Policy SP2: Settlement Hierarchy

Paragraph 13.5
Ashwell

The Local Plan 2011-2031 Proposed Submission, October 2016, has amended the existing development boundary of Ashwell village to include additional land to the south and to the east. It is noted that the Parish Council (PC) state that no local consultation was undertaken on the amended boundaries now shown.

It is considered that a more sensitive approach to the amendment to the development boundary should have been undertaken to enable additional parcels of land immediately adjacent to the village to be incorporated. This would enable small scale housing development to occur, in a sustainable location, to meet locally assessed housing need.

The PC, in its response to this proposed Submission Plan (18 November 2016), makes clear that there is considerable local interest in Ashwell in respect of the provision of new housing, which will be expressed in a forthcoming Neighbourhood Plan. What is also clear is that the well supported Parish Survey on Housing Issues identified that:

"* Housing was required for those who wanted to downsize, which in turn would free up larger houses;
* private housing for older people who have mobility issues;
* people did not want houses built outside the village boundary; and
* people did not want sites of more than 10 houses.

One such small site is that shown on the accompanying plan and identified on the Google Earth image. It is located on the north eastern side of the village bounded by Springhead to the south and Cow Lane to the north west. The land is bounded by substantial and well maintained hedgerows, is laid to grass and intermittently grazed by sheep. It does not form a part of an agricultural holding. It is in the ownership of Duck Lake House and has been used intermittently by the owners for the growing of vegetables.

The site currently is located outside the village development limits. It is not clear why this is the case, as its boundary abuts an area of land to the east, which falls within the defined settlement boundaries of the village. It also shares a rear north eastern boundary with that parcel of land. The site is therefore well defined by physical boundaries and its incorporation into the Development Boundary would, in both a physical and visual sense, be completely logical.

The site was assessed in September 2016 as a part of the Sustainability Appraisal of the North Hertfordshire Proposed Submission Local Plan (CAG Consulting). Appendix 7: 'Non Preferred Sites - Summaries and Appraisal Matters'. The report states as positive effects that the site is: "Close to the local centre and facilities; would support the rural community; is not in a flood risk area; is within 400m of a Green Space; within 400m of a bus stop". The negative effects are: "Further than 800m to train station; (as is the whole village); Greenfield site; site included as part of a designated wildlife site (we can find no evidence of such a designation); that the initial construction phase may impact on adjoining residential properties (all development would have this effect); the site is in the Conservation Area; (this of itself does not prohibit development per se).

There is, in fact, no substance to the negatives identified in respect of this site that would not occur on any other site within the core of the settlement. There are no identified constraints either practical or visual that should prevent it being considered favourably for inclusion within the defined settlement limit of Ashwell.

There is no logical reason why this small site should have been included the settlement of Ashwell. It is of a similar scale, size and appearance to the immediately adjoining land which is included. It would create a small site that could be effectively used to provide a dwelling in a sustainable location.

Baldock, the oldest town in North Hertfordshire, is expected to grow by 80%
with the largest development separated from the town by the railway and traffic congestion

NHDC have failed to satisfy me that the housing need will be for our local population

Policy SP2 of the draft local plan identifies Ashwell as a Category A Village in the settlement hierarchy where general development will be allowed within the defined settlement boundary.

The draft proposals map shows the proposed settlement boundary for the Village and there are significant changes to the boundary when compared to the boundary in the adopted District Local Plan No 2 with Alterations. One example is the inclusion of an area of land located south of Lucas Lane.

There is no evidence or explanation in any of the documents forming the evidence base to justify these changes to the Village settlement boundary and it is therefore unclear why the changes have been made and what criteria have been used to justify the inclusion of the additional land within the boundary.

The Housing and Green Belt Background Paper forming part of the evidence base does explain that two sites (304 - land north of Ashwell Street and south of Lucas Lane and 305 - land west of Station Road and north of Ashwell Street) were submitted as being available for development through the SHLAA process. Appendix 2 of the Paper states that the sites are not to be allocated for development in the draft local plan but in the reasons section it suggests that the sites will be brought into the village boundary where development in principle will be supported on unallocated sites. The assumption therefore has to be made that the only reason the land is to be included within the settlement boundary is because of the potential for windfall development in the future.

The New Sites since 2015 (additional sites submitted since 2013) Document prepared with the Preferred Options Local Plan in 2015 states that Site 304 has the potential for around 12 dwellings and Site 305 has the potential for around 29 dwellings. Assuming that both sites come forward once they are included within the settlement boundary, and taking into account completions and permissions together with the allocated site also proposed in the Village in the draft Local Plan on land at Claybush Road, this will mean that Ashwell will accommodate a minimum of 136 dwellings in total over the plan period. Ashwell has 841 dwellings (2011 Census) and 136 dwellings will therefore represent close to a 20% increase in the number of households.

The approach being proposed in the draft local plan to formally allocate one site in the Village and then extend the settlement boundary to include a number of parcels of open land, such as land to the south of Lucas Lane, which have been promoted for development through the SHLAA process and which will then be supported for development because they are within the settlement boundary is not transparent and is not justified. It the Council's intention is for sites 304 and 305 to come forward for development then they should be assessed as part of the local plan and sustainability appraisal process rather than treated as windfall sites.

Paragraph 13.265 - Pirton has long been designated as a selected village in the rural area (beyond the Green Belt), wherein development has been permitted within the "main area" of the village defined by the "village policy area" on the current Local Plan Proposals Maps. On the current 1996 Plan, the line is drawn fairly tightly and, in order to allow development, two "character Areas" (V3 and V4), have now been developed as residential cul-de-sacs. V1 is undeveloped, being a Scheduled (Ancient) Monument and V2 is landlocked, so other than redevelopment, which is unlikely to yield much, if indeed any, net increase in housing, there is little room left to meet either the needs of the village or the wider needs of the district. Indeed, the most recent development is 11 affordable homes, built adjacent to, but outside the current village limits, in order to cater for existing housing needs in the parish.

Its Category A designation in the new Local Plan recognises the status of the village in the district settlement hierarchy and its defined boundary as shown on the Proposals Map is drawn to extend around the two proposed allocations, which featured in the previous iteration of the Local Plan (Preferred Options - Winter 2014-15). Neither of these feature in the current version, which allocates no sites, but refers to an outline planning approval for 82 homes at Holwell Turn and 12 other dwellings built or approved since 2011.

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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.

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.

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

I object to the draft consultation and the inclusion of site AS1 on several grounds based on the soundness of the NHDC Local Plan.

These objections can be summarised as

*Site AS1 fails to meet the requirements for highway safety to protect pedestrians and other road users as defined in both National Planning Policy Framework (NPPF) and NHDC's own current and emerging planning policy for Highway Safety (Policy T1).
*Site AS1 fails to meet the requirements to protect valued landscapes. The site is within the North Baldock Chalk Uplands Character Area and development is restricted under National Planning Policy Framework (NPPF) and NHDC's own local planning policy, both current and emerging.
*Site AS1 fails to meet the requirements to protect the historic environment. The site is within the setting of the scheduled ancient monument Arbury Banks and is protected by NPPF and NHDC policy (SP13, para 4.151).
*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) and has not responded adequately to previous representations.

I do not support the allocation of site AS1.

I would like to take this opportunity to reiterate the comments of Ashwell Parish Council in the evaluation of the proposed Site AS1 plans and record my objections to these.

Whilst personally I am not qualified in terms of the legal nuances and procedures I understand that there are legal aspects to the proposal raised by the Parish Council as follows;

These objections to the soundness of the NHDC Local Plan for Ashwell can be summarised as
*Site AS1 fails to meet the requirements for highway safety to protect pedestrians and other road users as defined in both National Planning Policy Framework (NPPF) and NHDC's own current and emerging planning policy for Highway Safety (Policy T1).
*Site AS1 fails to meet the requirements to protect valued landscapes. The site is within the North Baldock Chalk Uplands Character Area and development is restricted under National Planning Policy Framework (NPPF) and NHDC's own local planning policy, both current and emerging.
*Site AS1 fails to meet the requirements to protect the historic environment. The site is within the setting of the scheduled ancient monument Arbury Banks and is protected by NPPF and NHDC policy (SP13, para 4.151).
*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) and has not responded adequately to previous representations.
In addition to the above I am also concerned that with the planned development of the factory site in Ashwell Street that this area of the village will become extremely congested. You only have to see the excess number of cars already parked on bends, near junctions in Ashwell Street to realise that more housing will lead to a compromise of safety.

Site AS1 fails to meet the requirements for highway safety to protect pedestrians and other road users as defined in both National Planning Policy Framework (NPPF) and NHDC's own current and emerging planning policy for Highway Safety (Policy T1).

Site AS1 fails to meet the requirements to protect valued landscapes. The site is within the North Baldock Chalk Uplands Character Area and development is restricted under National Planning Policy Framework (NPPF) and NHDC's own local planning policy, both current and emerging.

Site AS1 fails to meet the requirements to protect the historic environment. The site is within the setting of the scheduled ancient monument Arbury Banks and is protected by NPPF and NHDC policy (SP13, para 4.151).

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) and has not responded adequately to previous representations.

Ashwell is a beautiful historical village surrounded by relatively unspoiled agricultural land. The people who live in and around the village chose to continue to live here because of the character of the village. However, there has been a constant trickle of small-medium housing developments permitted by NHDC over the past years which has pushed the central village and its services to bursting point.

For example, the high street (the only vehicular way through the village as as peripheral roads are one way / very narrow) is practically unusable at rush hour. One used to have the odd car parked on either side of the road and traffic would weave back and forth along the road using the gaps. Now there are long continuous blocks of parked cars the full length of the high street, and all it takes is for two lorries to meet each other and one can be stuck for 20-30 minutes, whilst traffic builds up, vehicles mount pavements etc.

It is unsustainable, and has been caused both by natural trends in car ownership but also by the council allowing the village density to increase through all the developments, converting farm buildings into more housing etc. If anyone is reviewing the feasibility of this development I invite them to drive the length of the high street at 8am and see if they still think it is advisable to proceed with another 30+ homes' worth of cars.

This argument also applies to all the key services in town, including:

* the school, where families who live in the village now have real fears as to whether their primary-school age children will end up having to go to schools elsewhere
* sewage, in that there have been several incidents of waste water backing up into properties
* broadband - the village was recently named by the BBC as having the "second-slowest broadband in the country, slower than Everest base-camp"

Every single additional house built in the village compounds these problems. NHDC is effectively trying to turn Ashwell village into Ashwell town. It is not able to cope with this, to the detriment of all the existing residents plus all those who will occupy the new development. It is for this reason I suggest the new development is not sound.

Furthermore I note that:

* Planning permission for developing site AS1 has been rejected three times for all these good reasons above and many others. Bringing it in via this plan is effectively trying to sneak it in via "the back door".

* Site AS1 fails to meet the requirements for highway safety to protect pedestrians and other road users as defined in both National Planning Policy Framework (NPPF) and NHDC's own current and emerging planning policy for Highway Safety (Policy T1).

* Site AS1 fails to meet the requirements to protect valued landscapes. The site is within the North Baldock Chalk Uplands Character Area and development is restricted under National Planning Policy Framework (NPPF) and NHDC's own local planning policy, both current and emerging.

* Site AS1 fails to meet the requirements to protect the historic environment. The site is within the setting of the scheduled ancient monument Arbury Banks and is protected by NPPF and NHDC policy (SP13, para 4.151).

* 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) and has not responded adequately to previous representations.

* I do not believe development of site AS1 is legally compliant as it may breach existing residents' rights under the ECHR - articles 8 and article 1 of protocol 1, particularly when one considers that the village has fought this proposed development three times and had it rejected, for very good reasons, only for it to appear again now.

* I do not believe it complies with the Duty to Cooperate as it seems that the Ashwell Parish Council's views, which surely should be primary in any decision about whether to permit development in the village, seem to be ignored.

Site As1 fails to meet the requirements for Highway safety to protect pedestrians and other road users as defined in both National Planning Policy framework and NHDC's own current and emerging Planning policy for highway safety
It also does not meet requirements to protect valued landscapes under the NPPF
It does not the requirement to protect the Historic environment and is protected by NPPF and NHDC policy Sp13. para 4.151 of the document
There has been no consultation to extend the settlement boundary in locations other than AS1 by NHDC

Site AS1 fails to meet the requirements for Highway safety to protect pedestrians and other road users as defined in both National Planning Policy framework and NHDC's own current and emerging Planning policy for highway safety
It also does not meet requirements to protect valued landscapes under the NPPF
It does not the requirement to protect the Historic environment and is protected by NPPF and NHDC policy Sp13. para 4.151 of the document
There has been no consultation to extend the settlement boundary in locations other than AS1 by NHDC

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We object to the NHDC Local Plan for Ashwell because we believe the Local Plan is unsound because it is not consistent with National Policies (especially NPPF 11). When this site was originally offered to NHDC by the landowner in July 2009 as a potential development site NHDC failed to take adequate account of historical expert assessments which concluded it was unsuitable for development. Having included it in their draft Local Plan options NHDC have subsequently persisted in ignoring past & recent expert evidence which highlights the unsuitability of the proposed site AS1, and also ignored the views of the large number of residents of Ashwell who have criticised the inclusion of site AS1. NHDC have failed to explain their reasons for continuing to include the site. We also object to the proposed changes to the Settlement Boundary on grounds of the change being unjustified and lacking consultation or justification. Site AS1 fails the Soundness test on the following grounds:
* It fails to meet the requirements to protect valued landscapes. The site is within the North Baldock Chalk Uplands Character Area and development is restricted under National Planning Policy Framework (NPPF) and NHDC's own local planning policy, both current and emerging.
* It fails to meet the requirements to protect the historic environment. The site is within the setting of the scheduled ancient monument Arbury Banks and is protected by NPPF and NHDC policy (SP13, para 4.151).
* It fails to meet the requirements for highway safety to protect pedestrians and other road users as defined in both National Planning Policy Framework (NPPF) and NHDC's own current and emerging planning policy for Highway Safety (Policy T1).
* 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) and has not responded adequately to previous representations.

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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

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