Policy SP15: Site LG1 - North of Letchworth Garden City

I have tried to navigate your online form unsuccessfully.

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

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

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

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

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

Ebenezer Howard was already aware of the danger of the urban sprawl, which is why he developed the concept of the agricultural belt, now known as the green belt and is such a vitally important part of town planning all over the world, something we seem to be in a hurry now to get rid of in our Garden City.

He would have been horrified to learn that this urban sprawl was now, in fact, threatening the whole of Hertfordshire, but I am digressing from Letchworth.

Ebenezer's Garden City was always planned to provide housing AND work; it was very much meant to be an industrial town, not a commuter town; closeness to nature and wildlife were good for the body and soul; roses may look great but veggies tasted grand!

Last of all is the threat to the biodiversity of LG1 North of the Grange Estate, Letchworth which is devastating. I believe Brian Sawford has given you all the details of the species of wildlife which we may well stand to lose for evermore if the housing development is given the green light.

As custodians of Ebenezer's heritage our generation owes him to make it clear to all that we OBJECT to the LG1 housing development North of the Grange.

See attached

There are many issues which indicate that the development of land north of the Grange for 1,000 houses is not appropriate or acceptable.

The Green Belt issue. We should not be building on Green Belt land as it is designed to be there for a very good reason. The proposed North of the Grange development encroaches on Letchworth's Green Belt and expands the town nearer to Stotfold and comes to within 50 metres of the Bedfordshire border at Fairfield. Any housing plans should specifically prevent urban sprawl; existing Green Belt land should be the very last option.
Councils no longer need to invade their Green Belts 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).]

Increase in local population beyond designed capacity: The Letchworth Garden City Heritage Foundation's total proposals for about 2,000 new dwellings in Letchworth (including the 1,000 north of the Grange) would increase Letchworth's population by about 5,000, raising it to almost 40,000; almost 8,000 above Ebenezer Howard's planned 32,000.

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. The totals will depend on whether any, and if so which, relief roads to the Norton Road and to the Stotfold Road are built. Pollution and congestion will be increased, which is going against the NHDC's own policies.

There is no public parking for commuters north of the railway. Letchworth is already groaning under commuter parking. The NHDC is struggling to protect the town and homeowners from difficulties associated with this issue.

Infrastructure is lacking for doctors, roads, motorways and schools.

The adverse effect on loss of farmland, nature and ancient hedgerows does not seem to have been considered.

The proposed area north of the Grange is extremely well used by residents of Letchworth and beyond for nature and recreation, accessing footpaths and spaces for jogging, walking, cycling, nature appreciation. The adverse effect on the health and well being of families in this area is not recognised in the proposed destruction of this precious Green Belt space.

I suggest that Brownfield sites including derelict land, disused garage areas etc must be utilised first and empty homes numbering over 1000 in the area be forced back into use. A small new Garden City buffered from joining existing towns would be preferable to adding housing to existing struggling developments. It would include properly planned infrastructure and would create a considerable amount of jobs.

I urge the Secretary of State to consider that this development is not appropriate in Letchworth Garden City for the reasons above.

We reside in Area LG1 and write understanding that North Herts District Council Cabinet approved the Local Plan which is now in the Pre-submission stage, we respond in order to register our objections to the Plan. In brief:
1. The South of England is already over-developed. There are strains on local services (already badly affected by the political choice of "austerity" to extend viability of banks and their instruments) and also on transport. Yet parts of the North are deprived. What is needed is a more informed regional development policy to rebalance the North-South divide, before this starts to affect cohesion.
2. Government policy clearly states there must be 'very exceptional circumstances' plus 'the support of the community' for development on the green belt. None of the 10 local plans proposed in Herts have demonstrated 'very special circumstances'.
3. We read that population in North Hertfordshire - based on pre-Brexit projections - is expected to increase of 0.34 per cent per year, for 20 years. Even this suggests a housing "need" of 3,750 additional homes. However, 4,340 homes have already been completed or have permission. We question the justification for 1,600 further homes.
4. Specific to Area LG1, the land north of Letchworth is a valuable countryside resource and resort, as advocated by Howard's principles: one of which was "countryside near at hand". Look at the images. It is of ecological and biodiversity interest too. The separation between Letchworth and Stotfold is already depleted and this large incursion will likely mark the end of these as discrete conurbations. merging of Hitchin to Letchworth and Baldock is another example. Excuses will then be made to build right up to the highways. Why should "countryside near at hand" be lost ? Why should Howard's principles be abandoned and were those better informed about the long term sustainability of towns ?
5. There is potential in ex-industrial sites, as demonstrated in Letchworth, to preserve countryside. But this does not appear to be part of the plan. It seems it must be big, and designed for large developers. This disadvantages smaller developers and actively reduces variety in the built environment. Variety in the built stock is made a virtue in Letchworth.
6. There need to be public transport and employment improvements. Data shows a large proportion travelling out of Letchworth to work. Since the Fairfield development, Cowslip Hill has become a chicaned car park. Area LG1 would put further stress on parking to connect with rail, increase overcrowding on trains (the only solution there appears to be longer trains) and intensify local road traffic. Importantly it would also increase road traffic noise and pollution, both recognised to have health impacts.
7. Much has been made of developing the A1 corridor. Frequent correspondents note the increasing intensity of RTAs and blockages on the A1. It is difficult to see how the A1 can during peak hours cope with any more traffic.
Accordingly, please register our objections.

We are 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 has been accessed adequately with respect to impact on local infrastructure - schools, traffic load and environmental. Furthermore, the plans are not 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."
The area, marked as LG1 in the plan is North of the Grange 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. Traffic between Stotfold and Norton has already seen a dramatic increase since we moved to the area in 2012, with increased traffic speeds and indeed accidents. This area can not contain further development. Additionally with the increase of traffic through the Estate (estimated at 3000-6000 vehicles) the pollution levels of the town will greatly increase.
As a resident it also concerns 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. This strikes of purely a fund raising exercise.
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.

Also of great concern to our family is the proposed building of 37 houses on the old Norton School playing field (LG10). I can see no logical argument that can show 37 properties will positively impact housing shortages. This is clearly a money making exercise by NHDC. It will have a huge negative impact on the conservation area within Norton and Norton Pond. Massively increased traffic on the small roads of Cashio and Croft Lane and increase traffic on Norton Road, which is already far busier than a residential road should be. The school field is also rich with wildlife and plants (Woodpeckers, Herons, King Fishers, Foxes and Deer) and an area of beauty for the residents of Cashio Lane, Croft Lane and Norton Road. Additionally 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!

I agree there is a need to provide access to affordable housing for all, however the plans laid out in the North Hertfordshire District Council 3 Local Plan 2011-2031 are way above local needs will destroy GREENBELT and areas of natural beauty and have a massive negative impact on the local infrastructure of Letchworth and surrounding area. We are completely against these plans.

I'm writing to show how much I disagree with building on green belt, especially the recently proposed in our local area LG1, which would basically join towns together.
I have looked at the plans for LG1 and went to the consultation evenings at the hub in Letchworth.
I object mainly because it's land protected for many a good reason as laid out on the government website under
Planningguidance.communities.gov.uk
http://planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/9-protecting-green-belt-land/#paragraph_79

Also highlighted by housing and planning minister Gavin Barwell
On 15th July 2016
When stated...
"Most building on the green belt is inappropriate and planning permission should be refused except in very special circumstances"
However
The local plan proposes to build large new houses estates on green belt.... yet nowhere in the local plan has NHDC demonstrated any VERY SPECIAL CIRCUMSTANCES.
In fact I see very special circumstances to not build on green belt..
* loss of farm land
* Wildlife, some of which are on the red list from the RSPB
* Public facilities already strained from the population. No new doctors, dentist or schools in proposals.
* A1 motorway is totally unsuitable for the amount of traffic on the roads now, adding more houses won't help the situation just add to the many accidents on the letchworth to welwyn stretch.
* More Public transport needed as building further away from town won't allow residents to walk so easily.
* NHDC are not able to maintain existing roads and pathways and adding more vehicles to the roads will not help this.
* Where will jobs for new residents come from or are we introducing commuters
* Train station has small car park which doesn't accommodate commuters now.

Looking at the whole infrastructure, just doesn't work with more houses.

I feel that not enough residents know about the proposal and the ones that do don't always voice there opinion as feel it won't be heard.

So please look for another solution for the ever increasing population. Not just for a quick fix now but for future generations.
Keep our green belt safe

When all the trees have been cut down,
When all the animals have been hunted,
When all the waters are polluted, when all the air is unsafe to breathe, only then will you discover you cannot eat MONEY

Cree prophecy, North America

I have been looking to these plans and some of the information and a few things concern me that I would like to respond to you with:

Firstly the consultation on this issue seems at best confusing, there is loads of information out there and it is hard for a resident who has concerns to be able to muddle through all the documentation and produce a response that will be listened to. As someone who doesn't know the correct lingo in this area I feel out of depth responding and know many who feel the same way. For such a controversial plan, surely the consultation itself should provide better ways to facilitate a discussion. As a resident that will be affected by any additional housing on the Grange I have had to hunt about for the information that has been published.

Secondly, I would love to understand better the need for this housing - from what I've read on other sources the true local need for new housing for North Hertfordshire District Council (NHDC) (as determined by Consultants for the Council) (i.e. to meet the forecast, natural increase of population by 2031, including North Herts youngsters) from 2011 to 2031 is about 6,000 new dwellings, not the 14000 that NHDC is saying they need. If this 6000 houses was the true number required housing sites could be found from other sources and reduce the need to build north of the Grange in Letchworth.

Thirdly I am incredibly concerned about the additional housing north of the Grange and the impact this will have on traffic through the estate and also on the pressure on our local school. Our estate doesn't need the additional 1000 cars driving through its roads making them less safe for our children.

I am completely against the building of land north of the Grange Estate.
Our town has seen a massive increase in traffic over the last few years and the A1 cannot cope with more commuters traveling southbound in the mornings.
With more traffic comes hold ups and vehicles standing on Tickover in traffic jams is not a healthy situation to be in.
We need to keep our green spaces for our well being our children and our children's children. With more housing comes less peace we simply cannot cope with our schools, doctor surgery at the moment let alone with more housing.
Keep this town green tranquil and with congestion at a minimum, which means no more houses thank you very much.

After careful perusal of the Local Plan I submit objections to site LG1 Policy SP15. I conclude The Local Plan is Not Sound.

1. Building on Green Belt conflicts with the National Planning Policy framework which states that all inappropriate development harmful to the Green Belt is not allowed. There is a very small amount of Green belt to the north of Letchworth Garden City before the Bedfordshire Boundary, this will be greatly reduced by the proposed development.

2. It conflicts with the NHDC Strategic Objectives on Green Belt.

3.It conflicts with NPPF on Transport. The NHDC Traffic modelling is flawed 4.188 It conflicts with NHDC policy on Transport.

4. The local Plan is not sound. The NHDC have not accounted for any impact associated with The Central Bedfordshire Local Plan.

I'm writing to show how much I disagree with building on green belt, especially the recently proposed in our local area, which would basically join towns together.
I have looked at the plans, particularly on the back of the grange.
I object mainly because it's land protected for many a good reason as laid out on the government website under
Planningguidance.communities.gov.uk
http://planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/9-protecting-green-belt-land/#paragraph_79

Also highlighted by housing and planning minister Gavin Barwell
On 15th July 2016
When stated...
"Most building on the green belt is inappropriate and planning permission should be refused except in very special circumstances"
However
The local plan proposes to build large new houses estates on green belt.... yet nowhere in the local plan has NHDC demonstrated any VERY SPECIAL CIRCUMSTANCES.
In fact I see very special circumstances to not build on green belt..
* loss of important farm land
* Wildlife, some of which are on the red list from the RSPB
* Public facilities already strained from the population. No new doctors, dentist or schools in proposals.
* A1 motorway is totally unsuitable for the amount of traffic on the roads now, adding more houses won't help the situation just add to the many accidents on the letchworth to welwyn stretch.
* More Public transport needed as building further away from town won't allow residents to walk so easily.
* NHDC are not able to maintain existing roads and pathways and adding more vehicles to the roads will not help this.
* Where will jobs for new residents come from or are we introducing commuters
* Train station has small car park which doesn't accommodate commuters now.

Looking at the whole infrastructure, just doesn't work with more houses.

I feel that not enough residents know about the proposal and the ones that do don't always voice there opinion as feel it won't be heard.

So please look for another solution for the ever increasing population. Not just for a quick fix now but for future generations.
Keep our green belt safe

When all the trees have been cut down,
When all the animals have been hunted,
When all the waters are polluted, when all the air is unsafe to breathe, only then will you discover you cannot eat MONEY

Cree prophecy, North America

General Comments

1. Historic Towns
I am disappointed and surprised that Letchworth Garden City is not included in your designation of historic towns. The world's first garden city is of national and international importance, much studied and visited by researchers and planners. It is valued too by residents.

2. Numbers
Where have the enormous numbers of required housing come from? Increases of this size cannot be justified for the extension of small settlements such as Letchworth. Many existing residents are beyond child bearing age, so will not be producing more children who require housing. Where will the new residents come from? Letchworth has now reached its planned maximum size of 32,000.

3. Green Belt
Letchworth's Green Belt is an integral part of the garden city. It is where the idea of a green belt was pioneered. It has been much copied around this country and is revered around the world. It is part of national legislation, a valuable and popular part of planning laws. It has been reaffirmed by the present government which states that green belt should not be built on just to meet housing numbers. Open space is needed as well as housing.

Specific Areas
1. LG1 Land north of the Grange Estate
This area is not suitable for a large number of houses, which will destroy the green belt leaving only a narrow one field strip between Letchworth and Stotfold. As well as preventing urban sprawl, this land is valuable for biodiversity.

2. LG3 Land north east of Kristiansand Way
Here the green belt provides separation between Letchworth and the village of Norton, which has a long history as a separate settlement and is valued as such. There are archaeological sites here which need investigation and should not be built on.

Policy SP5 Countryside and the Green Belt
Policy SPG15 Site LG1 North of Letchworth Garden City
Paragraph 13.215 LG3 Land East of Kristiansand Way and Talbot Way
Where a large areas of existing Metropolitan Green Belt North and East of Letchworth has been re-designated as residential development land and proposals for the use of these sites (LG1 and LG3) for housing development.
These policies are not Legally Compliant as the Sustainability Assessment does not form a suitable assessment of the sustainability of the council's proposals. The SA does not consider the undesignated heritage asset status of the Green Belt which was an integral part of the design of Letchworth, and the first designed Green Belt in England. The Green Belt is an important factor in the setting of the Heritage Asset which is the town of Letchworth.
These policies are not Sound as:
a) They are not positively prepared as they are not consistent with achieving sustainable development as set out in NPPF. 7 pg 2
"There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:"

"an environmental role- contributing to protecting and enhancing our natural, built and historic environment;......"
They are not justified or consistent with national policy as they do not comply with the following sections of NPPF:
a) 9 Protecting Green Belt Land
79 The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence.
80 The Green Belt serves five purposes:
to check the unrestricted sprawl of large built up areas
to prevent neighbouring towns merging into one another
to assist in safeguarding the countryside from encroachment
to preserve the setting and special character of historic towns
to assist in urban regeneration, by encouraging the recycling of derelict and other urban land."
The proposals in SP5, SP15 and para 13.215, to re-designate the Green Belt land north of Letchworth, do not recognise or conform to all of the above five purposes.
83"...Once established Green Belt boundaries should only be altered in exceptional circumstances..."
MP Brandon Lewis confirmed in his letter to Boris Johnson of January 2015, that the need to meet Housing Targets did not constitute exceptional circumstances.
"NPPF is clear that Green Belt should be given the highest protection in the planning system and is an environmental constraint which may impact on the ability of authorities to meet their housing need. This Department published guidance on 6 October 2014 which re-affirms that Green Belt boundaries should only be altered in exceptional cases, through the preparation or review of the Local Plan. The guidance also states that the housing need alone does not justify the harm done to Green Belt by inappropriate development when drawing up a Local Plan."
The exceptional circumstances have not been demonstrated and reasonable alternatives to the use of sites LG1 and LG3 have not been identified, described and evaluated before the choice was made. The sites included in the appraisal were only those which owners put forward and the Draft Sustainability Appraisal document sets out in para 5.2.1 that to be considered a site had to be available for development. No alternative sites which would not cause such harm to the significance of Letchworth and its Green Belt were sought.
b) 11 Conserving and enhancing the natural environment

109 " The planning system should contribute to and enhance the natural and local environment."
110 "...Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this framework."
The Green Belt Review Study, sets out a scoring process for the sites put forward by owners which aims to establish which sites make the most significant contribution to the Green Belt. This system is flawed in the following ways and therefore not justified or consistent with national policy:
a) It says on page 30, para 44. "Letchworth Garden City has a relatively strong relationship with the surrounding countryside, particularly to the south where there is a clearer connection to the original footprint of the town."
This statement is not justified, the "original footprint of the town" quoted is simply the first area developed, from Norton Road in the north to Baldock/Hitchin Road in the south. This was by no means the intended size of the Garden City, Howard designed it to have 32,000 residents, that number has only recently been achieved with the addition of the Grange, Jackmans, Lordship, Manor and Westbury Estates. The town's relationship with the surrounding countryside is equally as strong in the north as in the south.
The following quote from Ebenezer Howard's book, Garden Cities of Tomorrow 1902 is relevant:
"Garden City has, we will suppose, grown until it has reached 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 forever 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."
b) Page 25, Parcel 22, under heading "Preserve setting and special character of historic towns"
"Forms part of countryside between Letchworth and Stotfold in Beds. Performs a more limited function due to landform resulting in limited views of any historic towns".
This analysis is far too simple, the historic town of Letchworth, the world's first garden city, and its integral Green Belt is completely ignored. The built up boundaries of Letchworth are clearly visible and its surviving Green Belt still performs its original design function to allow residents access to the countryside and for the grade 2 agricultural land to be farmed, and to provide the countryside setting for the Garden City as envisaged by Howard.

c) Page 117 section 5.3. Assessment of Potential Development Sites Land East of Talbot Way, and Land North of Croft Lane.
These sites adjoin Norton Conservation Area and Norton should be assessed as a village whose built boundaries should not be extended (in the same way that Willian the village to the South of the town, has been assessed). The statement in the Local Plan 2011-2031 page 181 para 13.209, that Willian has not been absorbed into the Garden City whilst Norton has, is not correct, Norton retains 3 sides of the village in contact with the countryside and it is only the houses on the East side of Norton Road which link it to the Garden City. Willian has a similar link along Willian Road from Letchworth Gate.
d) Page 118 North Letchworth
We do not consider the assessment to be accurate, this potential development site has 3 sides (North, East and West) which do not have development adjacent, if this had been used for analysis, rather than how many sides have development adjacent, then this site would have scored more highly. The wildly different shape of sites means that this method of assessment is not accurate.
There is no mention in the NHDC Local Plan or any background documents, of the proposed 22.5 hectares of residential sites to the East of Hitchin Road, in Central Beds Draft Local Plan, (work has already started on some of the houses). These proposals will bring the proposed development of North Letchworth closer than 500m to this Central Beds development, which as an extension of the Fairfield development will almost link Letchworth and Fairfield. The effect on the Green Belt has not been taken into account and this should result in a higher score under Towns Merging heading. The proposed development would also reduce the Green Belt between Letchworth and Stotfold to 500m in places. It is evident that the development of this North Letchworth site would result in the unrestricted sprawl that Green Belt designation is designed to prevent. The issue of co-operation on strategic and cross-boundary issues is relevant here.
Under the heading of "Preserve setting of historic town" this analysis says "site not within or affecting setting of a conservation area of a historic town". This is not a correct assessment of the importance of Letchworth's Green Belt as an integral part of the town's design and an important factor in its setting. The significance of the historic town of Letchworth, the world's first Garden City, would be seriously harmed by the loss of this area of Green Belt. A higher score should have been given here.
There is no Heritage Assessment Document for Letchworth prepared as part of the Background Papers, although Baldock Hitchin etc. have such assessments. A well informed Heritage Assessment for Letchworth would have identified the special historic character and significance of the World's First Garden City and its Green Belt, the first designed Green Belt in England.

Whilst Letchworth has its designated heritage assets in the form of listed buildings and Conservation Areas, it is also of local heritage importance in its entirety, as designed, with its Green Belt. This has not been considered in this Local Plan exercise.

Policy SP17 Site HT1 Highover Farm Hitchin
This policy is not Sound as it is not consistent with national policy.
NPPF says that green belt should only be altered in exceptional circumstances. Here the green belt between Hitchin and Letchworth will be reduced to 500m if this development goes ahead. No exceptional circumstances have been demonstrated.
The development will result in the unrestricted sprawl that the green belt is designed to prevent.

The modifications we would like to see are the removal of LG1, LG3 and HT1 from the list of proposed development sites and an exercise to identify sites to provide the housing needed in locations which do not harm the significance of Letchworth Garden City and its Green Belt.

We would like to participate at the oral part of 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.

See attached

See attachment

I object to North Herts District Council's Local Plan 2011 - 2031 on two main counts: first the violation of the Green Belt; second, the specific proposal to build on Green Belt land North of Letchworth (LG1).
NHDC proposes to build large housing estates East of Luton, East of Hitchin, North of Letchworth, North of Stevenage and North of Baldock. It is against Government policy to build on Green belt land unless "very special circumstances" pertain (see attachment 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 and sense of identity. Several hitherto distinct village communities such as Cockernhoe, Gravely and Bygrave will be either absorbed or annexed. 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 attachment 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.
My second main objection is specifically to the Green belt site North of Letchworth (LG1). Apart from my objection above to building on the Green belt in general, there are three further objections specific to this site: first, the uniqueness of this site for its archaeology, geology and biodiversity; second, its particular unsuitability owing to the unique heritage of Letchworth Garden City; third the role of the Letchworth Garden City Heritage Foundation in selling the site for development to NHDC.
The site LG1 is ancient cultivated land dating back to medieval times and probably far beyond. Its ditches, banks and hedges are artifacts of early agricultural systems of archeological 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 attachment 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. Therefore I object to the proposed development of site LG1 because it will necessitate the destruction of biodiversity and study opportunity for archaeology and geology.

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 attachment 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. There is no scope for enlarging the railway station carpark.
I object to site LG1 because of the circumstances of its proposed sale by the owners. The owners, Letchworth Garden City Heritage Foundation, proposes 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 the principles espoused by Ebenezer Howard. The Green Belt was integral to the project, deemed essential to the concept of combining the best of both town and country living. As such it was the world's first Green Belt. The sad irony is this proposed sale represents 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.
Attachments:
1. Extract from Hansard 15.7.16
2.Foreword to NHDC Biodiversity Action Plan 2005
3. Endangered species on LG1
4. Extract from Ebenezer Howard's Garden Cities of To-morrow (Faber and Faber, London, 1902)

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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 attachment

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

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

1. I JUDGE THIS PLAN TO BE UNSOUND

The plan is unsound for the following reasons:

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

NOT POSITIVELY PREPARED

Plan Policy SP8

Para 158 of the National Planning Policy Framework (NPPF)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

NOT JUSTIFIED

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

NOT EFFECTIVE

Plan Policy SP8

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

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

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

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

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

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

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

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

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

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

Plan Policy SP1

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

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

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

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

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

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

Policy SP5 - Countryside and Green Belt

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

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

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

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

6.02 Para 79 of the NPPF is crucially important as it defines the Green Belt here:- The Government attaches great importance to Green Belts. The fundamental aim of Green Belt Policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

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

6.03 Para 80 states that:

Green Belt serves five purposes:

Amongst these:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

7.04 One should consider:

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

It is not acuteness that matters it is exceptional acuteness.

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

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

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

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

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


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

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

Plan Policy SP10

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

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

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

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

Plan Policy SP13

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

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

10.00 Conclusion

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


ADDITIONAL COMMENTS

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

David

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

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








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

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

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

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

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


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



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

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

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

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

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

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