Policy SP2: Settlement Hierarchy

Showing comments and forms 91 to 103 of 103

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5758

Received: 24/11/2016

Respondent: Mrs Sheila M James

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP2 (Whitwell): Identification as Cat A village, assessment flawed, unsustainable location

Full text:

I am writing to object to the inclusion of site SP2 Whitwell in the local plan and would like to make the following comments.
Public Engagement- Chapter 4, Policy SP8
SP2 has been added to the draft local plan at the final round of consultation. This means that the community had had an insufficient and unacceptable time to respond. The NPPF states that true community consultation must be undertaken. It states 'early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential'. By adding SP2 at the final stage this requirement has not been met.
By introducing this site, the draft local plan disregards
a) The findings of the NHDC planning committee who found the site inappropriate for development in August 2016
b) Has not engaged early with the community
c) Ignored previous comments from our community and St Pauls Walden Parish Council supporting green belt protection to this land.

To make the plan sound, SP2 should be allocated as new green belt.
Object to Chapter 4, Policy SP2
The plan is not sound as the evidence used to identify sustainable villages is flawed. Hence resulting 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.
NHDC has labelled Whitwell a 'category A' village deeming that it requires an increase in housing numbers in order to thrive. This is simply not correct and unsound, also contradicting the Parish Council's own assessment of local needs. Whitwell is accessed by narrow country lanes, has no supermarket or secondary schools with 5 miles, very few employment opportunities, only 1 public house, and minimal public transport. It is therefore not a sustainable location for significant volumes of new housing. In the previous Local Plan Whitwell was designated as a village beyond the Green belt, which is a more appropriate designation.
The NPPF core planning principles at paragraph 17 clearly state that patterns of growth should be actively managed to make the fullest possible use of public transport, walking and cycling and focus significant development in locations which are, or can be made sustainable. Whitwell's unique rural location, set in unspoilt Chiltern valley landscape surrounded by larger conurbations, attracts high volumes of ramblers and cyclists who appreciate its beauty. It lies within the proposed extension to the Chiltern AONB. The draft local plan has failed to grasp the essence of Whitwell's identity and function. Whitwell's role should not be to provide housing towards district targets, but to continue to provide highly valued amenity for North Herts, Luton, Stevenage and other neighbouring urban districts.
To make the Local Plan justified, effective and legally compliant Whitwell should be reclassified as Category B village and SP2 removed as an allocated site.
Object to Chapter 13, Site Allocation SP2
The plan is unsound as it identifies SP2 as suitable for development. There are a number of physical features and constraints that render the site SP2 as completely unsuitable.
a. Flood risk SP2 site is assessed, by the Environment Agency, as having a high - medium risk of surface water flooding. The SFRA clearly shows water flowing across the site in a 1 in 30 year flood event. The NPPF asserts that development should be directed away from sites at high risk of flooding
The NPPF also outlines the need for a Strategic Flood Risk Assessment (SFRA) to be completed to determine flood risk in relation to allocating sites for housing. The SFRA commissioned by NHDC in 2008 pre-dates the inclusion of SP2. On updating the SFRA, NHDC acknowledge the serious surface water issues present at the site. This is against NPPF guidance which states development should be directed away from flood risk altogether, towards sites with a lower flood risk.
New sites should not be sited in areas at high flood risk.
b. Sewerage and Ground Water Thames Water has determined that there is insufficient capacity remaining in the sewage system for new homes on SP2. This fact has been omitted by NHDC in their documentation. SP2 lies on the principle chalk aquifer, a source of water for the River Mimram. SP2 is therefore a highly sensitive location for groundwater. In fact Whitwell is in a source protection zone 1. Whitwell's famous water cress beds are located just 100 meters from SP2. If the ground water source were to become contaminated, the potential for pollutants to very quickly damage water quality at the cress beds is disastrously high.
Pump based solutions, most often introduced by developers under these circumstances, are unsustainable. Continued maintenance measures that these systems require, to avoid common problems such as septic tank overflow, cannot be guaranteed.
c. Visual Impact SP2 is a widely valued, attractive Greenfield agricultural site. It is visible from the Chiltern Way and other footpaths and bridleways. It forms a prominent part of our unique valley character landscape.
The North Hertfordshire and Stevenage Landscape Character Assessment, an independent report instructed by NHDC to review of the landscape character area of Whitwell Valley, identifies SP2's location visual sensitivities as being moderate - high. "Cross valley views from the higher vantage points are an important feature of the character area. Panoramic views are common from the higher valley slopes, views along the valley are an important feature in the character area."
It also states that: "large urban extensions and new settlements (>5ha) would not be appropriate within this Character Area, due to its relatively remote, rural and undeveloped character. It would be of an inappropriate scale and would introduce elements that would urbanise the landscape, altering the character and removing the existing key characteristics. Visual impacts would also be high due to the cross valley views currently experienced."
SP2 is a site of nearly 6ha. The allocation of the site is contrary to the independent report findings for reason of visual impact.
In summary we consider that amendment of SP2 from housing development to new Green Belt is necessary to make the plan sound.
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 planning application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable
For the reasons above I consider that SP2 should be removed

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5841

Received: 30/11/2016

Respondent: Whitwell Protection Group

Number of people: 306

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to SP8:
- Whitwell's village classification changed from 'A' to 'B'

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5871

Received: 30/11/2016

Respondent: Ms Carol Hare

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP2:
- Change to Ashwell boundary

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5873

Received: 25/01/2017

Respondent: Mrs Linda Brent

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP2:
- Should be classified as a Category B village

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5917

Received: 24/11/2016

Respondent: Hitchin Town Action Group (HTAG)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Support for SP2:
- proactive approach
- policy needs to be more specific: extent to which local circumstance is reflected in the proposed policies.

Full text:

See attachment

Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5933

Received: 30/11/2016

Respondent: Mr Wilfred Aspinall

Representation Summary:

Support SP2:
- Pirton is a Category A village and can sustain additional building of new houses

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5958

Received: 25/11/2016

Respondent: Christopher James

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Object to Whitwell being category A village: narrow roads, no supermarket, no secondary school, 1 public house, minimal public transport - unsustainable. attractive landscape and should maintain rural feel.

Full text:

I am writing to object to the inclusion of site SP2 in the local plan Whitwell and would like to make the following comments.

Public Engagement- Chapter 4, Policy SP8
SP2 has been added to the draft local plan at the final round of consultation, very late in the process. This means that the community has had insufficient and unacceptable time to respond. The NPPF states that true community consultation must be undertaken. It states 'early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential'. By adding SP2 at this final stage this requirement has not been met.
In introducing this site, the draft local plan disregards:-
a) the findings of the NHDC planning committee who rejected an application and found the site inappropriate for development in August 2016;
b) has not engaged early with the community;
c) disregarded the previous comments from our community and St Pauls Walden Parish Council supporting green belt protection to this land.
Articles 18-20 of The Town and Country Planning (Local Planning) (England) Regulations 2012 outline the requirement for a Statement of Community Involvement This demonstrates that the plan is not consistent with National Policy.
To make the plan sound, SP2 should be allocated as new green belt.
Object to Chapter 4, Policy SP2
The plan is not sound as the evidence used to identify sustainable villages is flawed. Hence the result being that isolated village, with no facilities such as a senior school and shops, and very little public transport, are seen as unsuitable for significant development.
NHDC has labelled Whitwell a 'category A' village deeming that it requires an increase in housing numbers in order to thrive. This is simply not correct and unsound, also contradicting the Parish Council's own assessment of local needs. Whitwell is totally accessed by narrow country lanes, has no supermarket or secondary schools within 5 miles, very few employment opportunities, only 1 public house, and minimal public transport. This cannot be regarded as a sustainable location for significant volumes of new housing. In the previous Local Plan Whitwell was designated as a village beyond the Green belt, which is a more appropriate designation.
The NPPF core planning principles at paragraph 17 clearly state that patterns of growth should be actively managed to make the fullest possible use of public transport, walking and cycling and focus significant development in locations which are, or can be made sustainable. Whitwell's unique rural location, set in unspoilt Chiltern valley landscape surrounded by larger conurbations, attracts high volumes of ramblers and cyclists who appreciate its beauty and amenity values. It lies within the proposed extension to the Chiltern AONB. The draft local plan has failed to grasp the essence of Whitwell's identity and function. Whitwell's role should not be to provide housing towards district targets, but to continue to provide highly valued amenity for North Herts, Luton, Stevenage and other neighbouring urban districts.
To make the Local Plan justified, effective and legally compliant Whitwell should be reclassified as Category B village and SP2 removed as an allocated site.
Object to Chapter 13, Site Allocation SP2
The plan is unsound as it identifies SP2 as suitable for development. There are a number of physical features and constraints that render the site SP2 as completely unsuitable.
a. Flood risk
SP2 site is assessed, by the Environment Agency, as having a high - medium risk of surface water flooding. The higher ground topography funnels rainfall into the natural valley landscape area marked as SP2 increasing flood risk for properties lying in its direct fall including Cresswick and Mimram View. Indeed the SFRA clearly shows water flowing across the site in a 1 in 30 year flood event. Paragraph 100 of NPPF asserts that development should be directed away from sites at high risk of flooding
The NPPF also outlines the need for a Strategic Flood Risk Assessment (SFRA) to be completed to determine flood risk in relation to allocating sites for housing. The SFRA commissioned by NHDC in 2008 predates the inclusion of SP2. On updating the SFRA, NHDC acknowledge the serious surface water issues present at the site. This is against NPPF guidance which states development should be directed away from flood risk altogether, towards sites with a lower flood risk.
New sites should not be sited in areas at high flood risk.
b. Sewerage and Ground Water
Thames Water has determined that there is insufficient capacity remaining in the sewage system for new homes on SP2. This fact has been omitted by NHDC in their documentation. SP2 lies on the principle chalk aquifer, a source of water for the River Mimram. SP2 is therefore a highly sensitive location for groundwater. In fact Whitwell is in a source protection zone 1. Whitwell's famous water cress beds are located just 100 meters from SP2. If the ground water source were to become contaminated, the potential for pollutants to very quickly damage water quality at the cress beds is disastrously high.
Pump based solutions, most often introduced by developers under these circumstances, are unsustainable. Continued maintenance measures that these systems require, to avoid common problems such as septic tank overflow, cannot be guaranteed.
c. Visual Impact
SP2 is a widely valued, attractive Greenfield agricultural site. It is visible from the Chiltern Way and other popular footpaths and bridleways. It forms a prominent part of our unique valley character landscape.
The North Hertfordshire and Stevenage Landscape Character Assessment, an independent report instructed by NHDC to review the landscape character area of Whitwell Valley, identifies SP2's location visual sensitivities as being moderate - high. "Cross valley views from the higher vantage points are an important feature of the character area. Panoramic views are common from the higher valley slopes, views along the valley are an important feature in the character area."
It also states that:
"large urban extensions and new settlements (>5ha) would not be appropriate within this Character Area, due to its relatively remote, rural and undeveloped character. It would be of an inappropriate scale and would introduce elements that would urbanise the landscape, altering the character and removing the existing key characteristics. Visual impacts would also be high due to the cross valley views currently experienced."
SP2 is a site of nearly 6ha. The allocation of the site is contrary to the independent report findings for reason of visual impact.
In summary we consider that amendment of SP2 from housing development to new Green Belt is necessary to make the plan sound.
Object to Chapter 13, site allocation SP2
The proposed development is not in a sustainable location and will depend heavily 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 planning application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable
For the reasons above I consider that SP2 should be removed from the Local Plan 2011-2031

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5972

Received: 29/11/2016

Respondent: F and P Property Management

Agent: Rapleys LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP2 (Pirton): Support identification of Pirton as Cat A village in principle, village boundary should be further considered

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6049

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP2 - (part 2) Villages currently washed over should not be included in the policy, boundaries are established, no exceptional circumstances. Para 86 relates to newly created Green Belt.

- (part 3) plan should not give unlimited support to any infill development. Built core should be identified in relation to category B villages.

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6099

Received: 21/11/2016

Respondent: Rumball Sedgwick

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP2: Overreliance on large sites adjoining town, high risk approach, unlikely to deliver five-year land supply, village boundaries arbitrary and do not allow for growth

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6259

Received: 29/11/2016

Respondent: Mr John Hare

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP2 (Ashwell): Village boundary excludes sites being considered by neighbourhood planning group, no consultation with Ashwell Parish Council

Full text:

Would you please append this email to my letter dated 24th November 2016 delivered by hand to Strategic Planning & Projects Group, NHDC, Gernon Road on the 28th November 2016 at 12.35.

* The Draft Emerging Allocation July 2016, Ashwell shows the boundary of Ashwell has been changed to exclude two of the three sites identified for development in Ashwell's Neighbourhood Plan. Bearing in mind that NHDC's Planners were aware of these sites prior to the cut-off date of March 2016 makes one think that NHDC has removed them wilfully in an attempt to influence the Neighbourhood Plan prior to the Inspector viewing the contents. It appears that there has been no reference or contact with Ashwell Parish Council.
* The CPRE has objected to the development of AS1 because of its impact on the landscape and Ancient Monument and their reasons should be taken into consideration as they are the Trustee for Rural England
* NHDC's website has and still is creating major problems to access and complete the form provided. Although there are alternatives the failure of this website is making the process untenable as having made several unsuccessful attempts they abort it, so their views are not represented making the democratic process unworkable. No doubt this problem will be reflected in the number of responses that will be forwarded to NHDC re AS1 Ashwell.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6285

Received: 28/11/2016

Respondent: Mr & Mrs M H Lush

Number of people: 2

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP2:
- Ashwell Neighbourhood Plan
- Failed to consult on proposals to extend the settlement boundary

Full text:

See attachment

Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6617

Received: 29/11/2016

Respondent: Bellcross Company LTD

Representation Summary:

Support SP2: Support principles and that majority of development will be in or adjoining towns

Full text:

See attachment