Policy SP11: Natural Resources and Sustainability

There are inadequate amenities to support the proposed development on the Blackhorse Farm site north of Baldock . Affinity water have said that the area has 'serious water stress'. I live in Upper Bygrave and have had no water at times over the past year with current capacity.
Para 177 of the NPPF has been ignored and Councillor Levitt falls back on his usual mantra of 'Its not a planning issue' . It may not be but it is a real and present one, that makes the size of this new settlement untenable.

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

See attached

I am writing this email in response to the NHDC Local Plan Consultation to express my concerns and objections on the proposed plan. My comments and concerns are as follows:

1. Spatial Strategy - On review of the proposed Local Plan, the percentage of proposed housing to and around the small historic town of Baldock is extremely high. Based on the current size of Baldock, the proposal to build 3290 new homes will double the size of this historic town. Baldock has a thriving community as it stands which would be hugely impacted on with this number of properties. Based on an average of 3 to 4 people per property, this would equate to between 9,870 to 13,160 additional residents of Baldock, which in turn has further implications as I will identify below.

2. The number of proposed residents if we use the above average (which could potentially be 4 or more depending on the number of bedroom spaces proposed for each development), will have an impact on the current town centre of Baldock.
Baldock is a small town with limited parking. The high street has a good historic feel to it with the St. Mary's church at the end of the high street.
The parking on the high street of Baldock already is insufficient, with the number of people visiting Baldock during the day and evening exceeding the number of parking spaces, which proves difficult to park when you need too.
With the proposed number of new residents, Baldock town will be choked.

3. Under Policy SP6 - Sustainable transport. The proposal is already at risk of being flawed. The current rail network company (Govia) are proposing to reduce the number of trains stopping at Baldock Station. The current Baldock station platform is at the limit, the number of passengers boarding the train during peak times is already large and virtually fills the train. As a commuter, I have noticed that as soon as the train reaches Letchworth station (being the next stop from Baldock), there is insufficient seats or space for commuters from Hitchin, Stevenage and the following stops. The proposed number of new residents in Baldock will consist of a majority of commuters moving to the countryside with good links to London. This will mean the trains will be overcrowded to a point where the trains are unable to function safely. This in turn will cause a loss in revenue for companies due to the number of people that will not arrive to work on time. It has become clear that NHDC have not been in consultation with Network Rail or Govia in relation to the proposals.
This was confirm via the Save Baldock Trains petition, when a local MP discussed the proposals with Govia, which they knew nothing about the proposed over development of Baldock.

4. The proposed new development is to include a new surgery. Currently Baldock Surgery has over 12,000 Baldock residents registered, The proposed new surgery would have to be part of the first phase to be constructed to enable the practice to be set up sufficiently to accommodate the proposed number of residents. The surgery would have to be of a substantial size similar to Baldock Surgery. One concern here is whether the surgery is able to employ the number of doctors and medical staff to accommodate the extremely high number of residents proposed. I believe our country is struggling to find the number of doctors required to run a doctors practice sufficiently.

5. SP11 - Natural Resources & Sustainability - Areas BA3, BA4 and BA5 were prone to flooding prior to the A505 Baldock Bypass being constructed. The ditch alongside the Old Wallington Road used to Flood. There was numerous remedial works that had to be carried out to area BA4 after the bypass was constructed.
The Land within Baldock is made up of chalk.

6. SP14 BA1 site North of Baldock - This is the largest area proposed to construct housing, retail and schools. The proposal for a new link road between the A1 and the A505 would not work. Has Network Rail been consulted on this proposal, has Herts County Council actually reviewed the level change to create a link road, if they have, then the proposal should be issued for public view.
From our understanding at consultation meetings, the proposed bypass is proposed as a single carriageway road. This will only shift the traffic jam onto the new road. Before any development on Baldock takes place the following needs to be constructed:
i) - The proposed new bypass from A1 to A505 needs to be a dual carriageway
ii) - The A1 to A505 bypass would need to be extended to the A10. The traffic running through Baldock not only goes to the A505, but a huge number of traffic and HGV vehicles cut through Baldock and Cottered to reach the A10. The number of potential residents and traffic that will take this route may cause the road to the A10 to be gridlocked. The road through Cottered has not even been considered during the consultation period. This will have a substantial impact on Cottered, Walkern and Buntingford. This needs to form part of the consultation, a traffic assessment needs to be carried out on the Cottered / Buntingford Road to ascertain the traffic levels now prior to any development.
iii) - We understand from media reports that the A1 is subject to being widened to 3 lanes. This is a good thing, but needs to be completed before any construction takes place in Baldock. The A1 would need to be widened from the Baldock Services all the way to Welwyn where it has already been widened to 3 lanes. As it currently stands, the A1 is gridlocked between Baldock and Welwyn on a daily basis during rush hours (6am until at least 9:30am and 3:30pm until 7pm). This would ease congestion substantially before any works take place in Baldock which may ease the level of traffic trying to go through Baldock slightly.

Infrastructure - Drainage and risk of flooding. With the number of houses proposed, the local plan mentions a provision of Sustainable Urban Drainage Systems will be required. The number of houses proposed will have a dramatic impact on SUDS. The houses would produce approximately 105 litres of water per day each (based on Code for Sustainable Homes values). This will impact on the current drainage system and potential create a higher risk of flooding over a
15 - 30 year period. The drainage infrastructure would need substantial improvements to accommodate the number of proposed properties. This needs consultation with the water authority.

If you have any queries, please let me know.

I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.

Policies SP8 and SP14 - The proposed allocation of 2,800 homes at North of Baldock (site BA1).
Other policies referred to are SP1, SP4, SP5, SP6, SP7, 9, 10, 11, 12, 13.

1. This site is acknowledged by the council as making a significant contribution to Green Belt purposes (Housing and Green Belt background paper para 3.14.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

2. Table 4 sustainability appraisal notes that this site creates a high probability of adverse impacts on landscape and townscape character and Landscape Sensitivity Study of July 2013 identifies the land north of Bygrave as having moderate to high landscape sensitivity. The Bygrave Road from Baldock has environmentally protected grass verges.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

3. Baldock sits in a valley which is well known for having poor air circulation causing air pollutants like PM2.5 from diesel emissions to be trapped and concentrated. The Eastern Baldock Bypass was finally built in 2003, following intervention in parliament by Sir Oliver Heald MP, to alleviate this pollution. Before the build asthma levels in 5-16 year olds was at 15% and the bypass brought them down to the national average of 6%.
Since then traffic has risen and now the levels of pollutants in Hitchin St and Whitehorse St are in danger of exceeding EU permitted levels (para 9.28). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The extra vehicles, domestic and service vehicles, which will arise from the building of 3,590 new homes and which will travel through and around Baldock will tip the balance and affect the health of all residents especially the very young, the old, pedestrians and cyclists raising health problems such as respiratory disease, cardiac problems and even cancer.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

4. The local highways network will be severely affected by the development of this site.
Almost all of the traffic wishing to pass through Baldock travels from the A1 to Buntingford and Stanstead along the A507, and from Cambridge and Royston towards London along the A505 (now redesignated B656), and these two roads cross at traffic lights at the north of Baldock at Station Road and Whitehorse Street. The two roads are offset and the traffic lights are slow because of three way lights and now pedestrian crossing time when requested, mainly at school rush hours. The crossroad is bounded by listed buildings which makes turning difficult especially for the huge lorries on the A507, some going left to Royston at that junction, which still go that way despite recommendations that they use the A1 and new bypass. One of the listed buildings has suffered many hits by vehicles.

The proposed mini-roundabout at Whitehorse St/Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.

The A507 passes the only access road to the railway station causing extra congestion in peak travel periods. The railway access is shared by about 100 houses in a cul-de-sac, Icknield Way East, and work is currently in progress to build another 41 houses which will also have to use this access. The survey used to discuss traffic impact of these new houses at this junction refers only to Icknield Way East, not the Station Approach nor the A507 on to which they both deliver traffic. Inadequate research and modelling.

Station Road passes under the 14ft 6in railway bridge which historically has suffered frequent hits by lorries (8 or so per year). Despite the building of sacrificial metal beams at each side of the bridge and new signage the hits continue to occur. Whilst the long delay to rail traffic no longer happens, road traffic is still impacted while the mess is cleared up, the vehicle is extracted, two police vehicles are deployed. In addition to this there are numerous smaller holdups when lorries realise they will hit the bridge and manoeuvre via small residential roads damaging road furniture and grass verges as they do. See appended photo of lorry hitting bridge just before photo taken at 12.43pm on November 9th 2016 necessitating two police vehicles. Also the screen shot of ongoing congestion as a result at 1.30pm. This is a regular occurrence. Screenshots of the A507/ B656 junction and A1 at other random times show congestion.

The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.

In the IDP the Traffic Baseline (para 5.1) shows that for North Herts as a whole traffic volume between 2014 - 31 is expected to increase by 16.1% and the average commuting distance in 2011 was 19.4km. Rail patronage at Baldock (para 5.12) went up 61% between 2005/6 to 2014/15. Para 5.19 mentions cycle paths in North Herts including Baldock but those referred to are mainly for leisure. Traffic demand in the A1 corridor may increase by 30% by 2031.

No traffic surveys on the A507 have been carried out by NHDC for development of this Local Plan. It has not been included in any meaningful traffic modelling exercises during research and forward planning. I can report, as a resident of this road, that the traffic volume has increased substantially since the Bypass was opened in 2003 and particularly since the A1 services at Radwell were built. GPS navigation also directs traffic along this road as an alternative to the A1/ Eastern bypass.

All of this ensures that the A507 from the traffic lights to the A1 roundabout is not a suitable road to give access to a new development at BA1 as NHDC plans. It is very likely, since there are few work opportunities in Baldock, that most of the residents will commute to other parts of North Herts, Bedfordshire and Cambridgeshire. NHDC has projected 2-3 vehicles per house so 5-7000 vehicles at least can be expected to be generated from this BA1 site and most will want to visit Baldock, Letchworth, Hitchin i.e pass through the traffic lights at Station Rd /Whitehorse St.

The link roads proposed by NHDC will do nothing to solve this traffic problem. A "northern" link is proposed through the BA1 site and a "southern" link road is mentioned between BA 3 and BA4 but with even less substance. No information is provided as to route impact or viability. Indeed these roads threaten to conduct traffic of all descriptions through the new residential areas forming a real hazard to residents both by potential accidents and by air pollution. These roads are referred to in the Infrastructure Delivery Plan para 5.110 and it is stated they "have been included in the traffic modeling." But where is the evidence? Their "provision (cost and delivery) is assumed to be absorbed within the specific proposals for these areas and they are subsequently not specifically identified in this IDP." This and the fact that Baldock is listed as a separate town but in traffic terms is always grouped with Letchworth which has its own completely different transport problems is concerning, leading to the belief
that Baldock traffic problems have not been acknowledged and addressed. There is no Masterplan for BA1.

The Plan is UNJUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14).
There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

5. Baldock's railway station is on the northern edge of the town with few houses lying to the north of the railway line. A major development on this side of the railway line would result in a pinchpoint for traffic at the WhiteHorse St/ Station Road intersection. The AECOM's technical note, table 4.1, identifies this crossroad and Letchworth Gate at the southern end of Baldock as problems (above capacity, unacceptable queuing) by 2013 even without further development.

The Plan acknowledges that "not all" traffic from BA1 will have to use the Whitehorse St/Station Rd crossroads (4.179) but this also acknowledges that a good proportion of it will. The Plan makes employment provision at above modelled levels SP3, 4.26 and this could increase traffic flow between Baldock and Letchworth and Hitchin. The plan stresses how interconnected Baldock, Letchworth and Hitchin are (paras 2.31, 4.27, 13.14) and that many residents commute out (4.25, 4.26). This will lead to more peak hour traffic.

Since it is expected that most new Baldock residents will commute to work outside Baldock, as well as extra pressure on the roads there will be unacceptable pressure on the railway. The station is small and would need extending to accommodate more passengers and the longer trains needed for them. Govia are currently holding their own consultation on their future rail provision and intend to cut "fast" trains stopping at Baldock other than at peak rush hours. This will not serve 7-8000 extra people well. Moreover British Rail had not till recently known of the Local Plan which includes recommendations such as building a bridge over the railway from the A505 Royston road into or round the BA1 site.
There is no information on deliverability or cost of this proposed road / railway crossing which will be very expensive if it is to be delivered without visual impacts as it is quite exposed at this point.

This indicates that NHDC has produced a poor plan without much forward planning and appreciation of all the related infrastructure required.

The link road proposed through BA1 will not relieve congestion at the Whitehorse St/ Station Rd crossroad if it is not the shortest route into Baldock. It may, however, be used by many people as a shortcut from A505/ B656 to A507 and will deliver more air pollution to the site BA1. Roundabouts through this development would increase air pollution and associated problems as brakes and gearboxes add to particulate production.

There is no modeling of the impacts from Baldock developments BA1-4 and BA10 employment area or their dependency on new infrastructure (AECOM section 7 Summary). No information is given about mitigating measures. It has not been shown that this part of the plan is deliverable.

The Local Plan Viability Assessment (update 2016) has not considered specific infrastructure pressures and mitigation concerns associated with the major sites, of which BA1 is the biggest proposed.

The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network.

6. The National Planning Policy Framework states in para 32 that "All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether.....the opportunities for sustainable transport modes have been taken up" but the Plan does not give information of things such as cycleways between towns for commuters, "safe and suitable access can be achieved for all people" but the increased traffic on A507 and through any link road and under the very narrow railway bridge will act against this, "improvements can be taken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused where THE RESIDUAL CUMULATIVE IMPACTS OF DEVELOPMENT ARE SEVERE". I believe that in this case they are severe.

The full impact of the scale of development proposed for Baldock - 3590 homes BA 1/2/3/4 and BA10, industrial development, or the individual major sites,- have not been properly assessed. Nor has evidence been offered on the impact of these developments on the existing town of Baldock and its environs and its local transport network. No information has been given about proposed mitigation measures.

The Plan is NOT CONSISTENT WITH NATIONAL POLICY.

7. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Indeed by trying to build a new development BA1 on the other side of the railway line it encourages a pinchpoint for traffic and a pulling apart of the community.

Developments should "be expected to work closely with those directly affected by the proposals to evolve designs that take account the views of the community" (NPPF 66) but NHDC have not done this. They have not sought the views of existing residents.

"By designating Local Green Space local communities will be able to rule out new development other than in very special circumstances". But NHDC have decided to locate many sites including BA1 on Green Belt land, going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land as they should, showing "exceptional circumstances". Indeed the area BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as shown in NPPF chapter 9. It is good quality agricultural land and of great importance for feeding the local area. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality" NPPF 112.

Water provision, at a time when water in this area is scarce and in danger of being inadequate, and the provision of sewerage over an enormous area (BA1) have not been adequately documented. The protection of the Ivel Nature reserve has been glossed over as has the mitigation measures for protection of other wildlife such as the endangered corn bunting on BA1.

"It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area e.g. Great Ashby have discovered this to their cost.

The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.

If indeed development on this scale is really needed in North Herts then I support Sir Oliver Heald in his recommendation to build a new settlement instead of tacking on large areas of development such as these in Baldock which create real problems for the future of existing communities whilst destroying their heritage.

I should like to be kept updated on the Plan's progress
I should like to be invited to the Public Hearing.

See attached

See attached

See attached

Thank you for the opportunity to comment on the North Hertfordshire Proposed Submission Local Plan. The following response is submitted on behalf of Anglian Water.

I would be grateful if you could confirm that you have received this response.

Policy SP7: Infrastructure requirements and developer contributions (legally compliant - yes and sound - yes)

Anglian Water is generally supportive of Policy SP7 as it states that planning permission will only be granted if it can be demonstrated that development proposals make provision for infrastructure that is necessary to accommodate the additional demands resulting from the development.

Policy SP9: Design and sustainability (legally compliant - yes and sound - yes)

It is noted that Policy SP9 includes a requirement for residential development to meet the optional water efficiency standard (110 litres per person per day). We would support the optional water efficiency standard being applied within the North Hertfordshire Local Plan area.

Policy SP11: Natural resources and sustainability (legally compliant - yes and sound - yes)

Policy SP11 includes a requirement to optimise the potential of the site to include the Sustainable Drainage Systems (SuDS) prior to planning permission being granted. We support this requirement as it is important to maximise the potential use of the SuDS to ensure that new development does not increase the risk of surface water and sewer flooding.

Policy SP15: Site LG1 - North of Letchworth Garden City (legally compliant - yes and sound - no)

Historically, sewage treatment assets have been sited at a distance from sensitive land uses, in recognition that these are an incompatible use. Our concern is to prevent the encroachment of Anglian Water's assets by sensitive development which could give rise to future amenity loss and impose additional constraints on the operation of our assets.

The above strategic site is located within close proximity to Letchworth Water Recycling Centre (formerly sewage treatment works) in the ownership of Anglian Water.

Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage. Where it is proposed to allocate sites within close proximity of the water recycling centres there is a need to consider further the odour impact and the extent to which sensitive development (that which is regularly occupied by people) could be accommodated on the site without having an adverse impact on future residents and/or employees who will be based on the site.

It is therefore suggested that Policy SP15 should be include the following wording:

'Undertake a detailed odour assessment to demonstrate no adverse impact on future residents and occupants of non residential buildings. To provide evidence to demonstrate that a suitable distance is provided from Letchworth Garden City Water Recycling Centre and sensitive development (buildings which are regularly occupied) as part of the detailed masterplanning of the site.'

Burymead Road (sites HE2 and HB3) (legally compliant - yes and sound no (effective)

Historically, sewage treatment assets have been sited at a distance from sensitive land uses, in recognition that these are an incompatible use. Our concern is to prevent the encroachment of Anglian Water's assets by sensitive development which could give rise to future amenity loss and impose additional constraints on the operation of our assets.

The above sites are located within close proximity to Hitchin Water Recycling Centre (formerly sewage treatment works) in the ownership of Anglian Water.

Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage. Where it is proposed to allocate sites within close proximity of the water recycling centres there is a need to consider further the odour impact and the extent to which sensitive development (that which is regularly occupied by people) could be accommodated on the site without having an adverse impact on future residents and/or employees who will be based on the site.

It is therefore suggested that Policy HE2 and HB3 should include the following additional wording:

'Undertake a detailed odour assessment to demonstrate no adverse impact on occupants of non residential buildings. To provide evidence to demonstrate that a suitable distance is provided from Hitchin Water Recycling Centre and sensitive development (buildings which are regularly occupied) as part of the detailed masterplanning of the site.'

RY4: Land north of Lindsay Close (legally compliant - yes and sound no (effective)

Historically, sewage treatment assets have been sited at a distance from sensitive land uses, in recognition that these are an incompatible use. Our concern is to prevent the encroachment of Anglian Water's assets by sensitive development which could give rise to future amenity loss and impose additional constraints on the operation of our assets.

The above strategic site is located within close proximity to Royston Water Recycling Centre (formerly sewage treatment works) in the ownership of Anglian Water.

Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage. Where it is proposed to allocate sites within close proximity of the water recycling centres there is a need to consider further the odour impact and the extent to which sensitive development (that which is regularly occupied by people) could be accommodated on the site without having an adverse impact on future residents and/or employees who will be based on the site.

We note that Policy RY4 includes reference to the preparation of an odour assessment for the above site which is welcomed. However it is unclear how the findings of the odour assessment (once prepared) would be considered further as part of the planning application process.

It is therefore suggested that Policy RY4 should be include the following wording:

'Undertake a detailed assessment of the impact of the Royston Water Recycling Centre in relation to odours, lighting, noise and traffic impacts to demonstrate no adverse impact on future residents. To provide evidence to demonstrate that a suitable distance is provided from Royston City Water Recycling Centre and sensitive development (buildings that are regularly occupied) as part of the detailed masterplanning of the site.'

RY8: Land at Lumen Road, Royston (legally compliant - yes and sound no (justified and effective)

We closely monitor growth in our region and develop investment plans to reduce flow and load from the catchment or provide additional treatment capacity when appropriate. Reference is made to development of this allocation site being phased in relation to the improvements at Royston Sewage Treatment Works. It is unclear why this has been identified a specific requirement for this allocation site only and no other sites within the Royston catchment.

It is therefore suggested that the fifth bullet point of Policy RY8 should be deleted as follows:

Phasing of development to link with Sewage Treatment Works improvements;

Policy D1: Sustainable design (legally compliant - yes and sound - yes)

Policy D1 includes a requirement to optimise the potential of the site to incorporate Sustainable Drainage Systems (SuDS) prior to planning permission being granted. We support this requirement as it is important to maximise the potential use of the SuDS to ensure that new development does not increase the risk of surface water and sewer flooding.

It is also noted that Policy D1 includes a requirement for residential development to meet or exceed the optional water efficiency standard (110 litres per person per day). We would support the optional water efficiency standard being applied or exceeded within the North Hertfordshire Local Plan area.

Policy NE8: Sustainable drainage systems (legally compliant - yes and sound - yes)

We support the requirement that drainage solution follow the SuDs hierarchy as this will ensure that disposal of surface water to the public sewerage network will be only be considered where it is demonstrated that there are no suitable alternatives. This will help to ensure that new development does not increase the risk of surface water and sewer flooding.

Policy NE10 : Water Framework Directive and wastewater infrastructure (legally compliant - yes and sound - (justified and effective)

Reference is made to new or improved waste infrastructure being secured under the requirements of Policy SP7.

In general, water recycling centre (previously referred to as sewage or wastewater treatment works) upgrades where required to provide for additional growth are wholly funded by Anglian Water through our Asset Management Plan. Foul network improvements are generally funded/part funded through developer contribution via the relevant sections of the Water Industry Act 1991. The foul infrastructure requirements will be dependant on the location, size and phasing of the development. All sites will require a local connection to the existing sewerage network which may include network upgrades.

As set above we seek contributions directly from developers in accordance with the provisions of the Water Industry Act 1991. Therefore Anglian Water would not expect there to be provision within planning obligations sought by the District Council or Community Infrastructure Levy in accordance with planning legislation.

The majority of allocations sites proposed within the Anglian Water region are expected to require improvements to the foul sewerage network. Please see enclosed spreadsheet for further information. It is important to note that the impact on the foul sewerage network and relevant water recycling centres have been assessed on an individual site basis.

Therefore we would suggest Policy NE10 should be amended to make it clear that applicants will be expected to demonstrate that there is capacity within foul sewerage network and at the relevant water recycling centre or that capacity can be made available in time to serve the development.

It is therefore suggested that Policy NE10 be amended as follows:

'Mechanisms for delivering any necessary new or improved water and wastewater infrastructure are secured under the requirements of Policy SP7. Adequate foul water treatment and disposal already exists or can be provided in time to serve the development.'

Attendance at examination

Where we have sought modifications to the wording of proposed Local Plan policies as set out above we would wish to participate at the examination.

See attached

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.