Policy SP7: Infrastructure Requirements and Developer Contributions

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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.

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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.

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The Bedfordshire and River Ivel Internal Drainage Board makes the following comments to your proposed Local Plan 2011 -2031 consultation.

The Plan does not adequately address Flood Risk and should be amended to strengthen the requirements of addressing flood risk and development, particularly in the north of the District in Letchworth and Baldock.

Below are some examples of paragraphs which should be redrafted to ensure development does not have a detrimental effect on flooding:

2.29 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

2.78 The paragraph must include infrastructure that is required to accommodate growth as SuDS which are strategic, integrated and maintained. This is critical given the scale of development in Letchworth (900+ houses) and Baldock (2800 + houses).

3.6 The spatial vision of high quality sustainable design and managing flood risk needs to refer to the provision of strategic and integrated SuDS, which include effective and funded SuDS maintenance.

4.73 Policy SP7. This infrastructure should include SuDS and flood risk management, such that a public authority can ensure drainage infrastructure operates as designed in the future.

4.131 Policy SP11. It is inadequate to state that this Plan 'seeks'.... when other policy state 'will'. The Policy should state the Plan will deliver the provision of strategic and integrated SuDS that will be maintained.

4.136 For clarity, WFD seeks to meet good ecological "potential" for heavily modified and artificial water bodies, as well as good ecological "status" for natural water bodies.

4.137 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

SP14. Downstream of Baldock is Stotfold which has experienced flooding from the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

SP15. Downstream of Letchworth is Stotfold which has experienced significant flooding from the Pix Brook and the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

NE7. There is a requirement to reduce the existing flood risk in Stotfold immediately downstream of the urban runoff areas of Letchworth and Baldock, as in SP14 and SP15, this Policy should be strengthened to include mitigation being designed and implemented on development sites to attenuate flows c) and d). It is fundamental that flood risk is minimised and that functional and effective infrastructure is provided that is maintainable in addition to items e).

NE8. This Policy should include strategic, integrated and maintainable SuDS for all sources of flood risk, and not just surface water, particularly given that flood risk exists from the Ivel and Pix Brook. The area is heavily modified with public storm sewers, modified watercourses and large flood attenuation reservoirs (Pix Brook), so any solution for development needs to be appropriate to the scale of development, rather than simply mimic the natural drainage pattern.

NE8 and 11.59. For developments draining in the Ivel and Pix Brook catchment, the Council and developers should also consult the IDB, as well as the Lead Local Flood Authority and the EA.

NE9. For any development in the Bedfordshire and River Ivel IDB district, a developer will be required to comply with the Board's Byelaws including maintaining a minimum 7 m wide undeveloped buffer zone for ordinary watercourses and applying the land drainage consenting regime.

I trust you find the Board's comments clear and informative.

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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!

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