Policy SP15: Site LG1 - North of Letchworth Garden City

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 151

Received: 22/10/2016

Respondent: Mr Damian Griffin

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to LG1: infrastructure, traffic, waste, population density, coalescence, infrastructure demand, Southfields capacity, biodiversity, Grange deprivation score, lack of employment, A1(M), Green Belt, carbon footprint, climate change.

Full text:


I would like to take this opportunity to lodge a protest against the plans for the north side of Letchworth for 1,000+ houses (Grange Estate), could you please pass this on to the relevant person(s).

The following reasons for my protest are listed below;
1.The plan for building 1,000+ houses on the north side of Letchworth would have an adverse effect on the following infrastructure(s) owing to the increase in density to an already populated area:
A. Increased traffic, which would be using the existing /proposed roads on which the existing roads are already under poor repair and no current budget can/will be allocated to this and roads owned by a different council body. (i.e. Western Way on the Grange Estate).
B. Extra strain on the environmental issues which are finding hard to sustain current levels such as waste collection, carbon footprint and recycling collections.
C. Population density will be a major factor as the council states in its core policies that it does not want a merge of villages and unrecognisable expansion of towns, with this approach, with this proposal you will be failing your own policies.
D. The housing growth in this area will change the nature and size of demand for facilities, including the need for additional facilities in areas of new development and issues arising from loss of facilities in rural area.
E. The need for doctors, dentists, schools, hospitals, transport links and leisure activities which will all be additionally required with this proposed area cannot be sustained as currently all facilities are fully utilised and could not accommodate the additional intake of at least 2,000 extra residents.
F. The Council has stated that the local parade of shops on Southfields on the Grange estate in Letchworth Garden City is in a state of deprivation these facilities could not accommodate the extra housing requirements on north side of Letchworth (Grange Estate).
G. The current wildlife in the proposed area inclusive of grass and woodland would suffer immensely there is also a fenced area that is used for wildlife observation and measurement by a government body adjacent to this proposal which would be greatly effected/destroyed and holds rare wildlife/plant life which is being investigated. Also habitat for a significant number of endangered wildlife would be under threat.
H. As quoted in you core policy upon which wildlife is concerned is ; " The policy also aims to protect the quality of the natural environment as development pressures increase in the District and help to create a sustainable pattern of development. As the policy says that detrimental proposals will not be permitted, this policy will be expected to take precedence in situations where there is a conflict. For example, the policies on housing may suggest that a site is acceptable for housing, but to build there, would be detrimental to a recognised wildlife corridor, and so the proposal would fail on the basis of this policy." - This would fail.
I. The council states in the corporate part "Index of Multiple Deprivation 1 scores exceeds 20, one of them is policy of the Grange estate (20.50)" how can we add additional housing and put more strain on this area when we need to address the depravity issues and to further ensure an integrated community, the council would be contravening at least two of it's promised policies.
J. The council's core policy state that the use of greenbelt land (or the release of it) for building should not interfere with the well being and harmonious living conditions of current dwellings or character, this proposal would have a dramatic negative effect on the conditions, infrastructure and character.
K. The current availability to be live locally and work locally is very constrained (as policy states this would be a desired requirement) employment levels within Letchworth is very limited, industry and manufacturing is in decline throughout Hitchin, Letchworth and surrounding areas, as is job availability. The employment availability could not cope with this extra volume of people residing in the proposed area.
L. The current A1(M) is under great traffic strain in core commuting hours and takes 1/2 hour to get to Stevenage now in peak period (usually 15 minute journey) the impact of 1,000 extra houses would impact all directions of highways traffic and only increase pollution and travel times thus making it unsustainable to travel to work.This would impact current households ability to keep employment owing to the impact of delayed travel times.

2. The Government Policy States:
Councils no longer need to invade their Green Belts just to meet housing needs forecasts. [New paragraphs 44 and 45 of the Government's / Parliament's Planning Practice Guidance make that clear. The forecasts are for between 2011 and 2031 and made by the Office for National Statistics (ONS).
2.Your core policy statement quotes;
"The District's ecological footprint has been assessed at 5.50 global hectares
per person (Hertfordshire Environmental Forum, The Ecological Footprint of
Hertfordshire, July 2006). A global hectare is an estimate of how much
productive land there is on the planet. Given that the global average is 2.2
global hectares per person, North Hertfordshire residents are therefore using
2.5 times their hypothetical fair share of the planet's resources and slightly
more than the UK average of 5.4 global hectares per person"
By building these extra houses in an already populated environment this will increase both the Carbon and ecological footprint to an unsustainable more.
3.Your environmental core policy statement quotes;
"The natural environment forms the background to the towns and villages in which people
live, work and spend their leisure time. It should be protected and enhanced
in the future to maintain the existing high quality of life that people in the
District enjoy.
This would be severely hampered with the addition of 1,000+ houses been built on north side of Letchworth
4.Your environmental core policy statement quotes;
"Furthermore,
the more travelling that people are having to do, the greater the contribution to
climate change and traffic congestion."
The implementation of this proposal would have a massive effect on effects to the contribution to
climate change and traffic congestion.

Core Strategy options instead of building north of Letchworth
As your Core Strategy states, these could be some very viable alternative areas that could be used instead of north of Letchworth:
Use the land between Royston and/or Baldock and their respective bypasses.
Use the land between Letchworth and/or Baldock bypass.
Focus more on the villages than the towns.
Increase the number of dwellings built at West Stevenage.
Enlarge Great Ashby.
Building on/by the Western Hills, Baldock.
Build a new town.

OR

As stated in YOUR Core Strategy the following areas can be of consideration instead of the plans for the north side of Letchworth for 1,000+ houses;

"The options relating to West Stevenage and Great Ashby cannot be ruled out
at this stage as they will be considered in the Stevenage and North Hertfordshire Action Plan".
"The villages of Ashwell, Ickleford, Offley, Pirton, Preston, St Ippolyts, Weston
and Little Wymondley should have development boundaries drawn around
them within which development may occur."
"Based on our Landscape Capacity and Sensitivity Study and our Peripheral
Sites Study, we have identified one principal direction for growth - the north of
the town within the bypass, although not to the west of the farm track from Ivy
Farm, or to the east of Melbourne Road, so as to protect views between the
town and Therfield Heath and the Cambridgeshire Plain. More detailed
consideration will be carried out at the land allocations stage."
"Knebworth should be allowed to expand a modest amount, but not towards
Stevenage or Woolmer Green"

Other ALTERNATIVE options instead of building north of Letchworth
Potential for building in the Norton Road area pastures/ fields. (not being currently productively used)
Refurbishment of dilapidated / boarded up properties and housing new arrivals. (which there are many in Letchworth and surrounding areas)
Extension to the relatively new site located adjacent to Green Lane Letchworth.
Vacant land areas located by the Irish Club in Letchworth.
Rebuilding new homes and the regeneration of existing flats in the Pelican Way area.
Potential for building in the Wilbury Hills area pastures/ fields.

Other Considerations if the plan goes ahead building north of Letchworth
Potential noise pollution with traffic and workers/machinery during building times
Excess building traffic and relative access to sites
Unnecessary lighting used during construction and light pollution
Effect to wildlife/plant life during construction
Value of homes bordering sites during and after construction will decrease (who will compensate?)
Health & Safety of people outside sites owing to extra traffic


I sincerely hope that this protest and information is passed on correctly, digested and thorough consideration given to this very important matter, which many community members I have liaised with have expressed grave concern.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 229

Received: 08/11/2016

Respondent: Mrs Fiona Hutton

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Objection to LG1 on grounds of:
- impact on Graveley
- traffic on B197
- noise and air pollution
- road safety

Full text:

I object to this proposal due to its consequencies for the village of Graveley. The B197 is used as a route by motorists travelling between Letctworth and Stevenage (and beyond) to avoid the congested A1 and at times traffic is nose to tail. This proposal will serve only to exacerbate the problems already experienced - in terms of noise and air pollution and poor road safety - particularly for residents wishing to pull out onto the carriageway and in trying to cross the road especially at peak times.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 334

Received: 11/11/2016

Respondent: Mrs Chris Jones

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to LG1: lost green margin

Full text:

I am very disappointed to read in the Comet that your plan incorporates 2000 more new homes than necessary, with the suggestion that this is linked to financial incentives under the New Homes Bonus Scheme. Shame on you. In Letchworth we have little enough green margin left and you, the "planners", are hell bent on destroying that little. I am sad and angry and ashamed of you, our elected body.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 643

Received: 16/11/2016

Respondent: Ms Linda Crampton

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to SP15: LG1 on the grounds of:
- Green Belt
- countryside for recreation
- consideration of alternative and brownfield sites needed
- infrastructure: doctors, schools, roads, pressure on A1M
- Garden City principles - access to open space

Full text:

As a Letchworth resident of over 30 years I strongly disagree with the plan to build houses on our greenbelt. We chose to live here because of the fact that we could take advantage of the surrounding countryside. We walk, bike ride and go for dog walks all within walking distance of our house. If these plans go ahead, the area where we do these activities will be built on. There are plenty of areas in Letchworth that can either be refurbished or brown sites could be used.

We have NOT got the infrastructure for so many new houses. Our doctors surgeries, schools and roads are already over subscribed plus there will be more pressure on the already inadequate A1M.

I feel local residents voices are not listened to but I cannot just ignore the issue hoping it will go away.

I would also like to remind everyone concerned that Letchworth is the first Garden City and Ebenezer Howard's ideal was for the residents of the first Garden city to be surrounded by green open spaces, not to fill the green spaces with more and more houses.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 660

Received: 22/11/2016

Respondent: Dr Kathryn Thompson

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Objection to SP15: LG1 on the grounds of:
- GP provision
- traffic
- loss of important green space between Letchworth Garden City and Stotfold
- destruction of Green Belt

Full text:

Letchworth Garden City cannot support this number of homes. It is almost impossible to get a GP appointment now and there is no reference to a new surgery. The roads are already clogged. We will lose an important green space between LGC and Stotfold, and the destruction of the green belt is a travesty. LGC is special and should remain so.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 664

Received: 30/11/2016

Respondent: Mrs Dianne Judges

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Object to SP15 - LG1:
- Letchworth Garden City is a special case being the first Garden City in the world.
- Two of the founding principles are the Green Belt and the size of the town being planned to self sustain.
- Traffic congestion caused by the new site will be severe or, if rerouted to Stotfold, will make the new site detached from Letchworth.
- Scale of development

Full text:

We object to the development labelled LG-1. The local plan does not include acreage therefore the housing density cannot be calculated.
THE SPECIAL CASE OF LETCHWORTH.
The genesis of Letchworth Garden City was Sir Ebenezer Howard's revolutionary project for a healthier society and as such generated a new social movement worldwide. The main principle was Letchworth would be a self-sustaining town with a carefully planned balance between urban and rural living. Tourists and students of town planning from all over the world visit this prototype modern garden city; they would be dismayed at the iconoclasm of the Local Plan. Moreover, to preserve proximity of the countryside, an agricultural belt (later designated green belt) was to provide farm produce and health-giving open space and fresh air. Nowhere was to be more than 15 minutes walk from open countryside. This purposely restricted the growth of the town and the population to a projected 32000. The town was renamed 'Garden City' quite recently to help promote the whole concept of Howard.
Letchworth was to be self-sustaining in the sense that the people would work locally, in local industry, so housing and industry were in exact mutual need. The Local Plan does not propose any new industrial sites to absorb the workforce from new housing in fact the proposal includes plans to repurpose industrial land for housing and this has already happened along Blackhorse Road; the sense of community will weaken as Letchworth becomes ever more a dormitory town.
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.)

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 959

Received: 27/11/2016

Respondent: Hertfordshire Local Enterprise Partnership

Agent: Dan Bone

Representation Summary:

The LEP generally supports the designations of all 6 Strategic housing sites but considers that small scale employment related activities should be considered for the at least some of the sites, particularly the larger allocations SP14 and SP19; it should also promote the development of sustainable transport modes to serve such development

Full text:

The LEP generally supports the designations of all 6 Strategic housing sites but considers that small scale employment related activities should be considered for the at least some of the sites, particularly the larger allocations SP14 and SP19; it should also promote the development of sustainable transport modes to serve such development

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 968

Received: 27/11/2016

Respondent: Ms Samantha Cairns

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP15: Alternate brownfield sites available, infrastructure, traffic, loss of wildlife habitat

Full text:

There are plenty of brown sites to consider first. Letchworth does not have the right infrastructure to cope with the additional dwellings. We are already seeing a build up of traffic as a result of the houses on blackhorse road. This will bring letchworth to gridlock. loss of wildlife habitat is a serious concern at a time when various species are in decline.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1071

Received: 27/11/2016

Respondent: mrs Sarah Quiggin

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Housing should not be built on the greenbelt, this is a garden city.

Our boundaries and separation from neighbouring towns need to remain clear.

Additional infrastructure needed is not sufficiently catered for in the plan.

Full text:

Letchworth is a Garden City, a core principal being the protection of green spaces as enforced on all residents. Its a farce that the council can deem it acceptable to build on greenbelt land, land that the hertiage foundation spent a lot of money building the Greenway round to encourage outdoor activity. The land is regularly used by walkers, runners and children and is a small gap of green between Stotfold, Fairfield and Letchworth. With increasing development from Fairfield there will be very minimal space between this and Letchworth if the development were to go ahead as planned.

Access is also not well planned, the roundabout at the end of Norton way north/ Wilbury Road/ Norton Road/ Eastholm is already very busy with traffic going from norton way north and onto the grange. This makes it very busy when trying to access from Wilbury Road and this significant increase in traffic will only exacerbate the issue making it dangerous for children that cross the road to get to school or into town.

Infrastructure is poorly accounted for given the increase in housing. Whilst the plan references more schooling will be looked at (which would be essential) it makes no reference to the A1 or trains. This is a commuter town and already traffic on the A1 is horrendous in the mornings with a 15 mile journey to Welwyn Garden City taking an hour on a regular basis. The only change referenced is to the A1 junction at Letchworth. Whilst this can be improved this is not what causes the delays. The A1 needs widening between Stevenage and Welwyn to cope with the huge volume of traffic already.

Train links are also challenging already, more housing will make this a lot worse without addressing two issues. Firstly train capacity is not enough, at peak times it can be a challenge to get a seat in the morning. The trains will not cope with hundreds of extra passengers. Secondly and most importantly parking for commuters needs addressing. The existing car parks are tiny, holding barely 30 cars. This means already commuter cars clog up neighbouring roads wherever they can (e.g. Cowslip Hill) making it very dangerous for pedestrians and passing traffic. Given all this housing will be at least 2km from the station this needs addressing as the current town cannot cope with the existing situation let alone more.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1209

Received: 28/11/2016

Respondent: Mr Simon Franklin

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

- not in keeping with the master plan for Letchworth laid out by Howard
- will not increase community cohesion with limited facilities planned
- will restrict access to countryside for many
- does not create appropriate diversity of accommodation
- appears to use agriculturally important land

Full text:

I object to a large tranche of green belt land being removed from the countryside north of Letchworth.
It is not clear to me that all attempts to utilise brownfield sites in Letchworth have been made. Sites which have been in the original master plan for Letchworth set aside for industry have in some cases remained derelict or semi derelict. The density of such areas is also very low.
The town centre itself could continue and increase its successful regeneration through addition of refurbished flats and apartments. Opportunities to create places of design merit in these locations should be explored.
There is a large office building on the Broadway that has remained unlet for the whole of the last 7 years as far as one can tell, which with redesign could create wonderful flats for communters and local workers alike. I would like to see options for change of use of this site.
What makes Letchworth special is that has in the past been a centre for excellence of self builds, back to the original competitions for design. I see that only 9 plots are proposed for the new works. This is missed opportunity to engage with the original ambitions of Howard etc to create affordable yet architecturally interesting developments.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1305

Received: 29/11/2016

Respondent: Mr Graham Stapleton

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Object to LG1:
- Scale of development at Hitchin & Letchworth and the impact on Baldock.
- There is an expectation schooling, sports facilities which are already under significant strain will cope but development at three neighbouring towns will add to each other problems.

Full text:

HT1, LG1 LG3 LG4 LG10 - all of these developments are on the east side of their respective towns (Hitchin & Letchworth). There are over 1,800 properties proposed a portion of which will generate additional traffic that will now travel through Baldock. This is not just about the changes in Baldock
There is an expectation schooling, sports facilities which are already under significant strain will cope but development at three neighbouring towns will add to each other problems.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1319

Received: 30/11/2016

Respondent: Miss Alison Basford

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Object to SP15: Green Belt, contrary to Garden City principles, lack of infrastructure capacity, biodiversity,

Full text:

Letchworth Garden City is the World' s First Garden City and is promoted worldwide for it's planning. However, historical assets are being threatened, backed only by a small hand full of officials despite an outcry from residents of Letchworth (those who are aware of this proposed housing as there has been ineffective communication).
The site is inappropriate as being too far from town. Our garden city principles state that amenities should be within reasonable walking distance.
I object to building on our green belt as our population capacity is also a historical asset. Our population is specified at 32,000 by being the World's First Garden City.
The importance of our green belt is paramount and it's preservation was stipulated by Parliament in 1993.
I also object because the Local Plan also exceeds hugely our Local Needs, and by doing so, looks at green belt to fulfil. Any development in these circumstances should be restricted - according to National Framework guidance.

Green Belt Policy
NHDC have failed to demonstrate any exceptional circumstances to build on green belt, justified with unconvincing figures. Half of the housing proposed in Letchworth is Green belt - and this percentage only increases through the Local Plan sites.
In October 2014, the dept. of communities and Local government stated that" drawing on protections in the National Planning Policy Framework to safeguard their local area against urban sprawl, and protect the green lungs around towns and cities".
LG1 is an proposed housing estate of 900 homes attached to a current housing estate at the north of our town is urban sprawl therefore I object.

This site is within 60 metres of Bedfordshire border and Stotfold continues to grow and recently has began to expand into the land only one field away from this development.
(see photo expansion of Stotfold and view from edge of LG1 as attached)

Biodiversity
This is one of the most biodiverse in the county and is a haven for many red listed wildlife and flora. I understand that the hedges date back 400 years or more.
This land has been given grants to created stewardships for nature to flourish and this has led to a haven for wildlife. This is a long list of wildlife - many red species. Also the Letchworth Gravels should also be recognised dating back 500,000 years ago.
In turn, this land is priceless for recreation. The calling for a Nature and Wellbeing Act continues. The land north of Letchworth is exactly what this Act would be protecting. The sense of quiet and calm is very strong for walkers, runners and cyclist throughout the year. NHDC's Biodiversity Action Plan 2005 should continue to protect this heavily rich land.

Infrastructure
I object because the current infrastructure is not flexible to adapt to accommodate further traffic.
North of Letchworth suffers terribly with traffic. Our roads are often grid lock at peak times and are dangerous. Routes for the housing run past schools. Traffic is backed from Green Lane/Norton Road junction to Glebe Road every day, Norton Way North is often backed up from the Grange junction to Icknield Way, Cowslip Hill is a rat run and is severely congested also due to commuter parking. Road parking in our town is becoming increasing more dangerous due to amount. There is little commuter parking and so far, no plans have transpired to facilitate the current commuter parking, let alone anymore. Taking away grass verges and tree lined road is not an option due to world-wide recognition for town planning.
Traffic filters to and from the A1M from junction 9 and 10. There is currently no signage at junction 10 to indicate Letchworth However, the traffic from A507 towards Letchworth is at capacity -due to having to go through the village of Norton. Any further excessive housing would increase this to dangerous levels and again there is little flexibility to change road configuration. Any traffic from junction 9 blocks the roads currently. Pixmore Road is the main access road and has always been dangerous.
(see photos attached of Norton Road at peak times).

Alternative sites

I suggest that the need for housing figures are looked at again. This Local Plan seems heavily weighted on green belt land rather than accessing brownfield sites, as stipulated by the National Planning Policy and therefore unsound.
I understand that North Herts population is projected, even pre- Brexit to increase 0.34% per year for 20 years. The Local Plan has been exaggerated by NHDC, and considering 4,340 have already been built/approved, the figures here also need looking at.

I also object because NHD do not seem to have taken into consideration empty dwellings. At a public council meeting, Mr Levett didn't have any figures available for this. The figures are that in October 2013, there were 1,249 empty dwelling in North Herts (422 long term).

I object also as NHDC have disregarded true brownfield figures.
CPRE document 'From Wasted Space to Living Spaces. (Nov 2014) the figure for North Herts is listed as having brownfield land suitable for 11,000 homes.

https://www.gov.uk/government/collections/national-land-use-database-of-previously-developed-land-nlud-pdl

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1423

Received: 29/11/2016

Respondent: Mr Richard Meredith-Hardy

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

LG1 as farmland is of vital importance in maintaining the green belt design of the world's first garden city. To erode this beyond the natural skyline boundary of the existing built up area would be a critical loss to Letchworth's integrity and therefore no developer could possibly satisfy Policy SP15 condition a,i "How the site will follow and implement Garden City principles".
LG1 will cause flooding in Radwell and also in Stotfold.
The proposal for site LG1 is contrary to policy SP11 which claims to be "directing development to areas at lowest risk in accordance with the NPPF"

Full text:

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

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

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

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

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

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

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

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

"The River Ivel catchment is a fast responding catchment meaning it is vulnerable to flash flooding following a significant rainfall event." (Central Beds report CB/FLO/15/09003)

Currently (and for the last 60 years since my family have lived here) Radwell has NOT suffered from flooding, but in wet winters it does come close to it.

The proposed developments in Letchworth plan to add c. 900 new homes, all of which are in the River Ivel catchment. This infers the development is likely to significantly affect Radwell and Stotfold through increased water flows both from runoff and sewage treatment outfall.

Apparently no Surface Water Management Plan (SWMP) study has been conducted despite the fact that Flooding regularly occurs in Stotfold. This happened as recently as July 2015 and again in June 2016 when extreme rain events in Letchworth (c. 25mm in 90 minutes) overwhelmed Pix Brook and flooded houses in Stotfold.

River flow at Radwell Mill has been measured to vary between 3.5 and 16 Megalitres(Ml)/day (oct 2015 - oct 2016, Affinity Water study).

Treated water:
In the absence of any alternative proposals, it is reasonable to assume the treated water from the development will be pumped over the hill to Letchworth sewage plant thereby exacerbating the existing flooding issues with Pix Brook in Stotfold.

Runoff:
"Developing a green field site may result in 10 times the runoff during extreme rainfall" (Woods-Ballard et al 2007). The policy mentions "Incorporate ordinary watercourses (and any appropriate measures) within comprehensive green infrastructure and / or SUDs approach" In this development the fall of the land is towards the Ivel at Radwell where we already have flooding issues from the land between the Norton Road and the Grange Estate. (The land drains were relaid in 2013 which resulted in the Norton Road being flooded and the ditch on the Radwell side of the Norton Road overflowing.) It is therefore easy to envisage that a development of this size is highly likely to lead to flooding in Radwell and other settlements (eg Stotfold) downstream.

25mm (c. 1 inch) of rainfall over 40 Ha is 10 Ml of water. The 5% runoff expected from the green field site would be 0.5 Ml, the runoff from the same area as residential development could be expected to be between 30% (3 Ml) and 60% (6Ml) representing a potential increase of between 2.5 Ml and 5.5 Ml of runoff in a single event. Besides increasing the flow in the Ivel by between 30% and 80% the existing ditches into the Ivel cannot possibly be expected to cope with this sort of increase in flow so flooding is to be expected.

Pollution:
Radwell lake is already deemed an area of "Wildlife and Nature policy 14" and we work hard to keep it nice. The massively increased runoff is likely to increase temperatures in our river, harming fish and other organisms; A sudden burst of runoff from a rainstorm can cause a fish-killing shock of hot water. Salt used to melt ice and snow on pavements and roads in the new developments will further contaminate our river.

Oil and other hard-to-monitor pollutants will get into our river from the newly developed areas. This already happened when the SuDS ponds associated with runoff from the A1(M) built in 1966 silted up after only 25 years of service and we began to see an occasional oil film (on one occasion a large quantity of it) polluting our river. Eventually the ponds were dredged at considerable expense because the silt was classified as hazardous waste.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1832

Received: 30/11/2016

Respondent: Mrs Jane Head

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Object to LG1: Cumulative impact of BA1 and LG1; Highway infrastructure, bio-diversity (Corn buntings that nest in the area), This area forms part of low lying chalk lands which will be lost

Full text:

Failure to consider this development in relation to the Baldock development BA1 in particular with the increase in traffic that will travel through the already congested town to travel for employment to Cambridge and toward the A10 via A507

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1889

Received: 23/11/2016

Respondent: Ms Hilary Wood

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP15 -LG1: Green belt, urban sprawl, highway infrastructure, conservation and heritage, community infrastructure, car parking facilities, affordable housing need, protection of natural environment, occupy empty houses and businesses, brownfield first, park and ride services.

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1927

Received: 23/11/2016

Respondent: Mrs Bernie Hancock

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP15 - LG1:
- Agricultural Land
- Loss of Green Belt
- Wild life, protected/endangered species and biodiversity
- Brownfield site available

Full text:

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

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1946

Received: 23/11/2016

Respondent: Ms Vicky Cameron

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP15: Green Belt, biodiversity, conflict with Garden City principles, loss of countryside, detrimental effect on local facilities, GP capacity, education provision, traffic

Full text:

I am writing to express my concerns about the 900 dwellings planned for Letchworth.
I am concerned about the soundness of the plan. Letchworth is the template and original Garden City, and I believe the Green Belt is an integral part of that. The plan is in conflict with the national Green Belt policy (section 9 of the NPPF).
I do not believe that there is justification for this excessive target, and think wherever possible dwellings should be built on brown field sites first. Currently this is not the case and doesn't take properly into account the Green Belt constraints. Destruction of the green belt will also have a massive impact on local flora and fauna, much of which is already compromised.

As well as the impact of this particular part, the cumulative effect of all the local building work will lead to many villages merging into one another, and even less countryside being left. These plans will have a majorly detrimental effect on local facilities. It is already almost impossible to get a place at a Dr surgery, and some are already turning people away, those still accepting people have a long waiting time to see anyone. Local schools are over subscribed, and we already have 3 secondary that are consulting on increasing their intake, based on current levels. Roads are often queueing, and the A1 is often queued back to Baldock Road, and at a standstill when you actually reach it.

I am born and bred in Letchworth, and would hate to see an already strained town, put under even more stress. I feel these dwellings would destroy Letchworth as it is now, and was planned to be.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2102

Received: 25/11/2016

Respondent: Miss and M Sally and Darren Charter and Milligan

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP15 - LG1:
- Building on the Green Belt
- First Garden City
- Agricultural land
- Access to Open Space
- Wildlife and biodiversity
- Affordable housing
- Highway infrastructure and congestion
- Education facilities

Full text:

Myself and my partner Darren Milligan strongly object to the building of 1000 houses on green belt land to the north of the Grange estate in Letchworth. Letchworth, the world's first garden city was designed with a green/agricultural belt, to allow residents access to the countryside and to keep Letchworth separate from surrounding towns and villages. The proposed development will leave just ONE field between the development and Stotfold.

Our objections are:

-We believe that building on Letchworth's green belt is wrong in principle. Once the precedent is set the green belt around other parts of Letchworth will be under threat from development.
-The area for development has part of the Letchworth greenway on it, this 13.6 mile circular path was created in 2003 to mark Letchworth's centenary. It cost £1 million and walkers, runners and cyclists alike enjoy using it all year round. There is lots of wildlife on the greenway and losing it would be a great loss to many.
-We don't think that building on green belt land will address local housing needs. Only a fraction of the housing will be 'affordable' housing for rent and its likely that two thirds of the housing for sale will be bought by buy to let investors.
-There will be significant additional traffic in the town with increased congestion, and pressure on already limited parking for commuters, residents and wider users of the town.
-Schools are an issue, Letchworth has lost 2 secondary schools and 2 primary schools in the last 20 or so years. Housing developments have been built on the land of 3 of the 4 schools that have closed down, surely more houses means more children who need a school place? I cannot believe that 2 secondary schools is enough for all the children of Letchworth. Building 1000 more houses would surely stretch the 2 remaining secondary schools beyond their limit.


Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2181

Received: 30/11/2016

Respondent: Ms Caroline Crawford

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP15 - LG1:
- Highway infrastructure and congestion
- Access option

Full text:


I would like to object to the local plan regarding access for building houses on the The Grange, Letchworth. I am aware houses need to be built but I oppose the access route via The Grange.
We have such an influx of traffic coming into & out of the estate as it is and I have been assured via The Heritage Foundation when a traffic flow was done in October 2013 that extra parking would be enabled via the grass verges to alleviate the roads.
The main route out, Northfields & Eastern Way is always a problem with cars parked on both sides of the road, which I recently had an accident on. Then further round on Eastern Way buses are trying to access the estate with sometimes only one lane of traffic moving due to more parked cars.
I personally would like to see access up the hill from the Stotfold roundabout near the Fairfield estate. Or alternatively from along Norton road also an accident black spot so a new roundabout along that road from Norton to Stotfold would slow the traffic down.
I hope my objections to the access route are considered.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2276

Received: 30/11/2016

Respondent: Mrs Elizabeth Battarbee

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Objection to SP15: Site LG1:
-this amount of housing not required
-breach of both the Council's aims and objectives (with regard to transport and congestion), together with those of the original Garden City movement.
-access to both town and country
-increases in traffic (further away from the town centres/shops/stations, and number of houses)
-pollution
-train consultations: proposing to reduce particular services
-infrastructure provision
-provision needs to be clear:town centre and residential parking, doctors, schools, public transport.
-empty homes in Letchworth - conversion and allocation needed
-need for housing lower than quoted in the plan

Full text:

I wish to note my objection to the housing expansion on the north of the Grange Policy SP15: Site LG1 - North of Letchworth Garden City

I do not believe this amount of housing is required, and I consider that the development is in breach of both the Council's aims and objectives (with regard to transport and congestion), together with those of the original Garden City movement. The Council is eager to promote the Garden City movement and its origins, both for academic and tourist appeal, and it must therefore honour these objectives and principles. The Garden City design was based upon a particular number of people being able to access both town and country; increasing the size of our town by too high a percentage makes this ambition impossible for residents in these new housing areas.

Any of the developments will create huge increases in traffic (both because of their location further away from the town centres/shops/stations, and because of the sheer number of houses). The council argues that it is working towards reducing traffic congestion and pollution, but these ambitions are incompatible with the proposed housing developments. Current train consultations are also proposing to reduce particular services from Letchworth to London causing more pressure and stress on those transport routes. Locally, there is a lack of reference in the proposals to crucial developments in infrastructure to cope with this influx of cars and people. Provision needs to be clear with regard to town centre and residential parking, doctors, schools, public transport.

It is my understanding that during an assessment in 2013, there were over 1000 empty homes in Letchworth. This is a waste of useable accommodation; converting and allocating these into useable accommodation would go a considerable way to solving the housing crisis. The local need for housing (in order to meet local population requirements and increases) has been independently assessed at 6000 new dwellings by 2031. Not the much greater amount quoted in the plan.

In summary, I believe greater care should be taken to ensure the correct number of houses are provided to cater for the predicted increase (rather than quick profit), and greater respect and honesty should be displayed towards the claims of the council to reduce pollution and congestion, whilst subscribing and promoting the original aims of the Garden City movement.

Thank you for taking the time to consider my representations.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2277

Received: 30/11/2016

Respondent: Mr Jonathan P Dawson

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Objection to LG1:
- Green Belt
- principles of Ebenezer Howard
- loss of vital green spaces
- scant regard for the impact on the environment and the current Letchworth residents
- infrastructure: may be necessary to implement a one-way traffic system around Letchworth
- no mention of the potential to develop the existing buildings in the town centre, ie the old Grammar School or the Goldsmith's Centre.
- need for sympathetic development
- traffic flow and width of roads
- lack of public support

Full text:

I wish to register my objection to the proposals to develop land specifically on the green belt north of the Grange Estate, LG1
It seems to me that the proposals go against everything that Ebenezer Howard was trying to achieve with Letchworth Garden City.
As well as the loss of vital green spaces, there has been scant regard for the impact on the environment and the current Letchworth residents.
It is clear that the proposals pay little attention to the catastrophic infrastructure ramifications of the proposed developments. Has anyone considered that it may be necessary to implement a one-way traffic system around Letchworth (as currently exists in Stevenage Old Town)? There are already logjams along the entire length of Norton Way North/South at several times during most days of the week!
I can also see no mention of the potential to develop the existing buildings in the town centre, ie the old Grammar School (which presumably has the same attractions as the old Norton School building) or the Goldsmith's Centre.

My confidence in the ability of NHDC to sympathetically develop anywhere in Letchworth is seriously undermined by its recent developments around the Avenue One/Sainsbury's area, where on street parking already causes major disruptions to
traffic flow simply because the planners did not think to make the roads wide enough!!!!
Little wonder that I can find no-one in Letchworth who supports the current proposals.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2284

Received: 30/11/2016

Respondent: Ms Sally Dawson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP15 - LG1:
- Highway infrastructure and congestion
- Air quality and pollution
- Parking infrastructure
- Green Belt and 'exceptional circumstances'
- Available Brownfield Sites
- Utilise empty buildings/properties
- Transport assessment
- The greenway should be left 'as is' or Letchworth will lose it's identity
- Preserve Heritage
- Garden City Principles
- Loss of Town Character
- New Garden City

Full text:

The proposed North of the Grange development will increase the vehicle movements per day through the Grange Estate by between 3,000 and 6,000. I am extremely concerned that any plan addresses this in detail. Pollution and congestion will be increased still further; and it is already a major problem. Parking is increasingly causing gridlocks in Norton Way South, Glebe Road, Cowslip Hill and surrounding side roads. It is only a matter of time before this extends onto Norton Road and Norton Way North. Chaos will then ensue as these roads cannot cope, plus these are original LGC properties which are suffering. I have no confidence that this will be looked at properly. Letchworth has implemented too many poor road design decisions already which are neither currently viable nor future proof..

Careful assessment of the roads most affected should be made - some of our oldest Letchworth buildings (e.g. the Settlement) particular must not bear the brunt of the traffic, whilst side roads must not become 'short cuts' or congested with parked cars.

Many local areas have potential for change without encroaching on the Green Belt.

Brownfield sites including derelict land, disused garage areas etc must be utilised first and empty homes numbering over 1000 in the area should be forced back into use.
The Wynd and Station Road shopping parade should include more flats above.

All empty properties in the town should be used: eg. the old 'Tower' Shop. They should all be identified and used unless there are sound reasons why not. Letchworth has not expanded as a shopping centre, and this must be faced.

Therefore, developing empty properties and brownfield site usage must be maximised.

This whole issue should be explored further through the transport assessments that will accompany any planning applications on these sites. This will help to determine the most appropriate approach, and any other local measures which may be required, on a case-by-case basis. The requirement for radical changes in transport management should be acknowledged and therefore equally far sighted solutions be discussed. "A one-way system to take a percentage of the traffic away from already congested areas such as Norton Way North and South should be considered".

The greenway should be left 'as is' or Letchworth will lose it's identity. There is no issue with the need for new housing; just not created in this way, in this space. I am not convinced that the well documented arguments are sufficient evidence that this is the way to go. Green space is in the end good for you - one day perhaps this hard to measure impact will be seen in mental and physical health terms rather than simply utilisable spaces in which numbers of houses can be placed. I wonder who in any case would benefit from most of the building? Those most in need or more commuter belt housing?

We need to preserve our heritage, and consider what is being destroyed, not just now but for future generations. We cannot get back what we destroy. This garden city is not just bricks and mortar; it is a community which needs to be protected. It needs a heart. That comes from good design and careful development. Too much of the towns character has already gone.

So firstly, I would therefore focus on the brownfield sites and empty building - maximising and utilising them - but even so, sweeping changes need to be made to our town's roads in order to accommodate any more traffic. Our town centre is full of empty shops, and I can't see that will ever change. They, and empty flats should be used for housing. It is really sad to see the centre in such a bad way, but who is going to take on these expensive spaces except charity shops now? Letchworth missed it's chance a long time ago to be a vibrant town centre like Hitchin, or a bustling garden city like WGC. Logically therefore there is little in the very centre to destroy except a few key buildings - and it might be possible to convert the Old Grammar School after De Vinci closes, and re-purpose or rebuild the Goldsmith Centre, which has no provenance. Both of these are large spaces, and are not addressed in the plan as far as I can see.

Once all options of this nature are exhausted, discuss other options, such as another Garden City. These existing conditions are not the exceptional circumstances the government requires!

Please note:

This is what happened when I tried to submit online without answering questions to which I do not, and could not, know the answer. Therefore please accept this as a cobbled together last minute objection, taken from my on-line (failed) submission. I would like to object strongly to the way this consultation software has been designed - to obfuscate and inhibit.

"One of your representations has failed to submit. Please correct the errors listed below and then resubmit all remaining drafts.

You must choose if you consider the DPD to be Legally compliant.

You must choose if you consider the DPD to be Sound.

You must choose if you consider the document to comply with the duty to co-operate.

You must choose how you wish your representation to be considered at the examination

Validation failed ................................................................................"

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2309

Received: 30/11/2016

Respondent: Mr Nick Hailstone

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to SP15 - LG1:
- Brownfield sites first
- Building on the Green Belt

Full text:

I am writing to complain about the proposed plans for construction in the area. There are plenty of brown-field site that can be developed, and the few recent examples such as Blackhorse Road in Letchworth have gone down well. But instead of developing on the remaining ones you are planning to build on green belt land. This appears to defeat the whole object of a garden city.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2330

Received: 30/11/2016

Respondent: Mr Martin Phillips

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to LG1:
- Building on Greenbelt Land
- Transport
- Education facilities
- Brownfield sites
- Build a new town with proper infrastructure

Full text:

I wish to object to your planning application to build on GREENBELT land ref: LG1.

Clearly no thought has gone into this application. The local are especially the Grange Estate cannot cope with todays traffic flow let alone with another 4000+ cars daily, the roads were not built for such an amount of traffic. The community cannot cope with more people, we have shut schools in the past and now pupils have to travel far and wide just to get an education, ridiculous in a 'green' society. You cannot get an appointment at your local GP for love nor money.

And now you want to build on GREENBELT land just because Letchworth Heritage Foundation want some money, it's a disgrace! Plenty of Brownfield site just open your eyes!

Please think again, build a new town with proper infrastructure that can cope for the next 100 years and not screw up what was actually a great idea in 1903, think again .... Ebenezer Howard will be turning in his grave

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2353

Received: 30/11/2016

Respondent: Mr Steve Ingle

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to LG3:
- Scale of development
- Garden City heritage
- Building on Green Belt
- Both the LG1 and LG3 sites risk merging Letchworth with stotfold and Baldock
- Increase traffic and congestions
- Increase in pollution
- Pedestrian safety
- Highway infrastructure
- Community facilities and health care
- Brownfield first
- New garden city/township

Full text:

I wish to register my opposition to the plans for the LG1 and LG3 sites in Letchworth as part of the council's local plan.

I believe that the number of proposed dwellings would have an extremely detrimental effect on the local area and on Letchworth Garden City as a whole. Building on Green Belt is unacceptable as it flies in the face of Ebeneezer Howard's principals for a Garden City and current government advice. It seems very odd to destroy the key principals the first gardens city whilst the government plans to build new garden cities.

Both the LG1 and LG3 sites risk merging Letchworth with stotfold and Baldock respectively, LG1 will expand Letchworth to within 50m of the Bedfordshire border. Any proposed sites should avoid urban sprawl and therefore I believe that this is unacceptable.

Both sites (particularly LG1 ) will greatly increase the traffic in the area and therefore increase the amount of pollution in the area as well. Many of the roads in especially Norton road and Green lane are already at capacity during peak times.The proposed sites are about 1.5 miles (2.4 km) away from Letchworth Rail Station. As acknowledged in the COTTEE report this is outside of expected walking distances hence additional traffic will add to congestion suffered at peak times. The station also has no infrastructure to cope with the likely increase in cars.

With the infrastructure of the town as a whole it lacks the doctors and schools to support the developments and there is no mention of how this will be addressed within the plans.

The LG3 site it proposed to be built right next to the newly discovered Bronze Age Henge, a site of national significance this should be celebrated and enjoyed rather than surrounding it with houses.

There are many brownfield sites within north Hertfordshire which though may not be as profitable should be built on first. If further housing is required then proposals suggested by our local MPs should be pursued and a new garden city established this would enhance Letchworth legacy rather than the current plans which would destroy it.

I hope you take these objections seriously.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2408

Received: 26/11/2016

Respondent: Ms Gillian Farron

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Objection to SP15: LG1 on the grounds of:
- water supply
- sewage facilities
- roads
- need to give existing residents access to the countryside via the Greenway and local parks

Full text:

I object strongly to the Local Plan, particularly the 900 houses suggested to wrap around the Grange Estate. Letchworth simply cannot cope with the addition of so many new homes. It does not have enough water, sewage facilities or even roads to get more people to other destinations. Combined with this is the need to give residents already here the opportunity for access to the wider countryside via the Greenway and the local parks. The green acres should not be mutilated by unwanted housing.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2468

Received: 30/11/2016

Respondent: Ms Wendy Gross

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to LG1:
- Unique Heritage and Heritage Assets (First Garden City)
- Garden city principles
- Scale of development
- Highway infrastructure and congestion
- Site owner
- Loss of Green Belt- no "very special circumstances" identified
- Environmental impact and weakening communities
- Wildlife, protected species and Biodiversity
- Archaeological Land
- Agricultural Land

Full text:

I object to North Herts District Council's Local Plan 2011 - 2031 as follows.
I object to NS1, GA1and GA2 proposed housing for Stevenage expansion into Hertfordshire Green Belt; EL1,EL2 and EL3 proposed housing for Luton overspill in to Hertfordshire Green Belt; BA1 proposed near doubling of the town of Baldock into Green Belt land; HT1 proposed incursion into Green Belt bringing Hitchin within a stone's throw of Letchworth. It is against Government policy to build on Green belt land unless "very special circumstances" pertain (see Appendix 1). Nowhere in the Local Plan are any "very special circumstance" identified. The Green Belt was expressly put into place to curb urban sprawl. The siting of these proposed developments, mostly adjoining already existing estates is typical of the urban sprawl long discredited by town planners for its poor environmental impact and weakening of community. Several hitherto distinct village communities such as Cockernhoe, Gravely and Bygrave will be either absorbed. The Green belt promotes physical and mental health by providing recreational space. It is vital for biodiversity, especially when 60% of British wild species are in decline. Up to the present, NHDC has a good record of management of the Green belt. In its Biodiversity Action Plan of 2005 it pledged to protect it (see Appendix 2). This measure, having had no formal modifications since, is deemed to be still in force. Therefore I question the legality of NHDC's proposed flagrant disregard of it.
The site LG1 is ancient cultivated land dating back to medieval times and probably far beyond. Its ditches, banks and hedges are artefacts of early agricultural systems of archaeological significance. There are a number of pollarded oak trees estimated to be over four centuries old. These features carry their own biodiversity which has evolved over the same time-span. The richness of biodiversity is also the result of soil diversity, generated by the particular mix of sand, gravel, chalk and boulder clay laid 500,000 years ago in the last glaciations and known to geologists as 'The Letchworth Gravels'. NHDC has played its part too, cutting down the use of agri-chemicals and encouraging wide field margins. 114 bird species have been recorded, 28 of which are endangered, together with Great Crested Newt, Brown Hare, Common Toad, Polecat and 3 rare butterfly species (see Appendix 3). There is a House Sparrow roost of over 300 birds, the biggest in the county which is now under consideration for a designation of protected status. There is in increasing currency an idea that land lost to the Green Belt can be balanced by new Green belt designation elsewhere. Quite apart from the fact that there is no spare land in North Herts for such new designation, an eco-system such as that of LG1 cannot be moved as its centuries of evolution has been specific to that site.

I object to site LG1 because of the threat it poses to the unique heritage of Letchworth. This heritage is that of the world's first garden city, embodying influential principles of town planning and social welfare. Proximity to the open countryside was one of them, to which end the founding father, Ebenezer Howard, proposed to limit the population to 32,000 (thereby limiting the footprint of the town) (see Appendix 4). He further stated nowhere on the urban boundary should be more than 15 minutes walk from the town centre. Such principles have already been infringed but this is no reason to abandon the spirit of them; there is still a heritage to be preserved if tourists and visiting students of town-planning from all over the world are not to be disappointed. Another principle was the town should be self-sustaining, in the sense that the population would work locally, so housing and industry were carefully balanced. Rather than use the opportunity to restore this balance, the Local Plan proposes to upset it further. With the increase in population generated by LG1, plus the change of use from industrial to residential of many of the smaller sites in the town under the Plan, the percentage of residents employed locally will sharply decrease. Letchworth will become predominantly a dormitory town with all the weakening of community that entails. The increase in commuter numbers will cause insuperable problems for road infrastructure as Letchworth's narrow roads were designed for low car use. In a self-sustaining town everybody could walk to work or school. The crucial routes from LG1 into the town centre and station are already bottlenecks: narrow roads lined with grass verges and specimen trees, some rare, which cannot be removed for road widening without completely destroying the distinctive garden city ambience.

I object to site LG1 because of the circumstances of its proposed sale by the owners. The owners, Letchworth Garden City Heritage Foundation, propose to abdicate its responsibilities to protect and preserve the site. The Foundation was set up by Parliament in 1993 to continue the town's development by Ebenezer Howard's the principles, of which the Green Belt was one - the world's first Green Belt. The sale of this land is a betrayal of principle by those whom Parliament has charged to be its protector. The sale of the land could be (and should be) open to legal challenge.

I wish to object to the development site LG6. This land was compulsorily purchased by Letchworth Urban District Council as part of the Jackman Estate land. The Inspector at the time stipulated that it should be left as a Garden City-style green space. NHDC now wants to forget this decision, together with its own Biodiversity Action Plan (2005) which identified the same piece of land as an Urban Wildlife Site to be protected.
I wish to oppose the LG10 which would nearly double the number of households using Croft Lane, part of Norton old village. The pond at Norton is a breeding area for toads and other species which make their way to the pond inevitably crossing local roads especially Croft Lane. Doubling of the traffic would risk wiping them out.

Appendix 1

Extract from Hansard 15.7.2016
Green-belt Land
Next


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18 July 2016
Volume 613
* Philip Davies (Shipley) (Con)
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16. What his Department's policy is on the building of houses on green-belt land. [905899]
* The Minister for Housing and Planning (Gavin Barwell)

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The Government are committed to the strong protection and enhancement of green-belt land. Within the green belt, most new building is inappropriate and should be refused planning permission except in very special circumstances.
* Philip Davies


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I welcome the Minister to his post, although I am sure he is disappointed to no longer be my Whip.
My constituents in Burley-in-Wharfedale, and other villages such as Baildon and Eldwick, to name but a few, are facing planning proposals for green-belt land, with 500 houses proposed for Burley-in-Wharfedale alone. Surely the whole point of the green belt is that it should not be subject to housing, and particularly not until all brownfield sites in the district have been built on. My constituents do not trust Bradford council to look after their interests, so they look to the Government to protect them. What can my hon. Friend do to protect their interests and stop that building on the green belt?
* Gavin Barwell

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I thank my hon. Friend for his kind words and wish his new Whip the best of luck.
If he looks through the national planning policy framework, he will see a clear description of what development is appropriate on the green belt, and a strong presumption that inappropriate development is harmful and should not be approved except in very special circumstances.
* Mr Speaker

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The Whip will certainly need to be a natural optimist.

Appendix 2

North Hertfordshire District Council Biodiversity Action Plan (2005)
Foreword
Diverse rural and urban landscapes, their integral habitats and wildlife, still make North Hertfordshire a very special place in which to live and work. However we should not become complacent, for all is not well. Many changes, some quite dramatic and others very subtle, continue to degrade local habitats, reduce the diversity of wildlife and threaten the qualities of our surroundings.
The importance that your Council places upon the environment that we share, not least with many important facets of wildlife that indicate its health, is clearly outlined within its corporate vision. Its priorities promote conservation of our historic towns and rural settlements together with protection of the countryside.
In the wake of national and international concerns about environmental degradations together with loss of biodiversity, including the tenet to 'think globally, act locally', the Council initiated measures to effect positive local conservation to both habitats and species. Detailed studies and correlation of holdings of data have facilitated a timely overview that elucidates the ranges and status of the District's wildlife and wild places, and have facilitated production of this, our very own Local Biodiversity Action Plan.
With policies and evolving programmes towards effective conservation of the environment we share, the North Hertfordshire Bio-diversity Action Plan meets criteria of the Council's vision and priorities. However, these can only be really workable if each and everyone of us share in the many challenges and commitments required to ensure appropriate care for our surroundings, whether it be in town or countryside
Your Council will lead these challenges but there will be opportunity for all of us to be involved, not least toward education at all levels, joining partnerships and actively supporting the care that our urban and rural countryside needs and deserves.
Local Actions make Global Changes
Leader North Hertfordshire District Council
Councillor F.J. Smith

Appendix 3
BIODIVERSITY OF SITE LG1
Red-listed species
(Red -listed species have the highest conservation priority. In addition, where indicated SAP, some are subject to national Species Action Plans )

Skylark (SAP)
Lesser Redpoll
Common Linnet (SAP)
Cuckoo
Corn Bunting (SAP)
Yellowhammer (SAP)
Reed Bunting (SAP)
Yellow wagtail
House Sparrow
Grey Partridge (SAP)
Dunnock
Common Bullfinch (SAP)
European Turtle Dove (SAP)
Common Starling
Song Thrush (SAP)
Northern Lapwing (SAP)
Woodcock
Grasshopper Warbler
Fieldfare Redwing
Mistle Thrush
Nightingale
Whinchat
Grey Wagtail
Bittern
Red Kite

A further 20 or so species found on the site are amber-listed: unfavourable status in Europe

Other red-listed fauna found on Local Plan site LG1
Brown Hare (SAP)
West European Hedgehog
Polecat
Common Toad
Great Crested Newt (SAP)
Small Heath butterfly
Small Blue butterfly
Wall butterfly

INFORMATION: Brian Sawford: NHDC Countryside Officer (Retd), Curator of Natural History for North Herts Museums Service (Retd).
:Trevor James: Curator of Natural History for North Herts Museums Service (Retd), Director of Herts Biological Records Centre (Retd).
Appendix 4

GARDEN CITIES OF TO-MORROW
Ebenezer Howard
Garden Cities of To-Morrow (London, 1902. Reprinted, edited with a Preface by F. J. Osborn and an Introductory Essay by Lewis Mumford. (London: Faber and Faber, [1946]):50-57, 138- 147.

Let me here introduce a very rough diagram, representing, as I conceive, the true principle on which all towns should grow, Garden City has, we will suppose, grown until it has reached a population of 32,000. How shall it grow? How shall it provide for the needs of others who will be attracted by its numerous advantages? Shall it build on the zone of agricultural land which is around it, and thus for ever destroy its right to be called a 'Garden City'? Surely not. This disastrous result would indeed take place if the land around the town were, as is the land around our present cities, owned by private individuals anxious to make a profit out of it. For then, as the town filled up, the agricultural land would become 'ripe' for building purposes, and the beauty and healthfulness of the town would be quickly destroyed. But the land around Garden City is, fortunately, not in the hands of private individuals: it is in the hands of the people: and is to be administered, not in the supposed interests of the few, but in the real interests of the whole community.


Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2497

Received: 30/11/2016

Respondent: Ms Louisa Ingle

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object on the following grounds:
detrimental effect on the local area and the Garden City as a whole;
goes against the design principles of the Garden City;
brownfield sites should be used;
protection of the green belt and the Greenway;
possible merging of Letchworth with Stotfold;
road congestion; and
no provision for education or healthcare services.

Full text:

I wish to register my opposition to building on the LG1 and LG3 sites in Letchworth as part of the council's local plan.

I believe that the number of proposed dwellings (especially in LG1) would have an extremely detrimental effect on the local area and on Letchworth Garden City as a whole. Building on Green Belt is unacceptable as it flies in the face of Ebeneezer Howard's principals for a Garden City and current government advice.

There are a number of brownfield sites around the town that should be redeveloped and used in place of this valuable countryside. The Green Belt and Greenway are the jewel in Letchworth's crown and should be protected rather than destroyed.

In addition, the proposed development would take Letchworth to within a few metres of the border with Bedfordshire (LG1) and potentially merge the town with Stotfold, which is also currently expanding at a rapid rate. LG3 also sees Letchworth move even closer to Baldock, with only the A1 and a field dividing the two towns.

The local road network is already extremely congested during peak hours, especially the junction of Norton Way and Green Lane and these developments would only serve to exacerbate this situation. The COTTEE report that was commissioned by the Heritage Foundation states that
1. "Letchworth town centre is about 3km walk (40 mins) which, although outside standard walking distances, is not unreasonable as a walk to work for an adult or college student."

This clearly implies that most residents in the new developments will travel by car to the town centre or station as LG1 will be "outside standard walking distances". LG3 will also be around this distance from the station and the town centre with Talbot Way being 2.6km from the station.
There is also no provision in the plan for any more school places or access to health care. Existing services are already being stretched- how will local services provide for this substantial growth in the local population? Are there sufficient school places for the expected number of children or will we see families forced to travel further afield to access schools or hastily erected temporary classrooms?
I would urge North Herts council to protect Letchworth, the world's first garden city, and to consider alternatives such as a new Garden City, which is an option supported by local MPs, Stephen MacPartland, Sir Oliver Heald and Peter Lilley. (http://www.thecomet.net/news/mps_back_new_garden_city_as_alternative_to_council_s_north_herts_housing_blueprint_1_3936165)
The role of the council is to represent the people. Please listen to the opinions of the people you represent. Once the Green Belt has been built over, it is lost forever. Please do not remove the "green lungs" and also the heart of the Garden City.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2532

Received: 30/11/2016

Respondent: Mr & Mrs Martin & Mary Penny

Number of people: 2

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP15 - LG1:
- Worlds first Garden City
- Landscape Character
- Healthcare, Education and other amenities
- Highway infrastructure, safety, parking and congestion
- Village Character
- Impact on water table
- Loss of Green Belt
- Brownfield sites first

Full text:

Formal Response to consultation on North Hertfordshire District Council 3
Local Plan 2011-2031 (proposed submission)

We are writing to object to the proposed Local Plan 2011-2031 that NHDC has recently submitted for consultation.

Section 4.187 of the plan comments that "Letchworth holds a special place as the world's first garden city. Although development of the town to Ebenezer Howard's original vision of 32,000 residents has been achieved, it is considered there remains scope for a sensitive extension of the town to the north, which respects the town's original ideals while making provision for the needs of the 21st Century. "

Nowhere are these needs set out. We do not understand how removing the 'green lungs' and open spaces (notably around the Greenway) of the areas marked LG1, LG4 and LG10 and replacing them with 1000 houses can be characterised as 'sensitive'.

This area of the town is already under considerable pressure due to the low provision of doctors, dentists, schools and other amenities. Bus services have been reduced and the increase of traffic through the Grange Estate (estimated at 3000-6000 vehicles) would put immense pressure on the junction of Norton Road, Norton Way North, and Eastern Way. The alternative of a relief road connecting directly onto the Stotfold Road is likely to create a tempting and dangerous 'rat-run' for north-bound traffic through the estate.

With regard to LG10, we are also unclear as to how additional traffic through Croft Lane and Cashio Lane can be safely accommodated without a widening scheme that removes the 'country village' character so jealously preserved for so long and a key part of the Garden City Pioneer's vision for the town. The field is a relatively small site and 37 properties will have a significant impact - not least on the water table (the area is prone to flooding due to 'heave' - the same mechanism that fills Norton Pond).

Clearly this many additional residents will create additional commuter traffic, adding to the considerable current congestion at peak times on the approaches to Junction 9 and southbound am/northbound pm on the A1(M). There is already a shortage of public parking for commuters north of the railway - where can more cars go?

We believe that building on Greenbelt should be a last resort. There are several brownfield sites such as Icknield Way East, Radburn Way, Station Road, The Wynd and Arena Parade that would provide suitable sites and whose development would improve the local scene.

In summary, it is hard to see how developments LG1, LG4 and LG10 in any way reflect the "original ideals" of Ebenezer Howard of creating a healthy, safe, self-sustaining community.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2574

Received: 30/11/2016

Respondent: Mr and Mrs David and Alison Ribchester

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to LG1:
- Heritage assets
- Village character
- Building on the Green Belt
- Community facilities (Doctors, dentists, schools and other amenities will be required)
- Highway infrastructure and congestion
- Housing need assessment
- Brownfield sites first
- Impact on conservation area
- Wildlife and biodiversity
- Flood risk
- Green space
- Housing design
- Pollution

Full text:

I am writing to object to the proposed Local Plan 2011-2031 that NHDC has recently submitted for consultation. As a resident of Letchworth Garden City I do not feel that any of the plan relating to Letchworth and surrounding areas is in line with current Garden City developments or historic character housing.
Section 4.187 of the plan comments that "Letchworth holds a special place as the world's first garden city. Although development of the town to Ebenezer Howard's original vision of 32,000 residents has been achieved, it is considered there remains scope for a sensitive extension of the town to the north, which respects the town's original ideals while making provision for the needs of the 21st Century. "
This area, marked as LG1 in the plan is north of the Grange. This area of the town is GREENBELT LAND. The proposed area of development expands the town to nearer to Stotfold and comes within 50m of Bedfordshire border at Fairfield Park. This is such a huge development that I wonder if thought has really been given to how the town will cope with such an influx in its population? Doctors, dentists, schools and other amenities will be required. Along with the increase of traffic through the Estate (estimated at 3000-6000 vehicles) the pollution levels of the town will rocket - this is totally against the councils own policies!
It also alarms me greatly that NHDC are considering building on GREENBELT land. Land that has historically been there to preserve the green nature of our towns and cities. Surely it is well known that councils no longer need to invade greenbelt land to meet housing needs??
The true local need of housing in North Hertfordshire (as determined by Consultants for the Council) is 6000 new dwellings. Why then, does the Local plan suggest 12000? DOUBLE WHAT THE STATED NEED ACTUALLY REQUIRES.
Building on Greenbelt should be a last resort. We should utilise all the brownfield sites around the town (of which there are several - Icknield Way East, Radburn Way, Station Road, The Wynd and Arena Parade) In particular I would prefer to see the Wynd and Station Road shops redeveloped to include flats above.
Other developments in the north of Letchworth will also have a negative impact to the town. Building 37 houses on the old Norton School playing field (LG10) will negatively impact the conservation area within Norton and Norton Pond. Massively increased traffic around Cashio Lane, Croft Lane and Norton Road will be detrimental to the toads in the pond. The area is also prone to flooding and the field is a flood plain. Building houses on this area will be an unwise move. The field is also a relatively small areas -and packing 37 houses onto it will not be in keeping with the character heritage houses which surround the field and which the Heritage Foundation fight so hard to keep looking the same as when they were built!
Ton conclude, we need to be creative with our housing - not tacking huge developments on to the top of the town without a creative thought or process behind it. Not squashing houses onto every green space we can find regardless of wildlife! We need to save our green fields for future generations to enjoy. We should not build houses that are not currently required just because we can. We need to think about how to meet the need for local housing in a unique, creative and inspirational way. We should follow the example of Ebenezer Howard and create a Garden City nearby - a town that we can be proud of. A town that is not crowded, busy, polluted and without character!