Policy SP2: Settlement Hierarchy

My observation, it appears that the boundary is incorrectly drawn. The boundary seems to have missed out the the first property on the northern (left hand side ) of Hitchin road. The house is located after the village sign, i.e. within the village, adjacent the proposed new 40 homes, one would assume that it is indeed part of the settlement. There is a similar observation to made adjacent School Lane and Maiden Street at the entrance to the village from the east?? One assumes that this/these draughting error can/ will be rectified before being enshrined in the Local Plan.

The Parish Council generally supports this policy and the settlement hierarchy for the District. It supports the designation of Knebworth as a Category 1 settlement in line with the principles described in paragraph 4.13. Comments on the detailed policies for Knebworth are set out in our representations elsewhere.

The Parish Council also supports the intention (paragraph 4.11) to focus the majority of development on towns and urban extensions.

Some detailed changes to the policy wording are suggested. In the first part of policy SP1, on Stevenage, the reference in the bracket should state ("including Great Ashby and west of Stevenage") The reasoning for this is set out in our comments on the strategic housing sites.

In the second part of the policy, it is recommended that the introductory wording should be changed to read as follows:
" General development will also be permitted in the defined settlement boundaries of Category A villages. The amount of development shall be specified in Neighbourhood Plans, to be prepared for each of the settlements. Provision for housing shall be not less than 10% of the number of dwellings in the 2011 Census returns. The Category A villages are:....."

This is based on an assumption that existing towns have spare capacity within their facilities and infrastructure, but this is incorrect. In Baldock for example the schools are already over subscribed, the road network is at capacity with no options for expansion (due to pinch points at historic junctions and narrow roads bounded by listed buildings hundreds of years old, and the situation of the railway line and the narrow rail bridge allowing traffic under it), the GP surgery is at capacity, and leisure and sporting facilities are also at capacity (in fact Baldock has far below the recommended level of open space and sporting recreational area/facilities). Furthermore, it assumes that development of existing towns will help to meet local housing need - however, since the biggest site (north of Baldock, Blackhorse Farm) lies in what used to be greenbelt (until it was removed as part of the review which forms part of this Local Plan) and is situated right next to the train station with a fast connection to London (34 minutes to London Kings Cross) then development of this site will in fact lead to massive upward pressure on house prices in that development (within 20 minutes walk of the station) and a consequent uplift in prices in North Hertfordshire. In short, a very large number of houses in this plan will go toward inward migration of people currently living in London who wish to continue working in London - this will leave housing need left unmet and also drive up prices, in fact exacerbating problems in North Hertfordshire. This would be easily mitigated by scaling back the development north of Baldock and separating it from Baldock by a strip of Greenbelt (or developing this strip only at the end of the period).
Also, the council needs to accelerate efforts to establish new towns (garden villages) within the district. Although little work has been done so far, and so these cannot contribute to the figures in this plan, it should be the aim of the plan to establish 2 new garden villages in the district by the end of the period (for example at Odsey which is further along the train line and less desirable for commuting to London, and at a location half way between Luton and Stevenage, which would not be on a current train line, but would offer short commutes to the local towns) - depending upon how these new settlements progress, then the Plan will have flexibility to alter plans elsewhere as the plan is reviewed over the period.

Although the text claims that the Plan seeks to allow villages to grow as vibrant functioning communities, it looks like it will actually act to stifle growth in the villages of all sizes. The green belt review, which forms part of this Local Plan, whilst removing large areas of green belt around existing towns intends to smother the whole of the south of the district in greenbelt - this is quite unnecessary the existing green belt areas provide sufficient protection against the encroachment of the existing large settlements of Luton, Stevenage and London. Plan seems to indicate that in the villages only infill or development within existing village boundaries will even we considered - this actively works to limit options for development and will stifle development, drive up house prices and kill these villages and functioning communities. The plan needs to be clearer about the circumstances under which development outside village boundaries will be considered. The villages should not be allowed to die under a misplaced desire to leave them untouched by modern development.

Developing close to Baldock train station with its fast link to London as a result of releasing Green Belt land will only serve London housing need and will leave local housing need unmet, whilst also driving up house prices and placing Baldock facilities and infrastructure under additional strain, when they are already over stretched and unprepared for extra load.
The plan should include the establishment of 2 new garden villages that will in time grow into garden towns (even if building of them is barely begun by the end of the period).
Plan seems to actively stifle development of villages of all sizes (whist the text states it aims to do the opposite), by restricting options for development too much.

See attachment

This policy is unsound and not consistent with National Policy on sustainable development and potentially in conflict with the Spatial Vision above in Para 3.3. Specifically, in Para 4.13, the classification of Category A villages is based on a false premise rather than on proportionate evidence.

This policy effectively permits district planners to expand the boundaries of remote rural villages at will, at the expense of precious countryside and without regard to the best interest of the community, simply in order to meet the District's overall housing totals.

This goes beyond the vision in Para 3.3 above, which makes it clear that this should be only where needed for villages to thrive. The background documents relating to this policy make the argument in terms of preventing social and economic harm. This is a false premise. Just because a village has a primary school, which may be (as is the case in Whitwell) already full and thriving, it does not follow that the village needs to expand to become a town, at the expense of valuable countryside. Smaller village have a special character and community spirit that should be fostered and protected.

Furthermore, where the nearest secondary schools, supermarkets, train stations, shopping and employment, are all many miles away by private car through narrow country lanes (as is also the case in Whitwell), this is clearly contrary to the NPPF on sustainability.

Before designating a village as in need of expansion (Category A), specific local evidence should be gathered on a case by case basis, with regard to housing need and demand, views of the community, and sustainability, including daily travel patterns and carbon impact

I am writing to express support for the proposed alteration to the settlement boundary, in the east of Ashwell, specifically in the area of Ashwell Street (known locally as 'The Ruddery') which is off Station Road.
There are some areas of land between the last house on the south side of The Ruddery and Ashridge Farm that could provide suitable additional land for small scale housing development.

Reasons for supporting this proposal by the Local Authority are as follows:

Positively Prepared:
Providing additional plots of land for new housing, in a village that is in need of additional dwellings and responding to the general shortfall in the North Herts. region.
Small scale development in this location will not detract from the Historic centre and existing Conservation area.

Justified:
The inclusion of this area for development appears to be a good strategy compared with other areas within the village that have been proposed in the past.

Effective:
Development in this area appears to be deliverable, with good access and availability of existing utility services in the location.
Development in this area should have limited affect on the locality and with limited neighbouring properties.

Constant with national policy and sustainable development:
Sustainable location - with good access from Station Road.
Village facilities, school and shops can be reached by foot on pavements.
Main line train station is 1 3/4mile, a reasonable cycling distance, providing access to Royston, Cambridge and London etc, without the need of a car.
Bus stops close by, easily reachable by foot on pavements.

Please will you keep me informed of any developments to your proposals and if and when adoption of the Local Plan is carried out.
Please keep my details on your mailing list.

Please add the following comments to the submission of the local plan to the Secretary of State.

North Hertfordshire District Council's Local Plan is lacking in flexibility for the provision of housing in the future by drawing the new green belt proposals too tightly around villages and settlements within the district thereby eliminating small scale development within and on the edges of villages and settlements which would enhance their viability and long term future. Furthermore, applying green belt protection to settlements by sweeping the green belt over them precludes any natural growth.

The argument that development in settlements and villages within the green belt is not sustainable is clearly false as these communities have been sustained some for many hundreds of years.

I am writing to you in response to the final stage of developing the Claybush Rd site in Ashwell. I would like to raise my family's objections to the recent planning application for said site.

Personally we are aware that Ashwell Parish Council has already objected to the inclusion of the Claybush Hill site (AS1) in the emerging local plan knowing it to be unsound, in so far as it is not consistent with National Policies (especially NPPF 11). APC is being proactive, through the Neighbourhood Plan, in identifying what type of development is required to satisfy the housing needs of the village & the sites suitable for it. Yet NHDC continue to ignore both the work of the APC in identifying the real needs of our community & the concerns & views of us villagers. This is undemocratic & fails to satisfy the requirements for local democracy (Localism Act 2011).

To summarize in brief....

AS1 fails to meet the requirements to protect the historic environment. This site will be in the setting of the ancient monument Arbury banks and is protected by NPPF & NHDC policy.

Site AS1 fails to meet the requirements for highway safety to protect pedestrians & other road users as defined in both NPPF & NHDC's own current & emerging planning policy.

Site AS1 fails to meet the requirements to protect valued landscapes. The site is within the North Baldock Chalk Uplands Character area & development is restricted under NPPF & NHDC's own local planning policy, both current & emerging.

NHDC has failed to consult on the proposals to extend the settlement boundary in locations other than AS1, within which there would be a presumption in favour of development; Policy SP2, & has not responded adequately to previous representations.

I truly hope you take the time to consider all the objections raised by myself & others.

The settlement hierarchy as proposed is supported and is an appropriate method of determining the associated policy

I cannot see how this local plan takes into the account the rural character of Baldock when the increase in housing will support the thriving rural community of Baldock nor protect the Green Belt, especially when the propsoed housing is planned for existing farmland

I refer the inspector to the NPPF bullet 21 where local plan needs to take account of the different roles and character of different areas,
promoting the vitality of our main urban areas, protecting the Green Belts
around them, recognising the intrinsic character and beauty of the
countryside and supporting thriving rural communities within it

Herts LEP supports this policy

Object to the change of settlement boundaries around category A villages because this is a clumsy attack on the long-standing green belt area of Hertfordshire. No exceptional circumstance has been demonstrated.

Policy SP2: Settlement Hierarchy:
The policy is supported. This is because the settlement hierarchy set out in the policy is the most sustainable approach and is consistent with the guidance in both the National Planning Policy Framework (NPPF) and the Government's web-based Planning Practice Guidance (PPG).

This policy is not legally compliant as it is inappropriate to categorise Whitwell as a Category A village.
These villages are defined as needing to increase in size to thrive. This completely conflicts with the findings of the Parish Plan and Housing Questionnaire. The PP indicates that only 70% of the village does not consider small scale development to be appropriate or required. respondents also stated that if the village was required to expand then only 13-14 homes could be accommodated. Whitwell is a popular hub for walkers and cyclists from nearby towns and this role should be preserved.

Chapt 4 SP2 Settelement
I object on the grounds that the assessment of sustainable locations for housing in rural areas is not sound as not based on an adequate assessment of environmental impact as required by the NPPF and not consistent with NHDC's own transport policy criteria (T1) 'developments to be in locations which enable sustainable journeys to be made to key services and facilities.'

Climate Change is the biggest long term threat that we face. It is vital that the NPPF's requirement for sustainable development which reduces our environmental impact (especially CO2 emissions and air pollution) is followed. Siting more than very small numbers of new houses in villages with little or no public transport and at distances from essential amenities such as employment, supermarkets, secondary schools etc which require the use of cars is not sustainable.

Paragraph 13.324 Site SP2 in Whitwell designated for over 40 houses (site capacity over 100 houses) is more than 5 miles from the nearest supermarket and other essential amenities such as employment and secondary schools. Public transport is impractical (2 hr bus service).

The road infrastructure supplying the village consists of narrow country lanes often with single track passing places. These roads are already overcongested at peak times.

The inclusion of Whitwell as a category A village and of SP2 as a potential development site is not sound as it is not justified (not the most appropriate way of fulfilling housing needs) and is not consistent with National Policy for sustainability or the core planning principals of the NPPF para 17 which states that patterns of growth should be actively managed to make the fullest possible use of public transport, walking and cycling and focus on locations which are or can be made sustainable.

Focusing development and growth in a limited number of locations is not consistent with Policy SP1 or the Plan's objectives or supported by National Policy
The development strategy fails to plan positively for rural areas by limiting growth within it. This will ultimately adversely impact on the needs of these areas and the wider needs of the District. It does not allow smaller communities to grow sustainably and sensitively to meet housing needs
This Policy is at odds with NPPF (paragraph 55), which recognizes the needs of rural areas must be identified and catered for. Whilst we support development in the Settlements identified as Category A, B and C we do not consider that the policy is sound in only providing for limited development in these settlements and none in settlements outside this categorization. Appropriately scaled development in any Settlement is likely to be beneficial to these villages both to meet local housing needs and to underpin local facilities and services like the local hall, pub, and bus service.
We suggest that the development strategy is amended to allow for the needs of the rural area to be acknowledged and permit development within or adjacent to any settlement boundaries, where it can be justified.

See attachment

I feel there is some scope for development (as there may be in other "category C" settlements) which may serve to take some of the pressure off building unsustainable 'mega settlements' like the ones proposed at BA1 and LA1

To label Whitwell as a category A village is an incorrect assessment. This categorisation deems that the village needs an increase in housing numbers in order to thrive but there is no evidence to this effect in the case of Whitwell. The village thrives BECAUSE of its rural nature and location. Its attraction to those who live in the nearby conurbations are those very attributes that would be put under threat by development . The village is a magnet for ramblers, hikers, cyclists and those who wish to escape the nearby towns for a short while and experience the atmosphere of a country village with its attendant pace of life - an amenity all too rare in this corner of North Herts. Whitwell would be correctly classified as a 'category B' village.

Paragraph 13.74

Codicote village warrants its Category A status as a local centre at the southern end of the district. It has long been an 'excluded' Green Belt village and continuing incremental peripheral growth is endorsed. In this regard, some of the 20th century development has left something of a hard edge which can now be remedied upon the chosen development sites.

Paragraph 13.316

The identification of St Ippolyts/Gosmore as a combined Category A Village and the defining of a settlement/Green Belt boundary is welcomed and supported. These twin villages have a distinct identity and community with a modicum of facilities, but also benefit from easy access to Hitchin and all the higher order facilities therein. Allowing general development within the settlement boundary and the allocation of a housing site in each village is also endorsed.

Paragraph 13.171

The Category A status of Kimpton village is endorsed. It is noted that following Regulation 18 consultation, only one site is now allocated, but that the redefined Green Belt boundary, within which policies will allow general development during the Plan period, affords potential for sustainable growth to keep the community vital and its facilities viable.

Representation (Objecting)

The policy designation of the rural settlement of Blackmore End / Gustard Wood is considered unjustified and inconsistent with other relevant policies of the Plan and the wider context. The part of the settlement that falls within North Herts settlement is considered correctly classified as a Category B Village (Policy SP2 Settlement Hierarchy 'infilling development which does not extend the built core of the village will be allowed').

However the settlement part will sit within the newly proposed, extended, Green Belt area and should therefore be washed over by Green Belt, as set out at NPPF paragraph 86. The proper scope for development is considered therefore to be 'limited infilling in villages' in the Green Belt under NPPF paragraph 89 (Bullet 5), in conjunction with NPPF paragraph 86.

The policy proposed also creates cross boundary issues, which have not been raised directly with St Albans City and District Council. The settlement designation is inconsistent with the longstanding designation as a 'Green Belt Settlement' of the part (just under half of the same village) within St Albans City and District in the adopted St Albans City and District Local Plan Review 1994. It is also inconsistent with the (same) approach taken in the emerging St Albans Strategic / Detailed Local Plans.
References: Para 4.15 et al / Policy Nos SP2, SP5 / Policies Map Sheet 1 Side B

Supporting points:

* The settlement has previously been dealt with under rural development restraint policies that are consistent in terms of a limitation to infill development only. The new policy should align completely with the NPPF. Exclusion of the part of the settlement that falls within North Herts from the Green Belt appears unjustified as it is very small and sits within an overall area that is presented as requiring full Green Belt protection. It appears the settlement is still acknowledged as unsuitable for significant development. It follows that it should therefore be washed over by Green Belt, as the NPPF envisages.

* The policy designation is inconsistent with the treatment of other villages in Category B (Old Knebworth) in the Plan. This appears to be justified on the basis of the relative physical age and character of development and a view that a more historic village makes a greater contribution to the Green Belt than a more recent suburban area. This appears to miss the importance of the whole range of NPPF Green Belt purposes and the need to deal effectively with likely future development pressures. Both settlements appear to demonstrate a broadly equal contribution to openness of the Green Belt in that current development is low density / dispersed and should remain so (the core purpose of the national GB policy).

The settlement hierarchy set out in Policy SP2 lists Ickleford as a Category A village, the second tier of the hierarchy behind the main towns. We support this conclusion as it reflects the size and function of the village. While development is understandably directed towards the main towns, the Local Plan nevertheless acknowledges that "it is important to allow growth of the villages in order to allow those communities to continue to function". We support the level of growth directed to Ickleford as part of the overall hierarchy.

ConnectedCities focuses all development in the 1 km radius pedsheds (see http://www.connectedcities.co.uk/vision-2050/pedshed ) of rail station, whether existing or new. This results in three conditions:

1. Town Growth Zones: development around existing stations. See http://www.connectedcities.co.uk/vision-2050/town-growth-zones

2. New Green Quarters: urban extensions in the pedsheds of new stations on the edge of existing towns. See http://www.connectedcities.co.uk/vision-2050/new-green-quarters

3. New Green Towns: new settlements in the pedsheds of new stations. See http://www.connectedcities.co.uk/vision-2050/new-green-towns

I do not agree with the categorisation of Whitwell as a category A village where development is permitted within the village boundary when part of this plan is extending the village boundary to make it bigger to enable development of greater than 10% of the current housing numbers. Whitwell could facilitate some infill growth. Extending the village boundary to enable growth in a particularly landscape and flood sensitive area is not sustainable growth for the village, nor is it necessary to meet the small scale growth that the village can support within existing boundaries.

We support the decision to categorise settlements within the district and generally support the principle of development boundaries around the defined villages. As identified in Policy SP2, Weston is defined as a Category A settlement, where general development will be allowed within the defined settlement boundaries.

Paragraph 4.13 Defined Settlement Boundaries

The defined settlement boundary to Weston as shown on the Proposals Map excludes The Cricketers Public House, which is located at the southern end of Weston, on the western side of Damask Green Road. The proposed boundary to Weston extends down as far as the southern tip of the settlement, where the road bifurcates.

The proposed settlement boundary, incorporates within it, all the dwellings and their garden areas on the eastern side of the road. On the western side of the road, the boundaries steps in to follow the highway edge, thus leaving the public house and the small site adjacent to it to the north, outside of the village.

It is considered that the settlement boundary proposed, should more appropriately include all the existing developed area, including the public house, which is an integral part of the settlement. There is in fact no logic to excluding the site as clearly both visually and physically this area is a part of the village and its built form. The public house may wish to expand, in order to remain viable in this location. It would be more sensible to ensure that it is, in policy terms, viewed as a part of the settlement rather than being constrained by Green Belt. Conversely, in this context, the location of the site of the Cricketers would make no contribution to either the character, openness or appearance of the Green Belt and so should not be included in it. The boundary should be amended accordingly (see attached plan and Google Earth image).

Not to do so and impose more restrictive Green Belt constraints on this important local facility would appear to be entirely contradictory to the thrust of Policy SP1 'Sustainable Development in North Hertfordshire'.

At the time of the Draft Local Plan Consultation in February 2015, we commented on the categorisation of settlements in the district. As now published, little change appears to have been made. The three categories for the villages continue to be predicated on the facilities available in each settlement. This is the criteria chosen without any recourse to the level of population, the relative isolation of the settlements and their unsustainability in terms of transport modes.

Category A Villages
Are generally those with the largest populations and consequential services. However, even in this category, there are villages included such as: Preston (pop 420); Reed (pop 310); Sandon (pop 495) and Therfield (pop 556), which are relatively remove and have very few, if any, essential services such as a shop that would enable residents to restrict their everyday use of the private car. It is difficult to differentiate between these Category A settlements and those included in Category B.

Category B Villages
A number of the villages set out in Category B, appear to have been identified as having only a village hall and church in the settlement (examples are Kelshall (pop 163); Newham (pop 209); Rushden (pop 242)). Neither of these facilities is particularly useful to the residents in a practical day-to-day sense. All of these settlements are relatively remote, having little access to any useful public transport and residents are entirely reliant on the private car for their everyday needs. However, these settlements are designated as areas where infill development can occur within the 'built core' of the village. This is a policy currently applied in the existing Local Plan. The lack of any certainty as to what is the 'built core' causes confusion and uncertainty. The areas considered to be appropriate for development should be demarcated. If this is not the case, then the likelihood of such settlements providing for any, albeit modest level of housing, will be extremely limited, as proposals will be judged against the stringent policies of the proposed CGB1 'Rural Areas beyond the Green Belt'.

Category C Settlements
This category includes a more limited number of settlements, but development will be more restricted as a consequence of a "modest level of facilities". Bygrave is included in the category notwithstanding that it is of a not unsubstantial size.

Bygrave is a settlement of 304 people, but is included in Category C, where "a more restrictive approach will be taken...." It is larger in population terms than two Category A settlements and a number of Category B settlements. It is also considerably less isolated, being physically closer to the main town of Baldock, with easy links to both the local railway station and the main and motorway routes. Bygrave should be reclassified and upgraded to Category B.

Site at Garthlands, Jacksons Lane, Weston

We support the inclusion of Weston as a Category A settlement where "general development will also be allowed within the defined settlement boundaries of the Category A Villages". These villages, of which Weston is one, contain a number of local facilities, which are of benefit to the local residents and assist in making the settlement more sustainable.

Paragraph 4.13
We wish to object to the defined Settlement Boundary as drawn around the settlement of Weston and seek to have it amended. We consider that is should be adjusted to incorporate land at Garthlands, an existing residential site which takes access off Jacksons Lane and which lies to the west of Munts Meadow and to the north of the recreation ground (see attached plan).

The site has been in residential use for many years and the original property on it was redeveloped a few years ago with two houses. It is a large site of 7,251m sq and is currently in use as garden land and is well screened with mature landscaping along its boundaries.

In terms of its location, it forms a part of the built form of the village and does not extend further into open countryside than does the existing housing in Munts Meadow. It also abuts the recreation ground to the south, it is, therefore, contained by uses other than the open countryside. As such, it is an integral part of the village and the boundary indicated on the Proposals Map should logically be modified to include the site within the proposed Settlement Boundary (see attached plan).

The site could provide for a small development of family houses, which would benefit from its central location, close to the core of the village, within a short walking distance of the school, shop and public houses. The site is not prominent from any point and is well contained by boundary treatments. Development would not have any adverse impact on either the character or appearance of Weston or the Conservation Area it abuts. Rather a small development would be entirely consistent with the thrust of Policy SP1 'Sustainable Development in North Hertfordshire', specifically sub-section (b) which states to ensure that "the long term vitality of the district's villages by supporting growth which provides opportunities for existing and new residents and sustains key facilities". The more local residents there are within walking distance of the village facilities, the more support will be given to them and consequently they are likely to remain viable. Its inclusion in the defined settlement boundary would be both physically and visually logical.

The site is in residential use. It is located close to the core of the settlement and does not extend into open countryside. There is no reason why it should not be included within the settlement boundary.

We generally support the proposed settlement hierarchy.

Ashwell is currently identified as a Category A settlement wherein general development will be allowed within the defined settlement boundaries.