Policy SP16: Site NS1 - North of Stevenage

I wish to make the following representations in response to the Submission Draft Local Plan.

The whole plan is "unsound" because it is fundamentally flawed in a number of ways:
* The supposedly objective assessment of housing need is based simply on projections produced by the Office of National Statistics. No attempt has been made to validate these against past trends. In fact they would require that houses are built in North Herts at a greater rate than has ever happened in the past. Since the plan is for the period from 2011 to 2031 a quarter of the plan period has already happened. During that time the rate of development has been less than half that projected for the plan period as a whole.
* The housing target has not been influenced by the need to limit or avoid building on green belt land. The government has said that assessed need does not, on its own, represent a case for building on green belt land, but that is exactly what the plan argues.
* The mechanism that has been used for identifying sites is flawed. The Council simply asked land owners or developers to suggest sites that they would like to develop (at least one major site has been put forward by a developer who does not own the site concerned). There has been no attempt to identify sites that would be suitable for meeting housing need whilst meeting community and sustainability requirements. The result is that housing is proposed in the locations that suit the developers rather than those that provide the best solution for the community.
* The plan includes inadequate provisions to would ensure that brown field sites will be developed first with green field and green belt sites only following later if the demand is shown to exist.
* The traffic impact assessment is totally inadequate. The plan relies on an assessment that covers Stevenage, Hitchin and most of Letchworth and Baldock, together with another that covers Royston. The largest development proposed at Baldock is beyond the edge of the area covered by the traffic model. In addition whilst the effects of Stevenage and Welwyn Hatfield are considered, Central Bedfordshire and the proposed developments there are completely ignored. The supporting report sets an absurdly high threshold for congestion, only regarding junctions as congested if they will have "more than 100" vehicles queuing at the end of the peak hour. The proposed mitigation measures fail to identify the extent to which the problem will be improved and the proposals appear to take no account of traffic diversion to rural or residential roads.
The second level of objection is to the flaws in the proposals for individual sites:
1. GA2 - Tilekiln
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For most of its length if follows a footpath or a poorly defined field boundary. The strange shape of the site relates to land ownership rather than any natural feature and demonstrated that this is not a suitable boundary.
* Access to the site from Great Ashby is restricted to a narrow path through a wood land beneath powerlines.
* The site is proposed as the location for a school, but placing a school right on the edge of a settlement in this way will ensure that many children are brought by car.
* The development will clearly relate to Stevenage (despite being in North Herts) yet is remote from any of the town's facilities and will encourage longer car journeys to shops, secondary schools and leisure facilities.
2. GA1 - Roundwood
* Access to the site is unsatisfactory, requiring measures to prevent parking on roads in Great Ashby that are outside the site.
3. NS1 - North Stevenage
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For much of its length it is in the middle of a field.
* The site will clearly result in coalescence of Graveley with Stevenage. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* In addition it appears that access issues may not have been adequately considered.
4. WE1 - Weston
* Access to the Hitchin Road site needs to be from Hitchin Road and not from The Snipe.
*There is no pavement along a section of Hitchin Road that residents in the new development would need to use to get to the school, the shop and other village facilities. Any development here should require this to be addressed.
5. BA1 - Baldock
* The traffic assessments do not identify what would be required to make the large site north east of Baldock achievable.
* The land is admitted to "make a significant contribution to the Green Belt purposes".
* The site will clearly result in coalescence of Bygrave with Baldock. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* The National Planning Policy Framework requires that, for proposals of this sort, infrastructure should be planned at the same time as the Local Plan is prepared but there are no details of this in the plan.
* If built the proposed road linking the A505 with the A507 north of Baldock would have inevitably see use as a Baldock eastern by pass. Its specification and construction would need to reflect this use which would require placing significant parts of the road in a cutting to avoid unacceptable impacts on both the urban area and the adjacent countryside.

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.

I have tonight examined the plans at the evening session for the Bellway Miller Homes and would like to raise the following points and observations for your most urgent response.

1. The proposed 2 entrance/exits onto and off the development onto The NARROW Great North Road is already busy enough with morning/evening queues of traffic, from Letchworth and the North and for those Stevenage residents going in the opposite direction to work.
2. You may be planning filter lanes but the road is simply not wide enough for the CURRENT volumes of traffic and the congestion shall be intolerable backing up still further into Gravely and will affect ambulances into and out of the Hospital and the secure mental institution.
3. I observe the operational high value homes are to be overlooking the meadow which we once overlooked and now it is to be blighted, which in turn may affect the value of our homes which what we aspired to owning.
4. I read that the latest population projection figures from the office of National Statistics predict an average annual natural population growth in the East of England of just 0.32%. Accommodating that growth in North Herts and Stevenage requires 5962 extra houses for the 2011 to 2031 period, but 6691 houses have already been built or have permission to build. So why are more needed?
5. There had been plans to build on the western side of the A1M and I ask why is that development not being proposed in place of this proposal?
6. The A1 M has always congested from 06.30 till 09.30 Southbound backing up to Junction 9 Letchworth and from 1600 to 1900 hours Northbound backing up before junction 6 at Stanmore Lakes to junction 8 Stevenage, as it only has 2 lanes in each direction. How will you accommodate the additional traffic on a already congested motorway?

I am terribly disappointed in what I have seen this evening and I am opposed to the development and I look forward to your response at your earliest opportunity.

We wish to object in the strongest terms to your plans to build vast numbers of houses on land north of Stevenage.

The plans to build so many homes is appalling and will completely ruin the ambiance of the area. This is vital greenbelt land and beautiful Historical Forster Country. It is the lungs of the local area and a local favourite for country walks.

Local services are already at stretching point, with North Road very busy especially during rush hour times. The Lister is at full capacity and creates so much traffic already, with so little parking and little near on-street parking, which already affects us. Our own road is very busy and cannot take much more traffic. We already have problems getting out of our driveway because traffic comes round the bend far too fast from Chancellors Park area. This road should have a speed limit of 20 mph.
Also, what will happen to the value of the local housing -- are we all to be penalised and lose yet more of our pension savings in these already austere times.
In addition, the roundabout at Junction 8 of the A1M is already over capacity and a real hold-up at times. It cannot take any more traffic, and at times can take 30 mins to get round.

We do not need yet another Tesco but we most certainly need our Garden Centre, the only one left in Stevenage.

We understand that the plans are for many more houses than are required and that, in addition, the councils get a nice hand-out per house as a Government incentive!

In conclusion, the plan to built so many houses is deplorable for the established local communities and we ask that you seriously reconsider all the damage you are doing to the area.

I have already objected to the Local Plan but here are my objections again.

The loss of green belt land and in particular Forster country, the lungs of the Old Town residents, with unnecessary housing and joining up with Graveley so losing the open country we all use to keep healthy.

The siting of a Gypsy site on green belt land when there is already a site in Dyes Lane which could be enlarged without touching
green belt land.

We would lose the only Garden Centre in the area if you build a totally unnecessary Super Store on the site. This would affect the viability of the New Town Centre and increase traffic, noise, and pollution problems around the Hospital and the existing residents in the area. Most days it is gridlock around the area already.

These are some of my objections and I ask you to think again.

I have witnessed many changes in that time, and the proposal to build 1700 homes on Green Belt Land around Graveley, Stevenage and the Great Ashby areas I want to object to.
At the moment developers Bellway/Millerhomes are proposing to build 800 homes (1 bed flats up to 4 bed homes)on greenbelt land to the north of Stevenage, and this will generate up to 1500+ more cars (morning and evening) coming onto the North Road which is already nose to tail in the rush hour periods, due to the traffic coming from Baldock and Letchworth along the Graveley Road then down the North Road and into Stevenage. This will make it more difficult for the people who currently live in the Granby/Chancellors Road Estate to get onto the north road
Therefore I strongly object to any homes being built in this area.

I would like to object to the local plan, specifically the lack of justification for the excessive housing target, lack of associated infrastructure that a local plan of this size requires and further rolling back of the Green Belt (or land swaps) around the A1M towns of Stevenage, Hitchin, Baldock and Letchworth. Instead I would support that NHDC and Stevenage Borough Council deliver a sensitively designed new Garden city, to support additional and justified housing need in the area, local employment can be generated and where the local infrastructure is adequately considered and delivered.

There is an absence of justification for the excessive housing target that does not take into proper account of Green Belt constraints and in many cases. The current framework makes it very clear Green Belt boundaries should only be adjusted when very special circumstances exist, through the Local plan and with the support of local people. The need for additional housing alone does not constitute exceptional circumstances for rolling back further the green belt around the towns on the A1M corridor.
The North of Stevenage already had a large area removed from the green belt for Great Ashby as exceptional circumstances to meet Stevenage housing need during the last local plan, and now is expected to do so again. NS1, GA1 and GA2 will close the gap between Graveley and Stevenage with Weston and will fully immerse Chesfield losing the character of all villages and hamlets.
The development sites NS1 (900 dwellings), GA1 (330 dwellings), GA2 (600 dwellings) are to meet the needs of Stevenage which itself has a developing local plan for 7600 new homes during 2011 and 2031. There also plans for 600 dwellings to the East of Stevenage in East Herts local plan. This constitutes an increase of 10030 homes or 11% increase to meet the needs of Stevenage alone. This is a similar proposal to what was included in the now defunct SNAP, which indicated a relief road for a development of this size, yet this is not indicated in the local plan, and relies on funnelling traffic through existing roads not designed to cope with such an increase in traffic. All of these sites are away from the main town centre, public transport does not link these sites together so will increase car journeys and commuting outside of the town further exacerbating the daily issues on the A1M and rail network.

I am writing to restate my objections and concerns to the proposed development of 900 houses on green belt land from Graveley cricket ground towards Stevenage.

Have any of the officers of NHDC ever tried joining the A1M at Corey's Mill during peak times which gets earlier every morning and later every evening - I am sure you have and will know that it is often grid locked. Even trying to get into Hitchin after 9.15 am and after 7pm from Graveley it is grid locked. THERE IS NOTHING IN THE NORTH HERTFORDSHIRE LOCAL PLAN 2011-2031 THAT ADDRESSES THIS. LOCAL INFRASTRUCTURE CANNOT COPE WITH FURTHER HOUSING DEVELOPMENT .

With pressure for continuing expansion of Luton Airport there appears to be no plan to provide better road access from the A1M . If this was proposed, surely a link from Luton to A1M via Hitchin would provide a natural opportunity for housing development.

Finally, why is North Herts District Council , hell bent on destroying village cultural and choice. We don't all want to live in a large sprawling lonely urban wilderness!!!

Please may I make the following comments to object to the plan as a resident of Graveley, therefore my comments are principally referring to site NS1 and also to some extent, GA1:

1. Destruction of Green Belt land in this instance is not justified. In towns across North Herts and Stevenage there are still many untapped brownfield sites that would benefit these locations bringing life back intro these business centres, reducing the inducement of traffic congestion through commuting into such towns/railway stations and already using a ready-built infrastructure. Locating housing in areas such as this is not convenient for rail travel being around 2 miles from Stevenage station and traffic congestion along North Road makes any linking bus journey time-consuming and unreliable. There is plenty of brown field land to the west of Stevenage that is only 1/2 a mile from Stevenage station that remains derelict yet is only a 10 minute walk from the town's station.

2. There is insufficient transport infrastructure in this area already and we have heard no proposals as to how such saturated roads can be improved to cater for such growth, caused by both the proposed housing developments and supermarket. Both the A1 J8 and North Road Junction with Graveley Road are already accident black spots and Graveley village will not cope with much higher traffic flows down Church Lane from Great Ashby. This road cannot already cope when it's used by many residents of Great Ashby in the peak periods and with very tight corners and listed buildings backing onto the road on the approaches to Graveley there are no ways it can be widened. The land take of the new sites also appears to only provide an road connection to the east and south-east placing massive stress on the Stevenage to Hitchin, Letchworth and Baldock corridors.

3. A loss of the potential to ever expand the hospital and associated facilities. Lister Hospital and its immediately adjacent sites catering for palliative care and mental health are now ( critically important to all of North and East Herts and Stevenage. There has already been huge upheaval and expense in consolidating care there and downgrading other sites such as QE2 in Welwyn Garden City and Hertford Hospitals which was justified at the time that Lister is better suited to expand. A housing scheme of such a size running right up to the hospital site will restrict what would have been a far more justified reason to threaten Green Belt land in the future.

4. Stevenage and it's immediate surrounding areas have been woefully neglectful of the history and culture that has, and still remains. EM Forster and the notion of 'Forster Country' would greatly improve the image of this area. Such swathes of blanket development with no focal point and the associated destruction of woodlands and hedgerows does undermine such efforts by a great many people in the past to increase the profile of the area as a pleasant and sustainable place to live, work and visit. The relief of the proposed area would make such a development visible from many aspects to the north of Stevenage and undermine the historical importance of sites such as Manor Farm.

5. The density of housing that is proposed and lack of strategic infrastructure to cope is an insult to foresight and concepts of Ebenezer Howard, again another unique selling point of this area. He was an early proponent of sustainability and I would question the overall environmental credentials of this scheme.

I would like to object to the local plan with particular respect to sites NS1, GA1 and GA2

There are significant access issues with regards to GA1 and also GA2. The roads are not suitable for the level of traffic proposed to be going down these roads and with respect to the planning application for GA1 the traffic survey conducted is flawed.

Some other residents and myself have conducted a more details traffic survey which shows that the development will result in severe parking issues and potentially be dangerous due to emergency vehicles being unable to get down the road.

I am unaware of what the access points for GA2 will be but if it is through existing roads then the problem will be the same.


Both of the proposed developments are on green belt land and in NHDC email dated 19/4/2016 they stated that the sites were located in metropolitan green belt and as such they were unable to support the principle of the development."

Development on green belt land as per government policy is only supposed to be under "exceptional circumstances and with the support of the local community" which is patently not true with regards to GA1 and GA2.

Building on NS1 along with development in SBC local will result in the effective destruction of forster country which is the last remaining farmland in Stevenage Borough was the inspiration for Howards End by EM Forster and should be protected.

I thank you for taking into account my submission and would like to be informed with regards to the local plan in future.

I wish to make the following comments on NHDC Local Plan, and specifically regarding the proposed development north of Stevenage

1. I object strongly to the NHDC proposal to allow about 80% of the development to be on Green Belt land. Government policy is to protect Green Belt and prioritise the use of Brown Field sites to support housing developments. The Green Belt protects communities from urban sprawl and provides clear environmental benefits to North Herts residents and our Green Belt should be protected and maintained. More of the development should be on Brown Field sites.

2. The proposed development north of Stevenage on Green Belt land will extend urban sprawl and will drastically change the character of Graveley village. Graveley is a small historic rural village mentioned in the Doomsday book. It is essential that it's rural character is protected and maintained, and Graveley must not be allowed to coalesce with Stevenage. This would be contrary to NPPF80. A decent buffer zone must be provided between Graveley and Stevenage development where no building on the Green Belt is allowed and Graveley is allowed to maintain its village status, as it has done for hundreds of years.

3. The number of houses proposed north of Stevenage is 19,500 (including west of Stevenage 3100 houses). While I accept that some development is necessary, I believe that the number of houses proposed is much higher than necessary and should be reduced.

4. Congestion on the roads north of Stevenage, eg the B197 through Graveley, is already bad and development in this area on the scale proposed in the NHDC Local plan will make the current problems much worse.

As a resident of Graveley village for more than twenty years I have reviewed the local plan by NHDC to intend build 1,700 houses on a new estate (NHDC 900/SBC 800) south of Graveley, and the creation by SBC of a proposed industrial estate next to the Stevenage Tennis Club on the North Road. I have several major concerns and objections as follows;

* This will be on 'Green Belt' and will effectively erode any remaining boundary that Graveley as a village has with Stevenage. The loss of identity and urbanisation goes against all principles of why 'Green Belt' legislation is in place to protect our already encroached village life.
* If approved this will lead to a further unacceptable increase in traffic congestion through Graveley, particularly at peak times, and with additional volume of commercial traffic that use Graveley (High Street/B197) as a means to avoid the already high levels of congestion on the A1(M).
* My drive leads directly onto the B197 and during peak times there is a high road accident risk as the traffic is either congested, or where free flowing it is often at high speeds as the vehicles fail to slow down to the 30 mph limit.
* The proposed developments in Great Ashby of 360 (GA1) and 600 (GA2) will if approved impact Graveley further by traffic using Church Lane to avoid congestion in Stevenage.
* These developments beyond the major traffic, pollution risk will lead to significant strain on already stretched local resources health, education etc.

In Graveley we have tolerated for too long the impact of unacceptably high traffic, congestion and pollution and these developments offer no protection to the long terms residents of this historical North Herts village. I urge you to re-consider and stop these plans.

I object to the concept of building on green belt land which by law should be protected unless there are exceptional reasons and I don't think it has been shown that these are exceptional circumstances.

Graveley has a unique character and is largely a conservation area. Building houses and extending Stevenage right up to our cricket field is going to change the character of the village for ever. We will effectively be joined to Stevenage.

The large number of houses planned in NS1, GA1 and GA2 are going to generate a lot of traffic on roads that are already overloaded. The A1M is congested every morning. The traffic diverts onto the B197 through the village and it can be very difficult to get out, especially turning right out of Oak Lane with the Primary School traffic.

Martins Way is extremely slow and so the additional traffic from Gt Ashby is going to slow everything down even further.
The roundabout at J8 is extremely difficult to get out onto as we don't have our own traffic light control and on busy mornings is close to gridlock, the traffic backs up from Stevenage blocking the roundabout or sometimes the traffic going to Hitchin becomes stationary and does the same.

I wish you to register my formal objection with regarding the plan to build 1700 homes on the Green Belt land know as Forster Country in Old Stevenage.

My reasons for my objection are as follows:

- Green belt land should only be sacrificed in exceptional circumstances. I see no justification for this, and wish to emphasis the need to develop numerous brown field sites first.

- This is a historic site of cultural interest, which you are seeking to destroy.

- Part of the development is located in a Conservation Area.

- Site is compromised due to national grid pylons dividing the site. This also creates fears regarding general standard of housing types proposed.

- The infrastructure in this area can not take any further development.

- Congestion is a constant and feel additional traffic will result in total gridlock.

- Traffic levels in the area are already excessive and pollution levels will significantly increase causing health problems to the inhabitants.

I understand that the council benefits £7000 for every house built. This should not be the main driver for destroying our Green Belt.

It is worth noting that - The Woodland Trust rank Stevenage as one of the best places in the UK for ease of access to large woodland, only slightly behind the Forest of Dean and The New Forest.

Stevenage has suffered enough from numerous development projects, and feel it will further destroy the limited green areas that we love as a family.

The current planning proposal of North Herts for 330 homes in GA1, 600 in GA2 and 900 homes in NS1 are irresponsibly placed and not supported at all by local communities. North Herts council have failed in their remit to provide sustainable future build plans. They have also contradicted their own aims (see below). Current plans will:
1. Undermine and disrupt all local access routes
2. Destroy sensitive natural habitats and biodiversity
3. Increase carbon emissions in the area by developing significantly more dwellings away from local train stations, relying on carbon-heavy bus and car traffic. Increases in air pollution east of the A1(M) corridor.
4. Negatively impact the heritage and historic character of the area
5. Disrupt important water courses, negatively impacting water supplies (quality and quantity) and increasing risk of localised flooding
6. Put pressure on the organisation of local councils -close proximity of this "town"-size dwelling site will demand increased and unsustainable interactions across the boundaries of two different council authorities (Stevenage and North Herts)
7. Remove greenbelt and confuse boundaries
8. Fracture local communities and their resources

1. Unsustainable roads/traffic access to the site
Disruptive influence on current local access routes
NS1 site: The Graveley/North Road junction has been underestimated. Altering the junction alone will not improve flow of traffic or access in this region. If traffic is diverted from a significant new development North of Great Ashby towards the B197/North Road, greater traffic will be forced onto an already busy road.
The south section of the B197, North Road is normally a quiet 30mph high street and provides access for local village residents as well as access to the Lister hospital. At quiet times, road users often drive well over the speed limit through the village of Graveley. At peak times, the roads and all junctions become very congested. At peak traffic times (8am-9.30am and 4.30pm-6.30pm), the B197 North Road comes under severe traffic pressure with queues stretching from both junctions 8 and 9 of the A1(M). Only the Hitchin Rd/Lannock Hill access from Weston village or the Little Wymondley Lanes offer relief from these queues.
If road access is increased from the east towards this road - it will become impassable at peak periods. It will also increase pressure on the already-busy A1(M) junction 8 roundabout. If the current North Herts housing plan becomes an extension of Great Ashby, the road towards Graveley is likely to become a rat-run. Conversely, if the road system becomes segregated, access to local amenities will be undermined.

GA1 site: The current plan proposed to the council by Croudace Homes for GA1 cites Mendip Way as a new access point. This small, residential road is permanently double-parked and notorious to local residents for lack of parking and bad access. How can it safely become a major access route!?!?! There is also planned disruption of the secondary route to the large (i.e. >1,000 inhabitants) Weston village and surrounding area, impacting local rural, intellectual, technical and industrial businesses.

2. Destroy sensitive habitats
There are several Sites of Special Scientific Interest within GA1. These include sensitive woodland areas. The Proposal refers to a "protection" of these areas but does not mention any wildlife corridors.

A well-known ecological fact is that 'small island' or isolated habitats are more vulnerable to local extinctions. Development including building of up to 600 homes in this area could not support the current biodiversity in this area and would, without doubt, lead to considerable loss of natural habitats and endangered species.

The current pylon corridor in Great Ashby is named as something to be preserved - what function does this serve, other than reducing the potential danger of pylons and overhead cables from local dwellings? There are no other apparent functions for this corridor as it does NOT fulfil key habitat requirements to sustain local biodiversity. It is clear of vegetation (except grass) for health and safety purposes.
The conservation of the sensitive biodiversity of this site is the greatest fault in building here. There is MUCH to lose in the GA1 site by developing it for housing. GA1 would be most usefully directed towards development of renewable energy.

Willow/Miscanthus plantations in GA1, particularly surrounding the spring zones, would act to cleanse and protect local water systems and drive forward an innovative and sustainable renewables economy for Hertfordshire.

3. Impacts on air pollution and climate change
The North Herts proposal aims to: "ENV3, Mitigate the effects of climate change by encouraging the use of sustainable construction techniques, the appropriate use of renewable energy technologies and reducing the risk of flooding."

By extending the area of Great Ashby, the distance of central Stevenage from the surrounding settlements will increase. This will result in increased car and bus exhaust emissions. Plans should include greater access for cyclists and pedestrians. There is no evidence for any plans to innovate and increase renewables development in this plan.

4. Negatively impact the historic character of the area
Currently, the Croudace planning proposals within the GA1 area outline a plan to further disturb the running of existing, functioning road systems. There has been a lack of reference to historical sites for GA1, GA2 and NS1 - ancient boundaries and the importance of roads to county heritage, as well as efficient access routes. Further, ancient boundaries and routes into villages will be altered similarly. (This contradicts North Herts proposal in ENV2 to: "Protect and enhance the historic character of North Hertfordshire's towns, villages, hamlets and landscape by promoting good design that creates a distinctive sense of place.")

Additionally, a letter by Stephen McPartland defended the NS1 area and refers to E.M. Forster's literature and heritage (also referred to in 4.200 of the proposal). I believe North Herts County Council have over-reached the area that should be allowed to be built on to the deficit of sensitive and heritage countryside. These will be lost forever if this plan is undertaken.

The GA1, GA2 and NS1 plans appear to have lost the sense of cultural heritage for this area, which is in contradiction to the North herts aim to "2.69 promote sustainable growth.....whilst remaining mindful of our cultural and physical heritage". In order to preserve GA1, GA2 and NS1 areas, they should adapt neighbouring villages to increase their communities and allow them to thrive.

5. Disruption of water supply
2.29 in the draft proposal indicates that "North Hertfordshire is identified as an area of water stress".

Ordnance Survey maps indicate a large number of natural springs in the area directly North of Great Ashby (GA1). Building over these would be hugely irresponsible considering point 2.29. It is highly likely to impact downstream water sources/supplies through disruption of the supply or pollution. Additionally this could add to local flooding in the area. Areas further into the valley/lowland parts of the county are likely to provide more predictable sites regarding water supply.

6. Cross-council interaction, access to services and balanced housing provision
The draft proposal states that Great Ashby is to be considered a town, therefore, North Herts District Council is increasing the scale of a settlement that is:

1. Split between two council jurisdictions and resources, and with
2. Existing pressures on resources (e.g. oversubscribed schools).
3. There is also limited access to local services e.g. significant supermarkets, public transport and major employment.

The recent High Court battle to build on North Herts land, west of the A1(M) corridor by Stevenage County Council is evidence that there are already tensions between Stevenage and North Herts District Council. This has already cost the taxpayer thousands of pounds in legal costs. Further development North of Stevenage threatens the same issue.
Further, future developments would all lie along the border to large developments with Stevenage which is likely to cause a conflict and confusion for local residents and risk a loss of identity....do they live in Stevenage or the North Hertfordshire area?

Schooling provision:
Education is currently at an excellent/good level in the North Herts area, in particular Baldock has very good primary/junior schools and secondary school. Current developments North of Baldock and North of Great Ashby would significantly impact these services.
A huge number of North Herts residents in Great Ashby currently send their children to Stevenage secondary schools, therefore the provision and cohesion of future education strategies should be addressed BEFORE further developments are allowed. It is not clear where the children of GA1, GA2 and NS1 areas would go to school from primary to secondary education - would they belong to Stevenage or North Herts administrative areas and education authorities?
Similarly, Stevenage health provision covers much of Great Ashby residents, while many North Herts village residents in the area would use Baldock/Letchworth services. Have the NHS user provisions been properly considered prior to development on this land? Is there a significant risk of this new development undermining current social, health and education services in the area?
Balanced housing provision:
"2.21 At the start of the plan period in 2011, there were approximately 55,000 homes in North Hertfordshire. Almost one-quarter of homes in North Hertfordshire were detached houses. This proportion was slightly higher than both the Hertfordshire county and national figures. Conversely, the proportion of flats (including converted houses) was slightly lower19."
- Stevenage council has recently encouraged development of several large blocks of flats, close to the train station and shopping/administrative centres.
- In contrast, the North Hertfordshire plan focusses on development of further rural/suburban sites.
- North Hertfordshire should demonstrate greater ability to improve the vitality of town centres - employment and leisure provision.
- North Herts should be focussing on greater development of flat/apartment buildings and terraced housing provision within town centres in line with their "target to build 20% of new homes on previously developed land" (point 4.95). This would provide much-needed access for more affordable housing, facilitating first-time buyers and boost the housing economy.
- GA1, GA2 and NS1 are currently rural areas with limited access and are not obvious sites for flats and smaller dwellings due to their remoteness. Such rural planning sites should be focussed across all villages to increase the size of current rural settlements and reduce their isolation from the greater community.
- Future planning sites should be focussed across multiple rural sites e.g. WE1. Expansion of new larger scale sites should be slower, more detailed and have greater access from major trunk roads and public transport links.

7. Removal of greenbelt
The current Green Belt forms a practical function in conserving many sites of special scientific interest and important biodiversity. It also forms a small corridor surrounding all three settlements for leisure. Additionally it provides space for diffusion and access of local traffic to important resources e.g. retail, hospitals and schools. There are businesses thriving in the local area (e.g. local pubs, industrial estates and farms) as a result of the current access to rural settlements.

Over-crowding of these adjacent areas in a non-strategic way will undermine the function of Weston and Graveley as larger satellite settlements around Stevenage for smaller villages and hamlets.

8. Fracture local communities and their resources

Pro-developers, Anti-local plan

North Herts strategic objectives 3.7 include:
ENV1 Direct development towards the most sustainable locations which seek to maintain the existing settlement pattern.

The current GA1, GA2 and NS1 plans appeal primarily to developers - they offer a blank canvas to large, unprotected and hidden areas, away from the public eye.
In a public North Herts planning document available in 2014 - the GA1 site was named as priority three after the sites that would "in-fill" the Stevenage zones adjacent to Saint Nicholas, Lister hospital and Graveley. Would the current plan nullify that statement?
North Herts District Council should be able to demonstrate a complete lack of conflicts of interest or susceptibility to be influenced by other major parties. In particular, North Herts District Council should be able to demonstrate they are not allowing large developers free-access to council plans and consultations outside of public debate. There is a clear trend of rapid, competitive development in the Great Ashby area. The Croudace purchase and development within the proposed GA2 site is direct evidence of the danger of land acquisition set-aside for housing developments - outside of the current permitted plans.
The Great Ashby site was in the original plans as a "successful and thriving community". The reality is that this area is notorious for poor building standards, ill-conceived road access, availability of parking and lack of cohesive community structure. Great Ashby is currently isolated from the rest of Stevenage and the rest of North Hertfordshire by small, limited roads. It is also tightly bound by the parishes of Stevenage, Graveley and Weston.

GA1 and GA2 show a lack of consideration to urban vs. rural function. It will funnel more urban traffic to a rural area. It will undermine the mainly rural economy and increase risk of pollution to the area.
Rural communities dominate in this region and are under-represented in this plan. Rural poverty has been identified as a major issue nationwide. The North Herts District Council could have acted to fight against this by increasing local community housing projects for each village and increased public support for existing communities across the region.
The Weston plan WE1 is an example of one such plan that is not sustainable alongside the huge developments planned North of Great Ashby. Sufficient consideration has clearly not been given to: education provision, policing protections, social care, council services, access to shopping centres, traffic management and public transport services impacted by potential new developments in the area.
In the words of their own proposal, North Herts District Council have acknowledged:
"2.83 Any new development will need to be located in places which have good access to jobs, shops, services and public transport and also provide opportunities to travel by foot or on a bike. Provision of measures for water conservation, improved biodiversity, increasing energy efficiency of new development, and renewable energy can help to ensure that development is more sustainable."

Personally, we have lived in Stevenage, Baldock and now Weston. We believe the combined plans of GA1, GA2 and NS1 will act to isolate Weston village and similar villages from the surrounding areas. We also think that, while adding new accommodation to Baldock could enhance it as a bustling area, more consideration should be given to the risk of traffic increases in the area. Additionally, infrastructure would currently be crushed under the suggested weight of development. We think these plans should be seriously reconsidered with more attention given to realistic access problems and environmental factors e.g. sensitive habitats, water conservation and development of renewables energy sources. The existing GA1, GA2 and NS1 proposals seem to simply achieve a very efficient annexing of another fractured, modern-build community, while wiping out further sensitive ecosystems that will never be recovered.


Additional plea:
4.185 "biodiversity offsetting" - is this an evidence-based method? How does the council plan to significantly conserve current species levels by using areas elsewhere? I don't believe this is an evidence-based or realistically practicable approach. Nature corridors are significantly more important for preservation of existing populations and should be included in every new development.
Please consider the allowance of nature corridors in all new developments. Retaining a continuous stretch of land with significant food sources/habitats to sustain protected/endangered species would enhance the conservation of any threatened ecosystems.
Please employ independent qualified ecologists AND conservationists in the development of this plan.

We object to the following:

Section 2 - Spacial Strategy
1. Spacial Vision

Para 3.6 'Vision By 2031. North Hertfordshire will be an attractive and vibrant place where people will want to live, work and spend their leisure time.' Already the residents of North Herts feel that this area is overpopulated. Inadequate rail services for commuters, inadequate parking at all North Herts stations, inadequate capacity on the A1M with no plans for widening it and with roads gridlocked daily this proposed level of housing development will make people's lives intolerable.


2. Policy SP16: Site NS1 - North of Stevenage

900 homes proposed development. This site for these houses has now increased since the two public consultations resulting in the site abutting the village of Graveley thereby causing coalescence with Stevenage.

Para 4.195 and 4.196
The proposed development of 800 houses on adjoining land to the south of Site NS1 by Stevenage Borough Council will make a total of 1700 houses in this joint development and will result in a huge increase in traffic. The B197 North Road is an already congested road at peak times, often with standing traffic. The proposal of a looped estate road with both ends adjoining North Road will further greatly exacerbate traffic congestion, standing traffic and pollution.

Stevenage's proposed estate road junction will be approx. 250 metres north of the junction with Grandby Road onto the B197 and North Herts proposes 'that the northern end of this road will emerge at, or close to, the existing junction of the B197 at Graveley Road/North Road. A new arrangement, possibly a roundabout, will need to be provided.' This is not deliverable - this junction is already very dangerous with numerous accidents. Previous requests to Herts Highways Department for a roundabout have been refused as the B197 is the designated emergency relief road if the A1M is closed in either direction between Junctions 8 and 9 and therefore roundabouts are not permissible. Many adjustments have been made to this dangerous junction over recent years but there are still frequent accidents. Increased traffic can only result in further accidents and fatalities.
Further to this, the proposal by Stevenage Borough Council for an Employment site opposite this housing site and a large retail store close to the North Road/Graveley Road junction will increase traffic and pollution on the already congested B197.

The looped estate road at the northern end will cause both noise and air pollution to Graveley village.

Since the opening of the Baldock bypass traffic has increasingly used the B197 from the A505 as a rat run to Stevenage. With the proposed employment site east of Baldock and the proposed housing site for 2800 homes north of Baldock both with access to the A505 traffic levels are likely to increase considerably though the village of Graveley with resultant noise and air pollution.

Para 4.197
We object most strongly to use of Green Belt Land for this proposed housing development. Contrary to the AMEC report the Green Belt land between Stevenage and Graveley strongly fulfils the NPPF green belt tests and provides a clear boundary to the further expansion of Stevenage. Graveley is an ancient rural village and it is completely unacceptable that SBC and NHDC's proposed development North of Stevenage would result in the effective coalescence of Graveley with Stevenage urbanisation.
In NHDC's previous two public consultation documents an area of Green Belt land was proposed between the northern edge of the site and Graveley village. This has now been pushed back with the site abutting Graveley village and thereby the loss of all Green Belt between Stevenage and the village. This will result in the loss of identity of this rural community. This Green Belt land is used by many people for leisure pursuits and there are several public footpaths and a bridle path running across this land all of which are heavily used. These would all become paths through an urban sprawl. We object to this loss of Green Belt.

3. Policy SP18 Site GA2 - Land off Mendip Way Great Ashby
Proposed development of 600 houses
Whilst the principal access of this site will be from Mendip Way in reality residents in this development are likely to use Back Lane, a very narrow winding country lane running into Church Lane in Graveley, as a short cut to the A1M and area north of Stevenage. This, together with Site GA1 of 330 houses again with available access to Back Lane, will increase traffic within the village of Graveley with consequent noise and air pollution and further congestion at peak times.
There should be no access available onto Back Lane from either of these proposed developments.

Section 3 - Development Management Policies
8. Housing Strategy

Para 8.1 It is questionable as to whether 15,750 homes are necessary in this area. We have been unable to find any published evidence as to why so many homes are are specifically needed in North Herts a rural area that is already overpopulated and with such a poor existing infrastructure.

How widely known is The New Homes Bonus, the grant paid by central government to local councils to reflect and incentivise housing growth in their area? Is it possible that the vast number of houses proposed is directly related to the alleged £7000 government has offered to councils for every house built? Is it at the end of the day to simply to swell the council coffers irrespective of destruction of the green belt, of air pollution, of traffic grid lock and destroying the quality of life for Hertfordshire's residents?

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The B197 through Graveley becomes North Road as it approaches Stevenage. This is officially the busiest road in Stevenage at peak times. It is also a major approach to Lister Hospital serving the whole of North Herts, Stevenage and beyond.

The problem junctions are with A602, the entry into the Old Town. Improvements might ease the tailbacks but insufficiently to compensate for the extra traffic from NS1 namely traffic from hundreds of houses forced onto this road. Other or extra exit points would still problems.