Policy HS1: Local Housing Allocations

See attachment

I would like to reiterate my conviction that a suitable place in Preston for residential development is the field adjacent to Crunnells Green and opposite the main entrance to Princess Helena College.
The field is about 3 hectares and has tarmac road on three sides.
Development on this site would have less impact on neighbours that any of the other proposed sites, whilst allowing some open spaces inside the village. it could be used for a variety of uses.
This area should also be promoted for inclusion in the local plan.

See attachment for plan

See attachment

Paragraph 13.267 - Attached is an extract from the Preferred Options Proposals Map. PT2 is the Holwell Turn site, now approved in outline and contained within the newly defined boundary. As an approval, it is quite correctly excluded as an allocation and forms a part of the district's housing land supply. PT1 is land east of Priors Hill. A site in respect of which our clients have an option and which prior to its proposed allocation in 2014-15, was promoted as being available and deliverable and featured favourably in SHLAAs.

In the Regulation 18 statement of consultation summary there is no NHDC response in respect of either PT1 or PT2. Events surrounding PT2 are set out above. PT1 has simply disappeared as an allocation, albeit shown as within the new village limit. The reason for the removal of the allocation is attributable to the whole site (with the exception of the abovementioned 11 affordable homes, which are not plotted on either of the Proposals Maps) being designated as a Scheduled Monument on 16 May 2016.

This resulted directly from an outline planning application having been submitted on the balance (the entirety minus the 11 affordable units) of PT1 in December 2014 (14/03369/1), in parallel with the Preferred Options consultation. A copy of the illustrative layout which accompanied it is attached. Pre-determination archaeological investigations, including field trials, were undertaken for the applicants in conjunction with the County Council's archaeologists and in parallel, a third party requested that the whole application site be considered for scheduled monument listing, which was successful. The applicants sought a review and pending this, the outline application was withdrawn at the request of NHDC planning officers.

On 16 November 2016 scheduling was reconfirmed by the review, but the boundary was revised and, including a 5m internal buffer, the southern boundary, rather than running around the recently built 11 affordable homes and adjoining the rear of existing housing in Danefield Road, now runs eastwards from the rear of the new housing and parallel with Danefield Road. It can be seen on the attached drawing.

As a consequence of the review of the extent of the scheduled area, a 1.16 hectare parcel of land, formerly a part of PT2 and the parallel outline planning application (3.9 hectares), is now outside the recently scheduled monument. It adjoins existing housing to the south and east and has road frontage in the west.

Mindful of the fact that the larger site was deleted owing to the scheduling and that the boundary was revised very recently, and after the current version of the Plan was prepared for this round of consultations, then there is no reason why the reduced site should not be reinstated prior to submission of the Plan. Indeed failure to do so would logically fail the soundness test.

For the avoidance of doubt, the site remains under option and it is available and deliverable early in the Plan period. Although withdrawn and in outline, access provision was unreserved in the recent application and the County Council was satisfied that the 3.9 hectare site could be accessed satisfactorily. As can be seen, the previous proposal showed 77 dwellings, with 53 served off Priors Hill and 24 from Pollards Way.

In the short time available, a revised preliminary illustrative layout has been prepared as a basis for discussion. It is attached and it shows 29 houses served off the same Priors Hill access as agreed with the County Council as highways authority and a pedestrian access to Pollards Way. As portrayed, the proposal is of a similar overall scale and density to that the subject of the withdrawn scheme and it would have a similar relationship with the monument as the newly built housing at the head of Pollards Way. It is anticipated that this plan will form the basis of a new planning application to be submitted to the local planning authority.

In this latter regard, the Archaeology Collective, which acted on behalf of our clients in liaising with Historic England and the DCMS, has prepared a statement (attached) which amongst other matters examines the relationship between the illustrative layout and the monument. As can be seen, it concludes that: "This SM derives its value from its evidential value; its setting being a modern, ploughs field lined by hedged, some of which have pre-modern origins"; and "The monument derives a small portion of its significance from its setting. The changes that would result from the preliminary illustrative proposals for the 1.16 hectare parcel of land to the south of the SM and north of Danefield Road (figure 4) are negligible (paragraphs 4.9 and 7.2).

To conclude PT1 should be reinstated as suggested, with a format similar to the allocations tables elsewhere in the document (please see attached).

paragraph 13.157 - With the exception of allocation IC1, the promotion and assessment of which has been consistent and transparent throughout the very long process leading to this pre-submission Plan, the two larger sites, which make up over 99.5% of the allocations in the settlement, defy most tests of soundness. Leaving aside any assessment of their merit, IC2 was introduced at the Preferred Options stage and IC3 at this current advanced stage.

Others will no doubt comment on these latecomers, one of which alone accounts for over 75% of the Ickleford allocations. Each, however, comprises large areas of greenfield or non-previously developed land and each extends the existing settlement boundary either north into open countryside or south towards Hitchin.

There are alternatives and one such is land at Ickleford Manor, first drawn to the Council's attention in 2009 and again at the Preferred Options stage. Strangely, it does not feature in the current Regulation 18 statement of consultation. In this regard, it was rejected as being "too late for the site allocations process" in 2009, yet IC2 did not feature in a SHLAA until 2012 and IC3 has only just materialised in the current iteration of the Plan. Ignoring a suitable site either as an alternative or in addition, and the failure to carry out a comparative exercise is a serious failing on any application of the soundness test.

In order to ensure the land in question is considered by both NHDC and the Examination Inspector, we can but repeat what was said most recently at the Preferred Options Stage.

Ickleford Manor is the mirror image of proposed allocation IC2 on the Bedford Road. Unlike IC2, which is mostly not previously developed land, a significant part of Ickleford Manor is previously developed, including approximately 1,555m sq (16,750 sq ft) of mixed commercial floor space. Clearly, under the provisions of the NPPF (paragraph 89), parts of this site are, in principle, capable of appropriate redevelopment via the development management process, whilst remaining in the Green Belt, an option available to the land owner. Indeed, the westernmost portion of the site, bound by the A600 to the west and Turnpike Lane to the north is the subject of a current pending application for residential redevelopment (16/02012/1) for which the location plan is attached.

Mindful of the proposed extension of the settlement boundary, principally IC2, IC3, and the consequent adjustment of the Green Belt boundary along Bedford Road (A600), a comparable adjustment should be made in respect of Ickleford Manor, with the previously developed land at the core. Attached is a previously submitted sketch plan outlining the entire ownership, upon which an indication of the possible extent of development can be seen. This would extend no further towards Hitchin than existing or proposed development (the flour mill being a commercial site long excluded from the Green Belt and extending right down to the River Oughton) and respects existing vegetation in and around the site.

It is suggested as either an alternative to IC2 and/or IC3 (Ickleford Manor is previously developed, has an existing access and is closer to the core of the village) or in addition, in recognition of the sustainable location credentials of the village. Development here would help meet need in the Hitchin area of the district, in a sustainable location and include an element of previously developed land.

Land at Ickleford Manor is, therefore, commended for inclusion. The PDL (shown on the attached sketch and comprising the current application site and the Manor itself) should be excluded from the Green Belt as a matter of course and there is also no logical reason why some greenfield land running parallel with Turnpike Lane and towards Lodge Court should not also be added as, unlike IC2 and IC3, it is well related to the village centre, the 'right' side of the A600 and would not extend the settlement beyond either its existing northern or southern extremities.

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached

See attached