Policy SP2: Settlement Hierarchy

See attachments

See attachment

See attached

See attached

See attached

Section 1:

Knebworth Estates congratulates North Hertfordshire District Council on a Plan that has - not before time - been positively prepared, and - within its delayed and limited time frame - appears justified, effective and consistent with national policy.

Section 4.9 - Policy SP2:

Knebworth Estates supports Knebworth's inclusion as a Category A village, and Old Knebworth's inclusion as a Category B village - although it argues that there are sometimes cases where it is preferable for a village to evolve outside of its "built environment" rather than on the open and green spaces within its "built environment", and that the Plan should allow for such cases.

Section 4.37 - Policy SP4:

Knebworth Estates supports the Plan's commitment to protecting the vitality and viability of the range of retail facilities in the local centre of Knebworth.

Section 4.127:

Knebworth Estates supports the Plan's commitment to deliver appropriate primary and secondary school facilities for Knebworth.

Section 4.162:

Knebworth Estates supports the Plan's commitment "to find new, appropriate uses and solutions to secure the future of heritage assets."

Section 4.165:

Knebworth Estates does not support the Plan considering serving Tree Preservation Orders within historic parks and gardens as this could run contrary to the Plan's commitments in Section 4.162 and the management of historic parks and gardens - and the preservation of, interpretation of, and access to, the heritage assets within - are unlikely to be any better served than by those to whom it is a day-in-day-out commitment and responsibility. Knebworth Park and Gardens has its own Historic England approved Conservation Plan and an exemplary record in its heritage management, and yet another level of statutory requirement is unjustified, unnecessary and counter-productive.

Section 5.28 & 5.29:

Knebworth Estates supports the Plan's intent that Knebworth village centre should continue to provide a mix of shopping, services and community facilities.

Sections 5.39 to 5.48 and Policy ETC8:

Knebworth Estates supports the Plan's commitment to Tourism and argues that - whilst being an Historic England "Priority Building At Risk" - Knebworth House and Knebworth Park belie Section 5.41's statement that North Hertfordshire is not a major tourist destination. The Visit Herts DMO, VisitEngland, the LEP, and Hertfordshire County Council all recognise the district's strong tourism draw and impact. Knebworth House is one of only two Historic Houses in Hertfordshire with a national profile (the other being Hatfield House in the Welwyn and Hatfield district) and Knebworth Park is unique nationally in its capacity for large music events. The Plan should be aspirational to the benefits and potential of Tourism.

Section 6:

Knebworth Estates broadly supports the Plan's Green Belt policies - although, as in Section 4.9, Policy SP2 above - it argues that there are sometimes cases where it is preferable for communities to evolve outside of the "built environment" rather than threatening the quality of life, open and green spaces, balanced zoning and heritage of the "built environment". Knebworth Estates supports the consideration of "exceptional circumstances" within Green Belt policy.

Section 12 - Policy HE2:

Knebworth Estates supports the Plan's "Heritage at risk" policy.

Section 13.183 to 13.202 - Knebworth:

Knebworth Estates supports the Plan's policy for Knebworth within the context and scope of the Plan's objectives and time scales.

Ref - Knebworth - KB1 & KB2:

Knebworth Estates supports the Plan's Housing Allocation and site specific criteria for KB1 and KB2:

Commitment

As freehold owners of the sites identified as KB1 and KB2, Knebworth Estates reiterates its commitment, as expressed in previous consultation responses - and in consultation responses of the independent charity representing Knebworth House (The Knebworth House Education and Preservation Trust), to which Knebworth Estates is primary donor - that if these sites are brought forward for residential designation, it will move swiftly to work with the Council to deliver the full required housing targets with maximum sensitivity to the community of which it has been a part for over 500 years.

Proof of this commitment is to be found in the Estate's long record of involvement in the evolution of the community of Knebworth - since the settlement's beginnings - and specifically, in its multi-generational quest to restore and protect Knebworth House, its Park and curtilage, for public benefit and access (see "Opportunity" below).

The Estate treasures Knebworth's green spaces and environment - it has been a long term guardian of these - however it also believes that Knebworth should play its part in contributing to housing need identified in the Plan, and in the planned evolution of the District as conceived in the Plan. It recognises, with the Plan, Knebworth's pre-existing infrastructure - "a good range of facilities including a railway station, school, doctors and dentists, library, a range of shops, village hall and churches" - and thus considers it right that Knebworth shares responsibility to provide for residential growth with other communities in the District.

As part of Local Plan residential growth, the Estate supports the provision of affordable housing and schemes to provide homes for those who have grown up in the community. It recognises that new homes generate extra pressure on schools and supports increasing school provision. Increased school provision will strengthen Knebworth's independence of Stevenage and other growing towns, promote community spirit - a deficiency identified in the Knebworth Parish Plan (April 2007) - and ease pressure on road and rail networks at peak times.

Delivery

The Estate recognises the extensive evidence base compiled by the Council to support the suitability of sites KB1 and KB2 and looks forward to working with the Council, the community, neighbouring landowners and future development partners to conduct further studies to confirm and expand on this evidence, which it believes to be sound.

The Estate is pleased to have already contributed to existing evidence with input into Knebworth Parish Council's Knebworth Parish Plan (April 2007 - http://www.knebworthparishcouncil.gov.uk/uploads/knebworth-parishplan-1sted-web.pdf) and Knebworth Sites Appraisal Report (December 2007 - http://www.knebworthoptionsreport.org/).

Sustainability

The Estate recognises the Council's Capacity and Sensitivity Studies of 2006, and - as part of the community, and its owners resident within the community - is particularly sensitive to the issues raised by those who oppose development on these sites. It has listened to, recorded, and considered the practical concerns of its neighbours - through previous consultations, involvement in the Knebworth Parish Plan (April 2007) and the Village Appraisals of 1996 and 2007, and at a number of public meetings over the years - and is confident there are practical solutions and mitigations to the issues raised.

The Estate would seek - in working with the Council, any development partners and its neighbouring landowners - to work with Knebworth's new Neighbourhood Plan to promote a balance of achieving the Local Plan's targets, addressing sustainability and infrastructure issues and concerns, and fulfilling community aspirations. Within the parameters of the Plan, it would look to development in keeping with - and improving on - Knebworth's existing Conservation Areas and Edwin Lutyens' original 1910 framework for "Knebworth Garden Village".

Opportunity

Reinforcing the Estate's commitment, and adding to the opportunity of facility and infrastructure improvement in the wider community, is one factor that is unique to Knebworth Estates. Reflecting the intent of the Plan in Policy SP13a - "Maintaining a strong presumption in favour of the retention, preservation and enhancement of heritage assets and their setting" - the Local Plan's requirement of Estate sites for residential provision would present a once-in-a-generation opportunity to solve the Estate's multi-generational quest to endow the Knebworth House Education and Preservation Trust, a charity created in 1984 for the preservation and enhancement of the heritage asset of Knebworth House and its setting.

Residential designation of KB1 and KB2 would result in sufficient funding for this charity to halt the decay of Knebworth House - an Historic England designated "Priority Building At Risk" - complete its half-finished programme of urgent restoration, and secure an endowment for its future survival, and continued and expanded public access and interpretation.

The Knebworth House charity's record over its 33 year history, its established "exceptional circumstances", its Conservation Plan as submitted to North Hertfordshire District Council in July 2001 - and the Estate's record in endowing, and seeking to complete that endowment - is evidence of the commitment of the Estate and the Charity.

The collateral opportunity presented by the designation of KB1 and KB2 within the Local Plan therefore extends beyond the crucial issue of local residential shortfall, to address also major issues of benefit to the whole region and the nation beyond.

Ref - Knebworth - KB4:

Knebworth Estates supports the Plan's Housing Allocation for KB4. Whilst comfortable that KB1 and KB2 could be successfully delivered without KB4, Knebworth Estates expresses its support for KB4. The Estate enjoys a close and mutually supportive relationship with the landowners of KB4 and, in the event that both landowners have sites proposed for development in the final Plan, we would look to work closely with each other to take an holistic view of Knebworth village and, together, maximise infrastructure advantages for the greater benefit of the wider village and its long-term future.

See attachment

See attached

See attachment

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

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

* Site AS1 fails to meet the requirements for highway safety to protect pedestrians and other road users
* 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.
*The site is within the setting of the scheduled ancient monument Arbury Banks and is protected
* NHDC has failed to consult on the proposals to extend the settlement boundary in locations other than AS1 and has not responded adequately to previous representations.

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

Object to Chapter 4, Policy SP8

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

Object to Chapter 4, Policy SP2

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

Object to Chapter 13, Site Allocation SP2

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

Object to Chapter 13, Site Allocation SP2

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

Object to Chapter 13, Site Allocation SP2

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

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

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


Object to the allocation of SP2 for housing

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

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

See attached

See attached

See attached

See attached

I have attached a screen shot of the current proposed new local plan from your website with the village envelope outlined in Green. This current plan has missed a boundary of our piece of land, the piece of land is called Hoops Meadow. I have also attached a picture of Hoops meadow showing its boundary that I have outlined in red on your plan. I am writing to you in the hope that you can now include this title of land within the new local plan that you have outlined in green on your website map, as the boundary has not been included in the previous plan.

The agent that I had spoken with suggested that this would be the best course of action to send this email, detailing that the boundary had been missed of "Hoops Meadow" and that I ask you to consider to include "Hoops Meadow" within the new proposed local plan.

See attachment

See attachment

Representation on the Local Plan 2011-2031 submission document ("LPSD")
Objections
1.1 The LPSD proposal of 2,100 homes to the East of Luton will destroy the rural nature of the village of Cockernhoe. Reference to Cockernhoe can be backdated to the 10th Century by a manuscript of 980AD. The village of Cockernhoe, incorporating Mangrove, numbers 130 dwellings. Cockernhoe ward numbers 205 dwellings. The nearest point of Cockernhoe village to the existing Luton dwellings is 200 metres and this boundary around the village should not be encroached upon as it is surely the minimum needed to retain Cockernhoe's rural nature. In my view the release of Green Belt land surrounding the required settlement boundary of Cockernhoe would not meet the "tests of soundness" set out in the National Planning Policy Framework ("NPPF") -see 1.5 below.
1.5 The NPPF specifically seeks to stop urban sprawl where this affects communities. This is clearly the case with regard to Cockernhoe and other villages/communities affected by this East Of Luton proposal, which should be stopped.
1.7 The 2,100 homes to the East of Luton proposal is not "exceptional circumstances". Considering the objections to the proposal by residents of Luton in addition to those of North Herts it is disturbing that NHDC has recommended this proposal.
There are alternative areas, such as land adjacent to Butterworth Green and North of the A505, which could be developed without encroaching upon any existing settlement. There is no need to destroy the rural nature of an existing community, Cockernhoe, which has existed for more than 1,000 years.
The need to properly assess the need for development is difficult. In December 2012 NHDC concluded the need was 10,700 dwellings. By 2014 this had increased to 12,200 for their own needs and now in 2016 to 14,000. This must be due to immigration and therefore it must be concluded that "Brexit" will reduce this figure - but NHDC say not! None of us knows what the result will be! To make a decision in the next 5 years to destroy the rural nature of Cockernhoe and associated communities in Cockernhoe ward and the affected areas of Luton is surely irresponsible! The 14,000 dwellings required by NHDC for its' own needs already represents an increase of 25.5% compared to the 55,000 dwellings existing in NHDC in 2011. In England as a whole there were 22,976,000 dwellings in 2011 (Housing statistics release 28th April 2016 by the Department for Communities and Local Government). A 25.5% increase overall in England would mean this number of dwellings increasing by 6.0m by 2031,representing a population increase of 14m which is clearly incorrect. In the period from 31st March 2001 to 31st March 2015 the increase in dwellings in England was 2.3m. In conclusion the need for 14,000 new homes is virtually a guess having increased by 31% from the estimate in 2012. Thus these additional new homes should not be added to by the extra 2,100 homes for Luton. See clause 2.8 below for calculation of the figure needed.
1.8 The duty to co-operate should be qualified as to "where they are able to". A significant proportion of residents of North Herts already work outside the district, see clause 2.76, and this would be the same with the 14,000 homes required for North Herts own needs. Thus surely NHDC has already complied with its' duty to co-operate.
1.9 To the West of Luton Redrow is building some 350 homes at Caddington Woods. This is some 650m from the outskirts of the Bedfordshire village of Caddington. Why is this development so small? There was a proposal to build 5,500 homes there in 2015 that was rejected by Luton, see www.bushwood.info/docs/Bushwood-Masterplan.pdf. This was as close to Caddington as the 2,100 dwellings are to Cockernhoe. I believe Luton councillors were concerned about objections from residents of the village of Caddington but obviously completely ignored the objections by North Herts residents and those from affected areas of Luton. Similarly the majority of NHDC councillors have ignored the objections from their community.
1.19 Whilst NHDC have consulted with the local community on the incorporation of the 2,100 homes to the East of Luton they have ignored their objections. There is little purpose in requiring a consultation process if you ignore the result.
1.22 Similarly to 1.19 above the previous consultations have been ignored.
1.26 Similarly to 1.19 above the previous consultations have been ignored.
1.27 Similarly to 1.19 above the previous consultations have been ignored.
2.8 The forecast of an increase in population in North Herts of 24,000 by 2031 does not require the building of 16,000 new dwellings. Assuming households on average of 2.4 this would require 10,000 new dwellings. There is significant inconsistency in these figures. If you then add the 1,600 households on the housing register (clause 2.25) you would need a maximum of 11,600 homes.
2.77 The intention to improve physical and mental wellbeing for the several thousand residents of Wigmore, Luton and Cockernhoe ward affected by the 2,100 homes to the East of Luton is completely ignored by this proposal.
2.83 The new development of 2,100 homes East of Luton will not:
(a) Enable the village of Cockernhoe to embrace their role within North Herts. The village will be lost forever and just be part of the urban community of Luton
(b) The District's historical rural areas will not be protected
3.7 Cockernhoe is being sacrificed and it is clear is outside NHDC's strategic objectives for ENV2, ECON4, ECON 6. I do not believe that ECON8 will be possible for the 2,100 dwellings proposed and think the road infrastructure will not be possible to accommodate this growth. I cast doubt on the methods of collection of the data. For instance in the last two months we have had 3 occasions where the roads have been gridlocked for various reasons. When you are sitting in such a traffic jam how does the cables across the road measure that. They surely measure the traffic that crosses them and not the queue of traffic wanting to cross them. SOC 4 is being completely ignored for the rural community of Cockernhoe where its' residents have objected to these plans over the course of the last 8 years.
4.0(b) Once again Cockernhoe is being excluded from this policy. The 2,100 homes surrounding Cockernhoe are twice as big as the future increase to the District's largest town of Hitchin (1,009).
4.9 The settlement boundary of Cockernhoe, within the classification of a Category "A" village, should not be expanded to include the area covered by the land allocated for the 2,100 homes. Such area should be given a classification of its' own so that objections can be raised against that but not reflect on Cockernhoe's own inclusion within the policy of category "A" villages.
4.13 Similarly to 4.9 above the East of Luton development should not be associated with Cockernhoe's own settlement boundary.
4.53 I disagree that the 2,100 proposal East of Luton, resulting in the rural nature of Cockernhoe being destroyed, qualifies as existence of "exceptional circumstances".
4.55 Green Belt is surely pointless if it can be removed by Council at will and against the will of the local community affected by its' removal.
SP6 I do not believe that adequate proposals have been made to deal with the road infrastructure needed for the 2,100 homes proposed.
SP8 (b) I disagree with this policy.
SP19 This policy should be cancelled as inappropriate and undeliverable to the satisfaction of residents of Cockernhoe and the affected parts of Luton.
13.66 I totally disagree with inclusion of the East of Luton expansion within the Cockernhoe settlement boundary. It should have a classification of its own.

Support
4.9 Policy SP2 concerning general development being allowed within the defined settlement boundaries of the Category "A" villages is a significant step forward. These 23 villages include Cockernhoe but the settlement boundary of that village has been expanded to include space for the 2,100 new homes planned. This is wrong the settlement boundary of Cockernhoe is clearly shown on the map in white. The additional area coloured brown should not be associated with Cockernhoe's settlement boundary but should be attributed a classification of its' own.
SP5 (a) (iii) I support the definition of settlement boundaries for villages, including Cockernhoe, in SP2, see 4.9 above that were previously "washed over" by the Green Belt.
SP7 I'm in full agreement with this policy.
4.128 I agree with the NPPF, which supports the argument to exclude the proposed 2,100 new homes East of Luton.
8.5 Policy HS2 I agree with fully.

I strongly object to the Local Plan 2011-2031 proposal for the PR1 site in Preston.
The allocation of the PR1 site in Preston for 21 houses in the Local Plan is unsound for the reasons provided below. Furthermore, it is unclear why Preston Parish Council decided not to object to the Local Plan during this consultation period (Oct/Nov 2016). An overwhelming majority of residents in Preston strongly object and this suggests that Preston Parish Council have been given little choice by NHDC not to do so. There are many other more suitable areas for development than Preston that will not have such a dramatic and harmful impact on the environment and have more amenities and better transport already in place.

In summary:
The plan is not positively prepared - the plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements - The best option for Preston Parish is to infill, NOT to densely pack houses into a green space which has only been recently placed within the Settlement Boundary of Preston village that now appears in the Local Plan. This has not been objectively assessed. NHDC ignored the objections by the Parish Council and residents in the previous consultations and an Ecology report relating to the Wain Wood SSSI is completely unsound (see objections below). The infrastructure does not exist now for the current residents and will not support the 20-25% more houses or the people living in them. The requirements necessary will not exist by 2031. The cost and environmental impact is enormous. The Local Plan does not provide a sound strategy for providing the infrastructure that will be required specifically for PR1. The demand for affordable housing in Preston does not exist as evidenced by the vacant affordable houses (finally filled through renting because they were not affordable to those who demanded them in previous surveys).

The Plan is not justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence - This is not the most appropriate strategy given the size of the village and no. of houses proposed (nowhere in the parish is as densely packed) on a green space. The Parish Council strongly objected to the PR1 site previously and the changes to the Settlement Boundary in the second consultation round and reasonable alternatives were provided (including infilling within the Parish) that would meet the Local plan targets for Preston Parish by 2031. Residents also strongly objected. These views have been ignored. The infrastructure does not exist now for the current residents and will not exist by 2031.

More detailed objections to the Local Plan for the proposed PR1 site in Preston

Policy SP2 Settlement Hierarchy
Preston village has been defined as a Category A village because it contains a primary school. This method for categorising the villages makes no sense at all. A proper ranking of all facilities and infrastructure should have been undertaken across North Herts. Preston currently has an inadequate infrastructure, road access and public transport to support the current needs of existing residents, without the proposed 21 houses at PR1. The cost of improving the infrastructure is huge compared to the net housing gain and the impact upon the character of the village and the rural environment is immense (see objections below).

The Settlement Boundary proposed by the Parish Council since 2007 has been continually ignored by NHDC and has been changed by NHDC during the Local Plan 2011-2031 consultation period. The Parish Council strongly objected to the changes in the Settlement Boundary in February 2016 (2nd Consultation), together with residents, including myself and, according to Parish Council Meeting Minutes, the District Councillor. The Parish Council met with NHDC and were told they had 'little leeway'. The Settlement Boundary proposed in this Local Plan has been devised by NHDC to ensure that land owned by them is now included (the proposed site PR1) and, in addition another 3rd of the village has been included at the opposite end which includes land owned by a developer. This move appears underhand especially when the current infrastructure and the true situation within Preston village is taken into account.

Furthermore, this development would completely spoil the unique character of this small and pleasant rural village that sits neatly within its surrounding environment. Historically, the north western part of the village near this proposed site (around the junction of Butchers Lane/Charlton Road/Chequers Lane) was known as The Wilderness for obvious reasons which still remain today but would be instantly destroyed if this development went ahead (see History of Preston website http://www.prestonherts.co.uk/ ).

The Wrays of Preston, Hertfordshire
www.prestonherts.co.uk
My family and ancestors have lived in Preston for more than 260 years - from at least 1751 until now. I was curious to discover how they lived.


Policy SP6 Sustainable transport
This is unclear. Sustainable transport is not possible for Preston village. These statements cannot be met (see Policy T1 and objections below).

Policy SP7 Infrastructure requirements and developer contributions
The proposed 21 houses at the PR1 site will certainly 'place unreasonable burdens on the existing community AND the existing infrastructure'. It is also unclear how they can 'mitigate any adverse impacts' without completely changing the ancient rural environment and surroundings at huge cost (see objections below).

Policy SP9 Design and Sustainability
The PR1 site in Preston for 21 houses 'does not respond positively to its local context'. This will be high density housing, more dense than anywhere in the rest of the Parish. It will change the character and rural environment. Preston cannot sustain this high proportion of houses on this site (see objections below). Infilling across the Parish should be used if NHDC wish to respond positively to the local context for development.

Policy T1 Assessment of transport matters & Infrastructure Delivery Plan and Key Infrastructure. Development at the PR1 site WILL 'adversely impact upon highway safety'. There is no clear plan provided here for Preston village. It is based on predictions and mitigations are not explained (see objections below).

Policy NE6 Designated biodiversity and geological sites (note 11.46 pg. 123)
The PR1 site is in very close proximity to Wain Wood SSSI. NHDC commissioned an ecological survey/report in response to Natural England's and concerns of residents in the previous consultation. This report is unscientific, seriously flawed (see objections below) and, as such, its conclusions that mitigation is unnecessary are not justified. It is incorrect and it does not address the concerns of Natural England or residents of Preston.

MAP SHEET 1 SIDE B Southern Area & Luton Borders
The map is not up to date. The borders for my property in Preston village have not looked as they do on this map since 1970. Therefore, this outdated map does not truly represent the current situation, certainly for Preston and the PR1 site proposed in the Local Plan.

In land searches in 2005, NHDC documented that my property was in the conservation area and the 'Local Plan no.2 with alterations adopted 23rd April 1996' is stated in these documents. However, the map suggests that my property is no longer in the conservation area but I have not been informed of this.

Objections to Development of the Field adjoining Templars Lane "PR1"
The Wain Wood Site of Scientific Interest Impact document is a desk-based study prepared by BSG Ecology in Derbyshire (June 2016). These consultants use freely available data (mostly outdated), extrapolated averages and estimates to make their conclusions and, as such, these do not truly reflect local reality. The assessment, methodology, assumptions and conclusions are not robust. The document does not properly address the concerns raised by Natural England who commented on the Local Plan (letter dated 13 February 2013) as to 'the potential impacts that the development of the PR1 site for residential purposes will have on Wain Wood SSSI'. The allocation of housing proposed at PR1 is certain to impact upon Wain Wood SSSI.
* The credibility of the document produced by BSG Ecology can immediately be called into question by the erroneous and irrelevant reference to Royston (Section 1.1) which is 18+ miles away from the PR1 site. Another error (Section 4.1) suggests that the PR1 site (SG4 7TU) lies within the Impact Risk Zone for the Therfield Heath SSSI (SG8 9NU), 16.9 miles away (Google Maps). Presumably, these same consultants, with clearly no knowledge of North Hertfordshire or ability to research, review or check their information, were also commissioned by NHDC to provide a desk study on Local Plan proposed sites in the Royston area. How many other mistakes, errors or miscalculations are present in this document for PR1?
* It is a fact that Wain Wood SSSI already has a larger volume of human and dog traffic than is reported by BSG Ecology, who predicted visitor numbers using a 'Ramblers Association participation rate' taken from data compiled by Sports England in 2009. Walking for recreational purposes has significantly increased since 2009. Active People Surveys per local authority in England are conducted and published for Sports England every 6 months (gov.uk) and quote >50% higher rates (2014-15) than those used here. These latest figures have been ignored by the consultants who have not researched this adequately.

Welcome to GOV.UK
gov.uk
GOV.UK - The place to find government services and information - Simpler, clearer, faster
*
* A properly robust scientific survey should be undertaken on visitor and dog numbers. This should be conducted, over more than one season, to include weekdays, weekends and holidays, when children regularly use the wood for recreational purposes as can be evidenced by the numerous dens and tree swings within the wood.
* The attraction to Wain Wood SSSI by the occupants of PR1 will be high and frequent because there will then be a complete lack of green space within Preston village for recreational purposes if the PR1 site is developed for housing. Lack of green space alone will increase current footfall and activities within Wain Wood by existing villagers as well as additional occupants of the PR1 site. Furthermore, the majority of occupants are likely to be families (based upon the recently built and occupied affordable houses located adjacent to the site) and they will naturally be attracted to their nearest open space which is Wain Wood SSSI.
The green space currently at PR1 site could be used for a village green. Other green spaces in the village are a small roundabout and a cricket ground. The use of general recreation in either of these spaces is limited. The roundabout is surrounded by roads, limited in size and broken up by trees preventing ball games and general recreation. The cricket ground is in frequent use May to October and has to be maintained and is, therefore, restricted accordingly.

There are established ponds bordering the field at PR1 abundant with declining amphibians including newts, frogs and toads. The ponds, being at the border of the field, have suspicion of containing Great Crested Newts. Field surveys are needed to assess this ecosystem further.

Preston village benefits from the amenity value provided by the field at the PR1 site. The field is widely used by dog walkers, ramblers and walkers who enter the field from the public footpath and the gate in the boundary creating established paths that criss-cross in the field. The allocation of this site for residential development is likely to facilitate a Village Green Application by the local residents. In addition, some of the house owners with rear gardens backing on to the field have gates opening onto the field which has provided access to the field for generations.

The local road infrastructure within and around Preston is mainly narrow lanes rather than roads. This infrastructure would be unable to cope with the increased volume of traffic which the proposed housing development would generate. There continue to be issues with speeding without an additional 20+ cars. The road access to and from the site is mostly single carriage and is inadequate. Both Chequers Lane, leading to Templars Lane, and Butchers Lane struggle to cope with the amount of traffic using them at present and Butcher's Lane is single carriage with blind sharp bends. Widening would not only cause substantial upheaval at an enormous cost but such changes would also be destructive to the existing character of these ancient country lanes and would change the whole character of Preston Village.

All the access roads in and out of Preston have single carriage sections and are liable to flooding and snow fall leading to the village being cut off from the surrounding areas which is compounded by the absence of no Preston village shop, medical or dental practices. The roads include Preston Rd (Hitchin Rd), Charlton Road, Back Lane, St Albans Highway, School Lane, Little Almshoe Rd and Hitchwood Lane. The main access road (Preston/Hitchin road) has a steep incline close to the Preston where cars regularly get stuck in snow. Close to this inclination there is a 90 degree bend; a consistent site of cars skidding off the road into adjoining hedge and field. A few hundred yards further towards Gosmore, the road narrows to single carriage way, with another 90 degree bend at Dermal Laboratories. The narrow road continues with multiple sharp bends (site of recent fatality) to a blind cross roads where the road becomes single carriage way at the Bull Pub at Gosmore, where pedestrians become vulnerable to traffic. A few hundred yards beyond, there is regular flooding where the road has become impassable. Flooding also regularly occurs on Hitchwood Lane, close to the the B651, Almshoe Rd a few hundred yards before the B656 and Charlton Road approximately a quarter of a mile before Preston Village.

There is inadequate infrastructure in the village including no shops, no nearby medical practice, poor bus service (No 88. Luton to Hitchin between 8 am and 6 pm, 5 per weekday/4 on Saturdays and School Holidays; school children are regularly driven past and left behind because the buses are already full before they reach Preston) and inadequate sewage provision.

Since the building of 6 new dwellings adjacent to the PR1 field site, the manholes on Templars Lane are now prone to the back flooding of sewage. This is not only causing undesirable odours three times a day when sewage is pumped from the new dwellings, but also the flooding of raw sewage on to the open road is a potential public health hazard. Children have been observed playing in these puddles of raw sewage. This has continued despite quarterly rodding by professional sewer maintenance contractors.

The sewage problem has been investigated by a fully qualified experienced plumber. In the opinion of the plumber the addition of these 6 dwellings are overwhelming the current sewage capacity. The additional 21 houses will exacerbate this problem and would have the potential to cause back up of sewage to the top of Chequers lane and extending the hazard zone further.

If 35% of the new housing delivered on this site is affordable then the Council should seriously consider how sustainable this location will be for younger families who do not benefit from car ownership. A report published by University College London in July 2014 entitled 'Transport and Poverty - a review of the evidence' finds that ''lower incomes and unemployment benefits mean that the cost of owning and running a car are prohibitive for many young people (Commission for Rural Communities, 2012) and that the large distances and the higher cost of fuel in rural areas may exacerbate these barriers to travel.'' It is well evidenced that the level of car ownership of affordable housing tenants on low incomes is well below the national average and coupled with poor transport links begs the question just how sustainable is this location is for people in affordable housing to access shops, services and employment.

Furthermore, it was a struggle to fill the 6 affordable houses that were recently built adjacent to the PR1 site, with 2 being having to be converted to rented accommodation so they wouldn't remain empty. Thus, it appears that the demand for affordable housing does not exist in Preston.

The development of this site will lead to an increase in class sizes at Preston Primary School and a corresponding increase in pressure on the school's limited infrastructure. Currently 94 pupils attend the school, close to the full capacity of 100. The current year 3 /4 class size is already at full capacity. Capacity has also been a problem in the recent past where class sizes exceeded 30. Moreover, the school, which is open to children between the years of 4 - 11 has only 4 available classrooms. With Reception year children benefiting from their own classroom there are only three other classes available to service the educational needs of school years 1 to 6. This means the children are educated in mixed year groups where pupils of different school ages are educated in the same class room. Increased housing, particularly for young families will exacerbate this disadvantage to current and future pupils attending the school.

A 20-25% increase in dwellings in this small historic village will endanger the nature of the settlement. This increase is unsustainable and overwhelming for a village of this size. Given the high density of housing proposed for this site in comparison to the rest of the village dwellings, the unique character of Preston would be badly affected.
Much, if not all of Preston's housing demands could be met by in filling of other sites within the village development boundary. In addition there is an unsightly field adjoining Back lane, within the village envelope owned by a builder / developer which has now been included in the Settlement Boundary given in this Local Plan document. This field lies closer to the limited Preston facilities such as the school, Pub and village hall, and is further away from the SSSI than the field at PR1. Importantly, this field is not in recreational use and, in contrast to the PR1 field, is unlikely to be subjected to a potential future village green application from local residents.

I strongly object to the proposal detailed in the plan PR1. There are many detrimental affects this would have on the village and the inhabitants here. My key concerns are the increase in residents. The infrastructure is already under strain with school children sometimes unable to get a place on the bus in the morning to school because it's over subscribed. The roads are already busy, sometimes treacherous and littered with pot-holes from insufficient investment.

The boundary of the village should not be changed and there should be no more housing within the village.

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.

The residents of Ashwell continue to object to this proposed development as we feel that all our representations (including 135 relevant and specific letters of objection, and Parish Council representations), have been and continue to be ignored. The goal posts are continually changing, and there appears to be an agenda to force this proposal through regardless of the opinions of the vast majority of the people, and common sense interpretation of planning policies. Could this be democracy in action, 2016 version?

There has been no consultation to build on this land, having been previously rejected on 3 separate occasions, neither has it appeared in any Village Plan or study. A housing development here is inappropriate as it is outside the existing agreed village boundary; is elevated and will seriously affect the visual aspect of the village, in particular Arbury Banks ancient monument, the adjacent Conservation Area, the North Baldock Chalk Uplands Character Area, and the approaches from Bygrave. The intention to amend the settlement boundary to accommodate it, makes complete nonsense of any previous policies, agreements and consultations.

Vehicle and pedestrian access to the site is far too narrow and will be hazardous as the entrance onto Clay bush road will be on a left hand bend, on a sharp downhill slope with a poor visual sight line and adjacent school premises. Additionally the proposed building of 2800 houses north of Baldock (Site SP14) will significantly increase vehicular movements on Claybush Road, as it will throughout the village.

Although not a planning issue, village services, roads and infrastructure are already severely stretched, and there are no plans, willor money to improve them.

Ashwell is already well ahead of its requirement for new homes, and there is no identified local rural housing need or a need for the local community or for agricultural workers etc. It will take a further 1.74 hectares of agricultural land out of production, which the country long term cannot afford. There is no sensible reason to use this green belt land.

Taking the English countryside for granted and assuming that it will always be there, is one of its greatest threats. Successive administrations have done almost nothing to preserve our countryside. If we seriously value our rural villages and local countryside, this proposal must be rejected yet again, as nothing has changed, only the political pressure to change.

Ashwell is a historically significant village dating back over 800 years.
The proposed development is poorly planned and does not provide the type of accommodation that is needed in the village. The access to the site is dangerous and the plans misleading. Elderly disabled and young residents would not be able to access the village safely from this location.
Alternative sites in Ashwell and surrounding areas have not been fully explored prior to the submitting of this proposal, which is opportune and unwanted by the residents. The development will significantly impact on the historical feel of the village once lost this will not be able to be replaced. Why put a suburban estate in a prominent position in one of the jewels of Hertfordshire ?

We also object to the development AS1 on the following technical grounds.
*
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.

I oppose to the to the District Plan with regard to AS1 for 33 houses.

SP2 The District Council has failed to consult with the Parish Council on the proposal to extend the settlement boundary of our village. The council seems to have done this just in order to include site ASI without looking at the village as a whole and without consultation as to where it might be judicious to make other boundary changes. Therefore this approach to boundary changes was not justified.

North Herts District council has been made aware of the work of the Ashwell Neighbourhood Plan under the auspices of the Parish Council. The PC is aware that the plan is in its formative stages but already a housing survey has been conducted and the results made known to the planners. Also made known to the planners was the fact that other sites that are more in keeping with the village have been identified. At a meeting held in the village on 10 January 2015 attended by the local MP and the Councillor in charge of the draft district plan project, it was stated that the emerging policy of the Neighbourhood Plan would be taken into account and the PC was urged to put this forward. At meetings since then it was obvious that this was NOT taken account of. Therefore this point should be taken under the heading Sound because it was not positively prepared

The site AS1 identified in the plan is a protected valued landscape and has been turned down by NHDC on several occasions and does not fit in with the National Planning Framework Section 11 concerving and enhancing the natural environment. One only has to stand on this site to see what a negative affect it will have on the chalk uplands of this part of North Hertfordshire. I object that this is not sound or positively prepared as the village has other sites - made known to NHDC - which could incorporate more houses.

I wish to register my concern that although Ashwell Parish Council identified the need for small, affordable housing within our existing village boundary, and in spite of the fact that suitable building sites were identified to suit the needs of the young and elderly in particular, and they comply with the quota, you have chosen to completely ignore the wishes of our village on this very important matter.

To extend our existing village boundary without our wishes, in order to presumably build, is undemocratic. To allow building to take place on such an unsuitable site is beyond belief. Vehicle access to Claybush Road has already been deemed unsafe. Pedestrian routes to the village from any point is positively dangerous, especially for the young and elderly who need level ground and safe pavements on which to walk to school and the village centre. Also, the proposed site extends to Arbury Banks and would therefore adversely effect our historic environment.

In view of the above, I consider the proposals to be unsound as they do not meet National and NHDC planning policy on highway safety; unjustified, when more suitable sites within the village boundary have been suggested by the parish council; ineffective in terms of satisfying village housing needs for the young and elderly and inconsistent with Nation Policy regarding Highway safety and the need to protect our historic environment. I therefore ask that you reconsider your proposals and comply with the democratic wishes of the majority of Ashwell parishioners.

Ashwell site AS1 does not meet the requirements for highway safety to protect pedestrians and other road users as defined I both National Planning Policy Framework 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 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 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 most strongly object to building on site designated KW1 for the following reasons.

Introduction

Breachwood Green is a small village approached by four steep roads which are, in places, single track with blind bends. The village is essentially located around four roads; the Heath of which Heath Road and Chapel road are extensions, Oxford Road, Lower Road and Coleman's Road, which leads into Browning's Lane. Considerable residential infilling was carried out in the '60s and '70s and at the same time the creation of St Mary's Rise and Orchard Way.

The proposed area: Allotments West of the Heath:This area is a Greenfield site and is also currently used as allotments. It is classified as Grade 3 agricultural land and is located within groundwater protection zone 3. Many of those that use it to grow their own food live in the row of the formerly tied cottages that abut this land. Those old cottages did not have back land and rely on the allotments for growing their own food. It is a requirement for allotment holders to be offered a new site for their use. Apart from the fact that over the decades the ground of the current site has been continually improved, which would be lost on transference to a new site, some allotment holders own livestock which could not be safely husbanded at a remote site.

The proposal is for 16 dwellings and thus probably at least 32 extra vehicles.

Policy
economy/Tourism: Although North Hertfordshire is not a major tourist destination, the inclusion of a tourism policy reflects this sector's growing significance as a form of economic development. There is a wide range of attractions in the district, particularly those based on heritage and the countryside. Tourism fulfils some of the aims of sustainable development because its survival depends upon conserving and maintaining the quality of the resources upon which it depends. For rural proposals, the need is to protect the countryside for its own sake, with aspects such as nature conservation, landscape and agricultural land in mind. The Council supports development proposals which increase the attractiveness of the district as a tourist destination. In the rural area proposals will need to provide evidence why they cannot be accommodated within existing settlements and how they will support the rural economy.
Policy would be breached:
England's unique countryside with its villages is also a world renowned tourist attraction. I have had visitors who were in awe of the beauty and peacefulness or our local countryside. this proposal for new builds will detract from the rural atmosphere of this village.

Policy
Sustainable development is described as having three dimensions: economic, social and environmental. Development therefore needs to support the local economy, provide social benefits and protect and enhance the natural environment.
Policy would be breached:
The increase in traffic, disruption of local traffic and loading of traffic onto rural roads will increase the already dire road congestion within the village. This is NOT SUSTAINABLE.

Policy
Scattered local shops, services and facilities in towns and villages should be walkable with a range of facilities within 10 minutes (up to about 800m) walking distance of residential areas.



Policy would be breached:
Breachwood Green has no shops, the nearest being 3 miles away. There are no services or facilities apart from a church and an already over subscribed school. The proposal will not secure development that improves the economic, social and environmental conditions in the area.

Policy
Countryside: The policies seek to promote sustainable development in the countryside as well as to positively protect the countryside from urban development, whilst allowing the needs of the rural population and economy to be met.
Policy would be breached:
The proposal seeks to cover a green field/arable site (currently allotments) with housing thereby spreading urban development.

Policy
Transport: New development can help to improve the range of transport opportunities available in the district by helping to improve existing facilities and providing new components where required.
Policy would be breached:
The village is ill-served by transport links there being but one bus service between Luton and Hitchin. There are only 5 services per day in either direction - the last one arriving in the village at 1830. There is thus no possibility for young people to have an evening out independently.

Policy
Parking: Virtually all development proposals generate demand for parking. This policy is therefore required to ensure parking is provided.
Policy would be breached:
Breachwood Green is a quiet rural village but is already suffering from increased traffic congestion. Continuous roadside parking is constant not only in the Heath, from which the allotments are currently accessed, but also Chapel Road and Oxford Road. These roads are part of the bus route. Parking right up to the corners of the roads is so bad that, that in my personal experience, I have narrowly avoided three accidents caused by my line of site being impeded on exiting The Meadows into Oxford Road. Moreover there are an increasing number of 'road rage' incidents caused by the reduction to one lane of the Heath with cars coming head to head either through impatience or an inability to see oncoming traffic at the end of the line of parked cars. This is also the case in Oxford road during school days. It is now the case that in order to avoid exiting the village by this road my husband and I prefer to use Lower Road even with its narrowness and blind bends. There is now roadside parking in Heath Road such that lines of sight are impeded when driving along that road.

This proposal would increase traffic congestion, which is already a nightmare. Reduced parking provision often touted to justify affordable housing or new builds is mistaken because it actually increases traffic congestion since, instead of off-road provision being available, inappropriate on road parking is used. I have seen where reduced parking provision for housing development has created dangerous roadside obstructions with parked cars.

Policy
Air quality: The major source of local air pollution in the district originates from road traffic emissions it is important for this plan to deal with the implications for air quality of the anticipated development any other development likely to significantly increase vehicle movements
Policy would be breached:
The natural aspiration of people to own cars will increase carbon emissions and clearly air pollution will be increased with the introduction of probably more than 32 cars permanently and visits and deliveries. More settlements increase carbon dioxide emissions both through car use and general wastes. It is grossly insulting to be told by the UK Government that we must reduce our output of carbon dioxide at the same time as its policies are imposing these kinds of increases in emissions by forcing the production of new houses on our countryside.

Policy
Healthy Communities: The planning system plays a role in facilitating social interaction and creating healthy, inclusive communities. Community and recreation facilities together with green spaces can play an important role in the life of local people. These local facilities, whether publicly or privately owned, can be subject to development pressures for alternative uses. It is therefore important that, where appropriate, such facilities are retained within the local community.
Policy would be breached:
Allotments are becoming a scarce amenity. The UK's first food security assessment launched in recent years by the Government's Department of Food and rural affairs (DEFRA) as part of a package of material on the future of our food system. The material discusses issues ranging from how we can create a sustainable food system locally and globally. It is thus hypocritical to demand that more and more land capable of feeding us is destroyed. Allotment gardening promotes social benefits including benefits to health, education and community well-being. More and more children have no concept of where their food is grown or raised; indeed if it does not come out of a plastic wrapper they are liable to refuse to eat it. A report on the radio only recently indicated that when children were encouraged to grow their own food they were far more amenable to "eating their greens". Further building over productive land will distance more and more of our children from appreciating where food comes from and the vital necessity of keeping productive land free of urban development.

Policy
Green space: The Policy Framework addresses the importance that access to open space has for the health and wellbeing of a community.
Policy would be breached:
The relentless destruction of our natural environment with the creation and spread of settlements caused by an unnatural increase in population, encouraged by politicians, leads to the depletion of our natural resources. As a result our productive land is invaded and degraded. It should be noted that not only is England the most densely populated country in Europe but also as densely populated as Bangladesh.

Policy
Landscape and Environmental Protection: Ensuring the environment is properly protected. is an important element of sustainable development.
Policy would be breached:
Villages, such as Breachwood Green, and the landscape in which they are situated are unique to the English countryside. Destruction of these landscapes is a desecration of the heritage, character and tradition of England. Just as we accept that buildings of unique historical and architectural beauty and interest should be preserved and conserved so also must the historical landscapes of our country be treated. It must never be forgotten that building such as is proposed can and will never be reversed. When the land is gone it is gone for ever.
Tragically the proposed development will contribute to the destruction of the natural environment, which acts as an organic sink for carbon through the photosynthesis carried out by green plant chlorophyll.

Policy
Delivering sustainable water supply: Water is a precious natural resource. In North Hertfordshire there is a high level of demand for water whilst at the same time there is a relatively low annual rain fall. Any development will result in an increased demand for water. The district lies within one of the most water-stressed areas of the country and abstraction for human consumption can impact on the water environment, for example contributing to low river levels,
Policy would be breached:
Only in December 2008 the Environment Agency published a report which stated that East Anglia is already considered to be an area of great water stress and that many lakes, estuaries and rivers are drained so quickly that there is a danger to wildlife and that there is already less water available per head in this part of England than those living in Egypt and Morocco. The report says the pressure is greatest in the South East and Eastern England, the driest and most crowded parts of England and Wales.
It is also blindingly obvious that run-off from the hard surfaces created by building not only causes flooding, by rainwater flowing into river systems that cannot cope with it, but also, thereby, reduces the transport of water through the natural soil, rock and subsurface to replenish natural aquifers. Thus development not only increases flooding but reduces the water table and available ground water.

Policy
Infrastructure requirements and developer contributions: Development pressures have the potential to have a significant impact on the natural, historic or built environment. This could be through removing trees leading to a change in the biodiversity and landscape character of a site.
Policy would be breached:
It would seem looking at the map that the footpath leading from east of the site has been widened to allow vehicular traffic. That was also seen on the ground by the positioning of an electric fence. If access is moved away from the west of the site then stand of mature fir trees (Illustration 4) will likely need to be removed and the road widened.

Policy
Masterplans: The Council will prepare masterplans for the following sites: East of Luton (Sites EL1, EL2 and EL3). Should development prove necessary in the plan period to the west of Stevenage a masterplan will also be prepared for that site.
Planning blight
Over the last 20 years we have seen and resisted a growing pincer movement against our community. There is the current proposed East of Luton expansion, the West of Stevenage expansion, which was successfully opposed only to be imposed by the then MP for Hull East and Deputy Prime Minister, John Prescott and the proposed huge expansion of Luton Airport which would have completely destroyed acres of farmland and access from my village to the south.
There is another proposed expansion from Luton Airport for commercial premises over existing farmland almost to the borders of my home village. This country is of finite size and cannot continue to support the concreting over of productive and soak land. Moreover we are continually told that we have either reached or will soon reach peak oil. If that is the case, shipment by road, air and sea will become prohibitively expensive and we will have to rely far more, or even exclusively, on locally grown produce. How will that be achieved if our productive land has been swallowed up?

Settlement hierarchy
Breachwood Green is classed as a Category A village with a settlement boundary defined within which new development will be supported.
Comment
The local village community is made up of those whose roots lie in rural communities and those who are in voluntary exile from the urban and suburban rat race. There appears to be no concern over our community's sensitivity to the rural landscape and enjoyment of our homes as required by the Human Rights Act (Articles 8 and 14). In a multicultural democracy equal weight should be given to the needs of rural culture and the sensitivities of the rural community as to any other community.
What may be seen individually as a small development cumulatively these developments pose a threat not only to the environment but to the countryside and our whole way of life. They are short term measures for long term problems, which are not being addressed.

Policy
Protecting living conditions: All development has the potential to have an adverse impact on its neighbours, in a wide variety of ways. Particular care is needed to ensure that the adverse impacts of the development on local people are minimised and appropriate mitigation built into the scheme. The Council will permit development proposals which do not cause unacceptable harm to living conditions. Such harm may arise from traffic generation and parking;
Policy would be breached:
If planning permission is given for this site in Breachwood Green then not only will the already unacceptable congestion in the village be increased but also such additional housing will contribute to an increase in local pollution by creating rubbish and sewerage. Building over agricultural and natural land will also destroy wildlife habitats.

We have a moral and spiritual duty to protect and preserve our natural heritage and to leave a light footprint for future generations who must live in this land. Our natural heritage is also our cultural heritage. Clearly the permanent destruction of food land and soak land will have an ongoing detrimental effect on those who live here both now and in the future.

Policy
Housing and development strategy: The need for housing is one of the biggest issues for Local Plans to address. A balance needs to be struck between the large and pressing need for housing with the desirability of protecting the countryside
Policy likely to be breached:
Whilst lip service may be given to the provision of affordable housing for local people, experience shows that unless rented by the local authority or sold leasehold with caveats that only local people can be housed, such housing will inevitably be sold on at market prices. Moreover as far as I am aware there has never been a definition of who qualifies as local and if there is not enough local uptake then clearly the housing will be made available to incomers and the whole justification for building such houses will be betrayed.

Particular problems with the proposal
Access
The current access to the site is from the east. The exit view is extremely restricted and dangerous in both directions, often with cars parked right up to the exit.
If access is to be changed to the west then more agricultural land will be sacrificed in creating vehicular access and the destruction of a rural footpath, which currently runs through the whole site.
The road in both directions at this exit are single track, narrow country road.
Exit to Browning's Lane in the northerly direction leads to a very dangerous off set junction close to a dangerous bend on the left where Darley Road meets the Heath.
This exit, with a stand of mature fir trees limiting its width, has very restricted views in both directions.
Infrastructure
The village has no shop and a very restricted bus service. The school is currently running at capacity and any increase of local children would mean that they would need private transport (bus/taxi) out of the village to school.
The electricity supply to the village is already overburdened with regular phase failures due to poor distribution.

Representation on the Local Plan 2011-2031 submission document ("LPSD")
Notice
I have many objections to the LPSD and believe that changes are necessary, principally to eliminate the 2,100 new homes proposal for Luton. I wish to participate in the formal oral Examination of the Plan.

Objections
1.1 The LPSD proposal of 2,100 homes to the East of Luton will destroy the rural nature of the village of Cockernhoe. Reference to Cockernhoe can be backdated to the 10th Century by a manuscript of 980AD. The village of Cockernhoe, incorporating Mangrove, numbers 130 dwellings. Cockernhoe ward numbers 205 dwellings. The nearest point of Cockernhoe village to the existing Luton dwellings is 200 metres and this boundary around the village should not be encroached upon as it is surely the minimum needed to retain Cockernhoe's rural nature. In my view the release of Green Belt land surrounding the required settlement boundary of Cockernhoe would not meet the "tests of soundness" set out in the National Planning Policy Framework ("NPPF") -see 1.5 below.
1.5 The NPPF specifically seeks to stop urban sprawl where this affects communities. This is clearly the case with regard to Cockernhoe and other villages/communities affected by this East Of Luton proposal, which should be stopped.
1.7 The 2,100 homes to the East of Luton proposal is not "exceptional circumstances". Considering the objections to the proposal by residents of Luton in addition to those of North Herts it is disturbing that NHDC has recommended this proposal.
There are alternative areas, such as land adjacent to Butterworth Green and North of the A505, which could be developed without encroaching upon any existing settlement. There is no need to destroy the rural nature of an existing community, Cockernhoe, which has existed for more than 1,000 years.
The need to properly assess the need for development is difficult. In December 2012 NHDC concluded the need was 10,700 dwellings. By 2014 this had increased to 12,200 for their own needs and now in 2016 to 14,000. This must be due to immigration and therefore it must be concluded that "Brexit" will reduce this figure - but NHDC say not! None of us knows what the result will be! To make a decision in the next 5 years to destroy the rural nature of Cockernhoe and associated communities in Cockernhoe ward and the affected areas of Luton is surely irresponsible! The 14,000 dwellings required by NHDC for its' own needs already represents an increase of 25.5% compared to the 55,000 dwellings existing in NHDC in 2011. In England as a whole there were 22,976,000 dwellings in 2011 (Housing statistics release 28th April 2016 by the Department for Communities and Local Government). A 25.5% increase overall in England would mean this number of dwellings increasing by 6.0m by 2031,representing a population increase of 14m which is clearly incorrect. In the period from 31st March 2001 to 31st March 2015 the increase in dwellings in England was 2.3m. In conclusion the need for 14,000 new homes is virtually a guess having increased by 31% from the estimate in 2012. Thus these additional new homes should not be added to by the extra 2,100 homes for Luton. See clause 2.8 below for calculation of the figure needed.
1.8 The duty to co-operate should be qualified as to "where they are able to". A significant proportion of residents of North Herts already work outside the district, see clause 2.76, and this would be the same with the 14,000 homes required for North Herts own needs. Thus surely NHDC has already complied with its' duty to co-operate.
1.9 To the West of Luton Redrow is building some 350 homes at Caddington Woods. This is some 650m from the outskirts of the Bedfordshire village of Caddington. Why is this development so small? There was a proposal to build 5,500 homes there in 2015 that was rejected by Luton, see www.bushwood.info/docs/Bushwood-Masterplan.pdf. This was as close to Caddington as the 2,100 dwellings are to Cockernhoe. I believe Luton councillors were concerned about objections from residents of the village of Caddington but obviously completely ignored the objections by North Herts residents and those from affected areas of Luton. Similarly the majority of NHDC councillors have ignored the objections from their community.
1.19 Whilst NHDC have consulted with the local community on the incorporation of the 2,100 homes to the East of Luton they have ignored their objections. There is little purpose in requiring a consultation process if you ignore the result.
1.22 Similarly to 1.19 above the previous consultations have been ignored.
1.26 Similarly to 1.19 above the previous consultations have been ignored.
1.27 Similarly to 1.19 above the previous consultations have been ignored.
2.8 The forecast of an increase in population in North Herts of 24,000 by 2031 does not require the building of 16,000 new dwellings. Assuming households on average of 2.4 this would require 10,000 new dwellings. There is significant inconsistency in these figures. If you then add the 1,600 households on the housing register (clause 2.25) you would need a maximum of 11,600 homes.
2.77 The intention to improve physical and mental wellbeing for the several thousand residents of Wigmore, Luton and Cockernhoe ward affected by the 2,100 homes to the East of Luton is completely ignored by this proposal.
2.83 The new development of 2,100 homes East of Luton will not:
(a) Enable the village of Cockernhoe to embrace their role within North Herts. The village will be lost forever and just be part of the urban community of Luton
(b) The District's historical rural areas will not be protected
3.7 Cockernhoe is being sacrificed and it is clear is outside NHDC's strategic objectives for ENV2, ECON4, ECON 6. I do not believe that ECON8 will be possible for the 2,100 dwellings proposed and think the road infrastructure will not be possible to accommodate this growth. I cast doubt on the methods of collection of the data. For instance in the last two months we have had 3 occasions where the roads have been gridlocked for various reasons. When you are sitting in such a traffic jam how does the cables across the road measure that. They surely measure the traffic that crosses them and not the queue of traffic wanting to cross them. SOC 4 is being completely ignored for the rural community of Cockernhoe where its' residents have objected to these plans over the course of the last 8 years.
4.0(b) Once again Cockernhoe is being excluded from this policy. The 2,100 homes surrounding Cockernhoe are twice as big as the future increase to the District's largest town of Hitchin (1,009).
4.9 The settlement boundary of Cockernhoe, within the classification of a Category "A" village, should not be expanded to include the area covered by the land allocated for the 2,100 homes. Such area should be given a classification of its' own so that objections can be raised against that but not reflect on Cockernhoe's own inclusion within the policy of category "A" villages.
4.13 Similarly to 4.9 above the East of Luton development should not be associated with Cockernhoe's own settlement boundary.
4.53 I disagree that the 2,100 proposal East of Luton, resulting in the rural nature of Cockernhoe being destroyed, qualifies as existence of "exceptional circumstances".
4.55 Green Belt is surely pointless if it can be removed by Council at will and against the will of the local community affected by its' removal.
SP6 I do not believe that adequate proposals have been made to deal with the road infrastructure needed for the 2,100 homes proposed.
SP8 (b) I disagree with this policy.
SP19 This policy should be cancelled as inappropriate and undeliverable to the satisfaction of residents of Cockernhoe and the affected parts of Luton.
13.66 I totally disagree with inclusion of the East of Luton expansion within the Cockernhoe settlement boundary. It should have a classification of its own.

Support
4.9 Policy SP2 concerning general development being allowed within the defined settlement boundaries of the Category "A" villages is a significant step forward. These 23 villages include Cockernhoe but the settlement boundary of that village has been expanded to include space for the 2,100 new homes planned. This is wrong the settlement boundary of Cockernhoe is clearly shown on the map in white. The additional area coloured brown should not be associated with Cockernhoe's settlement boundary but should be attributed a classification of its' own.
SP5 (a) (iii) I support the definition of settlement boundaries for villages, including Cockernhoe, in SP2, see 4.9 above that were previously "washed over" by the Green Belt.
SP7 I'm in full agreement with this policy.
4.128 I agree with the NPPF, which supports the argument to exclude the proposed 2,100 new homes East of Luton.
8.5 Policy HS2 I agree with fully.