SP2 Land beween Horn Hill and Bendish Lane, Whitwell

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I wish to object to the allocation of the site of SP2 for inclusion in the local plan.

This site is preferred to be allocated as Green Belt and this is supported by the Parish Council and residents. This site is needed to mitigate for Green Belt losses elsewhere in the District.

The NPPF require that local people should be included in taking decisions in forming their surroundings and this is stated in paragraph 150. This emerging local plan has not been inclusive of our local community. The Planning department are insistent on recommending this plan despite widespread objection, environmental and flooding concerns, no sewerage capacity and an identified negative visual impact on the area. Additionally this site has had a refusal by the Planning Committee in August 2016.

I would like to object to chapter 13 for SP2. This site is not sustainable. The planning department require sustainable drainage and any development here would have an unacceptable impact on the visual aspect of the area. Unsustainable pumps and tanks are not a solution.

I would like to add my objection to chapter 13. This site has a known and identified risk of surface water flooding and the NPPF states that development should be steered away from areas at risk.

I further point out and object to Chapter 13 by noting that there is no need for the site to be allocated to meet the housing need. This site has been added at a late stage without due consideration and without reasonable alternatives. Importantly, this allocation is against the Council's evidence that large extensions in the small village of Whitwell (only 371 homes currently) would have a negative and unacceptable visual impact to the surrounding countryside.

I would also like to object to Chapter 4. This plan is not sound because the isolated villages have no facilities and very little public transport (one bus per hour and no direct links to Harpenden). The NHDC should use travel to work patterns to better understand lifestyle trends and to establish sustainability of a village.

Most fundamentally, and objecting to Chapter 4, this plan is not sound as it provides too much housing that would be of detriment to the beautiful open valley countryside that attracts walkers and cyclists to relax and enjoy.

SP2 should be removed from this plan and instead be given over to Green Belt and alternative sites that do not have such limiting constraints should be investigated.

I am writing to lodge my objections to the proposed inclusion of SP2 as a possible site for housing in the village of Whitwell.

Chapter 4, Policy SP8: The site SP2 has been added at a very late stage and the number of houses proposed is too great for the site and village to the detriment of the open countryside, therefore it should be removed from the local plan.

Chapter 4, Policy SP2: The evidence used to identify Whitwell as sustainable village is flawed. The primary school is not large enough to accommodate the possible increase in population, no secondary school (places at local secondary schools is at a premium), one shop, public transport is already inadequate therefore totally inadequate for a great influx of residents.

Chapter 4, Policy SP2: Whitwell High Street, which is narrow, is within a conservation area with the majority of residents having alternative but to park their vehicles on the street reducing the majority of the road to single land. This causes problems with traffic with many hold-ups at all times of the day due to the volume of through traffic added to village resident traffic. In addition, Whitwell is accessed by narrow lanes which in places is reduced to single lane with occasional passing places.

Chapter 13, Site Allocation SP2: The NHDC approach is not sound as there is no need for SP2 to meet housing need. It does not comply with NPPF as no consideration has been taken of the very high flood risk; the proposed number of houses will only exacerbate this very real threat by concreting over more land. The area last flooded about two years ago with several home badly affected. This risk is known and identified as high risk in the Council's Strategic Flood Risk Assessment. The NPPF states that development should be steered to areas with the lowest chance of flooding.

Chapter 13, Site Allocation SP2: The proposed development is not in a sustainable location and will depend on private transport for most travel adding to the traffic problem through and out of the village.
On 25 August 2016, the NHDC Planning Committee determined that required sustainable drainage (SUDS) would have an unacceptable impact on the site and he application was refused. Alternative solutions will require underground tanks and pumps which are not sustainable.

Objection 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 provided no justification for the site to no longer being categorised as Green Belt. Green Belt status is also needed to mitigate for losses elsewhere in the District where additional housing is being provided in more sustainable locations. The submission has not given the Parish Council or villagers the opportunity to be empowered and ignored their wishes to see SP2 to remain Green Belt.

NPPR Requirement to empower local people to shape their surroundings (Paragraph 150): NHDC is well aware of local feeling toward the potential development on this site but appears to be ignoring the objections particularly concerns of the environmental impact together with the high risk of flooding of the site.
Thames Water has stated lack of sewerage capacity.
The Planners have ignored their own Planning Committee who recently REJECTED this site for development.

For the reasons above, I urge that SP2 be removed from the 2011/2031 Local Plan.

I am writing to object to the local plan for Whitwell that designates it a category A village.
Whitwell is an isolated village with very poor public transport and no plans for any improvement or increase in such.
A large increase in new residents as allowed for in the plan (SP2 site between Bendish lane and Horn Hill) will incur a dramatic increase in traffic, as it is not possible to commute to areas of local employment or hub railway or bus stations
(eg Luton, Harpenden, Stevenage, Welwyn Garden City) at all by public transport and there is a very limited service(every 2 hours) to St Albans and Hitchin.
This similarly effects secondary school aged children and will be compounded in the future by the County Councils plans to remove school buses or make the places prohibitively expensive.
The surrounding lanes are narrow and in some places single track.

In addition I am not aware of any evidence to show demand for the size of development that the plan encourages.

Whitwell should be a category B village.

I wish to object to the inclusion of the land known as SP2 located in Whitwell village. I strongly argue that the proposed allocation of housing at SP2 renders the local plan unsound and not legally compliant.
My objections are set out as follows:
The plan is not sound as it provides for too much housing to the detriment of the open countryside. SP2 has been added at a very late stage and should be removed as it is not needed.
Whitwell has no facilities such as a senior school, shops and other public facilities. It has a very limited bus service. Of the 4 roads leading into and out of Whitwell, only one is not of single track, and that itself is narrow in places. Whitwell should be categorised as a 'B' village. The proposed development is not in a sustainable location and will depend on private transport for all travel. Those who wish to walk into the main centre of the village will have to walk along a very narrow footpath beside a busy road.
The development site is directly opposite a Primary School, there is no secondary school for many miles so more traffic along single track roads. The significant increase in traffic including service and delivery vehicles will have significant impact on traffic flow and will mean that it's only a matter of time that a child is injured or killed by the huge increase in traffic in and out of the site opposite the primary school. The primary school is already full to capacity. It does not comply with NPPF, SP2 will have an unacceptable visual impact due to high visual sensitivities associated with countryside views.
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. The NHDC councillors only in the past few months rejected the site for housing development due to surface water flooding and sewage flooding considerations, as well as other impacts.

The Local Plan has ignored our local community. NHDC is more than aware of the local adverse feeling towards potential development on this site. Well over 100 residents of this small village took the trouble to drive 10 miles to attend the planning committee meeting to object, the other month. This particular site is not needed to meet the identified housing needs. The application was rejected by the councillors.
The Local Plan Preferred Option allocated the site for Green Belt. This was fully supported by the Parish Council. 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 submission has not given the Parish Council or villagers the opportunity to be empowered and ignored their wishes for SP2 to remain Green Belt. The NPPF principles advise the use of brownfield sites, preserve the beauty of the countryside, build in low risk flood sites, and empower local people to help share their surroundings, this proposal is contrary to these principles.

We write to give our objections to the unheralded and late inclusion of SP2 in the Local Plan despite its being rejected by the NHDC Planning Committee in August 2016.

Chapters 4 & 13 Policy SP2.The plan is not sound - no thought given to matters as public transport, schooling, shops and narrow lanes creating havoc for unrehearsed motorists.

The NHDC does not comply with NPPF as no thought has been given to flood risk. Any development on the site would also be deleterious to the scenic beauty of the site.

The Council's Strategic Flood Risk Assessment recognizes the site's high risk of surface water flooding.

Your Planning Committee determined that sustainable drainage would have unacceptable visual impact upon the site and the application was refused.

All in all it appears that the Local Plan has ignored the people of Whitwell who better know the site. Thames Water state that there is a lack of sewerage capacity!

Last, the Local Plan Preferred Option allocated the site for Green Belt. What justification does NHDC have for its change of mind?

We consider earnestly that the SP2 should be removed from the Local Plan.

Whitwell is a Village. It has No amenities, apart from one post office/shop. To build homes in Whitwell is madness.

Object to Chapter 4 SP8:
This plan is mad as it proposes many houses for a totally unsuitable site.

Object to Chapter 4 SP2:
The Village will no longer be a Village with the proposed extra houses. Whitwell has already absorbed a huge amount of housing development , with houses being built up Horn hill, all over the once were Allotments, and out on the Lilley bottom road before the Cress beds. The congestion on the small roads is hideous, with the high street of Whitwell being impassable and dangerous to any local resident trying to get out of their front door. This traffic congestion then continues down onto Codicote high street through to the A1 and Welwyn garden City, along Whitwell road to Hitchin and out on the Lilley bottom road towards Luton. The quality of life in Whitwell can only deteriorate with more houses and the inevitable addition of many more cars. There is no work immediately around Whitwell so everyone will drive out towards the A1, Luton or the Railway stations at Stevenage or Hitchin.

Object to Chapter 13, SP2:
This sight is not acceptable due to a high risk of flooding. The more we build over countryside, the risk of flooding multiplies.

Personal objection;
We need green space and places for wildlife. Without bees and other pollinators we are all dead. DO NOT BUILD ON GREEN FIELD SITES.

Please find my objections to the inclusion of SP2 Land between Horn Hill and Bendish Lane, Whitwell in the Local Plan listed below.

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. In addition Whitwell is accessed by narrow, single track lanes, often requiring passing places. I believe more evidence is needed on impact on additional car usage.

Object to Chapter 13, Site Allocation SP2
The NHDC approach is not sound and it does not comply with NPPF as no consideration has been taken of flood risk. 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. Site SP2 should only be considered if there is an identified need that cannot be met elsewhere with a lower probability of flooding.
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 due to high visual sensitivities associated with cross country views

NPPF Requirement to empower local people to shape their surroundings (Paragraph 150)
The Local Plan has ignored our local community. NHDC is must be aware of the local feeling towards potential development on this site, as it was recently rejected as a site for development. Despite this, NHDC Planners remain determined to use this site despite the known objections, environmental and flooding concerns together with the visual impact on the intrinsic beauty of the countryside. I am bewildered how this can be added to the local plan when the NHDC Planning Committee 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 provided no justification for the site no longer being categorised as Green Belt. 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 late submission of SP2 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 consider that SP2 should be removed from the 2011 - 2031 Local Plan.

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

I believe the Plan is not legally compliant and unsound for the following reasons:

1. Breach of NPPF requirement to engage with community
SP2 has been included without proper community involvement or consultation as outlined in the Statement of Community Involvement. The site was actually allocated ne green belt in the previous consultation to which the community responded positively. As the housing need has been reduced in the current iteration of the plan from 14,400 to 13,800 it can be argued that the site is no longer required.

2. Unsuitability of site for development
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.

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 site is not sustainable as it will encourage 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.

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Object to Chapter 4, Policy SP8
The plan is not sound as it provides for too much housing to the detriment of the open countryside. Sites, including SP2, have been added at a very late stage and should be removed as they are not needed. There is no policy basis for increasing the buffer from the previously accepted 3% to 7%
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. In addition Whitwell is accesses by narrow lanes often requiring passing places. More evidence is needed on impact on car usage. Whitwell should be categorised as a 'B' village
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 due to high visual sensitivities associated with 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. 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 with a lower probability of flooding
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 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)
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. 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
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. 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. 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 consider that SP2 should be removed from the 2011 - 2031 Local Plan

1) (Chapter 13 SP2; NPPF para. 150) The decision by NHDC Planners to re-draw the boundary of the village has been made at very short notice. It immediately followed the rejection of (West Whitwell) SP2 by the Planning Committee in August, giving the village minimal time to react. If the Planners thought that changing the boundary was a desirable end in itself, why did they not propose it at an early stage? Changing the boundary of a community is a decision of major impact and consequence, not something to be done with the stroke of a pen. This lack of value given to the community's existence and views was something I encountered early on. My objection (along with others') was designated "Not Applicable". I do not understand why the Council used this misleading and dissuasive term, which most obviously means "Not Valid". It was only after enquiry that I discovered that I could re-submit my objection and it would be published in full. Again I do not understand why, if I could simply re-submit my objection, the Council could not itself have published all those previously unpublished contributions or at least informed us that we could do so. When mine was re-published, it prompted a flurry of interest on Facebook for the possible historical interest of the location. What I take from these two examples is that the Planning Dept. is less interested in the responses of individuals or the public at large than in exerting the fullest pressure to fulfil its intentions. This runs counter to a "positively prepared" and "objectively assessed" strategy.

2) It is inappropriate to designate Whitwell as a Category A village. It is accessed by small country lanes, its poor public transport service has recently been further reduced, it has no supermarket or any other relevant infrastructure. It should be re-classified as a Category B village more suited to infill. (Chapter 4, Policy SP2).

3) The number of houses which NHDC is required to deliver has been reduced from 14,400 to 13,800 but the Council has increased its contingency buffer from 3% to 7%. This suggests that the Council is taking unnecessary advantage of the opportunity provided by the Local Plan at the cost of disadvantaging the existing village. This does not meet the criteria of "justified" and "positively prepared."

4) In the last draft of the local plan, SP2 was allocated for green belt land. This was appropriate in the light of the proposed urban expansions of Luton and Stevenage. The designation has now been overturned. This indicates how little the Planning Department estimates the amenity value of the Whitwell environment. This action does not meet the criterion of "justified."

5) The site has been assessed by the Environment Agency as having a high-medium risk of surface water flooding. Para. 100 of NPPF asserts that development should be directed away from sites at high risk of flooding. This contradicts "positively prepared", "justified", and "consistent with national policy" criteria.

6) NHDC has omitted from its documentation that Thames Water state that the existing sewage system cannot cope with any additional requirements. The proposed development would depend upon a septic tank and pump. Given the proximity of the historic water-cress beds, the potential for disaster is unthinkable. This contradicts national policy in terms of sustainability.

7) No mention throughout has been given to the possible historical value of the site, which is known clearly to older residents as "Meeting House" on the basis that it was used by John Bunyan for his open air meetings. The amphitheatre shape of the site gives credence to this assertion and oral tradition usually has a reliable basis. Bunyan is known to have frequented Bendish for smaller gatherings; a larger site would have been necessary for an assembly of followers from surrounding villages. The former church of St. Mary in Bendish Lane was preceded by a chapel of the Countess of Huntingdon's Connexion, both of which are likely to mark the site of previous religious gatherings. In addition to the quality of the visual landscape, it is important to give credit also to the historical landscape. Although this factor was mentioned in my original submission, for six months it lay unpublished as a result of the Planning Department's haphazard supervision of its website, dedicated as it is to the recording of the concerns of its constituents; for this inadequacy it accepts no responsibility.

For all these reasons, I believe that the proposed Local Plan for Whitwell/St. Paul's Walden fails to meet the desired criteria in regard to positive strategy, justification, effectiveness and consistency with national policy.

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