SP2 Land beween Horn Hill and Bendish Lane, Whitwell

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I object to SP2 being at the last minute being included in the Local Plan.

This appears a very undemocratic way of proceeding and rather underhand.

I should appreciate a response as to the process by which this was selected for inclusion without public consultation particularly as planning permission was recently refused over concerns of flooding and visual impact.

My grounds for objection are the reasons planning permission was refused and there is not the local infrastructure to sustain such a development.

I live in the High Street in Whitwell and am extremely disappointed that North Herts Council is ignoring the views of local residents.

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Object to Chapter 4, Policy SP8
Sites, including SP2, have been added at a very late stage and should be removed as they are not needed.
Object to Chapter 4, Policy SP2
The plan is not sound as the evidence used to identify sustainable villages is flawed. This results in isolated villages with no facilities such as a senior school and shops and very little public transport being seen as suitable for significant development. More evidence is needed on impact on car usage. Whitwell should be categorised as a 'B' village
require SP2 to be removed from the local plan

Conflicts with NPPF on Flooding. Para 100 and 101 requires that development should be directed away from sites at high risk of flooding. The site is known to flood, with the most recent event in February 2014, which was not explained by the LLFA models. The SFRA map clearly shows a major flow across the site in a 1 in 30 year flood event. A sequential approach has not been followed. There is no need or justification for allocation of SP2. To persisit with this is against National Policy and unreasonable given the mounting evidence.
Conflicts with NPPF on Flooding. Paragraph 100 requires that development should be directed away from sites at high risk of flooding. Local Plans should apply a sequential, risk-based approach to the location of development. Sites at high risk of flooding should only be developed where absolutely necessary. Para 101 states: The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. This policy has been disregarded and a sequential approach has not been taken.
The NPPF requires a Strategic Flood Risk Assessment (SFRA) to be completed to determine flood risk in relation to allocating sites for housing. The SFRA map clearly shows a major flow across the site in a 1 in 30 year flood event. The site is also assessed by Environment Agency as having a high to medium risk of surface water flooding. Actually the site is well-known to flood, with several events in living memory, the most recent being in February 2014. However that event was not explained by the models of the Lead Local Flood Authority because their models failed to take account of the already saturated ground. It is now emerging that the role of groundwater may not have been adequately considered in understanding the hydrology of this area. It is likely that during a wet season the groundwater levels could be significantly elevated under the SP2 site. The Mimram chalk stream emerges from the chalk aquifer nearby, just a few metres below. Certainly, extensive scientific investigation and evidence would be needed before development could go ahead on this site, which raises doubts how achievable this site would be.
It has been argued that development of this site provides an opportunity for the betterment of risk to the 3 properties in Cresswick that have been previously affected. According to the SUDS hierarchy, the only sustainable solution on this site would be infiltration basins (although there is evidence that even this will not work due to elevated ground water levels). A solution has been proposed by the developer, but the size of the basin turned out to be one and a half times the size of an Olympic Swimming pool, cutting 5m deep in to the hillside. In August 2016 the NHDC planning committee determined that the visual impact of these earthworks was unacceptable in terms of the core principles of the NPPF (paragraph 17) and refused the application. Meanwhile I understand that these 3 properties have taken advice on property level protection and still consider that the negative impact of the development greatly outweighs the residual flood risk. The LLFA stated that the risk is not significant enough to warrant public expenditure.
Allocation of this site is against NPPF guidance which states that development should be directed away from flood risk altogether, towards sites with a lower flood risk. This development has been justified only on the basis of unsound policy SP2 solely to meet District totals; it is not justified by local need and is strongly opposed by the Parish Council. There are far more suitable locations in the District for development without flood risk. Since the housing requirement has fallen there is now too much housing allocation in the Local Plan and absolutely no need to introduce new sites at high flood risk. There is no need or justification for allocation of SP2, and to persist with this is not only against National Policy, it is ridiculous in the face of the mounting evidence.
Conflicts with NPPF on Sustainable Transport. Whitwell is one of the worst locations in the District for development in terms of these policies. Its remote location will result in excessive use of the private car. No Travel Plan has been submitted to justify the allocation of this 6ha site and there is no local need for development of this scale. The site SP2 has not been justified on any grounds, other than the unsound policy SP2 (Category A) which argues that any village with a primary school should be expanded to help meet district totals.

Conflicts with NPPF on Promoting Sustainable Transport, including paragraphs 30, 34, 36, 37.

Whitwell is situated in a relatively remote rural location in the district, in the middle of an area of high quality Chiltern countryside, which is being eroded from all sides, especially from the west (Luton) and east (Stevenage), under the duty to cooperate.

The nearest supermarket is 5 miles. The nearest school is 6 miles but due to the selection based on distance rules, most students have to travel at least 8 miles, often requiring two round trips daily by private car. Much of the working population drives a similar distance to railway stations for commuting to London. There is very little employment in the village and development here is likely to increase out-commuting from the district.

Whitwell is accessible only via narrow lanes with passing places, which, along with the High Street, are frequently congested. Public transport is severely limited, with just a 2-hourly bus to Hitchin and no service at evenings or Sundays. Therefore any development in Whitwell will result in a directly proportional increase in daily travel by private car.

No Travel Plan has been submitted to justify the allocation of this 6ha site, which could lead to over 100 new houses and over 200 private cars travelling more than 10 miles per day. This is a significant increase in carbon footprint, which is contrary to the NPPF.

In conclusion, Whitwell is one of the worst locations in the District for development in terms of sustainable transport, pollution and carbon emissions. There is no proven local need for development of this scale, indeed the evidence of the Parish Council is to the contrary. It will be to the detriment of the character and amenity of the village and surrounding environment. Allocation of site SP2 has not been justified on any grounds, other than the unsound policy SP2 (Category A) which argues that any village with a primary school should be expanded to help meet district totals, over-riding any other local consideration or evidence.

Conflicts with NPPF on Conserving and Enhancing the Natural Environment. Whitwell's special rural location, midway between surrounding towns, provides an important amenity for them with its recreational paths and routes in unspoilt Chiltern landscape at the source of the Mimram chalk stream. Development of this site will degrade this amenity, having an unacceptable visual impact. This is also contrary to NHDC evidence in Area 203 Landscape Character Evaluation. This site is in the most sensitive water source protection zone and problems of surface water flooding and sewerage capacity pose an unnecessary risk to groundwater and the chalk stream.
Conflicts with NPPF on conserving and enhancing the natural environment. NPPF core principles in Para 17 include: "contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value..."

Whitwell is situated in a relatively remote rural location for the District, in the middle of an area of high quality Chiltern landscape, which is being encroached from all sides, notably from the west (Luton) and east (Stevenage), under the duty to cooperate. The village and its environs provides a valuable amenity to these towns and also attracts many walkers and cyclists from further afield (see photos).

The surrounding area is proposed as Greenbelt in the Submission Local plan and this field would become Greenbelt except for its designation as Category A village according to unsound policy SP2, which allows planners to expand the boundary to accommodate development in order to meet District totals. In the 1996 Local Plan, this area, including site SP2, was previously protected with designation as Landscape Conservation Area (LC1). Those policies expired in 2007.

Since 2013 the Chilterns Conservation Board have proposed this area as suitable for inclusion in the Chiltern AONB, joining up with the existing AONB, the other side of the A505 to the north.

Contrary to NPPF Para 170, the plan fails to recognise NHDC own landscape character evaluation for Whitwell Valley Area 203, which concludes that:
"large urban extensions and new settlements (>5ha) would not be appropriate within this Character Area, due to its relatively remote, rural and undeveloped character. It would be of an inappropriate scale and would introduce elements that would urbanise the landscape, altering the character and removing the existing key characteristics. Visual impacts would also be high due to the cross valley views currently experienced."
SP2 is a site of nearly 6ha and therefore the allocation of the site is contrary to the independent report findings for reason of visual impact.

The site is currently a productive agricultural field forming a prominent and integral part of the surrounding valley landscape (see photo). It is much appreciated by local community and visitors, being highly visible from footpaths in the area. Many popular recreational routes meet in the Village, including the Hertfordshire Way, Chiltern Way and Chiltern Cycleway.

NHDC planning officer has recognised the visual sensitivity of the site and has required that any development should be restricted to the lower part of the site. This would be harmful in itself but would inevitably lead to future development on the remainder of the site.

Adjacent to the site on the South is an ancient Green Lane dating back to Roman times, identified as Byway 36. This links with the Chiltern Way and forms part of a popular walk out of the village, with open views across the field in question to the opposite side of the valley. It is proposed to incorporate this as a "green corridor through the site" which seems an inappropriate urban construction. On the contrary the rural character of the lane and views from it across the valley should be conserved.

Adjacent to the site to the West is Bendish Lane, which is a popular and picturesque section of the Chiltern Cycleway. This pretty narrow lane, winding down the hill from Bendish, directly links the conservation areas of Bendish and Whitwell, with currently no development in between. Development on SP2 would fill in a large portion of this precious space and would transform the views from rural to urban.

This site lies entirely outside the currently defined settlement boundary and has no access from within the village. A new housing estate on this site will require a new access road from Bendish Lane, opposite the school entrance. This will increase the traffic and spoil the rural character of this lane and its views, including the setting of St Marys Chapel (Listed Building), which presently greet the visitor approaching the village.

The river Mimram emerges from the chalk aquifer behind the famous water cress beds at Nine Wells in west Whitwell. In fact this is the ancient origin of the name of the village, meaning "White Spring". The Mimram is one of only 200 chalk streams in the world and provides some rare and valuable habitats (see photo). The water is also abstracted to drinking water supply. The site SP2 is in a highly sensitive location for groundwater. The stream source only 100m away and 10m lower). In fact it is designated the most sensitive Source Protection Zone 1 (defined a the 50 day travel time from any point below the water table to the source).

Thames Water have confirmed that the existing sewerage system does not have capacity for the proposed development at peak time, so sewerage would need to be pumped to an underground tank for managed discharge at off-peak times. This poses an unnecessary risk to the water cress beds, habitats and drinking water. Unfortunately this evidence emerged only after finalisation of the submission local plan documents.

The site is also subject to surface water flooding, most recently in February 2014. A recent planning application determined that this would require Sustainable Urban Drainage basins one and a half times the volume of an Olympic Swimming pool, cutting 5m deep into the hillside. Alternative solutions may be technically possible but less reliable and sustainable. In August 2016, after finalisation of the submission local plan documents, NHDC planning committee found these earthworks would have an unacceptable visual impact and refused the application. Now there is new emerging evidence that infiltration may not even work at all on this site when ground water levels are elevated during a wet season. It is requested that this evidence may be presented at the hearing stage.

In conclusion, the site is in conflict with NPPF including paragraphs 109 and 110 in that it fails to "conserve and enhance the natural environment." Particular issues for this site are the visual impact, especially impacting recreational routes and lanes, and risk to ground water and the Mimram chalk stream.

Conflicts with NPPF on Plan-making. NPPF requires that true community consultation must be undertaken. Site SP2 has been added to the local plan at a late stage, after all the scheduled opportunities for public engagement and consultation. This means that the community has had insufficient opportunity to respond. The present consultation requires a very specific legal format of response, which has discouraged many from engaging
Conflicts with NPPF on Plan-making. NPPF requires that true community consultation must be undertaken. Para 150 states: Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities. Para 155 states: early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential.

By introducing SP2 at such a late stage, these requirements of NPPF have not been met. Site SP2 was been added to the draft local plan at the final stage of preparation after all opportunities for public engagement and consultation had passed. This means that the community has not had a sufficient and reasonable time to respond, especially when compared to other sites. The present consultation exercise is no substitute because it requires a very specific and sophisticated format of response, which has discouraged most people from having their say.

Articles 18-20 of The Town and Country Planning (Local Planning) (England) Regulations 2012 outline the requirement for a Statement of Community Involvement. NHDC published their Statement of Community Involvement for the Local Plan in December 2012 and revised in 2015. This document specifies the timeframe and stages to be adopted Development Plan. This includes three separate phases of consultation prior to submission of the plan. The agricultural field now allocated as SP2 was previously designated as new Green Belt in the "Preferred Options" consultation 2014-2015. This was enthusiastically supported in representations from the local community (including from myself). The late inclusion of SP2 in the current version of the plan runs counter to the published SCI and did not provide local communities with adequate time or due process to respond.

In suddenly introducing this site, the draft local plan a) has not engaged sufficiently and early enough with the community; b) disregards the previous representations from our community and St Pauls Walden Parish Council supporting green belt protection to this land; and c) disregards the findings of the NHDC planning committee who found the site inappropriate for development in August 2016.

This part of the plan, which allocates site SP2 for housing, is unsound since it has not been prepared consistently with National Policy on Plan-Making. Therefore in order to make it consistent and legally compliant, the site SP2 should be deleted from the plan and the area reinstated as Green Belt.
The decision to include SP2 in the plan is not justified, not needed and is contrary to NHDC's own evidence.

Contrary to NPPF Para 170, the plan fails to recognise NHDC own landscape character evaluation for Whitwell Valley Area 203 (Attached), which concludes that:

Large urban extensions and new settlements (>5ha) would not be appropriate within this Character Area, due to its relatively remote, rural and undeveloped character. It would be of an inappropriate scale and would introduce elements that would urbanise the landscape, altering the character and removing the existing key characteristics. Visual impacts would also be high due to the cross valley views currently experienced.

SP2 is a site of nearly 6ha, so its allocation is contrary to the independent report findings for reason of visual impact.

The Strategic Housing Land Availability Assessment (Update 2016) Appendix 3 compares 5 sites in the Parish. According to this analysis (see attached), there are no clear winners, but SP2 has some conspicuous negative features: it is has high surface water flooding; it is the only site within the sensitive water source protection zone (SPZ1); it is by far the largest site but extraordinarily land-hungry, at only 7 dwellings per hectare.

The Sustainability Appraisal (update 2016) presents evidence in the form of appraisal matrices for these preferred sites (Appendix 6) and non-preferred sites (Appendix 7). Each site is rated positive, negative or neutral against 14 objectives. On this evidence, the preferred site SP2 actually ranks the lowest (most negative) of all the sites (see attached). Thus it is clear that the decision to allocate the site is contrary to the evidence presented to support the plan.

SP2 was the most recent site to be introduced, when a planning application was submitted after the last round of public consultation. In this latest version of the Local Plan, all other sites have been rejected in favour of SP2. However, this application was eventually tested by the NHDC planning committee in August 2016 and rejected, finding that the visual impact of the required SUDS would be unacceptable (see attached decision notice). That process brought a huge weight of new evidence into the public domain, which has not been taken into account in the present Submission Local Plan. Unfortunately by that late stage planners felt it necessary to allocate a site to the village at all cost and despite strong representations from the Parish Council, would not make any further changes to the Local Plan documents.

Housing Need is identified only in terms of District totals and unsupported generalisations in the unsound policy SP2 which is based on the false premise that any village with a primary school needs to expand to avoid social and economic harm. There is no evidence of any such local need for expansion of Whitwell. On the contrary, the school is already thriving and the local community are strongly opposed to the loss of countryside amenity and rural village character. This has been argued at every opportunity by the Parish Council, with the full support of the school. Now the district house target as reduced, increasing the buffer to 7%. The Local Plan now provides too much housing at the expense of precious countryside.

In conclusion, the allocation of site SP2 is not the most appropriate strategy, and is not justified when considered against the reasonable alternatives, based on proportionate evidence.

I am writing to object to the NHDC draft local plan on the grounds that the inclusion of SP2 in the plan neither complies with legal requirements or is a sound and sustainable plan for the future of North Hertfordshire
The area designated SP2 was not in the previous plan and was allocated as potential green belt outside the Village boundary. Recently planning permission for this area was refused as a high risk of flood and high impact to the visual beauty of the area. A strong village reaction to the planning permission co-ordinated through the Parish council helped defeat this planning application. The Parish council wrote a number of letter expressing the Villages objection to this area whilst accepting that some smaller developments at more suitable locations in the Village would be entertained. Despite the fact that the governmental targets for housing have been reduced the local plan contains SP2 within a re-defined Village boundary at a very late stage without proper recourse to the content and consultation set out in the town and country planning regulations of 2012. In addition it is contrary to the decisions made by its own planning committee to reject planning for this area.
The sustainability appraisal carried out for the SP2 by the NHDC in "The Sustainability Appraisal (update 2016, (attached)) presents evidence in the form of appraisal matrices for these preferred sites (Appendix 6) and non-preferred sites (Appendix 7). Each site is rated positive, negative or neutral against 14 objectives. On this evidence, the "preferred site" SP2 ranks equal lowest (most negative) of all the sites. Thus it is clear that the decision to allocate the site is contrary to the evidence presented to support the plan.
With regards to soundness, the plan has not been positively prepared. It has been prepared on the categorisation of the Village as category A village. This assessment is flawed. The Village is serviced by narrow roads and has a very poor public transport structure only travelling between Hitchin and St Albans every 2 hours with no service after 8pm or on Sundays. The Village has one primary school which is at capacity, one small post office come general store, one small café (summer only) and one Public House. It does not need further development to survive in fact it is creaking at the seams from a 15% housing increase over the last 10 years. A housing development of this nature cannot be accommodated by the present facilities such as sewage and will add dramatically to the traffic on the high street already used as a rat run to the A1 through Codicote. It is clearly an unsustainable site for development . The access is directly opposite the school raising safety concerns as noted by the school governors and headmistress in their objections to the planning permission in August. The nearest secondary school is 5 miles away and so pupils will require additional buses and there are not sufficient shopping or entertainment facilities to keep people in the village. Rather than sustaining a rural village the impact will be the creation of another suburb. It is the rural aspect and beauty of the area that brings the many walkers and cyclists to Village.
The plan to include SP2 is not the most appropriate strategy. The Parish council survey demonstrated that the majority of the Village believed that smaller developments in appropriate areas was the correct strategy. This has been ignored in the NHDC plan. The plan is not effective in meeting its housing targets. Adding this number of houses will only stretch and destroy the Village when in fact the housing targets have been reduced (through the recent OAN) and the plan now carries a 7% contingency when it is only required to carry 3%. The site is a known area where flood water goes through and such an area should only be considered in exceptional circumstances and when a strategic flood risk assessment has been carried out. Given the 7% contingency/surplus in the plan this is not an exceptional circumstance and a SFRA has not been carried out.

For the reasons above I believe the plan is neither legal or sound due to the inclusion of SP2 in the plan. To improve the plan the SP2 site should be removed and Whitwell village re-categorised from A

Dear Sir or Madam,

I wish to object to the inclusion of SP2 in the draft local development plan on the grounds it is NOT sound, legally compliant or complies with the duty to co-operate.

The introduction of SP2 has been a late inclusion into the plan and has not gone through proper consultation. In addition the Village boundary has been moved specifically to include this area despite it previously being a nominated green belt area outside the Village boundary. It has been incorporated despite the housing need in the area being reduced. The Village is in a rural location and the addition of this housing development would increase the Village size by 15% on top of the 15% increase the Village has sustained over the last 10 years. The previous expansion has stretched the Village facilities with the sewage at maximum capacity and increased traffic through the high street regularly bringing it to a standstill. The Village acts a rural retreat for cyclists and ramblers from the surrounding area. An increase of this amount will irrevocably change the nature of this Village. With poor public transport, no shopping amenities and no secondary schools the Village does not meet its classification of a class A village nor does the plan meet the councils own definition of sustainability.
I do not believe that the plan is legally compliant as not all the relevant surveys have been completed (e.g. strategic flood risk assessment) nor has there been any consultation with the village. In a recent Parish survey the majority of villagers believed that some limited expansion (10 houses) maybe sustainable in the right location. The SP2 site is not a good site. It is visually striking and is in the path of flooding during heavy rainfall. A recent planning application was recently turned down due to its visual impact and flooding potential. Should an appeal be forthcoming North Herts will be in the embarrassing position of both defending against development of the site and promoting it in their development plan.

I wish to object to North Herts District Councils housing development plan.

I specifically wish to draw attention to the inclusion of SP2 in the plan for the following reasons.
The plan provides too much housing for a village of the size of Whitwell. The village has increased significantly over the last 10 years with 3 major housing developments. The amount of housing proposed will adversely affect the village to the detriment of the surrounding countryside much loved by villagers, cyclists and walkers alike. The village provides an easy access rural environment for the local towns this will be further eroded if this plan is endorsed.
Of all the surrounding countryside of Whitwell the site of Sp2 seems the worse to pick for housing development. It is visually striking from a number of view points across the hills and up the Valley. it is situate opposite the primary school where additional traffic will cause a problem. The primary school is full and there are no secondary schools within 5 miles. It is hard to see how additional houses are going to help the Village. It has a poor public transport system; narrow roads many without pavements; no shopping or entertainment facilities. The village is likely to turn from rural retreat to suburb as Luton creeps ever closer.
It was disconcerting to see the site added to the plan especially as the housing requirement had gone down and North Herts District council planning committee had already agreed that this was an unsuitable site by turning down a planning application for the site. It seems the fact that the site was outside the village boundary was overcome by just redrawing the boundary. Both the inclusion of the site and redrawing of the boundary was done without any consultation with the village. The council is obliged to consult and for the inclusion of this site into the development plan they have not done so.
The site is known locally to occasionally flood in times of high rainfall and whilst the few houses at risk have taken precautions building on the site is likely to make the flood situation worse. 45 houses will be at risk rather than the present 3 or 4. It is also strange to recommend a site that is known to flood and houses should only be built in such areas under extraordinary cases. We are not in that position here there must be many sites in North Herts not susceptible to flooding.
The village is not against some natural expansion in the right areas but housing of this size rushed into the plan on an inappropriate site does not seem the correct way to go. I therefore object to the plan due to inclusion of the SP2 site in it.

North Herts Local Plan consultation
I write regarding the consultation on the above. I object to the proposed plan due to its inclusion of Whitwell for significant housing development, as well as various other reasons. Some of my reasons for considering the plan to be unsound are as follows.
* Government housing targets are flawed, and the numbers keep changing. Green Belt constraints seem to have been ignored.

* There does not seem to have been much time for public consultation, with the draft plan appearing to have been issued in a rush, after the council were way behind schedule in preparing such. I cannot see that any input from the local community in St Pauls' Walden (parish) and Whitwell has been taken account of.

* Whilst the surrounds of villages like Whitwell were not originally in the Green Belt (as it was originally put in place as a limit on the expansion of large towns into the countryside), it is now important that such villages are protected by Green Belt, without further expansion. Additional housing should only be allowed within the current village space, for which there is sufficient scope. The village attracts visitors from surrounding towns because of how it is now, and this will be spoiled by large developments.

* Proposing significant expansion of villages with poor communication connections, and few but adequate facilities, is hardly "sustainable", as it will just increase commuting through the narrow lanes to nearby towns and hence is not consistent with the NPPF. Additionally large expansion of Luton and further proposed expansions there, already put great pressure on the roads as people from those sites use the lanes as "cut-throughs". (Chapter 4 policy SP2).

* Specifically, in Whitwell, the draft plan fails since it proposes an unsuitable site (SP2) for development. This is unsuitable due to its landscape features, its flood risk, sewage issues, proximity of traffic to a school and so on. Also this site seems to have been added at the last minute and in opposition to a planning committee decision turning down a proposed development. (Chapter 4 policy SP8; Chapter 13 site SP2).
I trust that you will take my views into account in any decision made on the validity of the plan.

The proposed development is not in a sustainable location. It is effectively approving development of ~100 houses with 300-400 people. Most people will travel on private transport to a neighbouring town for school, work and recreation on a daily basis. In addition it detracts from one of the few remaining areas of undeveloped countryside in North Herts, which still represents the natural aspects of a countryside. Once this disappears, future generations in Hertfordshire will never benefit from it again.

Chapter 4, Policy SP2: Whitwell is already a sizeable village and struggling from the lack of infrastructure to support this. Therefore, the evidence used to identify sustainable villages is flawed. The road network to the village is narrow and frequently blind; 'near misses' are an all to frequent occurrence. Public transport is extremely poor, there is no secondary school and the single shop limited.

Chapter 13, Site Allocation SP2: The NHDC approach does not comply with NPPF. No consideration has been taken of the flood risk and a sequential approach has not been followed in site selection. NHDC's own evidence states that large housing extensions to Whitwell could have an unacceptable visual impact due to high visual sensitivities with cross country views.

Chapter 13, site allocation SP2: The site has a proven flood history and is identified as at high risk of surface water flooding, as recognised in the Council's Strategic Flood Risk Assessment. The NPPF states that development should be steered to areas with the lowest chance of flooding - this is exactly the opposite.

Chapter 13, site allocation SP2: The wholly impracticable infrequency and poor connection of public transport to Whitwell means that it is not sustainable, as it will depend heavily on the use of private cars. Moreover, there is no cycleway network and the lanes mentioned earlier would pose a danger to that mode of transport. The NHDC Planning Committee on August 25 determined that required sustainable drainage (SUDS) would have unacceptable impact on the visual impact of the site and the application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable

NPPF Requirement to empower local people to shape their surroundings (Paragraph 150): Strength of local feeling towards development on this site is well known to NHDC, as evidenced by attendance of the planning meetings; yet the Local Plan has ignored our community. The site is not needed to meet the identified housing need, but NHDC Planners seem determined to encourage its development even with known objections, environmental and flooding concerns together with the visual impact on the intrinsic beauty of the countryside. Thames Water state lack of sewerage capacity. The Planners even ignore their own Planning Committee who recently rejected the site for development

Allocation of SP2 for housing: The site was originally intended as Green Belt. This was supported by the Parish Council and the villagers - it is a valuable asset to our community and a very popular short 'ring' walk. NHDC has provided no justification for the change in status. The late submission has not given the Parish Council or villagers the opportunity to be empowered and ignored their wishes for SP2 to remain Green Belt

For these reasons we consider that SP2 should be removed from the 2011 - 2031 Local Plan

I am writing to you in relation to the proposed development in Whitwell - Site SP2. Please see below my reasoning. I look forward to this being considered in the appropriate way.

Object to Chapter 4, Policy SP8
1. The proposed plan to provide housing on this site will be a huge detriment of the open countryside.
2. SP2, has been added at a very late stage and should be removed as it is not needed.
3. There is no policy basis for increasing the buffer from the previously accepted 3% to 7%
Object to Chapter 4, Policy SP2
1. The plan is not sound as the evidence used to identify sustainable villages is flawed.
2. This results in isolated villages with no facilities such as a senior school and shops and very little public transport being seen as suitable for significant development.
3. In addition Whitwell is accessed by narrow lanes often requiring passing places and is already hugely congested and dangerous.
4. More evidence is needed on impact on car usage. Whitwell should be categorised as a 'B' village
Object to Chapter 13, Site Allocation SP2
1. There is no need for SP2 to meet housing need. The NHDC approach is not sound. It does not comply with NPPF as no consideration has been taken of flood risk and a sequential approach has not been followed in site selection.
2. SP2 was added at a late stage with an allocation of greater than 5ha - this conflicts with NHDC evidence that large housing extensions to Whitwell could have an unacceptable visual impact due to high visual sensitivities associated with cross country views
Object to Chapter 13, site allocation SP2
1. The site has a known and identified high risk of surface water flooding as recognised in the Council's Strategic Flood Risk Assessment. The NPPF states that development should be steered to areas with the lowest chance of flooding.
2. Site SP2 should only be considered if there is an identified need that cannot be met elsewhere with a lower probability of flooding
Object to Chapter 13, site allocation SP2
1. The proposed development is not in a sustainable location and will depend on private transport for most travel.
2. The NHDC Planning Committee on August 25 determined that required sustainable drainage (SUDS) would have unacceptable impact on the visual impact of the site and the application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable
NPPF Requirement to empower local people to shape their surroundings (Paragraph 150)
1. The Local Plan has ignored our local community. NHDC is well aware of the local feeling towards potential development on this site. The site is not needed to meet the identified housing need and yet NHDC Planners remain determined to use this site even with known objections, environmental and flooding concerns together with the visual impact on the intrinsic beauty of the countryside.
2. Thames Water state lack of sewerage capacity. The Planners even ignore their own Planning Committee who recently rejected the site for development
Object to the allocation of SP2 for housing
1. The Local Plan Preferred Option allocated the site for Green Belt. This was fully supported by the Parish Council. NHDC has provided no justification for the site no longer being categorised as Green Belt.
2. Latest figures (reduction in OAN) show that SP2 is not needed for housing. Green Belt status is also needed to mitigate for Green Belt losses elsewhere in the District where additional housing is being provided in more sustainable locations. The Local Plan pragmatically adds in late sites.
3. The submission has not given the Parish Council or villagers the opportunity to be empowered and ignored their wishes for SP2 to remain Green Belt
For the reasons above I/we consider that SP2 should be removed from the 2011 - 2031 Local Plan

This proposal has already been the subject of a planning appliction which was rejected just a few months ago. The same proposal must not be included in the Local Plan, it does not deserve to be given such legitimacy. The points raised at the planning application rejection still stand. The land is not suitable for development, the development is in excess of 5 hectares, the road infrastructure is simply unable to cope with the increase in traffic that will inevitably flow east along the High Street towards Codicote/Hitchin, west towards Offley/Luton or south towards Kimpton.

The plan is unsound as it includes SP2 as an allocated site for 41 houses. The summary states that the design must be sensitive yet the surface water flood risk must be mitigated. The specific nature of this site means that these 2 criteria cannot be met simultaneously. Such is the extent of flood mitigation necessary for this site, when coupled with the required position of the houses directly in the area of flood risk makes the site unsuitable for development. A conclusion reached by NHDC Planning Committee in August 2016.

The last minute addition of the site SP2 to the draft local plan and the redrawing of the village boundary to accommodate it clearly contravenes the code of conduct laid down in the National Planning and Policy Framework. This states that proper and true community consultation must be made before taking this type of decision and that said consultation should include local neighbourhoods, businesses and organisations. This has manifestly not been the case given the time scale involved. The local plan has been in the draft stage for the last several years and to introduce this change a matter of weeks before the consultation closes completely goes against the spirit of the NPPF with regards to changes and adoptions of this kind.
SP2 has long been allocated as green belt in the draft local plan, this was fully supported by the local community. To change the status of the site by redrawing the village boundary at this late stage clearly goes against National policy and as such is not legally compliant.

My wife and I would like to make the following objections to the Local Plan:-

Object to Chapter 4, Policy SP8

The plan provides excess housing to the detriment of open countryside. Sites, including SP2, have been added belatedly and should be removed as they are not needed. There is no policy basis for increasing the buffer to 7% from the previously accepted 3%.

Object to Chapter 4, Policy SP2

Flawed evidence is used to identify sustainable villages, which results in isolated villages with little infrastructure being seen as suitable for significant development. Moreover, Whitwell is accessed by very narrow country lanes requiring passing places.

Object to Chapter 13, Site Allocation SP2

There is no need for SP2 to meet housing need. The NHDC approach is not sound. It does not comply with NPPF as no consideration has been taken of flood risk and a sequential approach has not been followed in site selection. It was also added at a late stage with an allocation of greater than 5ha - this conflicts with NHDC evidence that large housing extensions to Whitwell could have an unacceptable visual impact on cross country views.

Object to Chapter 13, Site Allocation SP2

The site has a known and identified high risk of surface water flooding as recognised in the Council's Strategic Flood Risk Assessment. As the NPPF states that development should be steered to areas with the lowest chance of flooding, site SP2 should only be considered if there is an identified need that cannot be met elsewhere.

Object to Chapter 13, Site Allocation SP2

The proposed development is not in a sustainable location and will depend on private transport for most travel; this in a village which is already badly congested.

NPPF Requirement to empower local people to shape their surroundings (Paragraph 150)

Our local community is ignored in the Local Plan. NHDC is wholly aware of local feeling towards potential development of this site. The site is not needed to meet the identified housing need, yet NHDC Planners remain determined to use this site notwithstanding local objections, environmental and flooding concerns, together with the visual impact on the intrinsic beauty of the countryside. Thames Water state lack of sewerage capacity. The Planners, inexplicably, even ignore their own Planning Committee who recently rejected the site for development.


Object to the allocation of SP2 for housing

The Local Plan Preferred Option allocated the site for Green Belt, which was fully supported by the Parish Council. No justification for the site no longer being categorised as Green Belt is provided by NHDC. Latest figures (reduction in OAN) show that SP2 is not needed for housing. The Local Plan pragmatically adds in late sites. The submission has not given the Parish Council or Whitwell villagers the opportunity to be empowered and has ignored their wishes for SP2 to remain Green Belt.

It is for the reasons above that we consider SP2 should be removed from the 2011 - 2031 Local Plan.

As landowner of site SP2 support for the allocation and its availability is confirmed.

The site is visually protected from surrounding green belt and is well positioned within the village so as not to represent an unacceptable encroachment into countryside. Whitwell is a Category A village with a range of services and facilities. The scale of the allocation is in keeping with the settlement.

A promoter has been engaged to develop the technical aspects of the site to ensure early delivery to meet the housing needs of the plan period.

OBJECT to the inclusion of SP2 as an allocated site in the Local Plan (Chapter 4 . Policy SP2 and Paragraph 13.324)

The inclusion of SP2 in the Local Plan means it is not legally compliant or sound for the following reasons:

1. Breach of NPPF which states that states that true community consultation must be undertaken and 'early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential

SP2 has been included at this final stage in the Plan Development and without proper community engagement or consultation. The Statement of Community Involvement makes it clear that at least 3 stages of full public consultation should be undertaken. Regulation 18 of the Local Planning Regulations states that The site was actually allocated new green belt in the previous consultation and which was fully supported by local respondents. The site was included at the last minute in response to a temporary increase in OAN to 14400. The OAN has now been reduced to 13,800 and therefore it can be argued that the site is no longer required. The oversubscription buffer now pitched at an excessive and unnecessary 7% therefore it is unjustified to retain this last minute site which has not been subject to community scrutiny and is totally unsuitable for development (see points 2- 6 below).
This final stage consultation has a very prescriptive and complex format to the responses which has discouraged ordinary village folk from responding preventing constructive dialogue and response. The 6 week deadline for the consultation prevented residents from effectively disseminating the information and assisting folk to prepare and submit a response. The plan is therefore not properly prepared.

2. Unsuitability of site for development- Flood Risk and Failure to apply the Sequential Test
The site itself is completely unsuitable for development. It is categorised as 1 in 30 year risk of surface water flooding and therefore application of the sequential test, as required by the NPPF, means that new developments should only be considered if there are no alternative sites available with a lower risk of flooding. Given all the sites available in the Local Plan and the oversubscription buffer it follows that this site should not be developed. NHDC Planning Officer determined that the houses must be built in the lower half of the field to prevent significant impact on the landscape, however this is the area of field which is at risk of flooding. NHDC also determine that by mitigating the flood risk in the field using a drainage system will protect the houses adjacent to the site. This is misleading as the affected houses have been modified to prevent flood water damage and by building 41 houses on this field places the new inhabitants at a risk of flooding (which is exacerbated by the ground water factor described below) unnecessarily and is not justified.

3. Unsuitability of the site for development- Ground Water and SPZ1
The only method of water drainage on this site is infiltration, regardless of which SuDS scheme is employed. Incidentally the developer of the land is proposing an underground drainage scheme for this site which ranks the very lowest in the LLFA SuDS hierarchy and is not a method of choice. This method or any other infiltration scheme will NOT WORK in periods of high ground water. The site flooded in 2014 causing extensive damage and the flood consultant employed by SPW Parish Council JBA Consulting who concluded that

2.4 Conclusion
It is certainly true that the ground was saturated leading to surface water runoff on 7 February 2014, but we conclude that there is strong evidence that this saturation was caused by high groundwater levels in the Chalk. This is a very different flooding mechanism from surface water flooding alone and a very important consideration in any flood mitigation plans.

Furthermore NHTB consultancy, which has previous knowledge of the site as authors of the Section 19 Flood Investigation Report, report that the underlying geology for Whitwell is chalk. They raise serious concerns with groundwater flooding/problems if SUDS and infiltration is proposed. The groundwater situation is found to be similar to Kimpton where new equipment has been installed to enable groundwater flood warnings to be issued to residents.

SPZ Risk
Thames Valley Water have concluded that the current sewage system is unable to accommodate any additional housing and the developer has proposed a large underground sewage tank from which the foul water is pumped during off peak hours. The EA expressed concerns over the use of this tank and applied a high number of conditions. Unless the tank and pumps are managed perfectly - and tank will erode over time leakages will pose a risk to ground water and Mimram chalk aquifer and world famous Whitwell Watercress Beds. The site is designated SPZ1 and requires the highest level of protection.

Inclusion of this site poses unacceptable level of risk to local residents and is therefore not justified.

4. Unsuitability of the site for development- Impact on Landscape and conflict with NPPF
The site is adjacent to a conservation area, can be viewed from historic pathways and is key component of the landscape character of the village, development of the site would have a huge impact on the rural nature of the settlement and lower its appeal to the high number of walkers and cyclists who visit at weekends from surrounding towns. Whitwell has very limited employment opportunities and is largely reliant on visiting tourists.

The importance of this field to the intrinsic beauty of he village cannnot be underestimated. The Chiltern Society are proposing to include this area in their extension to the Chiltern Area of Outstanding Natural Beauty.

Historic views
Adjacent to the site on the South is an ancient Green Lane dating back to Roman times, identified as Byway 36. This links with the Chiltern Way and forms part of a popular walk out of the village, with open views across the field in question to the opposite side of the valley. It is proposed to incorporate this as a "green corridor through the site" which seems an inappropriate urban construction. On the contrary the rural character of the lane and views from it across the valley should be conserved.

Adjacent to the site to the West is Bendish Lane, which is a popular and picturesque section of the Chiltern Cycleway. This pretty narrow lane, winding down the hill from Bendish, directly links the conservation areas of Bendish and Whitwell, with currently nothing but countryside in between. Development on SP2 would fill in a significant portion of this precious space and would transform the views from rural to urban.

This site lies entirely outside the currently defined settlement boundary and has no access from within the village. A new housing estate on this site will require a new access road from Bendish Lane, opposite the school entrance. This will increase the traffic and spoil the rural character of this lane and its views, including the setting of St Marys Chapel (Listed Building), which presently greet the visitor approaching the village.

The river Mimram emerges from the chalk aquifer behind the famous water cress beds at Nine Wells in west Whitwell. In fact this is the ancient origin of the name of the village, meaning "White Spring". The Mimram is one of only 210 chalk streams in the world and provides some rare and valuable habitats. The water is also abstracted to drinking water supply. The site SP2 is in a highly sensitive location for groundwater. The stream source only 100m away and 10m lower). In fact it is designated the most sensitive Source Protection Zone 1 (defined a the 50 day travel time from any point below the water table to the source).

In conclusion, the site is in conflict with NPPF including paragraphs 109 and 110 in that it fails to "conserve and enhance the natural environment." Particular issues for this site are the visual impact, especially impacting recreational routes and lanes, and risk to ground water and the Mimram chalk stream.

5. Unsuitability of the Site Breach of NPPF and existing NHDC Landscape Policy
Contrary to NPPF Para 170, the plan fails to recognise NHDC own landscape character evaluation for Whitwell Valley Area 203, which concludes that:
"large urban extensions and new settlements (>5ha) would not be appropriate within this Character Area, due to its relatively remote, rural and undeveloped character. It would be of an inappropriate scale and would introduce elements that would urbanise the landscape, altering the character and removing the existing key characteristics. Visual impacts would also be high due to the cross valley views currently experienced."
SP2 is a site of nearly 6ha and therefore the allocation of the site is contrary to the independent report findings for reason of visual impact.

Unsuitability of site for development- Location, Parking and Safety Risk
Whitwell is situated in a relatively remote rural location in the district, in the middle of an area of high quality Chiltern countryside, which is being eroded from all sides, especially from the West (Luton) and East (Stevenage), under the duty to cooperate.
Whitwell is accessible only via narrow lanes with passing places, which, along with the High Street, are frequently congested. Public transport is severely limited, with just a 2-hourly bus to Hitchin and no service at evenings or Sundays. Therefore any development in Whitwell will result in a directly proportional increase in daily travel by private car.

No Travel Plan has been submitted to justify the allocation of this 6ha site, which could lead to over 100 new houses and over 200 private cars travelling more than 10 miles per day. This is a significant increase in carbon footprint, which is contrary to the NPPF.

The site is directly opposite the local primary school along a road with only one pavement. This creates an two fold increased safety risk the first to the children walking to school and the second arising from the families who arrive at school in the car and subject to the hazardous parking arrangements. There have been a number of near misses.

6. Unsuitability of the site - Sustainability
The site is not sustainable as as previously explained it will result in significant increased car usage (nearest secondary school supermarket, train station are all 7- 8 miles away and nearest bus stop is >400m). The sewage system and flood mitigation rely on power hungry pumps which conflict with Gov sustainability and low carbon policy.

7. Comparison of SP2 site against the site in Whitwell which have been rejected and removed from the Local Plan
The attached tables below show very clearly that SP2 compares unfavourably in terms of NHDC sustainability appraisal to other sites previously considered for inclusion in the Local Plan and REJECTED. SP2 the 'preferred site' ranks the lowest of all the sites considered during the development of the plan. Most notably SP2 has high surface water flooding, and is the only site in a sensitive water source protection zone (SPZ1). Development of this site therefore breaches the requirements of the EU Water Framework Directive. The current sewage system is unable to accommodate the site and an elaborate system of pumps is required to deal with foul water. In addition flood mitigation strategies rely on pumps to reallocate the flood and run off water. This renders he site UNSUSTAINABLE and conflicting with Government low carbon policies. It is also extraordinarily land-hungry, with only 7 dwellings per hectare. In particular the site SP1 was rejected on the basis of a decision taken by the NHDC Planning Committee to reject a planning application for the site, based on impact on the countryside and views from historic pathways. Reasons which are directly applicable to the unsuitability of SP2.

To conclude
The allocation of site SP2 is not justified when considered against the reasonable alternatives, based on proportionate evidence.

Changes required
Allocation SP2 should be removed from the text and proposals map.

This site has not been adequately assessed. The risk of flooding is highlighted in the Herts county council section 19 report from the actual flood event in 2014. This site was added late to the SFRA and not properly consulted on and no evidence of the sequential test seems to be available. Even if the site was to be developed, it may not be possible to develop 41 properties outside the overland flow route. Thames Water have raised serious concerns about the wastewater infrastructure for this site. Upgrades would be required, this was not flagged in the sustainability appraisal for the site. The site is in a source protection zone 1 so particularly vulnerable to uses that could pollute groundwater, including on site storage of sewage and inappropriate SuDS reliant on infiltration without tertiary treatment. The EA have highlighted that groundwater levels beneath the site are likely to be high in winter so infiltration is unlikely to work. Therefore SuDS and any flood mitigation measures proposed that are based on infiltration won't be functional in winter, when groundwater is high, which will lead to an increased risk of flooding to off site properties. Surface water can't be disposed off to sewer or river as they are not available at this site. The site is likely to be impacted by groundwater flooding when the water table is particularly high as it is of the same geology as the dry valley at Kimpton that has a disruptive history of flooding. The site is characteristic of the Chilterns landscape, visible from historic parks and gardens, ancient rights of way and promoted cycle routes and walks promoted as Chilterns explorer routes.
Although well connected to landscape and rights of way, SP2 is not well connected to the village of Whitwell and this development would not be integrated into the village.
Development would not be compliant with proposed policies SP9 on design as not well located or related to local context; SP11 - no sustainable transport options; D1 sustainable design, development proposals based on pumped systems will not lead to long term reduction in energy consumption and it will be difficult to incorporate effective SuDS that don't impact water quality or actually function; NE7 - no evidence the sequential test has been carried out and difficult to justify the exception test in a location where there is no demonstrable need or sustainability. In addition flow routes should be protected from all development, making this site difficult to access. The site provides feeding ground for iconic species including red kites, toads and swifts which are abundant in the area. This is a particularly constrained site.

I object to this site allocation on a number of grounds.
The site was previously considered in earlier drafts for inclusion as Green Belt land and the change from this position to housing allocation is merely convenient and has no basis in demonstrable need.
The site is prone to flooding as demonstrated by the LLFA and recent real life flooding events, it's allocation as housing land is therefore unsound.
The site does not integrate with the existing village and is outside of the current village envelope, this allocation merely seeks to move the goalposts and enable development where other smaller developments have been turned down on these grounds.
Parish Council consultation has established that local residents accept the need for additional housing, this site however does not fit with the scale identified or fit with residents aspirations for the nature of future growth.
The HCC landscape character assessment for this area concurs that small scale incremental growth is appropriate but also points out the significance of the land form exhibited by this site to the local area in the context of the Chilterns AONB.
Recent landscape and biodiversity grant targetting communications from the AONB office has identified the landscape between offley and whitwell specifically as a target area and indicated that that they are considered an area for any possible future boundary review to take account of.
The site is prominent within the typical chiltern hills fringe landscape and is significantly visible from the Hertfordshire Way, several definitive public rights of way and areas of historic parkland, all of which contribute significantly to the local tourist economy.
Scant consideration has been given to the ecological effects of the development of this site. This despite the national and local evidence that loss of farmland continues to have on our much beloved bird species as well as pollinating insects and iconic butterfly species.

Too much housing to the detriment of the open countryside.
Contrary to the recent refusal of planning permission on this site by NHDC.
No policy basis for increasing the buffer from the previously accepted 3% to 7%. Flawed evidence for categorisation.
Virtually no public transport.
No consideration has been taken of flood risk.
SP2 was also added at a late stage with an allocation of greater than 5ha. Unacceptable visual impact due to high visual sensitivities associated with cross country views.
Site not needed to meet the identified housing need.
Lack of sewerage capacity.

I would like to make my comments as following

Object to Chapter 4, Policy SP8

The Plan is not sound as it provides for too much housing at the expense of open countryside. Sites, including SP2 have been added at a very late stage. There is no policy basis for increasing the buffer from the previously accepted 3% to 7%

Object to Chapter 4, Policy SP2

It is not sound as the evidence used to identify sustainable villages is flawed. This results in isolated villages with no facilities such as senior school and shops and very little public transport being seen as suitable for significant development. In addition Whitwell is accessed by narrow lanes often requiring passing places. More evidence is needed on impact on impact of car usage. Whitwell should be categorised as a 'B' village

Object to Chapter 13, site allocation SP2

The site is not a sustainable location and will depend on private transport for most travel. The NHDC Planning Committee on August 25 determined that required sustainable drainage (SUDS) would have an unacceptable impact on the visual impact of the site and the application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable

NPPF requirement to empower local people to shape their surroundings (para 150)

The Local Plan has ignored our local community. NHDC is well aware of local feeling. The site is not needed to meet identified housing need and yet their planners stay determined to use this site even with known objections, environmental and flooding concerns together with the visual impact on the intrinsic beauty of the countryside. Thames Water see lack of sewer capacity. The Planners even ignore their own Planning Committee who recently rejected the site for development

Object to the allocation of SP2 for housing

The Local Plan preferred Option allocated the site for Green Belt. This was fully supported by the Parish Council. NHDC has not justified the site no longer being Green Belt. The reduction in OAN shows that SP2 is not needed for housing. Green Belt is also needed to mitigate for Green Belt being lost elsewhere in the District where additional housing is being built in more sustainable locations. The Local Plan has added late sites almost accidentally. The submission has not given the Parish Council or villagers the chance to be empowered and have ignored their wishes for SP2 to remain Green Belt

For the reasons above I consider that SP 2 should be removed from the 2011-2033 Local Plan. I would also like the Parish Council to represent me to the Inspector

Draft Local Plan Relating to Whitwell - SP2 - St. Paul's Walden

I write in response to your latest proposed Draft Local Plan, which is now under consideration by local communities. I object to the inclusion of site allocation SP2 in Whitwell for the following reasons:

*This area has not been offered up by the community, including the St. Paul's Walden Parish Council. This is against the NPPF requirement to empower local people to shape their surroundings (paragraph 150).

*SP2 has always been allocated as Green Belt and I am not aware of NHDC providing any justification for this designation to be changed.

*Flood Risk - Chapter 13 - SP2 is a known flood risk and on the 25th August 2016 I was at a Planning Committee Meeting whereby they refused permission for development on this site as it was not in a sustainable location and would also have an unacceptable impression on the visual impact of the site.

*The Mimram River runs within c. 200 yards from this site, down into the valley. This is a rare chalk river and if something should go wrong on this site, more run-off due to additional concrete, etc. this will severely damage the river.

*SP2 is not appropriate for additional housing due to the fact that the sewage cannot be taken away as the treatment farm is at maximum capacity and this part of the village requires the sewage to be pumped uphill in order to get it into the main pipes for removal at the other end of the village.

*The SP2 proposal is not appropriate (Chapter 4) as it has poor access to/from and through the village, all four roads leading into the village are single track at points. Any new houses would inevitably mean an additional two cars per household as a minimum. This is unsustainable for the village, also the damage to people's health along the main routes into/out of the village may well be severely damaged.

*St. Paul's Walden per sa has been for many years an area where people come to relax by walking, horse riding and cycling (we are part of the Chiltern Way) introducing a development of this size would destroy this for thousands of people.

Finally, let me say this proposed site is totally inappropriate not only for its location, but the fact that Whitwell does not need this additional housing. We have always accepted 'small scale housing projects' this is not 'small scale'! Whitwell definitely does not require the housing to ensure the village continues to 'thrive'! NHDC should immediately re-classify the village to a Category 'B' and not as shown in the draft document as a Category 'A' village.

I would like to make the following comments

Object to Chapter 4, Policy SP8

The Plan is unsound as there is too much housing against losing open countryside. Sites like SP2 have been added at a very late stage

Object to Chapter 4, Policy SP2

The evidence used to identify sustainable villages is unsound. This means that isolated villages with no facilities are seen as being suitable for significant development. Not only does Whitwell fall into this category but it is also accessed by narrow lanes requiring passing places. More evidence is needed on car usage. Whitwell should be categorised as a B village

Object to Chapter 13, site allocation SP2

The site is not sustainable and depends on public transport for most travel. The NHDC Planning Committee on August 25 thought that required sustainable drainage would have an unacceptable impact on the visual beauty of the site and the application was refused. Two pits of which one was larger than an Olympic swimming pool was rejected.Alternative solutions will require underground tanks and pumps which are also unsustainable

NPPF To empower local people to shape their surroundings (para 150)

Our local community has been ignored. NHDC is well aware of local feeling. The site was turned down 4 months ago, is not needed to meet identified housing need and still the planners are determined to use this site. There are real environmental and flooding concerns together with the visual impact on the intrinsic beauty of the area. Thames Water see lack of sewer capacity as a problem. As stated earlier the Planners even disregard their Planning Committee who recently rejected the site for development

Object to the allocation of SP2 for housing

The Local Plan preferred option allocated the site as Green Belt and was fully supported by the Parish Council. There has been no reason given for the site losing its Green Belt status. The reduction in OAN shows that SP 2 is not needed. The Local Plan seems to have added sites at a late stage almost gratuitously. Neither the Parish Council nor villagers have been given the chance to be empowered and have ignored the wishes for SP2 to be retained as Green Belt

For the reasons given above I consider that SP2 should be removed from the 2011-2033 Local Plan

I am writing to object to the inclusion of site SP2 Whitwell in the local plan and would like to make the following comments.
Public Engagement- Chapter 4, Policy SP8
SP2 has been added to the draft local plan at the final round of consultation. This means that the community had had an insufficient and unacceptable time to respond. The NPPF states that true community consultation must be undertaken. It states 'early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential'. By adding SP2 at the final stage this requirement has not been met.
By introducing this site, the draft local plan disregards
a) The findings of the NHDC planning committee who found the site inappropriate for development in August 2016
b) Has not engaged early with the community
c) Ignored previous comments from our community and St Pauls Walden Parish Council supporting green belt protection to this land.

To make the plan sound, SP2 should be allocated as new green belt.
Object to Chapter 4, Policy SP2
The plan is not sound as the evidence used to identify sustainable villages is flawed. Hence resulting in isolated villages, with no facilities such as a senior school and shops, and very little public transport, being seen as suitable for significant development.
NHDC has labelled Whitwell a 'category A' village deeming that it requires an increase in housing numbers in order to thrive. This is simply not correct and unsound, also contradicting the Parish Council's own assessment of local needs. Whitwell is accessed by narrow country lanes, has no supermarket or secondary schools with 5 miles, very few employment opportunities, only 1 public house, and minimal public transport. It is therefore not a sustainable location for significant volumes of new housing. In the previous Local Plan Whitwell was designated as a village beyond the Green belt, which is a more appropriate designation.
The NPPF core planning principles at paragraph 17 clearly state that patterns of growth should be actively managed to make the fullest possible use of public transport, walking and cycling and focus significant development in locations which are, or can be made sustainable. Whitwell's unique rural location, set in unspoilt Chiltern valley landscape surrounded by larger conurbations, attracts high volumes of ramblers and cyclists who appreciate its beauty. It lies within the proposed extension to the Chiltern AONB. The draft local plan has failed to grasp the essence of Whitwell's identity and function. Whitwell's role should not be to provide housing towards district targets, but to continue to provide highly valued amenity for North Herts, Luton, Stevenage and other neighbouring urban districts.
To make the Local Plan justified, effective and legally compliant Whitwell should be reclassified as Category B village and SP2 removed as an allocated site.
Object to Chapter 13, Site Allocation SP2
The plan is unsound as it identifies SP2 as suitable for development. There are a number of physical features and constraints that render the site SP2 as completely unsuitable.
a. Flood risk SP2 site is assessed, by the Environment Agency, as having a high - medium risk of surface water flooding. The SFRA clearly shows water flowing across the site in a 1 in 30 year flood event. The NPPF asserts that development should be directed away from sites at high risk of flooding
The NPPF also outlines the need for a Strategic Flood Risk Assessment (SFRA) to be completed to determine flood risk in relation to allocating sites for housing. The SFRA commissioned by NHDC in 2008 pre-dates the inclusion of SP2. On updating the SFRA, NHDC acknowledge the serious surface water issues present at the site. This is against NPPF guidance which states development should be directed away from flood risk altogether, towards sites with a lower flood risk.
New sites should not be sited in areas at high flood risk.
b. Sewerage and Ground Water Thames Water has determined that there is insufficient capacity remaining in the sewage system for new homes on SP2. This fact has been omitted by NHDC in their documentation. SP2 lies on the principle chalk aquifer, a source of water for the River Mimram. SP2 is therefore a highly sensitive location for groundwater. In fact Whitwell is in a source protection zone 1. Whitwell's famous water cress beds are located just 100 meters from SP2. If the ground water source were to become contaminated, the potential for pollutants to very quickly damage water quality at the cress beds is disastrously high.
Pump based solutions, most often introduced by developers under these circumstances, are unsustainable. Continued maintenance measures that these systems require, to avoid common problems such as septic tank overflow, cannot be guaranteed.
c. Visual Impact SP2 is a widely valued, attractive Greenfield agricultural site. It is visible from the Chiltern Way and other footpaths and bridleways. It forms a prominent part of our unique valley character landscape.
The North Hertfordshire and Stevenage Landscape Character Assessment, an independent report instructed by NHDC to review of the landscape character area of Whitwell Valley, identifies SP2's location visual sensitivities as being moderate - high. "Cross valley views from the higher vantage points are an important feature of the character area. Panoramic views are common from the higher valley slopes, views along the valley are an important feature in the character area."
It also states that: "large urban extensions and new settlements (>5ha) would not be appropriate within this Character Area, due to its relatively remote, rural and undeveloped character. It would be of an inappropriate scale and would introduce elements that would urbanise the landscape, altering the character and removing the existing key characteristics. Visual impacts would also be high due to the cross valley views currently experienced."
SP2 is a site of nearly 6ha. The allocation of the site is contrary to the independent report findings for reason of visual impact.
In summary we consider that amendment of SP2 from housing development to new Green Belt is necessary to make the plan sound.
Object to Chapter 13, site allocation SP2
The proposed development is not in a sustainable location and will depend on private transport for most travel. The NHDC Planning Committee on August 25 determined that required sustainable drainage (SUDS) would have unacceptable impact on the visual impact of the site and the planning application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable
For the reasons above I consider that SP2 should be removed

I am writing to object to the inclusion of site SP2 in the local plan Whitwell and would like to make the following comments.

Public Engagement- Chapter 4, Policy SP8
SP2 has been added to the draft local plan at the final round of consultation, very late in the process. This means that the community has had insufficient and unacceptable time to respond. The NPPF states that true community consultation must be undertaken. It states 'early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential'. By adding SP2 at this final stage this requirement has not been met.
In introducing this site, the draft local plan disregards:-
a) the findings of the NHDC planning committee who rejected an application and found the site inappropriate for development in August 2016;
b) has not engaged early with the community;
c) disregarded the previous comments from our community and St Pauls Walden Parish Council supporting green belt protection to this land.
Articles 18-20 of The Town and Country Planning (Local Planning) (England) Regulations 2012 outline the requirement for a Statement of Community Involvement This demonstrates that the plan is not consistent with National Policy.
To make the plan sound, SP2 should be allocated as new green belt.
Object to Chapter 4, Policy SP2
The plan is not sound as the evidence used to identify sustainable villages is flawed. Hence the result being that isolated village, with no facilities such as a senior school and shops, and very little public transport, are seen as unsuitable for significant development.
NHDC has labelled Whitwell a 'category A' village deeming that it requires an increase in housing numbers in order to thrive. This is simply not correct and unsound, also contradicting the Parish Council's own assessment of local needs. Whitwell is totally accessed by narrow country lanes, has no supermarket or secondary schools within 5 miles, very few employment opportunities, only 1 public house, and minimal public transport. This cannot be regarded as a sustainable location for significant volumes of new housing. In the previous Local Plan Whitwell was designated as a village beyond the Green belt, which is a more appropriate designation.
The NPPF core planning principles at paragraph 17 clearly state that patterns of growth should be actively managed to make the fullest possible use of public transport, walking and cycling and focus significant development in locations which are, or can be made sustainable. Whitwell's unique rural location, set in unspoilt Chiltern valley landscape surrounded by larger conurbations, attracts high volumes of ramblers and cyclists who appreciate its beauty and amenity values. It lies within the proposed extension to the Chiltern AONB. The draft local plan has failed to grasp the essence of Whitwell's identity and function. Whitwell's role should not be to provide housing towards district targets, but to continue to provide highly valued amenity for North Herts, Luton, Stevenage and other neighbouring urban districts.
To make the Local Plan justified, effective and legally compliant Whitwell should be reclassified as Category B village and SP2 removed as an allocated site.
Object to Chapter 13, Site Allocation SP2
The plan is unsound as it identifies SP2 as suitable for development. There are a number of physical features and constraints that render the site SP2 as completely unsuitable.
a. Flood risk
SP2 site is assessed, by the Environment Agency, as having a high - medium risk of surface water flooding. The higher ground topography funnels rainfall into the natural valley landscape area marked as SP2 increasing flood risk for properties lying in its direct fall including Cresswick and Mimram View. Indeed the SFRA clearly shows water flowing across the site in a 1 in 30 year flood event. Paragraph 100 of NPPF asserts that development should be directed away from sites at high risk of flooding
The NPPF also outlines the need for a Strategic Flood Risk Assessment (SFRA) to be completed to determine flood risk in relation to allocating sites for housing. The SFRA commissioned by NHDC in 2008 predates the inclusion of SP2. On updating the SFRA, NHDC acknowledge the serious surface water issues present at the site. This is against NPPF guidance which states development should be directed away from flood risk altogether, towards sites with a lower flood risk.
New sites should not be sited in areas at high flood risk.
b. Sewerage and Ground Water
Thames Water has determined that there is insufficient capacity remaining in the sewage system for new homes on SP2. This fact has been omitted by NHDC in their documentation. SP2 lies on the principle chalk aquifer, a source of water for the River Mimram. SP2 is therefore a highly sensitive location for groundwater. In fact Whitwell is in a source protection zone 1. Whitwell's famous water cress beds are located just 100 meters from SP2. If the ground water source were to become contaminated, the potential for pollutants to very quickly damage water quality at the cress beds is disastrously high.
Pump based solutions, most often introduced by developers under these circumstances, are unsustainable. Continued maintenance measures that these systems require, to avoid common problems such as septic tank overflow, cannot be guaranteed.
c. Visual Impact
SP2 is a widely valued, attractive Greenfield agricultural site. It is visible from the Chiltern Way and other popular footpaths and bridleways. It forms a prominent part of our unique valley character landscape.
The North Hertfordshire and Stevenage Landscape Character Assessment, an independent report instructed by NHDC to review the landscape character area of Whitwell Valley, identifies SP2's location visual sensitivities as being moderate - high. "Cross valley views from the higher vantage points are an important feature of the character area. Panoramic views are common from the higher valley slopes, views along the valley are an important feature in the character area."
It also states that:
"large urban extensions and new settlements (>5ha) would not be appropriate within this Character Area, due to its relatively remote, rural and undeveloped character. It would be of an inappropriate scale and would introduce elements that would urbanise the landscape, altering the character and removing the existing key characteristics. Visual impacts would also be high due to the cross valley views currently experienced."
SP2 is a site of nearly 6ha. The allocation of the site is contrary to the independent report findings for reason of visual impact.
In summary we consider that amendment of SP2 from housing development to new Green Belt is necessary to make the plan sound.
Object to Chapter 13, site allocation SP2
The proposed development is not in a sustainable location and will depend heavily on private transport for most travel. The NHDC Planning Committee on August 25 determined that required sustainable drainage (SUDS) would have unacceptable impact on the visual impact of the site and the planning application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable
For the reasons above I consider that SP2 should be removed from the Local Plan 2011-2031

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