Policy SP5: Countryside and Green Belt

The Green Belt boundaries, were defined 75 years ago, and, like my belly, that belt needs letting out. The proposal to use Green Belt immediately adjacent to settlements like Knebworth is entirely appropriate. There is leisure and activity countryside immediately adjacent to the proposed development sites, and, sensibly, a huge addition of newly designated very appealing landscape, west of Stevenage, is offered in compensation. It's a good deal. The restrictions imposed by the current boundaries, tighly around Knebworth, for example, have determined that almost available green space in Knebworth have been built on.

I wish to express again my concerns about erosion of the local Green Belt
Proposed large-scale development on the local green belt will drastically change the character of our area and impact our quality of life. In focusing development almost entirely around the area's main towns and Stevenage, planners are extending urban sprawl, destroying countryside and valuable agricultural land as well as the setting and special character of several communities such as Baldock and the Conservation Area of Graveley all of which are contrary to NPPF 80.
Further development around Great Ashby, especially at Roundwood would result in unacceptable increases in traffic coming down a very narrow road (Church Lane). Part of which is single track and is also constitutes a section of the Hertfordshire Way Walking Route so putting the ramblers at much greater risk.
The NPPF also makes clear that, once established, green belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. Meeting assessed housing need has been adjudged by Government not to meet the exceptional circumstances criteria.

There is not enough emphasis on prioritising development on brown field sites. This should be given much greater emphasis.

I have lived in Knebworth all my life and the changes I have seen have not been for the better parking is a nightmare traffic and now they want to add more houses on our greenbelt, I live in Stockens Green and the traffic has got worse with this so call planning its a disgrace leave the greenbelt alone we don't need anymore houses in Knebworth or traffic problems I love those fields and children need greenbelt for the future not looking onto other houses DISGRACEFUL not a happy resident.

Proposed large-scale development on the local green belt will drastically change the character of our area and impact my quality of life. In focusing development almost entirely around the area's main towns and Stevenage, planners are extending urban sprawl, destroying countryside and valuable agricultural land as well as the setting and special character of several communities such as Baldock and Graveley all of which are contrary to NPPF 80.
The NPPF also makes clear that, once established, green belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. Meeting assessed housing need has been adjudged by Government not to meet the exceptional circumstances criteria.

There is not enough emphasis on prioritising development on brown field sites. This should be given much greater emphasis. NHDC should be pursuing a policy of Brownfield Sites First.
Further development around Great Ashby, especially at Roundwood would result in unacceptable increases in traffic coming down a very narrow road (Church Lane). Part of Church Lane is single track and it also constitutes a section of the Hertfordshire Way Walking Route so putting the ramblers at much greater risk.

Knebworth residents have always been very opposed to any plans to close the gap between Stevenage and Knebworth. We note that part of the plans for Knebworth include reducing that gap on the NE side of Knebworth.

The proposed allocation of 2800 homes on site BA1 (North of Baldock) under policies SP8 and SP14 would have a serious negative impact on the Green Belt. This is acknowledged in the Plan and supporting documents (Housing and Green Belt background paper para 3.14) as making a significant contribution to Green Belt purposes and is identified as having moderate to high landscape sensitivity.

4.53 The 'exceptional circumstances' that North Hertfordshire District Council find itself in such that it needs to remove Green Belt protection from large areas of prime arable land, with a significant impact on the local setting and countryside is entirely self manufactured. By refusing to do any planning whatsoever for new settlements in North Hertfordshire it has created a manufactured urgency where the district is left without a Local Plan or a 5 year land use plan and councillors and residents are forced to accept a plan that many consider flawed. This sets a terrible precedent nationally for other district councils to follow whereby difficult decisions about reusing industrial land, creating new settlements or increasing density within larger settlements can be kicked down the road and large areas of easy to develop Green Belt can be rezoned under the 'exceptional circumstance' of local housing need. For this reason alone this rezoning should be objected to and scaled back. However, it is also ambitious and highly risky for a district council with low competency maturity for delivering large developments in partnership with commercial developers (for example the Church Gate development in Hitchin or the chaotic development of Great Ashby) to assume simply rezoning a large area and leaving it to developers will result in an effective plan. Whereas other options such as creating new settlements and/or spreading the development out more evenly with more nuanced changes to the Green Belt seem much less risky, easier for the district and county council to deliver and much more realistic. Furthermore, the Plan assumes that the particular area north of Baldock will result in large amounts of affordable housing, but ignores that its previous Green Belt status has prevented an area very close to a train station with a fast (34 minutes) link to central London from being developed in the past and that releasing it will simply create a pool of extremely high value housing that will not meet local housing need and may in fact drive up house prices in the area - they haven't fully considered what rezoning a large area of green belt means and what the implications of such as action might be - in other words they have not thought it through. But this can be mitigated by scaling down the development, separating it from Baldock and the train station (and preferably from Bygrave also), and then looking to make up the short fall in other areas of the district (perhaps by looking at areas considered in previous iterations of this plan) and by a commitment to establish (zone and build the first homes of) 2 new settlements in the district within the plan period (not in the next plan period, when the district council planners can once again kick the can down the road and manufacture the urgency requiring yet more large scale growth around one of the existing towns).

4.55 the assertion that Green Belt releases can be offset by additional Green Belt elsewhere is frankly ridiculous. What is more there is absolutely no need to cover the whole of the south of the district with Green Belt, stifling growth of villages and cutting off options for new settlements in the area - the existing Green Belt zones are sufficient - they have done their job until now and there is no evidence that they need to be strengthened. Encroachment from London, Stevenage and Luton as been sufficiently curtailed by the existing zones and they should be left largely unchanged.

The blanketing of the southern half of North Hertfordshire in Green Belt is unnecessary and counter productive. Where Green Belt has been released for development there are a number of additional policies which should be put in place to enhance the rural character of these communities and to encourage participation with the countryside.

Finally, it is important that there is sufficient tree planting in the development of newly release Green Belt, which will start as bare farmland.

This Local Plan includes a mass redrawing of the Green Belt in North Hertfordshire (although separated out into a separate document). The vast majority of North Hertfordshire (outside of its main towns) is undeveloped and facing challenges in terms of high property prices and under occupation. This plan covers these areas with Green Belt and creates additional developmental barriers whilst removing Green Belt protection from very large areas of highly productive and attractive land around the existing towns - particularly to the north of Letchworth and most notably all around Baldock. (It should be noted that District Council has recently been refusing development plans in villages on the grounds of impact to the country side, e.g. at Whitwell, whilst encouraging destruction of countryside around towns in this plan - this demonstrates the need for the to the plan to clearly and actively encourage rather than discourage development of the villages and hamlets of North Hertfordshire, otherwise the trend to underdevelopment, high cost of living and under-occupancy in these areas will continue.) I object strongly to the blanketing of all the the southern half of North Hertfordshire in Green Belt - the existing Green Belt zones provide sufficient protection against encroachment from Stevenage, Luton and London. It will also unnecessarily exclude (or make it more difficult to consider) these sites as possible sites for a new Garden Village - it could be seen as a cynical attempt to entrench a bias toward over development of existing towns and continued underdevelopment of other areas of the district.
Furthermore, the Green Belt review has removed Green Belt protection for very large areas around Baldock (and surrounding towns such as Ashwell) and north of Letchworth. 13.16 states the town boundary as being that shown on the proposal maps, but this is the boundary after the Green Belt review, which I understand forms part of this Local Plan. The sites BA1 and BA3 were previously greenbelt and this status has clearly been removed in order to facilitate development. It would be of considerable benefit to the areas adjacent to the sites (both developed and non-developed/farming) if their recent greenbelt status was recognised in the plan and additional policies put in place. It represents a significant unbanisation of these adjacent areas, particularly Clothall Common, which is currently bounded on 3 sides with open farmland, but instead will become bounded on 3 sides with urban areas - without mitigation this would reduce access to the countryside, deteriorate surroundings and have a negative impact on health and well being (for example, through diminished countryside access/activities, like jogging, walking, cycle riding, dog walking, etc.) - in short, without specific policies it would make these developments unsustainable. A review of Green Belt around these areas, particularly in light of housing need in the district is to be expected - that such huge areas of protection should be removed against the wishes of the residents of North Hertfordshire as expressed in such large numbers in the responses to the Preferred Options Plan, is astonishing. However, given the housing need (and lack of other options explored by the district council creating a 'manufactured urgency') I accept that these areas will need some development - it is vital that the Local Plan accepts the recent Green Belt status of these areas and identifies them for additional policies and protections. It is entirely possible to maintain the rural feel of these recently Green Belt areas, to encourage interaction and participation with the countryside, and to limit the impact of development in these areas to the countryside, and to do so without affecting the deliverability of development at these sites, or indeed by altering the actual number of homes delivered at these sites very much. For example, 'green lanes' or strips of actual green belt could be inserted between existing boundaries and the newly released areas of development; Also housing density could be limited in these zones and additional planning requirements in terms of 'rural' character of development and consistency with local historical architectural styles could be applied to these zones; Additional requirements for open areas, playing fields and recreational spaces could be placed on these zones; And to ensure continued access and participation with the countryside, green lanes linking existing countryside access points to the new access points at the new boundary could be required, as well as requiring a review of all permanent farm tracks in the adjacent countryside with the aim of upgrading them to footpaths and bridal paths to encourage greater participation in the countryside (to be carried out before development commences to ensure it is not simply ignored by the planning and development process, assuming it would be swift and cheap to complete - a 'quick win') - this would mean that development of these areas actually enhances the rural character of the developed areas and ensures the sustainability of these sites.
Finally, from reading the document, I don't think the policies are specific enough about the need for tree planting in the newly released areas of Green Belt - arable farm land will be starting very bare and for developments (particularly around Baldock and especially around Clothall Common) to be consistent with the character of existing developments and the local townscape, significant tree planting will be required. These policies need to be strengthened, and the sites themselves should give mention of this requirement.

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The plan to build on green belt is not sound, and is in conflict with national Green Belt policy (Section 9 of the NPPF). The justification for the excessive housing target that does not take proper account of Green Belt constraints is absent (NPPF para 14). The impact of individual developments on the countryside and communities including cumulative effects - for example, where there are also proposals in neighbouring Council areas is not justified. The effect of housing growth on local services and facilities including roads, schools, health services, and excessive local gravel and sand extraction.

LEAVE IT ALONE!

Theresa May, and before her David Cameron, have stated that nationally the Green Belt should be preserved intact; Mrs May has used the word "sacrosanct". Hansard records on 15th July 2016 the Minister of Housing and planning, Gavin Barwell, stated: "...most building on the Green Belt is inappropriate and planning permission should be refused except in very special circumstances". The 3 local MPs whose constituencies cover North Herts, have stated their support for this position. The Local plan Proposes to build large new housing estates on Green Belt land east of Luton, north of Letchworth, north of Baldock and north of Stevenage, yet nowhere in the Local Plan has NHDC demonstrated "very special circumstances".
Water and sewerage infrastructure is already struggling to cope with the density of housing in North Herts, one of the driest parts of the country. Local rivers such as the Beane are already over-exploited and suffering environmental damage. The Green Belt north of Letchworth has significance for several red listed species of bird, wildflower and butterfly and should not be considered for housing development.

4.60
Royston Town Council objects to the land shown on NH Sheet 2 Side B Royston Area being designated as Urban Open Space.

When the Gateway project goes ahead giving access to RY9 site, such designation would preclude expansion of any commercial area to the west of this site. This limitation might also detract from the justification for the Gateway access.

Royston welcomes the opportunity for more commercial and/or leisure development.

It is presumed that this designation is as a result of the recommendation made in 4.16 of the report by BSG ecology commissioned by NHDC "Allocation Site RY1: Land west of Ivy Farm, Baldock Road Recreational impacts on Therfield Heath Site of Special Scientific Interest (SSSI)" June 2016.

Para 4.16 "Incorporation of alternative areas of land of a suitable size for informal recreation purposes to include habitat creation to generate biodiversity and landscape interest. For example the two fields to the north of the allocation site could, for example, be used to create a country park. The layout and design of this alternative greenspace needs to be designed to ensure the park is sufficiently attractive to people and will provide an attractive alternative recreation resource to Therfield SSSI."

Royston Town Council does not agree with this recommendation. In addition, the land is privately owned and there are no means of access for the public as the site is bounded by the railway line and the A505 and the private owned site RY9.

With reference to 4.60, 13.298 & NH Sheet 2 Side B Royston Area

Royston Town Council objects to this land being designated as Urban Open Space.

Should the Gateway project go ahead giving access to RY9 site, such designation would preclude expansion of any commercial area to the west of this site. This limitation might also detract from the justification for the Gateway access.

Royston welcomes the opportunity for more commercial and/ or leisure development.

It is presumed that this designation is as a result of the recommendation made in 4.16 of the report by BSG ecology commissioned by NHDC "Allocation Site RY1: Land west of Ivy Farm, Baldock Road Recreational impacts on Therfield Heath Site of Special Scientific Interest (SSSI)" June 2016.

Para 4.16 "Incorporation of alternative areas of land of a suitable size for informal recreation purposes to include habitat creation to generate biodiversity and landscape interest. For example the two fields to the north of the allocation site could, for example, be used to create a country park. The layout and design of this alternative greenspace needs to be designed to ensure the park is sufficiently attractive to people and will provide an attractive alternative recreation resource to Therfield SSSI."

Royston Town Council does not agree with this recommendation.

The Blackhorse farm site north of Baldock is situated on green belt land that has been placed to stop urban sprawl (NPPF Para 80), however this site is a classic example of urban sprawl & exactly why the greenbelt act was enacted. NHDC have rode roughshod over this policy and have ignored brownfield sites that do fit the criteria. probably due to political pressure from the landlords of the Blackhorse farm site who happen to be Herts County Council. This is the type of activity that gives government a bad name.

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Ramblers Association strongly objects to building on Green Belt land and especially on NS1, also GR1 & 2. Any areas added to Green Belt elsewhere in the District will not compensate for the area separating Graveley and Stevenage.
The general area of NS1 is important to walkers (and probably wildlife) as the best of the few green corridors allowing them to connect areas east and west of the barriers of the A1 motorway and the railway.

Illegal because the council has not adequately consulted the community on the new proposal to remove important areas from the Green Belt, specifically area KB4 in Knebworth. In July 2016 the same council declared that KB4 makes a "significant" contribution to Green Belt purposes, helping to prevent sprawl, merger and encroachment. Why the sudden change? Reference:
http://www.north-herts.gov.uk/sites/northherts-cms/files/NHDC%20Green%20Belt%20Review%20July%202016.pdf
See section 2.5 Assessment - existing Green Belt, 8 Knebworth.

Unsound, against national policy, because the Council has failed to justify the permanent removal of Green Belt areas. Note that National Policy Planning Framework (NPPF) defines essential characteristics of Green Belts as being open and permanent. NPPF para 83 states that Green Belt boundaries should endure in the long term, beyond the local plan. The draft local plan makes no such provision.

Unsound, unjustified, because the building of more accommodation, as flats or houses or conversions, is normal for a developing village or town and is not an exceptional circumstance.

Lack of co-operation. There is no evidence of any co-operation with other councils to protect the Green Belt and prevent coalescence between population centres in North Herts and surrounding areas.

More effective alternatives exist. For example a substantial area west of Stevenage has been reserved for 3100 homes, which would be more effective in meeting the needs of North Herts than sacrificing significant Green Belt areas around Knebworth. A development west of Stevenage could indeed be part of a more effective strategic plan including a critical east-west link road joining Stevenage to Luton Airport.
Does not meet infrastructure needs, just suggests improvements.

This policy is a contradiction of the plan itself. Site WY1 at Little Wymondley is an inappropriate development, being an almost 100% increase in the number of dwellings in a very small village currently protected by over-development by all land outside the existing settlement being long-standing greenbelt. Not to mention the sites EL1, EL2 and EL3 at Cokcernhoe, an existing settlement of just 205 dwellings, whereby in the plan, it is proposed to completely overwhelm the village by an addition of 2,100 homes. Yet the policy tells us "We support the principles of the Green Belt and recognise the intrinsic value of the countryside. We Will only permit development proposals in the Green Belt where they would not result in inappropriate development" Really? The plan includes doubling the size of villages, and increasing them 10-fold - this is exactly what most people WOULD say is inappropriate development.

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Policy SP5: Countryside and Green Belt:
The policy is supported. This is because the Council recognised, in the preparation of its draft plan, the need for a comprehensive Green Belt review in order to be able to accommodate its objectively assessed housing need (OAN) for the plan period. The release of appropriate areas of land from the
Green Belt is the only way to be able to meet the OAN in the most sustainable locations (i.e. such as at North Stevenage - Policy SP8/SP16 - NS1). Having completed that review and removed certain areas of land from the Green Belt in order to accommodate new development, it is appropriate to protect the remaining Green Belt areas in accordance with the guidance in the NPPF and PPG.

The removal of land from the green belt for strategic development at the locations referred to in Policies SP8 and SP3 is in direct contradiction of the Governments guidance. The planning guidance makes clear that, once established, Green Belt boundaries should only be altered in exceptional circumstances. SP3 & SP8 would fail the fundamental aim of green belt policy to prevent urban sprawl, neighbouring towns from merging into one another, safeguarding the countryside from encroachment, preserve the setting of an historic town and restrict the regeneration of derelict and urban land within North Hertfordshire. NPPF para 14 & 83.

Is it right and fair to remove so much green belt from around Baldock? Effectively Bygrave will become part of Baldock once the development has been fully completed in 2031. When we bought our property it was because we wanted to live in a village environment which these changes will have a detrimental effect upon. Again we feel that not enough consideration has been given to brown field sites at the expense of green belt that was owned by NHDC and was therefore an "easy option" rather than considering other alternatives eg the area West of Stevenage.

I support the principal of the green belt and do not consider anything in this plan provides an exceptional circumstance justifying the need to move existing and long-standing green-belt boundaries.

In the opening statement you state "We support the principles of the Green Belt and recognise the intrinsic value of the countryside.", then you go onto move the green belt as suits and give back a meaningless section between Stevenage and Luton.

The government is quite clear on the purpose of green belt, to stop exactly the development you are trying to force through

The National Planning Policy Framework (published on 27 March 2012) is clear on this and Section 80 States:
Green Belt serves five purposes:

to check the unrestricted sprawl of large built-up areas;
to prevent neighbouring towns merging into one another;
to assist in safeguarding the countryside from encroachment;
to preserve the setting and special character of historic towns; and
to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

this scheme contravenes these guidelines from the government. The land n GA2 is not just agricultural land, it is green belt and is used as amenity space for the residents of Great Asby.

Also referencing the District Local Plan alterations 2 - it states

"Green Belt

In the Green Belt, as shown on the Proposals Map, the Council will aim to keep the uses of land open in character. Except for proposals within settlements which accord with Policy 3, or in very special circumstances, planning permission will only be granted for new buildings, extensions, and changes of use of buildings and of land which are appropriate in the Green Belt, and which would not result in significant visual impact.

Policy 3 - Settlements within the Green Belt

In settlements within the Green Belt, the Council will not normally permit development proposals, except for:

that strictly necessary for the housing and employment needs of agriculture, forestry, leisure and local services in the rural areas that cannot practicably be met outside the Green Belt; or
the local facilities and services needs of the settlement within which the development is proposed; or
the meeting of an identified rural housing need in compliance with Policy 29; or
a single dwelling on a small plot located within the built core of the settlement, which will not result in the outward expansion of the settlement or have any other adverse impact on the local environment or other policy aims within the Green Belt."

Noen of the above is satisfied with regards to the proposals for GA1 & GA2

I object to the proposal to remove Green Belt land. This is needed as a buffer between towns and villages in the district. Increasingly, I notice that the existing green belt is used for residents recreation, which in turn leads to physical and mental well being. This is vital in this age of helter skelter living. People must be enbaled and encouraged to look after themselves, by having easy access to countryside and open spaces.

Both LA1 and BA1 are proposed on Green Belt Land described as 'North Baldock Chalk Uplands' charactized by its remote and open landscape.

"The reference to areas of remoteness is fully supported. The feeling of tranquillity is also a perceptual aspect of the landscape that should be protected wherever possible. Tranquillity provides relief from urban areas and benefits health and wellbeing, protecting any pockets of tranquillity is especially important in close proximity to highly developed areas." (comment letter from Paul Donovan HCC Spatial Planning and the Economy Environment Department 3 Feb 15)

In respect of BA1, the open nature of the area north of Baldock is fundamental to the character of the town, being at the foot of the Chilterns and the edge of the Chalk uplands. The development of BA1 will destroy this characteristic, and 'replacing' green belt by some new areas near Luton airport is no mitigation.

In respect of LA1, In 1902 Ebenezer Howard wrote in Garden Cities of Tomorrow: "Shall it build on the zone of agricultural land which is around it and thus forever destroy its right to be called a 'Garden City'? Surely not." LG1 as farmland is of vital importance in maintaining the green belt design of the world's first garden city. To erode this beyond the natural skyline boundary of the existing built up area would be a critical loss to Letchworth's integrity and therefore no developer could possibly satisfy Policy SP15 condition a,i "How the site will follow and implement Garden City principles".

It is also difficult to imagine how any development at a density of c.35 dwellings per Ha can possibly "implement Garden City principles" in any case.

This high density housing at LA1 will be especially deliterious to views from afar, eg from North Road between Radwell and Baldock and from the water tower at the junction of the A1 and the Langford Road where Letchworth is currently out of view in its own valley. It will become highly visible, and be a ruinous encroachment on the rural aspect of Letchworth from the North and especially to Radwell and its Wildlife area.

NPPF and Government statements
The Planning Minister in March 2014 reaffirmed NPPF priorities saying "Unmet housing need is unlikely to outweigh harm to the green belt and other harm to constitute the very special circumstances justifying inappropriate development on a site within the Green Belt"

NPPF requires Councils to protect the green belt when preparing their Plans. Para 14 states that the extent to which assessed housing needs are met should reflect constraints such as Green Belt. Guidance 1 re-confirms this.

NPPF says "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belt are their openness and their permanence."

NHDC have used the caveat of 'exceptional circumstances' as detailed in the NPPF to allow them to make inroads on the Green Belt boundaries around Baldock without due concern for the safeguarding of the character of this historic town.

The plan is unjustified because it includes releasing for residential development green belt land (SHLAA sites 55, 56 and 58 which are part of KB4) categorised as 'Site makes a significant contribution to Green Belt' while other sites (RG and WS sites in Langley) with the lower category 'The site makes a moderate contribution to Green Belt' have not been allocated for residential development. This indicates that the process of allocating land for development has not fully taken into account the North Hertfordshire Green Belt Review dated July 2016.

There is an absence of justification for the excessive housing target that does not take into proper account of Green Belt constraints and in many cases. The current framework makes it very clear Green Belt boundaries should only be adjusted when very special circumstances exist, through the Local plan and with the support of local people. The need for additional housing alone does not constitute exceptional circumstances for rolling back further the green belt around the towns on the A1M corridor.