and sustainability (legally compliant - yes and sound - yes)

Policy SP11 includes a requirement to optimise the potential of the site to include the Sustainable Drainage Systems (SuDS) prior to planning permission being granted. We support this requirement as it is important to maximise the potential use of the SuDS to ensure that new development does not increase the risk of surface water and sewer flooding.

Policy SP15: Site LG1 - North of Letchworth Garden City (legally compliant - yes and sound - no)

Historically, sewage treatment assets have been sited at a distance from sensitive land uses, in recognition that these are an incompatible use. Our concern is to prevent the encroachment of Anglian Water's assets by sensitive development which could give rise to future amenity loss and impose additional constraints on the operation of our assets.

The above strategic site is located within close proximity to Letchworth Water Recycling Centre (formerly sewage treatment works) in the ownership of Anglian Water.

Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage. Where it is proposed to allocate sites within close proximity of the water recycling centres there is a need to consider further the odour impact and the extent to which sensitive development (that which is regularly occupied by people) could be accommodated on the site without having an adverse impact on future residents and/or employees who will be based on the site.

It is therefore suggested that Policy SP15 should be include the following wording:

'Undertake a detailed odour assessment to demonstrate no adverse impact on future residents and occupants of non residential buildings. To provide evidence to demonstrate that a suitable distance is provided from Letchworth Garden City Water Recycling Centre and sensitive development (buildings which are regularly occupied) as part of the detailed masterplanning of the site.'

Burymead Road (sites HE2 and HB3) (legally compliant - yes and sound no (effective)

Historically, sewage treatment assets have been sited at a distance from sensitive land uses, in recognition that these are an incompatible use. Our concern is to prevent the encroachment of Anglian Water's assets by sensitive development which could give rise to future amenity loss and impose additional constraints on the operation of our assets.

The above sites are located within close proximity to Hitchin Water Recycling Centre (formerly sewage treatment works) in the ownership of Anglian Water.

Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage. Where it is proposed to allocate sites within close proximity of the water recycling centres there is a need to consider further the odour impact and the extent to which sensitive development (that which is regularly occupied by people) could be accommodated on the site without having an adverse impact on future residents and/or employees who will be based on the site.

It is therefore suggested that Policy HE2 and HB3 should include the following additional wording:

'Undertake a detailed odour assessment to demonstrate no adverse impact on occupants of non residential buildings. To provide evidence to demonstrate that a suitable distance is provided from Hitchin Water Recycling Centre and sensitive development (buildings which are regularly occupied) as part of the detailed masterplanning of the site.'

RY4: Land north of Lindsay Close (legally compliant - yes and sound no (effective)

Historically, sewage treatment assets have been sited at a distance from sensitive land uses, in recognition that these are an incompatible use. Our concern is to prevent the encroachment of Anglian Water's assets by sensitive development which could give rise to future amenity loss and impose additional constraints on the operation of our assets.

The above strategic site is located within close proximity to Royston Water Recycling Centre (formerly sewage treatment works) in the ownership of Anglian Water.

Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage. Where it is proposed to allocate sites within close proximity of the water recycling centres there is a need to consider further the odour impact and the extent to which sensitive development (that which is regularly occupied by people) could be accommodated on the site without having an adverse impact on future residents and/or employees who will be based on the site.

We note that Policy RY4 includes reference to the preparation of an odour assessment for the above site which is welcomed. However it is unclear how the findings of the odour assessment (once prepared) would be considered further as part of the planning application process.

It is therefore suggested that Policy RY4 should be include the following wording:

'Undertake a detailed assessment of the impact of the Royston Water Recycling Centre in relation to odours, lighting, noise and traffic impacts to demonstrate no adverse impact on future residents. To provide evidence to demonstrate that a suitable distance is provided from Royston City Water Recycling Centre and sensitive development (buildings that are regularly occupied) as part of the detailed masterplanning of the site.'

RY8: Land at Lumen Road, Royston (legally compliant - yes and sound no (justified and effective)

We closely monitor growth in our region and develop investment plans to reduce flow and load from the catchment or provide additional treatment capacity when appropriate. Reference is made to development of this allocation site being phased in relation to the improvements at Royston Sewage Treatment Works. It is unclear why this has been identified a specific requirement for this allocation site only and no other sites within the Royston catchment.

It is therefore suggested that the fifth bullet point of Policy RY8 should be deleted as follows:

Phasing of development to link with Sewage Treatment Works improvements;

Policy D1: Sustainable design (legally compliant - yes and sound - yes)

Policy D1 includes a requirement to optimise the potential of the site to incorporate Sustainable Drainage Systems (SuDS) prior to planning permission being granted. We support this requirement as it is important to maximise the potential use of the SuDS to ensure that new development does not increase the risk of surface water and sewer flooding.

It is also noted that Policy D1 includes a requirement for residential development to meet or exceed the optional water efficiency standard (110 litres per person per day). We would support the optional water efficiency standard being applied or exceeded within the North Hertfordshire Local Plan area.

Policy NE8: Sustainable drainage systems (legally compliant - yes and sound - yes)

We support the requirement that drainage solution follow the SuDs hierarchy as this will ensure that disposal of surface water to the public sewerage network will be only be considered where it is demonstrated that there are no suitable alternatives. This will help to ensure that new development does not increase the risk of surface water and sewer flooding.

Policy NE10 : Water Framework Directive and wastewater infrastructure (legally compliant - yes and sound - (justified and effective)

Reference is made to new or improved waste infrastructure being secured under the requirements of Policy SP7.

In general, water recycling centre (previously referred to as sewage or wastewater treatment works) upgrades where required to provide for additional growth are wholly funded by Anglian Water through our Asset Management Plan. Foul network improvements are generally funded/part funded through developer contribution via the relevant sections of the Water Industry Act 1991. The foul infrastructure requirements will be dependant on the location, size and phasing of the development. All sites will require a local connection to the existing sewerage network which may include network upgrades.

As set above we seek contributions directly from developers in accordance with the provisions of the Water Industry Act 1991. Therefore Anglian Water would not expect there to be provision within planning obligations sought by the District Council or Community Infrastructure Levy in accordance with planning legislation.

The majority of allocations sites proposed within the Anglian Water region are expected to require improvements to the foul sewerage network. Please see enclosed spreadsheet for further information. It is important to note that the impact on the foul sewerage network and relevant water recycling centres have been assessed on an individual site basis.

Therefore we would suggest Policy NE10 should be amended to make it clear that applicants will be expected to demonstrate that there is capacity within foul sewerage network and at the relevant water recycling centre or that capacity can be made available in time to serve the development.

It is therefore suggested that Policy NE10 be amended as follows:

'Mechanisms for delivering any necessary new or improved water and wastewater infrastructure are secured under the requirements of Policy SP7. Adequate foul water treatment and disposal already exists or can be provided in time to serve the development.'

Attendance at examination

Where we have sought modifications to the wording of proposed Local Plan policies as set out above we would wish to participate at the examination.