Policy SP5: Countryside and Green Belt

Whilst adjustments to the longstanding Green Belt boundaries are, along with the exclusion of some previous washover settlements, very welcome, the plan is unsound in that it fails to acknowledge that there is the capability for infill in remaining washover settlements. It would appear to justify this failure on the basis that "the vast majority of land in North Hertfordshire is rural in nature" and "restraint on unsustainable development in rural areas is a well-established policy".

Any assessment of what is "rural" and "locationally unsustainable" is a relative and somewhat subjective assessment and it fails to identify settlements which, whilst they may, for example, be detached from the main towns and larger villages which are administratively within North Hertfordshire district, are both identifiable entities and may relate well to neighbouring urban areas. Policy SP5 should include a clause concerned with "Rows in Green Belt". It should recognise and identify groups or rows of dwellings washed over by the Green Belt, wherein infill development would not occasion any harm to the openness of the Green Belt. Other local planning authorities with a similar geography have such a policy (Chiltern, South Buckinghamshire and South Oxfordshire for example).

Such a policy may not be appropriate for all such settlements and discretion is required, but a perfect example is Todd's Green, it sits right at the edge of, indeed is partly within, Stevenage and has easy and ready access to all the facilities in that town. It comprises a tight knit group of suburban style development and infill in the form of one or two dwellings, would occasion no harm and importantly not undermine the openness of the Metropolitan Green Belt. Attached is a Google Earth image of Todd's Green and an extract from the Draft Local Plan Proposals Map. The area where a Green Belt infill Policy should be applied is edged in red.

See attachment

Summary - we object to the location of the proposed Green Belt boundary around the village of Offley, specifically in relation to a site at the Rookery, Harris Lane, Offley.

The Council proposes to designate a new area of Green Belt. As part of these proposals, the village of Offley is proposed to be inset from the proposed Green Belt and a new Green Belt boundary created around the village. The proposed Green Belt boundary appears to follow the existing settlement boundary of Offley, as shown on the adopted Local Plan proposals map. The location of the boundary in relation to the Rookery site is shown at Appendix A, Figures A3 and A4.

However, on 19 August 2016 planning permission was granted for the erection of three dwellings on land adjacent to the Rookery. The decision notice and approved plans are attached as Appendix B. This decision post-dates the publication of the Council's Green Belt Review (in July 2016) and the SHLAA (in March 2016). The land to which this permission relates is outside of the proposed village boundary i.e. within the proposed Green Belt.

In addition, the barn adjacent to the Rookery has planning consent for conversion to a dwelling, a two storey side extension and a detached double garage. The decision notice and approved plans for this development are attached as Appendix C. This development would also be within the proposed Green Belt boundary.

Appendix A, Figures A3 and A4 show the approximate locations of both approved development sites plotted on a plan of the area and an aerial photograph.

An essential characteristic of Green Belts is their permanence. It is therefore important that newly established boundaries are robust and can endure. Including recently approved development within a newly defined area of Green Belt makes no sense and would only serve to undermine the proposed Green Belt.

Notwithstanding the approved development, local planning authorities must follow advice in the NPPF when defining new Green Belt boundaries - not only in demonstrating exceptional circumstances to justify any changes (paragraph 83) but also to "define boundaries clearly, using physical features that are readily recognisable and likely to be permanent" (paragraph 85). The same test does not apply to defining village boundaries so merely following the previous village boundary would not be consistent with the approach in the NPPF.

The current village boundary divides the house known as the Rookery from the rest of its garden. There is no readily recognisable physical feature that forms the basis for this new Green Belt boundary. This is clear from the aerial photograph at Appendix A, Figure A1.

This is also reflected in the Council's assessment of this site in the SHLAA:

"Small, broadly square site located to south of Great Offley. Site well bounded on three sides by Harris Lane, hedgerow and woodland. However no boundary with adjoining Rookery and site sits within curtilage of this listed building and impact on setting a significant consideration."

Notwithstanding the conclusion about development potential, the lack of a boundary between the Rookery and its curtilage creates a problem in terms of defining a new Green Belt boundary.

This situation and the relationship between the site and its surroundings are addressed in paragraph 4.3.4 of the officer report on the recent approved application for three dwellings. Under "character and appearance", the officer states:

"The site is currently undeveloped orchard land attached to the main dwelling at 'The Rookery' The land has a frontage with Harris Lane which serves both 'The Rookery', The Red Lion public house and Nos 1 -3 Old Vicarage Cottages. Harris Lane also serves the adjacent barn also sited fronting Harris Lane which benefits from a recent planning permission for its conversion into a 3 bed dwelling and extension. The application site immediately adjoins the Offley Village boundary, the dwelling at 'The Rookery' being within the village boundary. To the east of the site is an arable field with the boundary between the field and the orchard being defined by a hedgerow with several semi-mature trees. The above factors suggest that the application site is more associated with the village settlement than with the open countryside to the east albeit that the site is located on the outer limb of the village as defined by Harris Lane. It is my view that a small development as proposed here of three dwellings would not necessarily be out of keeping with the nearby built development or the semi - rural character of area particularly given the traditional form of the dwellings, the farmyard layout and the use of more rural materials such as timber cladding, brick plinths and plain tiles and natural slate roofs all of which are commonly found in rural locations."

The officer's report highlights the strength of the boundary to the east of the development and the stronger association with the village settlement than with the open countryside to the east. We concur with this analysis.

It is clear that the currently proposed Green Belt boundary is unsuitable and not "sound", both on account of the recent substantial development approved within the proposed Green Belt and the lack of a readily recognisable Green Belt boundary. An appropriate boundary can be defined by following the footpath line to the north, the "hedgerow with several semi-mature trees" to the east of the site and then Harris Lane to the south. This proposed boundary is shown at Appendix A, Figures A3 and A4. This proposed boundary follows existing landscape features, as required by the NPPF and would be a sound boundary. It would also include the recently approved development within the village envelope.


Appendices
Appendix A - Aerial photographs and illustrations
Appendix B - decision notice and approved plans for development ref 15/02656/1
Appendix C - decision notice and approved plans for development ref 16/01409/1

The ConnectedCities methodology does not permit the development of Green-belt land unless it falls within the pedshed of a rail station in order that it be served with sustainable transport. It is therefore against the release of land on the edges of existing settlements unless the above criteria are satisfied. See http://www.connectedcities.co.uk/the-connectedtowns

The destruction and reallocation of the Green Belt land undermines current Green Belt Policy and a quick reclassification of this area does not mitigate the fact that the plan uses Green Belt land contradicting at least three of the fundamental principle of green belts - 1) prevent neighbouring towns merging, as the proposal joins settlements together into a type of Ribbon development from Hitchin to Baldock 2) Nor will it check the unrestricted sprawl of built up areas 3) it will not help preserve the special character and historic character of Baldock town centre.

See attachments (and below)

National policy on Green Belts not adhered to. Does not meet exceptional circumstances.
The vast majority of proposed new dwelling are in current Green Belt. (60% proposed dwellings within green belt despite the fact 2/3 of district land is outside green belt).

One of the five purposes of Green Belts as stated in the National Planning policy framework is "To assist in urban regeneration by encouraging the recycling of derelict and other urban land". The NHDC Green belt review part 1 recognises this in "Assessment against Green belt principles" (paragraph 32 and table 2) However this criteria is not included in Table 5: Assessment of Existing Green Belt. The purpose of the proposed removal of Green Belt to the east of Luton (in Sector 2 EL1 EL2 & EL3) is to meet the wider needs of the Luton housing market area. The destruction of the Green Belt to allow the development of 2100 new sites will effectively result in Luton extending into rural Hertfordshire. This significant number of sites will logically have an effect on the will to and cost effectiveness of recycling derelict and other urban land in Luton. Since urban regeneration is one of the five purposes of a Green Belt I feel this factor should have been included before the report recommended the significant destruction of Green Belt to the east of Luton. I could find no evidence of this having been done in any of the documentation. The assertion in the Green Belt review that "the fifth purpose has not been considered as the other four purposes are all deemed to contribute to urban regeneration" does not really hold water when considering destroying a significant portion of green belt which is currently constraining the spread of urban Luton to the east. The stated purpose of destroying the Green Belt to allow development to the east of Luton is to address housing needs of Luton not NHDC so there should be documentation of the effects this development will have on urban regeneration in Luton.
The green belt review is flawed. Luton is not included as a historic town.
The plan is contrary to national policy to prevent urban sprawl. The plan is not in line with Luton Borough council's statements on importance of Green Belt.

For these reasons I object to the Green Belt review and therefore Policy SP5 which references it.

The creation of vast new areas of Green Belt between Hitchin/Stevenage and Luton will make it increasingly difficult to provide for any future housing need.
The current Green Belts are stopping the current urban areas from spreading. If they are allowed to do so and all the land between them is made new Green Belt then the next time there is a need to provide more housing the only option will be to (again) allow the expansion of these settlements by destroying more Green Belt.
A genuinely plan led solution may see benefit in retaining current Green Belts. This would encourage Urban regeneration (of which there is a lot of land to redevelop in Luton). Further need could be provided by expanding current settlements outside of the Green Belt or creating new settlements such as a new Garden City.

NHDC have not demonstrated the exceptional circumstances required to justify destroying the Green Belt east of Luton.
NHDC in 4.221 reference Sir Michael Heseltines "leave no stone unturned" quote as justification (point 69). The report in question relates to growth and I could find no reference to it justifying destroying Green Belt. I did however find the following quote from Sir Michael Heseltine "It does indeed seem ridiculous that we should be scrabbling around for land in the South East - even contemplating the destruction of the green belt - when such a large and strategically-located area is in such obvious need of regeneration."

The assumptions made in the Draft Sustainability appraisal seem very biased and potentially flawed. In Table 4 What would happen without the plan? to sum up most of what could happen without a local plan "national policy might protect you but we might be able to do things better with a local plan". OK - now where's the table listing what could happen with the proposed local plan? (you're village / hamlet is subsumed into a neighbouring councils town and all the buses taking pupils to school miles away are increasing traffic and CO2 emissions). That outcome is a lot more likely than half the possibilities mentioned in the report. The sustainability appraisal is one long extremely biased piece of scaremongering propaganda and a document so lacking in facts or balanced predictions has no place being included in this process. I object to policy SP1 and the sustainability report.

I am sending a response to your planned submission for new homes to be built.

It is astounding that so many are to be built on Green Belt land. The CPRE have commissioned a study which states that there is enough brownfield land in North Herts for over 11,000 homes. It should be an absolute priority to use that first.

I live in Letchworth and am pleased you used the site north west of the Blackhorse Road for development but horrified at the amount of new homes planned covering green spaces vital to health and well being. It is a sadistic joke when you consider the principles of the first Garden City. I often visit sites LG3 in Letchworth and BA3 in Baldock and many others and they are little havens. It is so important to have long distance views near where you live and countryside for emotional health.

Also there is the problem of infrastructure. The train service is very good but well used and already there are not enough car parking spaces for commuters. Local schools have been closed down with no forward thinking. Medical services are struggling now.
These homes must not be built without proper care taken to ensure there will be extra facilities for the needs of the people and not try to cram more on services which are already finding it difficult to cope.

I am profoundly AGAINST the plan for this housing.
I am astounded that you are even considering building on prime agricultural green belt land. ‎There is numerous wild life and endangered species of plants on this land. It is also enjoyed by thousands of the general public of all ages who venture along this greenway . Letchworth is the First Garden City made by surrounding Green Belt. It's History. Don't take that away through financial greed. There are plenty of Brownfield sites to build on if it's a necessity.

No building on green belt

I have been a resident of North Herts for ten years and have grown to love this part of the world, having lived in London and Kent previously.
That development is needed in North Herts is axiomatic; it is clear that at this time, demand outstrips supply and ONS figures suggest that the District needs 14,400 new homes built between 2011 and 2031. North Herts District Council (NHDC) has increased this figure by 2,100, to take into account any 'unmet need' in respect of growth from neighbouring Luton, bringing the total number of new homes to be built in the period covered by the Local Plan (LP) to 16,500.
NHDC proposes that around 60% of these homes should be sited within the Green Belt, which will have dramatic effects on well-established communities in the District. The council seems to adopt a pragmatic view of this rolling up of the Green Belt, by simply designating land on more convenient sites as Green Belt. In this way NHDC can say that far from diminishing the Green Belt, they have increased it; this is rather like building a new football stadium in the middle of Dartmoor and recovering that lost moorland by designating a similar area in the centre of Exeter as National Park. It may look good on paper, but it is unlikely to fulfil its original purpose.
NHDC seem to insist on the adoption of a plan that covers the period 2011 to 2031, when legal advice commissioned by the Council has clearly stated that the minimum requirement is a five year plan, which would give time to properly plan for additional numbers. It is this insistence on a plan which covers twenty years which is at the heart of the Council's indecent haste and lack of preparation.
Two Stage Plan
The three MPs for this area, Sir Oliver Heald, Peter Lilley and Stephen McPartland have all endorsed the creation of a two stage plan, initially dealing with the first 10 years (2011 to 2021), which would look at planning for 6,050 sites. Planning permissions have already been given for over 2,600 homes; this leaves 3,450 new homes to be found district-wide before 2021. This period should be well used in identifying and planning a new 'Garden Village' development. We have an opportunity to create something worthwhile, rather than simply adopting a 'bolt on' principle to new homes within existing communities. I appreciate that this could not be included in this plan but the concept is only being included in the next planning cycle after much public opprobrium and protest, demonstrating the paucity of strategic thinking that runs through the whole plan.
Master Plans
NHDC has identified a number of significant sites, including Baldock, Letchworth and Stevenage, where infrastructure will be provided for within a 'Master Plan'.
Unfortunately no details of these plans have been made public. Public concerns about such sites have been met with assurances that concerns will be dealt with "as part of the Master Plan". My reservations concerning the efficacy of NHDC's planning were heightened when it was discovered during the previous consultation period (for the Preferred Options Plan), that Network Rail had no knowledge of the proposed settlement north of Baldock (BA1), that will mean 2,800 homes built on Green Belt land, as a bolt on to the medieval town of Baldock. It is accepted by the Planners that for the development to be viable, a bridge will have to be built over the railway for access and transport. But Network Rail hadn't even been approached at that time!
If the other Master Plans are built on such shaky foundations, I cannot see these plans becoming a reality without significant cost to the public purse. The Local Plan should include, where appropriate, full details of a viable Master Plan, which has the buy in of all stakeholders. At the moment, the Local Plan does not fulfil these criteria.
Transport Strategy
Trains. In September 2016, Govia Thameslink Railway, (GTR) issued a consultation document detailing proposed timetable changes. These changes, as originally published, would result in a significant reduction in trains stopping at Baldock Railway Station. I arranged a meeting with Jane Cobb, the Consultation Project Manager and Peter Lane, Lead Service Delivery Manager, of GTR to discuss the Baldock situation. The meeting was also attended by all the Baldock Councillors and the NHDC portfolio holder for planning and enterprise. This meeting was held on 2 November 2016.
I commenced the meeting by setting out our concerns, particularly in the context of a reduced train service when the Local Plan was intending to increase the size of Baldock by 80%; this would increase passenger flow to/from London from 330,000 journeys (GTR's own figures in the condoc) to 600,000 journeys annually. To my surprise, neither of GTR's representatives knew anything about the Local Plan and had not been included in any consultation/liaison. Both representatives acknowledged that they would now have to take this extraordinary growth into account when doing their modelling. This flies in the face of the NPPF (Promoting sustainable transport, para 31), which states that "Local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure necessary to support sustainable development..." It indicates that this plan was conceived in isolation and that NHDC has failed in its duty to cooperate with other bodies.
Roads. There are a number of gaps in the evidence offered relating to local traffic flows and I shall highlight three of them.
Road bridge. The major development north of Baldock has at its heart, the requirement to build a road bridge over the railway to provide access; indeed the provision of "a new link road connecting the A507 London Road to the A505 Baldock bypass, including a new bridge across the railway" is one of the site specific requirements for development north of Baldock. All enquiries about the provision of infrastructure were met with the response "It will be dealt with in the Master Plan". But when the 'Preferred Options' plan was sent out for consultation (2014-15), Network Rail knew nothing about any plans to build such a bridge. This is what the Senior Planning Officer of NHDC (in charge of the plan at that time), Richard Kelly, called a "show stopper", but NHDC only engaged with Network Rail after intervention from Sir Oliver Heald MP. Again no evidence of cooperation until the plan was sent for public consultation and very little progress made in this area since.
Gridlocked crossroads. The junction in Baldock where the B656 meets the A507 is a major junction; in many respects, all roads lead to it and it is currently at capacity, with traffic jams both during and outside rush hour periods. No traffic survey has been done at this junction, which is expected to deal with a significant rise in traffic once the new development begins. To cope with such an increase in traffic, the junction must be re-engineered; however, the options for such work are severely limited. Houses on two sides of the junction are listed, the oldest having been built in 1540. This seems to have been ignored by NHDC planners. Without solving the issues around this junction, traffic in Baldock is destined to remain gridlocked for most of the day, with consequential delays for traffic throughout the area. No coherent traffic plan has been put forward at any stage for coping with a massive increase in traffic and parking issues in Baldock town centre.
Deteriorating Bus Service. The removal of the 98 bus service between Baldock, Letchworth & Hitchin and the 391 service to Stevenage has resulted in a significant deterioration of quality of life, particularly for older people in the town of Baldock. There is, of course, no Sunday bus service. The impact of this hits the most vulnerable of our society; the Local Plan's Transport policy focusses almost entirely on private vehicular transport with the barest of nods to the needs of bus users and there is no evidence that NHDC has not failed in its duty to cooperate with transport providers for the provision of viable infrastructure necessary to support sustainable development.
Environmental Matters
The effect of traffic on air quality in Baldock. A Baldock GP recorded his concern some 20 years ago (before the Baldock bypass relief road was built) that "traffic generated pollution is responsible for the near epidemic proportions of asthma cases we see at the surgery." There is only one GP surgery covering the town of Baldock.
On looking at the evidence presented to the Baldock Bypass Public Inquiry the Inspector recognised a link between air pollution and asthma levels in the town, these being above the national average and rising. Despite the road being opposed by NHDC the Inspector approved its construction.
To underline how bad air quality was in Baldock at that time, the subject was raised by Sir Oliver Heald in the House of Commons in 1997, in support of the construction of the bypass to take traffic generated pollution away from the area. In 1994, figures from the local asthma register show that the child asthma rate was almost 12% (twice the national average), going up to 15% before the building of the Baldock Bypass in 2006. This year that same figure has declined to 6% (equal to the national average).
An NHDC draft Air Quality Report of January 2000 itself recognised the topographic influences on the situation (Baldock is, of course, located in a valley) by referring to the "physical character of Baldock inhibiting good dispersal of air pollutants." It also recorded that the annual mean standard (that applied at the time) for nitrogen dioxide had been exceeded in 1999.
North Hertfordshire District Council acknowledges that "no specific assessment (of air quality) using historical data has been undertaken at this stage." (email of 2 November 2016 from NHDC Strategic Planning to John Gingell).
Bearing in mind the inherent weakness of the Transport Strategy, I believe that there is a real possibility of rising air pollution within the Baldock basin as traffic levels rise due to the unparalleled expansion of this medieval town. The local authority is failing in its duty to the residents of Baldock by failing to conduct any meaningful assessment of that risk. In November 2016, Julie Girling, the MEP for South West England affirmed that poor air quality has a huge impact on human health, the environment and the economy, saying "Poor air quality is an urgent public health issue... estimated to cause 400,000 premature deaths across the EU... The UK should be a leader in the fight to tackle bad air quality... With our national health system, we bear the economic consequences of bad air quality directly and we should not allow the progress made in recent years to slip." No specific assessment of air quality is a major flaw in determining the environmental consequences of the Local Plan, which may well result in an increase in premature deaths in Baldock.
Natural Environment
The National Planning Policy Framework (NPPF) states that the purpose of the planning system is to contribute to the achievement of sustainable development with its three dimensions (economic, social and environmental). Development should support the local economy, provide social benefits in the form of new homes and social facilities and protect & enhance the natural environment.
The development north of Baldock (BA1) will seriously and adversely impact on wildlife in the area. The Corn Bunting was once a common, widespread farmland bird (originally called the Common Bunting). Due to changes in farming practices, the Corn Bunting has experienced a dramatic decline of 90% between 1970 and 2010. It has become extinct in Ireland and is possibly extinct in Wales. It is a Red Listed Bird. During 2014 an extensive survey was carried out, which indicated that the area north of Baldock is central to the population of this declining bird. This area also provides habitat for the following Red Listed species: Yellow Wagtail, Grey Partridge and Linnet. Development of this area will destroy the habitat of these protected birds with a disastrous effect on their overall numbers and sustainability.
Ivel Springs is a large Nature Reserve in Baldock and a Scheduled National Monument which means the site has national significance and is protected under statute. The springs, which are the source of the River Ivel, provide a diverse area for wildlife, including woodland, wetland and pasture; it is carefully managed to keep a mixed habitat and encourage wildlife to flourish. Chalk Rivers, such as the Ivel, are extremely rare and included in the Hertfordshire Biodiversity Action Plan. The River Ivel and its wetlands are important habitats for a wide range of species; however, for the past six summers, the river at Ivel Springs has dried up. It is contended that the imposition of the north Baldock development will increase the strain on this fragile ecosystem that has existed for at least 5,000 years. The loss of this Nature Reserve will have a catastrophic effect on wildlife and before NHDC embark on the development of north Baldock, research should be conducted to measure the level of threat that such proximity to a large development of 2,800 houses poses.
On 6 February 2015, the Natural Historic & Built Environment Advisory Team informed NHDC that site BA1, north of Baldock, in the Local Plan could contain heritage assets, which could be a constraint on the principle of development. This led to Hertfordshire County Council (the landowner) undertaking an archaeological trial dig evaluation of the site. So far, archaeological remains have been discovered, which probably date to the time of the Roman conquest of Britain; this investigation continues, but I have been informed that a principal archaeologist has stated that some finds may predate the Roman conquest and that indications are that the finds include a Roman villa, with muralled walls, which are incredibly significant. This is still being investigated, but indications are that much of this land may not be suitable for development, and inclusion in the Local Plan at this time is, to say the least, presumptive.
Green Belt
As previously stated 60% of homes in the plan are to be built on Green Belt land. Such land should only be used for development in exceptional circumstances. It is implicit in this policy that Brownfield and non-Green Belt land should be used before building on the Green Belt. Yet North Herts Homes (NHH) Brownfield Regeneration Project has not been included in this plan. This project aims to provide 400 homes, solely from the use of Brownfield sites between 2014-18. I have asked NHDC whether they have done any work to identify similar schemes without receiving any meaningful answer.
The proposed sites in the Baldock, Hitchin and Letchworth area will lead to a ribbon of development from Baldock to Letchworth, to Hitchin, creating unrestricted urban sprawl, with encroachment into the countryside. This proposition counters recent Government statements on the use of Brownfield sites. In 2014, the Minister for Housing said "This government wants to see the maximum amount of brownfield land being used to build new homes, whilst also maintaining protections for our beautiful countryside."
Virtually doubling the size of Baldock will damage the setting of Baldock in its natural basin, currently surrounded by countryside. The unique character of the town, dating back to medieval times with a strong connection to the Knights Templar and many listed buildings will be irrevocably and fatally marred.
More and more development is occurring on Green Belt land; in 2008, less than 20% of new homes were built on Green Belt land. In 2011, that figure had risen to 34% and will now be much higher.
Spatial Strategy
This plan focuses development squarely on the four towns within the district, who between them will have to accept 70% of the development. Of these four towns, the smallest and most historic, Baldock, is expected to assimilate 3,590 homes, or 25% of the total. This is not fair, nor is it equitable; neither does it take account any possibility of the development of a Garden Village/City. In this respect, the plan is shown to be short term and tactical, rather than strategic.
This plan relies on land that is put forward by developers and does not seem to be proactive in any way. Rather than look at land that would enhance future development and approach landowners, NHDC seems to have merely reacted to sites offered up by landowners, preferring sites that are Green Belt and owned by another public body (Herts CC).
Other Evidence
During the course of the development of the Local Plan, a number of sites have been put forward and then rejected by the planners of NHDC. The consultation paper related to the Housing Growth Targets consultation run by NHDC from 17 February to 30 March 2012 outlined eight different options for housing growth, ranging from 15,800 to 2,500 new homes. Unfortunately no rationale for rejection of individual sites has been published, which leaves residents frustrated and unable to understand a) what specifically has excluded a particular site and b) whether once a site has been rejected anything can be done to reverse that decision.
The NPPF states that Local Plans must be supported by a local evidence base, which means that NHDC must plan to meet objectively assessed needs for market and affordable housing and identify a five year supply of specific deliverable sites. I have been unable to ascertain why certain sites have been rejected in favour of others.
On the evidence, I believe that the plan, as it stands, is flawed; three local MPs believe the plan is flawed; even the NHDC Portfolio Holder, responsible for the submission of the plan believes it is flawed. There is public condemnation of the plan across the District and an overwhelming desire for a two stage plan looking at deliverable sites for 6,000 homes in the first ten years and working with other housing authorities to provide a new Garden Village/Town style settlement. I urge you to consider the overwhelming public view across the District and adopt a two stage plan, which will embrace localism and demonstrate objective and equitable measure to deliver the right level of development across NHDC.
If you think I can assist, I am willing to attend and give evidence at the Public Inquiry.

As I am sure you are aware the North Herts local plan has caused a great deal of concern amongst local residents and I wanted to include my representations for consideration even though I am sure these mirror those of a great number of local residents. I believe the plan as it currently stands does not comply with the National Planning Policy Framework. Whilst most people could accept some degree of development, proposals which increase the town population by 80% and increase the number of cars by as many as 5000 will destroy the town heritage and overwhelm the infrastructure

Specifically I believe these to be the main issues
1. NPPF Section 4 - promoting sustainable transport.
1. Currently the crossroads in Baldock town centre, linking Whitehorse Street to the High Street is a significant bottle neck. The plan currently has 2800 homes planned for north of Baldock. As things currently stand, a trip across Baldock in morning rush hour, starting in Bygrave takes as much as 45 minutes, with traffic streaming back towards the A1.
2. The significant number of new residents will likely be rail commuters. There appear to be no plans to accommodate extra parking at Baldock station and the rail company, Govia are currently in consultation to downgrade the Baldock service. As things stand many trains into and out of London from Baldock suffer from significant overcrowding. I have doubts as to whether the current rail service and station at Baldock could cope with the addition of additional commuters from more than 3000 new homes in the town
3. In the absence of accessible town centre parking to accommodate more cars, the additional strain on parking capacity will effectively isolate residents from both upper and lower Bygrave, who, unable to walk into town will have nowhere to park should they drive


2. NPPF Section 9 - Protecting green belt land
1. The individuality of the town will be lost by this upsurge in population. In addition the area on which the houses are planned is very scenic. There are alternative brown belt sites in the area which could be used to absorb at least some of the proposed development.
2. Bygrave is a rural community and a scenic, historical village. This identity will be lost with the number of houses proposed at the North Herts site and effectively create 3 pockets of housing


3. NPPF Section 2 - Ensuring the vitality of town centres
1. I have not seen any plans for additional parking in Baldock town centre. Even though it is only a 15 minute walk into the town from the north Baldock site, we know many people take the car even for short journeys. This will strangle the town.


4. NPPF Section 17 - Promoting healthy communities
1. I have not seen robust plans for schooling to accommodate such a drastic uplift in population. This is key. The schools in Baldock are already extremely difficult to gain entry into (the acceptance criteria to Hertsfield Primary school in 2015 was 360 metres distance to the school gates). Knights Templar secondary school is excellent, but is also heavily over-subscribed. Without adequate planning for schools existing resident's children in the rural communities such as Bygrave and Ashwell face horrific commutes. Going out in the direction of the Cambridgeshire villages then having to come back through Baldock
2. The road planned to link Bygrave Road with the A507 roundabout is planned to be above ground. This will create a great deal of noise and destroy the beautiful views. I believe if this road is to be built it should be in a cutting and go under the railway line.

I understand the need for additional development in Baldock, however I strongly believe the scale of planning is disproportionate with what can be coped with by the town. 3,290 homes are simply too many and I do not believe the local plan complies with the NPPF in several areas.

I wish to register my objections to the NHDC Local plan.

The land should not be removed from Green Belt Status while there are suitable undeveloped
Brown field sites.

The area does not have sufficient infrastructure and cannot accommodate any more traffic in the area,
there is often an issue of flooding already without further hard building.

I wish to make my objection to the Local Plan on the grounds that too much of the Green Belt seems to be in line to be built on. Baldock , it would appear, is to take the "lion's share" of the proposed building which is unacceptable. The infrastructure in the town is unsuited to the scale of housing proposed and local amenities are already stretched to breaking point. The addition of thousands more houses bringing with them more people for the GP surgery, children for the already over subscribed schools and more cars for the already congested roads will serve to destroy this historic market town. There must be an alternative to this Plan.

I urge those responsible to rethink these proposals.

I am writing to voice my strong opposition to ANY plans to build on Green Belt Land in Hertfordshire.

I do not see why beautiful, unspoilt Hertfordshire countryside is needed to meet Luton's housing needs when Luton already has an abundance of Brown Field sites within the town itself.

I don't doubt that greedy, unscrupulous developers would prefer to build on green fields rather than incurring the additional costs of clearing brown field sites. But BROWN FIELD SITES SHOULD BE THE ALWAYS BE THE FIRST PRIORITY. The countryside around Luton is an great natural asset, not only to the communities that live within it, but also to the people of Luton. To destroy it would be an act of pure barbarity.

I also don't see why Hertfordshire is being asked to fulfil part of Bedfordshire's housing needs. If they are hell bent of destroying Green Belt land then why don't they do it in their own county?

Aside from destroying this unique area of outstanding natural beauty, I don't see how this area can cope with any more traffic without more roads which will further degrade the area, creating even more noise and air pollution in the process.

The roads are already choked with traffic, with ever-longer queues becoming an everyday feature of our local towns and villages. It now takes ever longer to get anywhere and the quality of everyone's lives is gradually being eroded and they fight with increasing congestion.


We live in an era when the world's natural resources and open spaces are being destroyed at an alarming rate - the consequences of which are now increasingly apparent here in the UK with record declines in the country's natural wildlife, increased congestion and a reduced quality for everyone.

Please search you conscience - HOW COULD ANYBODY LIVE WITH THEMSLEVES KNOWING THAT THEY HAD DESTROYED A BEAUTIFUL PIECE OF GREEN BELT LAND WHEN OTHER ALTERNATIVES ARE AVAILABLE

There is no need to destroy Green Belt land for this development as there is plenty of Brown Field sites for building on. I live in Stopsley & the traffic situation every morning is horrendous. How many roads are there out of Cockernoe? The hole area will be gridlocked trying to get to the M1 the 5a05 the A5 & the roads to Dunstable & Bedford. This is all being ignored by the NHDC page 72 para.222. saying that the level of development can be accommodated without a significant adverse impact on the wider highway networks of Luton & Herts. Who do they think they are kidding. I could go on for hours with my objection but think I have made my views clear. STOP this DEVELOPMENT Now

I am writing to express my deep concern on the potential release of greenbelt land around Cockernhoe.
Greenbelt was designed to stop urban sprawl never has this been more important and relevant. However well architects and planners dress up plans and drawings the loss of this land is immense .
Cockernhoe will be overrun and destroyed. The land has major appeal to the residents in Wigmore as it is an area where than go for walks to clear their mind and enjoy gentle exercise.
these new houses will not in any way help the national housing problem . we need new towns with dedicated infrastructure to cope with our expanding population. more houses mean more cars more congestion more frustration more stress more pressure on doctors more pressure on hospitals more pressure on schools more pressure on everyday life. I am hoping that common sense will prevail and this greenbelt land will be left alone to serve the purpose it was designed for

I wish to strongly disagree with the proposed plan to build on "Green Belt" land bordering east Luton.

Why is a plan being put forward, being considered to build on Green Belt land at all? Land is classified as Green Belt for very good reasons and I can see no "good" reason to change the status of the land east of Luton. The country relies on us all abiding by the rules and regulations that have been agreed/passed by government and the people of this land so why is the current status under consideration?

There is no doubt that more homes are required in this country but care must be taken on where new homes are built so as to preserve a balance for all of the community.

I understand that there are numerous "Brown Field" sites within the Luton area that may better meet the development requirements and I hope that these will be fully considered before the irrevocable step is taken to permanently change the status of this very cherished plot of "Green Belt" land.

As a life long resident of Luton, I wish to participate in the Examination Stages for NHDC Local Plan 2011-2030, and wish to change parts of the Plan.

I ask you to please consider my objection as you carry out your review.

With reference to the Green Belt Review, part of the Proposed Local Plan 2011-2031

I have followed the progress of the Green Belt Review in its draft state and just spotted that extra sections have been added to the final version on which I would like to comment/object.

The first is in the analysis of the potential development sites in the green belt. Parcels are shown on the map on page 127 and detailed in the analysis on pages 107 and 108, namely parcel numbers 206 and 311. They are assessed to be of only moderate green belt contribution. I consider both these sites to be significant in that, although they have a boundary with the A!, beyond that lies Mardley Heath Nature Reserve. Wildlife uses this green belt as a very important corridor to move in and out of the reserve, passing over the A1 which is in a cutting at this point. The broader environs seem to have been overlooked in this assessment and should have been considered. These sites should be categorised as significant on their wildlife importance alone.

The same area which contains these parcels, area 6, has been shown on Fig 3.6 page 66 as of only moderate significance. The preceding maps - pages 62 to 65 - and table 3.1 page 41, has this area down as significant contribution. I think an error has been made in preparing the overall map on page 66. Areas 8a and 8b are classified the same as 6 on the table and preceding maps yet are coloured correctly on the overall map. Why is area 6 downgraded on this overall map? It is important that the significant category of area 6 be correctly described.

I do not live in Herts although my daughter does and many of my friends do and I object most strongly to the current plans to build thousand of houses in North Herts on Green Belt land. This is a beautiful area which will be destroyed by such massive building, not to mention the wildlife - flora and fauna.

There is absolutely no need to build on Green Belt. There is plenty of brown belt areas, plus thousands of sites in towns which could be built on. Also, there are millions of empty houses in the country, which could be purchased and used.
We are destroying our country and will pay a price in a few years.

I would also like to know if there has been an ecological survey which has taken into account the many badger setts which must be in the area. If there has been such a survey, I would like a copy. Disturbing setts without permission from Natural England is illegal and if work went ahead without knowing where the setts are, it could lead to the death of many badgers.

Objection to Planning application from Crown Estates to Destroy Green Belt East of Luton

We wish to register our objections to this Planning Application for housing to built on Green Belt land East of Luton on the following grounds

1 Absence of special circumstances that warrant the erosion of the Green Belt. The national Planning Policy clearly states that unmet needs are unlikely to outweigh the harm to the green belt. This seems to be being ignored by NHDC. In this case the unmet need could be met in many other brown site locations that are within the Luton Boundary. This could also be assisted if the local council were to look at the boroughs own needs before assisting other boroughs with their housing. Thereby not relying on NHDC who clearly from their own local plan do not require this addition.

2 The removal of the Green Belt leaves this land unprotected and open to further planning applications from developers.

3 Inevitable change to the character of Cockernhoe village in effect urban sprawl, The proposal is completely out of proportion 2100 homes is 14% of the total allocation of houses in the NHDC Local Plan, a 1,025% increase on the 205 houses in the hamlets, placing these, and houses in Wigmore bordering the development in to the middle of an estate.

4 Increase in congestion, and potential on-street parking in the area. The proposed road network is ill conceived and would mean many years of congestion causing even more issues trying to get through traffic for working times. Pure observations tell that these roads are already more than overused.

5 Potential for increase in accidents, due to extra traffic and additional decades of building and infrastructure needs.


6 Proposals are in direct conflict with Luton Borough Councils Local Plan objectives from both an environmental and infrastructure point of view

7 The proposed development gives rise to further difficulties with regard to off site parking for airport traffic, already making use of all surrounding roads.

8 Increase in environmental pollution in the form of noise, light, dust, ground and groundwater issues as more land is concreted over.


9 Impact on the local population with the likely increase that the site and surrounding area will become a magnet for petty crime due to the density of housing and total lack of amenities, i.e. library closure community centre planned closure Doctors already over subscribed to name but a few.

Further detailed reasoning for our objections is included in correspondence submitted to the Council prior to this objection.

I have tried to navigate your online form unsuccessfully.

Please take my objection into account.
I do not believe we should lose our green belt under these circumstances. Green belt is green belt for a reason.

I also do not believe that the forecasted quantity of housing is correct. If this is being thrust upon us from government and is wrong (North /South divide not being addressed - overflowing SE and deserted N) then it is incumbent on NHDC to stand up for local needs only, not absorb the problems of failed national policy.

I am unwell so unable to fully articulate all the reasons I am against this but please register that I passionately oppose construction of housing on all greenfield sites, and in particular Sp14 and 15.

The thing I love about Letchworth, and the reason I chose to return here to live, is its character and distinct town limits - i.e. NOT merging with anywhere else. I have previously lived in endless suburbia and it was depressing.

Please do the right thing NHDC and protect our wildlife, for it is priceless and irreplaceable.

I strongly object to this proposed residential development for the following reasons:
* This proposal would destroy a large amount of North Hertfordshire's Green Belt land, including large swathes of prime countryside which is designated of special significant landscape value. Government policy on Green Belt land is completely ignored in this proposal. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open.
* In March and October 2014, the Government updated its online Planning Practice guidance on the policies in the NPPF. This makes it very clear that unmet housing need in a particular area is unlikely to meet the "very special circumstances" test to justify Green Belt development. It also confirms that local authorities have the ability to "safeguard their local area against urban sprawl and protect the green lungs around towns and cities". The government said that it wanted to make planning policy clear that housing need does not justify the harm done to the Green Belt by inappropriate development. This development does not meet the "very special circumstances" test and would seriously harm the Green Belt.
* North Hertfordshire District Council seem intent on allowing their land to be used for building a large number of houses for Luton's alleged unmet housing need, but there is evidence available which clearly indicates that they are not required. .
* If this development went ahead, the ancient villages of Mangrove Green and Cockernhoe would be swamped and lose their individual identity and destruction of local community values
* There will be a devastating impact on wildlife in the area.
Green spaces are essential to the health and well-being of the population but this proposal would mean that access to the countryside for relaxation, recreation and tranquillity will be severely reduced. Many miles of country footpaths enjoyed by many and not least including Luton residents will be concreted over. Plans for green areas within the development will not compensate for this huge loss of green spaces.
* The road infrastructure in the area is already unable to cope with current levels of traffic. Roads into Luton, Luton airport and those which access the M1 are gridlocked at certain times of the day at present. This will be further exacerbated if this development went ahead.
* There are already long tailbacks of vehicles at both the Luton and Hitchin ends of the A505 with frustrated drivers taking to inadequate country lanes to try and avoid the worst bottlenecks. This continues through this part of Luton and towards the motorway. Further development will significantly exaggerate this, increasing danger to pedestrians and the many local school children who walk to school.
* Many local roads in the vicinity of the proposed site are narrow country lanes with single track stretches and they too will be unable to cope with increased traffic, particularly public transport vehicles and large delivery vans and lorries which will be required to serve the development.
* The proposals on transport infrastructure in the application do not do enough to assure us that they will mitigate or improve the problems outlined here. Further independent assessment and research should be undertaken before outline planning permission is granted.
* Local schools at Cockernhoe and Wigmore are already oversubscribed. The application does not indicate where the additional children will be educated.
* Emergency services will struggle to access and serve the community.
* There are no realistic plans for increased provision of essential services such as GP surgeries, hospitals, emergency services, police and adequate public transport. The number of dwellings in this proposal means that all these services will require more resources.
* This proposal is for 660 dwellings. This is an overwhelming number for such a small area. A development of this size in such close proximity to an expanding airport with its associated noise and pollution will not provide a good, healthy lifestyle for the residents.
Ancient bluebell woods will be completely over-run and risk destruction by additional residents new to the development.
I walk and bike in this area with my family, to keep fit and see the wildlife.
Do not let it be destroyed.
I sincerely hopes that these objections will ensure that this application is rejected

I am writing to put forward my strong views against the development of houses in the "green belt" area of Hertfordshire, these are obviously to meets luton's housing needs.
The fact that the plan is to build in a green area is preposterous, especially when you take into consideration that there are perfectly good areas of "Brown field sites" that would easily meet Luton's housing needs.
The fact that the developers plan to build on a "green belt" instead of a "brown field area" shows that the issue is largely a matter of greed- building on new land to save costs of redevelopment on old land- which frankly in this day and age is disgusting- sustainability is very in important and developers should be making it their priority to redevelop and reuse areas instead of destroying countryside. I think that the developers should be putting aside proportionally small profit losses and looking to make of areas new instead of ruining countryside that once it has been built in will never return to its original state.

I would like to object to the local plan, specifically the excessive housing target, lack of associated infrastructure that a local plan of this size requires, and further rolling back of the Green Belt (or land swaps) around the A1M towns of Stevenage, Hitchin, Baldock and Letchworth.

Instead I would support that NHDC and Stevenage Borough Council deliver a sensitively designed new Garden city, to support additional and justified housing need in the area, local employment can be generated and where the local infrastructure is adequately considered and delivered.

See attachment

See attachment

Policy Sp1 - Sustainable Development in North Herts Building 300 plus houses onto a village of 340 properties is not meeting in a sustainable way the needs of the residents of Wymondley. It brings with it issues of coalescence.
There does not appear to be in place any infrastructure, support plans or funding which would be needed to support a development of this scale.
The council has produced no evidence of exceptional circumstance to build on the Green Belt. They have unused Brownfield sites and non- Greenbelt sites available.
A development of this scale with hard surface run-off, particularly from roadways, will increase the flood risk in Little Wymondley which has a recent history of significant flooding.

Policy Sp 5 - Countryside and Green Belt This supports the principles of the Green Belt. The council has not, we believe, demonstrated or justified removing land from the Green Belt to make it available for building.

Policy Sp 6 - Sustainable Transport
The local area is already prone to gridlock on a daily basis in the rush hour and any minor delay can be the trigger.
The junction in Great Wymondley is identified by the council themselves as a particular problem. It already it has extremely high levels of 'rat running' as the Neighbourhood Plan traffic data confirms.
The local country lanes cannot simply be widened as this would destroy the rural nature of the parish.
The situation is made worse by the inability of the A1M to cope with the volume of traffic, forcing motorists to use alternative routes through the villages.

Policy Sp 8 - Housing
A 100% increase in the size of Little Wymondley housing stock is disproportionate to local needs as confirmed by the Neighbourhood Plan.
Hitchin on the other hand is just being asked to have a 10% increase!

Policy Sp 10 - Healthy Communities
Removing existing Green Belt land seems to be at odds with the policy statement to protect, enhance and create new physical green infrastructure to foster healthy lifestyles.
The levels of airborne pollution on the A602 already regularly exceeds the legal limits at the Air Quality Monitoring Point and is already one of the worst in the county. Additional traffic can only make the situation for the residents.

Policy Sp 11 - Natural Resources and Sustainability There is no budget to address the issue of the collapsed culvert in Stevenage Road which contributes significantly to flooding risk.
The drain clearing programme is ineffective and also adds to the flooding problem.
The SuDs regulation would not cover all aspects of a potential large scale development and hard surface run off would again contribute to potential flooding. The EA flood maps also shows the potential for water run off from the south of Stevenage Road.

Site WY1

The surface water movement through Little Wymondley is a major issue and there is currently no structural plan or adequate financial commitment to address this issue satisfactorily .
Currently surface water runoff from agricultural land to the north of the village and downstream water from Corey's Mill is sufficient to create flooding of properties in Stevenage Road Little Wymondley as has happened historically.
There is not just the problem of surface water runoff from the possible additional building in Little Wymondley but the construction of hundreds of houses in the upstream catchment area on the eastern side of the A1M with its associated runoff.
Additionally plans by Stevenage Borough Council to build an industrial complex directly on the flood plain at Corey's Mill will make the situation even worse.
Downstream at Nine Springs at the bottom of the Wymondley Road a greater flow of water will create a significant additional flood risk to properties bordering the stream culvert.
A practical and funded solution must be found for these problems before any commitment to further building is given the go ahead.

In Conclusion:-
The Wymondley Neighbourhood Plan states the residents' acceptance for housing need but that it must be on a manageable scale.
The Plan also clearly states opposition to building on Green Belt land which provides space between the area's villages and towns thus preventing urban sprawl eliminating the rural nature of a North Hertfordshire.
Clearly the traffic and flooding issues of the area need to be resolved before consideration is given to any substantial house building.
A retrospective approach with the traffic gridlocked and flooded properties in the area is not the way forward.

See attachment

The following representations are made with respect to the North Hertfordshire Proposed Submission Local Plan (the "Local Plan").

POSITIVELY PREPARED

1. The Local Plan has not been positively prepared in the context of Knebworth (paragraphs 13.183-13.202 of the Local Plan).

2. Knebworth is a village of some 4,500 inhabitants and contains approximately 2,000 dwellings. The Local Plan proposes to build another 663 homes in Knebworth, increasing the number of dwellings by a third. This is an unrealistic aim if proper account is taken of the logistical and environmental constraints to which the parish is subject.

3. The NHDC Infrastructure Delivery Plan of September 2016 sets out the current state of the village:

- Knebworth's railway station had patronage of approximately 600,000 travelers in 2014/15, a 71 per cent. increase on the figure ten years earlier. Commuting from the station is getting increasingly crowded, a problem which will be exacerbated if the proposed revisions to the rail network are implemented in 2018, leading to a reduction in the number of fast trains during the rush hour period
- Knebworth is classified as having very limited capacity for school provision, and has no ability to cope with housing growth
- Knebworth Medical Practice takes on 33 patients per square metre, and is over accommodated by 5,000 patients
- Knebworth Library is small (234 square metres) and requires additional stock, shelving and IT
- Thames Water is of the view that further consideration is needed of Knebworth's sewerage capacity, and that issues with the foul sewer system need reviewing as the village does not have a dedicated surface water system

4. To that I would add the following observations:

- The village's road network is limited both in terms of extent and with regard to the quality and capacity of the thoroughfares themselves
- The lack of adequate parking facilities in the village is a significant cause of congestion, and a source of frustration for local residents. The High Street (B197) is a constant pinch point for traffic, leading to significant tailbacks and traffic jams at peak travel times, with vehicles often unable to travel in opposite directions along the High Street at the same time due to the number of parked cars
- The High Street contains a modest number of enterprises and shops, albeit of some variety. As an illustration of the limited nature of local commercial activity, there is only one eat-in restaurant open in the village in the evenings.
- The village has two Conservation Areas (Deards End and Stockens Green) which would be negatively impacted (in terms of noise, pollution, traffic, outlook etc.) by the nearby construction of hundreds of new dwellings
- The land at Deards End Lane on the west side of the village, a Green Belt site on which development is proposed, is proximate to Knebworth Woods SSSI
- The Local Plan also envisages the creation of 150 new homes in the neighbouring settlement of Woolmer Green. The additional impact of these new homes upon Knebworth has not been considered at all in the Plan.

5. It is clear from the above that there are a number of constraints militating against any meaningful expansion of housing in the village. With regard to the Local Plan's potential impact upon Knebworth, it is particularly difficult to justify a proposed increase in housing of such a magnitude when land is reserved at Stevenage West for some 3,100 homes.

6. However, an examination of the Local Plan reveals a failure on the part of NHDC to take any of the above into account in a meaningful way. The NPPF lists three dimensions to sustainable development, none of which are addressed by the proposals for Knebworth:
An economic role - the Plan fails to meet the requirement of "identifying and coordinating development requirements, including the provision of infrastructure". No explanation is given as to how the roads around the parish could reasonably be expected to cope with the significant increase in traffic which the proposed development would bring (when it is clear to any local resident that this would be hugely problematic); no explanation is given as to whether and how public services such as medical facilities, library, pharmacies would be improved and extended; no ideas are put forward to address the impact on local parking facilities, particularly around the railway station.

A social role - implementation of the Local Plan in Knebworth could not conceivably be regarded as "creating a high quality built environment, with accessible local services that reflect the community's needs and support its health, social and cultural well-being". The proposals amount to nothing more than the unceremonious dumping of over 600 new homes and a primary school on the borders of a village which is already struggling with its existing infrastructure. The idea that this should be done through the removal of land from the Green Belt surrounding the village (as to which see further below) merely adds insult to injury.

An environmental role - the Plan could in no way be regarded as "contributing to, protecting and enhancing our natural, built and historic environment". It would involve the elimination of large quantities of the Green Belt surrounding the village; the building of hundreds of houses on a site adjacent to a Site of Special Scientific Interest and to a Conservation Area; a likely negative impact on local wildlife sites; and the construction of dwellings bordering on the A1(M) with its concomitant pollution and noise.

7. In the context of Site KB1 (land at Deards End Lane), I would in particular draw attention to the complete absence of suitable road networking to support housing development on this land. Occupants of this site travelling through the village either to Stevenage or the A1 would need to travel down Park Lane, under the railway bridge which struggles to accommodate two cars travelling in opposite directions, and on to the High Street, which already suffers significantly from congestion; or travel via Deards End Lane itself, which is a narrow unlit lane with no road markings and no street lighting, is too narrow in three or four places to allow cars to pass one another, and has at one end a Scheduled Ancient Monument in the form of a railway bridge. The failure of the Plan to address this fundamental problem, and indeed the problem of traffic around Knebworth more generally, at a preliminary stage is both bewildering and damning.

JUSTIFIED
Housing Requirement
1. The methodology employed in calculating the Housing Requirement for North Hertfordshire is fundamentally flawed (paragraph 4.86 of the Plan).

2. The Stevenage and North Hertfordshire SHMA Update 2015, jointly commissioned by North Hertfordshire District Council and Stevenage Borough Council, sets out in Chapter 2 the basis upon which the Objectively Assessed Need ("OAN") should be established; and it is from the OAN that the Housing Requirement is eventually derived. As the SHMA Update noted, paragraph 15 of the Planning Practice Guidance published in March 2014 places emphasis on the role of CLG Household Projections as the appropriate starting point in determining the OAN.

3. The 2012-2037 Household Projections produced by CLG, published on 27 February 2015, represent the most up-to-date estimate of future growth. These projections suggest that household numbers across Stevenage and North Hertfordshire will increase by 21,280 over the 20-year period 2011-31, an average of 1,064 per year. The SHMA Update of 2015, however, took the view that growth of 19,213 households over the period, equating to an average figure of 960 households per year, was a more appropriate figure based on 10-year migration trends. That figure of 19,213 households was then adjusted to take into account vacancy and second home rates (i.e. dwellings rather than households), suppressed household formation rates and market signals - see Figure 40 in paragraph 3.88 of the SHMA Update 2015. This resulted in a Full Objectively Assessed Need for Housing for the period 2011-31 of 21,685 dwellings.

4. A further update report, published in August 2016, adjusted the Full Objectively Assessed Need for Housing for the period 2011-31 down to 21,400 dwellings on the basis of more recent migration trends. This figure comprised 13,800 dwellings for North Hertfordshire and 7,600 dwellings for Stevenage.

5. There remains flexibility to allow the CLG Household Projections to be applied in the most rational and sensible fashion when calculating the OAN. Paragraph 017 of the "Housing and economic development needs assessments" section of the Planning Practice Guidance which sits alongside the National Planning Policy Framework states that:

"The household projections produced by the Department for Communities and Local Government are statistically robust and are based on nationally consistent assumptions. However, plan makers may consider sensitivity testing, specific to their local circumstances, based on alternative assumptions in relation to the underlying demographic projections and household formation rates. Account should also be taken of the most recent demographic evidence including the latest Office of National Statistics population estimates.
Any local changes would need to be clearly explained and justified on the basis of established sources of robust evidence.
Issues will vary across areas but might include:
* migration levels that may be affected by changes in employment growth or a one off event such as a large employer moving in or out of an area or a large housing development such as an urban extension in the last five years...." (emphasis added)


6. In the case of North Hertfordshire, migration rates over the past fifteen years have been impacted significantly by the Great Ashby development on the outskirts of Stevenage. Over 1,600 dwellings were delivered pursuant to this development between 2001 and 2011 in response to the housing requirements of Stevenage, of which Great Ashby forms part, although a majority of those dwellings actually fall within North Hertfordshire.

7. The significance of Great Ashby was acknowledged in the original North Hertfordshire SHMA from 2013 - paragraph 55 of that report noted that:

"An issue for North Hertfordshire is that over the past 11 years over 1,600 dwellings have been delivered in Great Ashby on the outskirts of Stevenage, or an average of 150 per annum. It can be argued that these dwellings are artificially boosting the number of in-migrants to North Hertfordshire, while fulfilling the role of meeting the needs of Stevenage."

8. The report seeks to make adjustments for long-term migration trends precisely over the period in which the Great Ashby development took place. If Great Ashby is relevant to in-migration levels, in that it artificially boosted them over the relevant timeframe, it will obviously need to be taken into account. The report goes on to show the effect upon the migration-led figures if the Great Ashby effect is removed from the equation - 150 homes per annum for 20 years means 3,000 fewer households. Given that the Full Objectively Assessed Need for Housing for North Hertfordshire for the period 2011-31 stands at 13,800 dwellings, an adjustment of this magnitude would be significant.

9. However, the flexibility granted under the Planning Practice Guidance to make allowance for the development at Great Ashby was not utilised, and the OAN was not adjusted to take account of Great Ashby and its effect upon in-migration figures. The original North Hertfordshire SHMA of 2013 dismissed the need to make an adjustment on the basis that "the number of migrants moving to or from North Hertfordshire is not closely linked to dwelling delivery in the whole of North Hertfordshire or in Great Ashby" (see paragraph 56 of that report). In support of this assertion, the report referred to Figure 8 (on page 15 of the report) which illustrated property sales in North Hertfordshire (including Great Ashby) compared with gross migration trends. The report concluded that Figure 8 displayed no meaningful correlation between in-migration and dwelling delivery rates (and, by implication, no justification for an adjustment under paragraph 17 of the Planning Practice Guidance) on the basis that "since 2008 it is noticeable that the number of in-migrants has not dropped in line with the drop in the number of sales of dwellings or completions since 2007."

10. An examination of Figure 8 shows this conclusion to be erroneous to a very significant degree. Firstly, there is a clear and direct correlation over the life of the graph between in-migration and both total property sales and total property completions, with each of the variables rising and falling in time with one another. Secondly, even if analysis is confined purely to Great Ashby completions versus in-migration, that correlation is still substantially there, with only one exception - an uptick in in-migrants in 2009-10 when Great Ashby completions decreased. However, for no obvious reason the report has taken that one exception as the justification for its conclusion that no correlation can be discerned.

11. Extrapolation of the historical in-migration data without adjustment for the obvious effect which Great Ashby has upon the figures will inevitably lead to a distorted conclusion. For what it is worth, I would note that the most recent ONS migration figures for North Hertfordshire (for the 12 month period to mid-2015) show net in-migration to the area of 425 persons; this compares with an average of 768 persons per annum over the previous ten year period.

12. The lack of meaningful and rational analysis in this section of the SHMA is underscored by the inclusion of completely conjectural statements ("If the dwellings in Great Ashby had not been completed, migrants who have been moving to Great Ashby may have moved to other areas of North Hertfordshire") and assertions which fly in the face of the empirical evidence presented in the report itself ("...a reduction in provision will...see more out-migration from North Herts.").

13. The failure of the original SHMA to take account of the Great Ashby development, a mistake which has fed through into the eventual OAN figure, is a fundamental error with a profound impact upon the eventual 'Policy On' Housing Requirement figure. More broadly, the clear lack of analytical discipline employed in considering the relationship between housing provision and in-migration suggests that any conclusions drawn are largely spurious. In the absence of a reliable and realistic Housing Requirement figure, the validity and credibility of the Local Plan is wholly undermined.

CONSISTENT WITH NATIONAL POLICY
Green Belt
1. The proposal under the Local Plan to remove land from the Green Belt, both from sites around Knebworth and more generally in North Hertfordshire, is not consistent with national policy as set out in the National Planning Policy Framework (NPPF) (paragraph 4.53 of the Plan).

2. Under the terms of the NPPF, "Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan." The notion of "exceptional circumstances" unavoidably involves an element of subjectivity, with the Department of Communities and Local Government content to entrust decision-makers with the obligation of reaching sound planning judgements on whether exceptionality exists in the circumstances of an individual case.

3. As a starting point, I would therefore draw attention to NHDC's purported approach to the question of Green Belt development. This is set out in Agenda Item No.6 of the Cabinet Meeting of 24 November 2014, being a Report of the Strategic Director of Planning, Housing and Enterprise. Paragraph 8.7 of that Report states that:

"In essence, the ability to use Green Belt to reduce housing targets requires exceedingly robust evidence (through some form of Green Belt review study) which shows that every part of a district's Green Belt is so essential to the purposes of a Green Belt that none of it can be released. Even if that level of evidence were to be established, the district would still have to consider the sustainability implications of a strategy which deflected their growth elsewhere."

4. This statement illustrates the fact that NHDC has its approach to Green Belt completely back to front. As noted above, the presumption enshrined in the NPPF is that Green Belt boundaries should only be altered in exceptional circumstances. By contrast NHDC is advocating a policy of resisting any reduction to housing target numbers unless it can be proved that every part of the Green Belt is indispensable; and even in the latter case it suggests that that might not be enough if wholesale preservation of the Green Belt would have a knock-on effect for sustainability elsewhere.

5. Paragraph 8.8 of the Report goes on to say that:
"The Green Belt Review finds that there are parts of land which, whilst they contribute to the overall Green Belt, are not essential for the fundamental purpose of the Green Belt of preventing towns from merging. Coupled with the Sustainability Appraisal's finding that it is better to meet needs in such a way that the main population centers of the district are able to take growth, the plan proposes amending Green Belt boundaries accordingly."
6. Again, this reasoning is not in line with the requirements of the NPPF. Amendment of the Green Belt boundaries cannot be justified purely on the basis that parts of the Belt are not essential in preventing the merger of conurbations; if nothing else, paragraph 80 of the NPPF sets out four other basic purposes which the Green Belt serves. Equally, it is not enough simply to say that it would be "better" if the main population centers were able to take growth. Neither of these reasons is in itself sufficient to establish that exceptional circumstances exist.

7. This, then, goes to the nub of the Report's deficiency. At no point are any exceptional circumstances put forward in the Report to justify the Green Belt Review. Indeed the phrase "exceptional circumstances" is not employed at any point in the Report.

8. Some analysis of the existence (or otherwise) of exceptional circumstances was eventually undertaken in NHDC's Housing and Green Belt background paper of 2016 - but given that this paper was produced nearly two years after the recommendation by the Strategic Director (reaffirmed in the Draft Local Plan of 2014) that the Green Belt boundaries be amended, it is difficult to avoid inferring that the background paper was produced in an attempt to back up the unjustified conclusion of the Strategic Director's Report rather than to undertake an objective assessment of whether exceptional circumstances exist.

9. Even if the Housing and Green Belt background paper of 2016 were to be taken in good faith, it provides nothing in the way of specific evidence to support the proposition that exceptional circumstances exist. The paper confines itself to broad generic observations that the objectively assessed needs of the District are considerable; that there are limits to the availability of land suitable for sustainable development; and that the social and economic roles of sustainable development might not be achieved without resort to Green Belt land. None of these reasons is obviously exceptional - indeed the fact that both NHDC and neighbouring authorities are seeking to revise the Green Belt to such a significant extent and in such a blanket fashion strongly suggests that there is nothing remotely "exceptional" about the exercise at all.

10. The Conclusions section of the Housing and Green Belt background paper of 2016 again highlights the back-to-front approach which NHDC has adopted in its thinking. Paragraph 4.90 states that:

"It is clear from both the SHLAA and this analysis that a number of potential development sites in North Hertfordshire are constrained by policy, heritage, ecological or other considerations. It is equally plain that, if the Council were to impose blanket restrictions upon development on any (combination) of the grounds above it would face severe challenges in meeting the identified needs for housing and, albeit to a lesser extent, employment."

It is not for the Council to decide whether to impose "blanket restrictions" upon development on any of the grounds mentioned above. Those blanket restrictions have already been imposed by the NPPF; it is for the Council to determine whether exceptional circumstances exist which allow for those restrictions to be pared back at all.

Equally, paragraph 4.94 of the paper goes on to say:

"Given the number of sites affected, it is similarly considered that any blanket policy of restraint on the grounds of agricultural land quality, surface water flood risk and / or heritage would be likely to impinge on the achievement of sustainable development for the same reasons."

Again, there is already a policy of restraint on these grounds as set out in the NPPF. It is for the Council to explain why it believes that the particular circumstances merit a deviation from that policy.

11. Ultimately there appears to be an unwillingness on the part of NHDC to acknowledge (or an inability to appreciate) that the NPPF does not always allow development to proceed in full, and that the presumption is that the Green Belt should not be touched in normal circumstances. The Housing and Green Belt background paper sets much store by the judgment in the Calverton Parish Council case of last year in seeking to explain its decision-making process. The Council might have done well to pay heed to Jay J.'s observation in that case:

"Review of the Green Belt in the face of sustainable development requires exceptional circumstances. Refraining from carrying out sustainable development, and thereby causing social and economic damage by omission, does not."

12. In summary, then, a reading of the various reports produced by NHDC leads to the conclusion that a decision was made to amend the Green Belt boundaries without any exceptional circumstances being identified; and that a subsequent report intended to provide some ex post facto justification for that decision failed to offer anything other than the most generic and non-specific reasons for the re-classifying of numerous sites.

13. Turning to the specific proposal to remove land at Deards End, Knebworth (Site 52 - Preferred Options KB1) from the Green Belt, I would simply note that the North Hertfordshire Green Belt Review 2016 classified the site as making a significant contribution to Green Belt purposes. In such circumstances NHDC would be expected to provide some compelling reasons for the land to nevertheless have been removed. In the event the only site-specific explanation is contained in a site selection matrix forming an appendix to the Housing and Settlement Hierarchy Paper 2014:
"Ability to make contribution to overall housing requirements and provide infrastructure with potential wider community benefits. Site-specific criteria and proposed dwelling estimate allow for appropriate mitigation of potential impacts and address a number of issues raised through the consultation. On balance, positive opportunities afforded by this site are considered to outweigh harms."
This wording is, if anything, more reminiscent of the test under the first limb of paragraph 14 of the NPPF ("any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole...."), than of the test of what might constitute exceptional circumstances. It is in any event difficult to conclude that the NPPF's concession to exceptional circumstances is intended to be applied in this particular instance - if that were the case, the protection afforded by the NPPF to the Green Belt would be little or non-existent.

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