Policy SP5: Countryside and Green Belt

Showing comments and forms 91 to 120 of 120

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5517

Received: 30/11/2016

Respondent: Home Builders Federation Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Rural Area policy excessively restrictive, impact upon housing delivery

Full text:

See attachment

Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5563

Received: 30/11/2016

Respondent: Mrs Brenda Parker

Representation Summary:

Support SP5:
- I support definition of settlement boundaries for villages, including Cockernhoe

Full text:

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

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

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5572

Received: 30/11/2016

Respondent: Picture srl

Agent: Keymer Cavendish Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Further land beyond GA2 might be released to long-term defensible boundary at Warrens Green Lane, contrary to NPPF requirement to look beyond plan period

Full text:

See attached

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5651

Received: 21/11/2016

Respondent: Homes England (Herts Team)

Representation Summary:

Support for SP5:
- consideration should be given for the provision of safeguarded land North and North East of Stevenage in accordance with NPPF para. 85

Full text:

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Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5755

Received: 29/11/2016

Respondent: Mr Roy Parker

Representation Summary:

Support SP5:
- (iii) I support the definition of settlement boundaries for villages, including Cockernhoe, in SP2, see 4.9 above that were previously "washed over" by the Green Belt

Full text:

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

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

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

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5839

Received: 28/11/2016

Respondent: Save Rural Baldock Group

Number of people: 3

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Objection to SP5 in relation to Baldock and BA1
-much of the Green Belt around Baldock is Prime agricultural land(grade 2)
-justification of the removal of the BA1 site from Greenbelt is that it will be able to be developed in the first five years. WYG Appraisal assumes only the first 100 houses will be developed until funding for road and railway are found from developing other sites
-plan cannot be justified as the most appropriate strategy,when considered against the reasonable alternatives
-not consistent with national policy-Green Belt

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5860

Received: 30/11/2016

Respondent: Mrs Linda Brookes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Exceptional circumstances have not been properly demonstrated
- Reduce extent of Green Belt land release, particularly around villages, to reflect Green Belt constraints as required by the NPPF

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5924

Received: 24/11/2016

Respondent: Hitchin Town Action Group (HTAG)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Support SP5:
-regretfully accepted that some readjustment of Green Belt is unavoidable if housing requirements to be met.
-broadly support analytical approach used

Object SP5:
-urgent steps should be taken to identify sites for one or more substantial new settlements through DtC with neighbouring authorities-to avoid future erosion of Green Belt
-Proposals Map:land west of the A1(M)at Stevenage-no exceptional circumstances demonstrated,no reasonable prospect of being required for housing development until well after currency of proposed Local Plan-release premature,should be deferred.

-no cross reference with Section8 Housing Strategy

HT1,HT2,HT3,HT5 andHT6:crucial importance of mitigation measures - Green Belt

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5934

Received: 06/11/2016

Respondent: Mr Paul Trotman

Number of people: 2

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Review does not meet requirements of NPPF, is not consistent with case law (Gallagher) and contrary to findings of Council's own Green Belt Reviews in relation to sites at Knebworth.

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5946

Received: 23/11/2016

Respondent: Mr Reg F Norgan

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: No exceptional circumstances as set out in Calverton PC v Greater Nottingham Councils

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5957

Received: 24/11/2016

Respondent: Ms Sarah Lovie

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Additional area of Green Belt sterilizing land for development.

Full text:

The destruction of the green belt goes against national policy. Brownfield plots should be utilised for the unmet housing needs rather than breaking greenbelt and destroying rural communities. Attempting to offset by making the land between Cockernhoe and Hitchin green belt is preventing further development there, for example a new garden city, which go much further in meeting future housing requirements. The tenets of the NPPF do not seem to have been followed in either the proposal to destroy existing Green Belt or the proposal to create new Green Belt (e.g. consideration of the consequences the proposed new Green Belt would have on sustainable development).
I've also been informed a Luton councillor also objected to the proposal stating that it does not meet their housing requirements as any housing development would be on the wrong side of town.
Insufficient traffic infrastructure. Queues along Crawley Green have already notably increased in recent months (presumably as a result of ongoing works at the airport) to the point now leave additional time to get to the station on time. Airport queues having been backing up to the M1. Surveys not being carried out correctly, the current housing proposal for this land is based on a road that doesn't exist and hasn't been proposed while assumptions are being made on 1 car per household. The expansion of the airport and the additional traffic this will bring has not seemingly been taken into consideration either.
Public services are already overstretched. School children are being bused to Hitchin due to a lack of school places in Wigmore, policing is already inadequate as typically come from Hitchin rather than Luton due to council boundary. (Took over an hour for police to arrive to a call out witnessed). With just Asda nearby there are insufficient supermarket facilities to meet needs of new development. Queues back up traffic to the roundabouts, to enter the supermarket and buy fuel (blocking Wigmore lane) while queues at check-out take 20+ mins.
Our neighbour has recently been informed they will be required to install a water meter due to Cockernhoe being in a deprived water area, yet it can seemingly support another 660 (potentially 2,100) houses. Surely this will massively increase the risk of drought and water restrictions in the area.
All visitors comment on the area, the countryside and the wildlife. A walk with friends visiting the area for the first time were amazed by the wildlife, rabbits, pheasant, birds of prey and the 'largest herd of deer they'd seen outside of Richmond park'. All of this seen within an hour. Have even seen owls during the day while walking to the pub.
One of the nicest things about Cockernhoe and surrounding area is the village life and social aspects of the community. The pub and memorial hall run many social occasions and everyone has been very welcoming since moving into the village, with this community life now under threat if the number of houses rises by over 1,000%. The current Green belt is very effectively serving its purposes to maintain the character of Cockernhoe village (check restricted sprawl / prevent merging with neighbouring town / safeguarding the countryside from encroachment)
The single access road already gets cars waiting to pass, the country lanes are not suitable for so many more cars (there would be many more than 1 per house - conservatively from government statistics about 1.3 cars per household could be expected but from local experience in Cockernhoe it is over 2 cars per household)). The additional traffic would be a threat to the walkers and cyclists in the area, both activities we do regularly (this would affect both local cyclists and also those following the Chiltern Way). There are also horses and tractors regularly in the area.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5963

Received: 30/11/2016

Respondent: Mr George Walsh Waring

Agent: Turley

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Identification of additional Green Belt, justification for Green Belt review, revised boundaries not defensible or permanent, exceptional circumstances not adequately demonstrated

Full text:

See attached

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5973

Received: 29/11/2016

Respondent: F and P Property Management

Agent: Rapleys LLP

Representation Summary:

Support SP5: Support approach to rural areas beyond Green Belt in principle

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6004

Received: 29/11/2016

Respondent: Hertfordshire County Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Many schools located within the Green Belt. This could restrict expansion of infrastructure required to meet the needs of proposed development.

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6025

Received: 29/11/2016

Respondent: Mr & Ms Andy & Lisa Darley and Hutchins

Number of people: 2

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Destroying productive farmland, including but not restricted to Green Belt land
- Impact on rural economies
- Loss of Green Belt
- Contrary to the NPPF

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6076

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Fundamental misinterpretation outlined in para 4.53 and the Green Belt Review of National policy in NPPF para 83-86. Para 83 requires exceptional circumstances to be shown to justify removal of land from GB by the redrawing of any individual GB boundary. None of the 3 categories of site liseted in SP5 paragraph (a) satisfy this national policy requirement. This applies to strategic allocations and development around towns and villages in the GB.
Furthermore the Council has used para 86 as the basis for removal of villages from the GB, as if the GReen Belt boundaries are being defined for the first time, whereas all of these villages are already washed over by permanent GB. As the plan accepts in several parts of the plan, eg "current Green Belt boundaries have been in place for 20 years". Any change needs to be justified by exceptional circumstances, which the plan makes to attempt to demonstrate.

Para 4.53 - Final sentence of 4.53 of the plan fails to meet the requirement of NPPF para 83 to set out exceptional circumstances for changing established GB boundaries. Not set out in Plan or Evidence. para does not refer to Housing and GB Background paper, and whilst this claims that exceptional circumstances exist the statement that assessed housing need is both acute and intense is patently incorrect. incorrect justification - proposals in plan unsound.

Para 4.60 - Para sets out boundaries defined following approach set out in para 85 and 86 of NPPF. Flawed interpretation as redrawing permanent GB boundaries should only take place in defined exceptional circumstances, not just because a local plan is being prepared.

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6084

Received: 28/11/2016

Respondent: Mrs Linda Green

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP5:
- Green Belt Review; did not take into consideration the views of the community
- Loss of access to Open Space and Country side
- Risk of coalescence with Stevenage

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6110

Received: 21/11/2016

Respondent: Rumball Sedgwick

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Green Belt type-controls imposed in non Green Belt areas, presumption against development

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6139

Received: 28/11/2016

Respondent: Mr and Mrs Peter and Sandra Barrow and others

Number of people: 48

Agent: Maze Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Compensatory Green Belt substantial distance away from Green Belt to be released

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6220

Received: 30/11/2016

Respondent: Mrs Cheryl Peers

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Green Belt review destroys permanence, exceptional circumstances not demonstrated, Calverton judgement flawed and not permissible

Full text:

TO THE LOCAL PLAN 2011-2031 BY NORTH HERTFORDSHIRE DISTRICT COUNCIL (NHDC)

(I want to change the Local Plan and I wish to participate at the oral examination)

1. I JUDGE THIS PLAN TO BE UNSOUND

The plan is unsound for the following reasons:

1) The Plan is not Positively Prepared
2) The Plan is not Justified
3) The Plan is not Effective
4) The Plan is not consistent with National Policy

NOT POSITIVELY PREPARED

Plan Policy SP8

Para 158 of the National Planning Policy Framework (NPPF)

1.00 Reliance upon figures, estimates or instructions obtained from the Dept. of Communities and Local Government (CLG) or the Office of National Statistics (ONS) does not remove the obligation of the Local Plan from complying with Para 158 when assessing housing need. The NPPF gives the guidance that the CLG Projections are the appropriate starting point in determining objectively assessed need but the CLG projections are only appropriate when they are in accordance with Para 158.

1.01 It should be noted that Para 158 refers to the economic, social and environmental characteristics and prospects of the area of the local planning authority except for that allowed by Para 182.

1.02 There is considerable reason to doubt the adequacy, up to date-ness and relevancy of the CLG household Projections and whether they provide a full account of relevant and economic signals as required by para 158.

1.03 The CLG household projections call for an increase of 15000 houses for North Herts between 2011 and 2031. This is an annual rate of increase of 1.39 %. These figures are employed as the basis for the Objectively Assessed Housing Need for the Local Plan.

1.04 The CLG household projections are, according to the CLG, based upon the 2014 ONS sub-national population projections for the East of England. These figures are calculated for the period 2014-2024. The population increase over this period is given as 8.9% or 0.89% per annum. Thus the CLG, in their household projections, give a rate of population increase 56% larger than the ONS figures. There is not the adequacy, up to date-ness or relevancy (as required by para 158) in the CLG figures to explain why they ae that much larger than the ONS figures.

1.05 Should some of this 56% increase in households by the CLG figures be to satisfy the unmet housing requirement of a non-neighbouring area, such as London, then in that case the Plan contravenes para 182 of the NPPF which states:- The Plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so.......

1.06 The ONS 2014-2024 sub-national population figures for the East of England do not themselves take into account the effect of an imminent Brexit event. Robert Goodwill, The Minister of State for Immigration has stated in November 2016 that the government is committed to reducing net immigration to sustainable levels - which he defines as "tens of thousands". This is a considerable reduction on pre-Brexit projections. It would imply a maximum net migration of 90,000. i.e.0.14% per annum (total pop.64.6 million). Brexit is expected to occur some time after March 2017. with some 14 years of the Local Plan yet to follow. Thus a Brexit event is very relevant and should be taken into account under the requirements of Para 158.

1.07 This post Brexit expected lower level of migration decreases the ONS 2014-2024 total annual sub-national population increase for the East of England to 0.46% from the pre-Brexit figure of 0.89%. Thus the reliance on 2014 ONS pre-Brexit population projections by the CLG and therefore also by the Local Plan, does not give the adequacy, up to date-ness and relevancy as required by Para 158.

1.08 It should be noted that the pre-Brexit 2014 sub-national population figures for the Est of England include an annual increase of 0.28% for internal UK migration. If this internal migration is to satisfy the unmet housing requirement of an non-neighbouring area, such as London, then the Plan contravenes Para 182 of the NPPF which states:- The Plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so.....

As London grows at a fast rate it is most likely that this is the source of the internal migration into North Herts. By not stating from where this internal migration originates the ONS subnational projections are not adequate for use by the Plan as required by Para 158.

1.09 The Plan calls for an increase in houses of 16900 over 20 years on a starting stock of 55150, which is an average annual increase of 1.53%. This, in turn, is an increase which, once again, does not meet the adequacy , up to date-ness and relevancy required by Para 158.

1.10 The proposed rate of average annual rate of increase of housing stock employed by the Plan of 1.53% should be compared with the post-Brexit adjusted 2014 ONS sub-national population projections for the East of England of 0.46% (internal migration not included). The difference amounts to 11830 houses - much of which is allocated to be built on Green Belt land. Legitimate internal migration would require some of these.

1.11 The Plan, in proposing so many more houses than are needed for local requirements, acts to encourage migration into North Herts by creating a availability of houses beyond local needs. This effect is the opposite to the requirement of Para 158 which states that the Local Plan should be based on up to date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.

Whether potential migrants exist in other areas capable of being attracted to the NHDC area is no concern of the Local Plan, except where there is unmet need from a neighbouring area. The unmet need from both the Luton and Stevenage areas has not been properly quantified according to the requirements of Para 158 for the same reasons as given above for the NHDC Local Plan.

1.12 A further relevant factor ignored by the Plan contrary to Para 158 is the inability, or lack of desire, of developers to build beyond a certain rate. Ths effect has been pointed out by the CPRE in their paper "Set Up To Fail". On average developers build just 50% (taken over the last 15 years) of what there is land available for. In this respect the Plan does not comply with Para 154 of the NPPF which requires plans to be realistic.

An unfortunate consequence of making too much land available is that developers are given a choice of which site to develop and they usually choose a Green Belt site in preference to a Brownfield site as it is cheaper for them to build on.

NOT JUSTIFIED

2.00 The Plan is not the most appropriate strategy as it proposes to build many more houses than are required on the evidence supplied or are likely to be built (see under Not Positively Prepared). Furthermore it breaches the NPPF both in the Foreward, Core Planning Principles and Paragraphs 14, 15, 17, 79, 80, 83, 89, 158 and 182 (see under Not Consistent with National Policy).

NOT EFFECTIVE

Plan Policy SP8

3.00 The Plan is not effective as it ignores the rate at which developers ish to build houses. This effect is described in the CPRE Paper "Set Up to Fail". On average developers build just 50% of what they have land available for. This gives the developers a choice of which site to develop and they usually choose a Green Belt site in preference to a Brownfield site as it is cheaper for them to do so. Thus the expected build rate of developers is a relevant factor in any Local Plan.

The Plan is also not effective as it proposes to build many more houses (16900 in total) than is required (see under Not Positively Prepared above).

NOT CONSISTENT WITH NATIONAL POLICY as outlined in the National Planning Policy Framework (NPPF)

The paragraphs listed below refer to the NPPF unless specified otherwise:

4.00 The Plan contravenes the NPPF in sites BA1, LG1, NS1,HT1, GA1,GA2.EL1, EL2, AND EL3 for the reasons given below:

4.01 The Plan contravenes the 1st Core Principle of Para 14 of the NPPF notwithstanding the statement of community involvement, Para 1.19 of the Plan.

The Ministerial Foreward of the NPPF notes that in recent years planning has tended to exclude, rather than include, people and communities and the NPPF allows people and communities back into planning.

4.02 This is addressed by the 1st Principle in Para 14 which states: Planning should empower people to shape their surroundings

and also by Para 155 which states:- Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be pro-actively engaged

4.03 The great majority of representations to the earlier stage of consultation (2014) of the Local Plan (7502 objections versus just 559 supports) have been ignored. Despite the many objections against building on Green Belt land, the amount of Green Belt land allocated for housing was actually increased after the consultation at Site NS1.

Plan Policy SP1

5.00 PARA 14 states there is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-making

The word sustainable is given in the Ministerial Foreward of the NPPF to mean:- ensuring better lives for ourselves without making lives worse fr future generations.

and opened to people to experience it, to the benefit of body and soul.

5.01 Para 15 states:- All Plans should be based upon and reflect the presumption in favour of sustainable development

Thus development on Green Belt land - as on Plan sites BA1, LG1, NS1, HT1, GA1, GA2, EL1, EL2, EL3 must, under the above definition of sustainability, make lives worse for those in the future, who would otherwise have enjoyed the Green Belt for walks on foot, by horse, for play/leisure, discovering and enjoying wildlife and for its views as are currently being enjoyed by the present generation.

Thus the Plan contravenes the NPPF both in the Foreward and in Paras 14 and 15.

Policy SP5 - Countryside and Green Belt

6.00 In Policy SP5 NHDC states :- We support the principles of the Greeen Belt and recognise the intrinsic value of the countryside.

6.01 CORE PLANNING PRNCIPLES, Para 17 states the Core 12 Principles for Plan-making and decision-making.

The 5th Principle requires the protection of Green Belts.
The 8th Principle requires the re-using of Brownfield land.

The Plan contravenes the 5th Core Principle ins ites BA1, LG1, NS1, HT1, GA1, GA2, EL1, EL2, EL3.

6.02 Para 79 of the NPPF is crucially important as it defines the Green Belt here:- 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 Belts are their openness and their permanence.

In Policy SP5 the NHDC accept Para 7 of the NPPF which determines that permanence is one of the essential characteristics of the Green Belt. Yet the Plan intends to remove land from the Green Belt, thereby destroying is permanence and contravening Para 79 and the Plan's own statement of agreement with Para 79.

6.03 Para 80 states that:

Green Belt serves five purposes:

Amongst these:

To check the unrestricted sprawl of large built-up areas.
To prevent neighbouring towns from merging into each other.
To assist in guarding the countryside from encroachment.
To preserve the setting and special character of historic towns.

Hence Para 80 gives the reasons for the establishment of the Green Belt legislation.

The Plan contravenes all four of these purposes in several proposed housing sites. For example:

6.04 The urban sprawl of Stevenage is exampled in sites GA1 and GA2 and also in NS1 which is designed to integrate (Policy SP16) with an adjoining proposed development in the Stevenage Borough (SBC) Local Plan to create a combined urban sprawl from Stevenage to the village of Graveley of 1.3 kms in depth. This is a monstrous contravention of the above four purposes of Para 80.

6.05 The third purpose of Para 80 I breached by sies GA1, GA2, NS1, BA1, LG,HT1, EL1, EL2, EL3.

6.06 The preservation of the setting and special characteristics of historic towns (the fourth purpose given in Para 80) is contravened in particular at Baldock and at Graveley where the proposed number of houses (2800 at BA1 and 900 at NS1) will have an enormous deleterious effect relative to the present number of houses in these two places.

6.07 Para 83 of the NPPF states that once established, Green Belt boundaries should only be altered in exceptional circumstances.

In Para 83 no more explicit definition is placed upon the phrase "exceptional circumstances".

6.08 In Policy SP5 the Plan quotes the judgement of Mr Justice Jay in the Calverton Parish Council v Greater Nottingham Councils (2015) EWHC 1078 case as justification for building on Green Belt land.

Mr Justice Jay stated that:- It would be illogical and circular, to conclude that the existence of an objectively assessed (housing) need could, without more, be sufficient to amount to "exceptional circumstances" within the meaning of Paragraph 83 of the NPPF".

The Plan does not provide evidence to show "exceptional circumstances" other than housing need, which is specifically rejected by Mr Justice Jay.

The following discusses the phrase "exceptional circumstances" in the event that the Local Plan is later modified to include certain circumstances purported to be acceptable within Para 83

7.00 It cannot be the case that a circumstance be considered as "exceptional" within the meaning of Para 83 or "very special" within the meaning of Paras 87 and 88 if the employment of that particular circumstance effectively destroys the fundamental purposes of the Green Belt as described in Para 80, or the essence of the Green Belt as described in Para 79. For if the purpose or the essence of the Green Belt is destroyed then Paras 83,87, and 88 themselves become meaningless.

7.01 The destruction of the essence of the Green Belt occurs when its openness is challenged by erecting buildings upon it. The destruction of the permanence of the Green Belt occurs if any part of Green Belt land is later designated as non-Green Belt land. Even relatively small incursions of the Green Belt have the effect of destroying the essence of the Green Belt when continuously repeated, as they may be.

7.02 The Hon Mr Justice Jay suggests five possibilities for exceptional circumstances:

1) The acuteness of the need
2) Constraints on the supply of available land
3) The difficulty of finding non Green Belt sites
4) The nature and extent of the Green Belt if developed
5) The extent to which the loss of Green Belt may be ameliorated.

7.03 My comment on Mr Justice Jay's ruling is that his 5 permissible exceptions destroy the intent and essence of the Green Belt as described in Para 79 and contravenes the purposes of the Green Belt as described in Para 80 and are therefore not permissible.

7.04 One should consider:

1) the acuteness of the need. Firstly, the need for housing must be determined within the restraints of Para 158. Under those circumstances the true need may not be acute, as is the case described in Paras 1.00 - 1.12 above. Need is an objective assessment which has to be considered whether it is exceptional compared to previous occasions eve though subjectively considered currently high.

It is not acuteness that matters it is exceptional acuteness.

2) No matter the constraint on land supply there always exists the possibility of building on non-Green Belt land in the form of a New Town or on Brownfield sites or on other green spaces owned by the NHDC (Barkas [2014]) Any constraint which still exists after all other avenues have been explored in its self has to be exceptional compared to previous constraints.

3) There may be difficulties but all other possibilities must first be considered. Once again the difficulties must be compared to previous difficulties in order to show exceptionality.

4) One exceptional characteristic of Green Belt (Para 79) is its permanence which thus denies the allowance of even small harms.

Thus the nature and extent of the harm is not an issue if no harm may be done.

5) A loss of Green Belt violates the essence of the NPPF as described in Para 79, so amelioration is not an issue.


8.00 Para 89 states a local planning authority should regard the construction of new buildings as inappropriate in Green Belt.

The exceptions listed are not applicable to the Local Plan. This definition of inappropriateness applies to Paras 87 and 88 and elsewhere. Thus the construction of new buildings is not allowed on the Green Belt. Thus the Plan contravenes Para 89 of the NPPF in proposing building on sites. GA, GA2, NS1, BA1, LG1, HT1, EL1, EL2 AND EL3.
.

Plan Policy SP10

8.01 Para 7 of the NPPF - a social role -states that the supply of housing is required to meet the needs of present and future generations.

Thus it is necessary to have an accurate prediction of the type and size of future generations. The inaccuracy of the housing need figures employed by the Plan is addressed under the Section Not Positively Prepared, above.

8.01 The Plan is seriously flawed in that it cannot meet the needs of a future generation as it does not employ the most accurate projection of the size and make-up of that future generation.

Thus the Plan is in contravention of the requirement of the NPPF Para 7.

Plan Policy SP13

9.00 The Ministerial Foreward of the NPPF also states that :
Our historic environment - buildings, landscapes, towns and villages - can better be cherished if their spirit of place thrives rather than withers.

The spirit of the small town of Baldock (BA1, 2800 extra houses) and that of the village of Graveley (NS1, 900 extra houses planned - a 450% increase) and Codicote (CD1, CD2, CD3,CD4, a 24% increase) for example, cannot be expected to survive undiminished if this Plan is implemented.
Thus Para 14 of the NPPF is contravened by the Plan.

10.00 Conclusion

The object of the NHDC Local Plan appears to be to maximise the number of houses built - whether on Green Belt or not - and irrespective of the requirements of the NPPF and the true needs of the current population. The requirements of the NPPF are observed more in its breach than in its observance despite several exhortations to the contrary. It is only logical to assume that the Government's New Homes Bonus - which is designed to encourage more house building- is working very effectively at NHDC.


ADDITIONAL COMMENTS

I wish to draw to your attention to the fact that I have emailed Cllr Levett, Planning Officer about a Green Belt matter which much concerned me and not received a reply at all. See below my email relating to recorded comment in Minutes of Cabinet Meeting July 20th 2016.

David

I still have not had a reply to my email of 21 September 2016 to explain how your comment on 20 July, which was a recorded comment saying that you were increasing the Green Belt.

Yu certainly aren't doing that in Graveley !!!!








I have asked for maps of GA1, GA2 and NS1 not for myself, but for other people at their request, because they could not locate the maps themselves. I was advised of the wrong location on the Local Plan information for these maps by Nigel Smith, NHDC's Principal Strategic Planning Officer.

I noted that Minutes of a Cabinet Meeting which took place in September 2016 were not made available to the public until November 2016 relating to adopting the Local Plan. This seems an excessively long time to publish Minutes. I asked the person responsible for compiling them for a copy but was never sent them.

On the subject of Brownfield sites, I emailed Planners for a map or list of Brownfield sites. The response was that NHDC does not hold such a thing. I then found out that I should have done a Freedom of Information Request to enable me to obtain this information. It is concerning that NHDC will not divulge such information willingly and I have been informed by a District Councillor that brownfield sites have been discussed at NHDC Council Meetings and rejected out of hand.

My over-riding concern is that this Local Plan has not taken account of residents' wishes at all. I went to the public meeting where the Local Plan was voted upon by Councillors, on 20 July 2016 which started at approx. 7.30 pm but did not end until after well after 12.midnight. the following day. The atmosphere, pushed hard by Cllr Levett, the Planning Official who created the Plan was of the very unpleasant type of very hard selling such as the elderly and vulnerable experience when someone intent on obtaining their bank details marches them off to the nearest cash point to take all their money out. He kept forcing Councillors, who had reservations about the Plan, and voiced them at the time to vote in favour of it. Councillors there said they "struggled" with it, and there were abstentions and some against.

I am told by a new LibDem Councillor that he was told he had to vote in favour of the Plan, by a person in the Legal Department of NHDC who was present on the panel at that meeting. Conservative Councillors also actually said that they had been forced to vote for the Local Plan or be ejected from their local party. All very unpleasant to see unfolding before your eyes.


Relevant Recent Case to NS1- November 2016 Planning Inspector P.Major Langley Burrell, Chippenham



There was another recent case where In the final balance, the secretary of state agreed with his Inspector that although the area had no special landscape character, the loss of the gap between the surrounding settlements involved physical intrusion into an area of countryside, and contributed to coalescence and loss of independent identity. See details below:Suffolk Coastal DC v Hopkins Homes Ltd and Richborough Estates Partnership LLP v Cheshire East BC,

The secretary of state has rejected a large housing scheme in Hampshire, finding the loss of an area of local green gap to outweigh the benefit of new housing in making his decision on a recovered appeal.
The proposed new housing estate of up to 225 homes plus a 60 bed care home and 40 extra care units, in outline, was acknowledged to contribute to housing supply in an area with a 4.86 year supply and to the choice of housing types meeting different needs, in accordance with NPPF policy.
Since the inquiry closed, judgment was handed down by the Court of Appeal in Suffolk Coastal DC v Hopkins Homes Ltd and Richborough Estates Partnership LLP v Cheshire East BC, which led the secretary of state to decide a local gap policy was relevant to the supply of housing, contrary to the inspector's view in the appeal. Although the policy was out of date, it was accorded significant weight in the decision because it accorded with the NPPF and the housing shortfall was only limited.
In the final balance, the secretary of state agreed with his inspector that although the area had no special landscape character, the loss of the gap between the surrounding settlements involved physical intrusion into an area of countryside, and contributed to coalescence and loss of independent identity. This was contrary to those policies of the NPPF which recognised the different roles and character of different areas, and carried significant weight against the proposal. The loss of best and most versatile agricultural land also carried moderate weight against the proposal in the decision.
Inspector: John Chase; Inquiry

Other concerns that I have about development in NS1 is the increase in traffic if development of GA1 goes ahead. It is intolerable already to encounter the queues of traffic outside my house at 7.30 am speeding towards the roundabout (Coreys Mill) and Church Lane is extremely narrow and rural. I will find any further increase unbearable and will affect my quality of life.

A major concern to me is the destruction of wildlife such as fallow deer, badgers and Pipistrelle bats who have setts in the woods such as Roundwood. [...]

It also concerns me that thousands of houses are to be built so that I will no longer be able to go for walks near to where I live. This will have an adverse effect on my wellbeing and health.

I would like to add that everyone I have met who has been doing Representations has found them very very difficult to do. In one area (GA2) even though Cllr Henry lived there only 75% of residents had heard of what was planned in their area. I know that because I called on some of these residents and leafletted these people as they were "horror stricken" when they found out only a couple of weeks ago. Why were none of them informed by NHDC ? I am surprised and amazed that Cllr Henry nor NHDC had bothered to tell them or tell them they should be making a Representation.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6222

Received: 30/11/2016

Respondent: Save The Worlds First Garden City

Number of people: 7

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Object to SP5: Special circumstances for Green Belt review not established, impacts on biodiversity and water courses

Full text:

See attached

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6240

Received: 29/11/2016

Respondent: Wymondley Parish Neighbourhood Plan Committee

Number of people: 56

Agent: Wymondley Parish Neighbourhood Plan Committee

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Object to SP5: Green Belt review, exceptional circumstances not demonstrated, consultation responses not taken into account, lack of support from local people

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6249

Received: 29/11/2016

Respondent: Mrs Fiona Hill

Number of people: 7

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object SP5:
- disappointed by the number of dwellings being imposed on the Council, resulting in it having to consider sites in the Green Belt (also potentially rural area beyond the Green Belt) and good agricultural land beyond the Green Belt, since there are very few further sustainable Brownfield sites available.

Full text:

See attached

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6258

Received: 30/11/2016

Respondent: Dr Sieglinde Diabal

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Available brownfield sites
- Green Belt played and important role in preventing the unrestricted growth of Letchworth
- First Garden City

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6260

Received: 30/11/2016

Respondent: Gladman Developments Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: The exceptional circumstances required by the NPPF to create new Green Belt have not been demonstrated

Full text:

See attachment

Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6303

Received: 30/11/2016

Respondent: Hertfordshire County Council

Representation Summary:

Support SP5: The policy is considered sound

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6308

Received: 30/11/2016

Respondent: Mr Peter Bracey

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Green Belt protection
- No special circumstances, housing is not an 'exceptional circumstance'
- Planning Minister's letter to Parliament June 2016
- Land West of Stevenage

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6312

Received: 30/11/2016

Respondent: Hutchinson 3G (UK) Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Erosion of Green Belt, only 500m between Hitchin and Letchworth - sprawl.

Full text:

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 Local Plan avoids all mention of the problem, let alone solutions. It assumes the local water authorities will cope with swathes of new housing, as is their statutory duty, but no-one has come up with an answer as to where the extra water is to come from.
It is assumed that new traffic congestion can be remedied by road-widening but in Letchworth this solution is not available. All Letchworth roads are narrow as its conception as a self-sustaining town would obviate the need for travel. Workers would walk to work, children would walk to school and car-ownership would be low. Narrow roads were bordered by grass verges, generously studded with trees, some of them rare. In this environment, road-widening would be totally destructive of character. The proposed new estate North of the Grange will feed its extra traffic through these narrow roads , causing severe traffic congestion through the Grange and Letchworth Centre, and, as it becomes predominantly a dormitory town (through failing to balance new housing with new local employment opportunity), extreme parking pressure on routes leading to the station (such as Cowslip Hill, Norton way North, Icknield Way) . On the other hand, if to avoid town centre congestion, it is decided to create new routes through to Stotfold Road to the West, or through to form a new junction with Norton road to the East, the new estate will lose its identity with the community of Letchworth. (Presumably, or hopefully, this is not the planners' intention.)
Significant erosion of the Green Belt (the first ever) means there will be only 500 metres between Letchworth and Fairfield to the North and Letchworth and Hitchin to the West. If this isn't Urban Sprawl then I don't know what is, and Green Belt was put in place precisely to prevent this sort of development. Once it's built on the land is gone and the wildlife will not just move to the next field!

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6328

Received: 30/11/2016

Respondent: Mr Anthony Burrows

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: GB sites adjoining settlements creating sprawl,

Full text:

See attached

Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6618

Received: 29/11/2016

Respondent: Bellcross Company LTD

Representation Summary:

Support SP5: Principle of Green Belt review and managed release of land outside settlement boundaries

Full text:

See attachment