Policy SP17: Site HT1 - Highover Farm, Hitchin

I have just been informed by my neighbour about the above development.
I have moved into my property 3, Collison Close approx 3 years ago and i was not made aware of this development.
Would you kindly keep me informed as my property backs onto this proposed development.
I was given to understand that this was Green Belt land, ONCE IT'S GONE, IT'S GONE FOR GOOD.

I object to the proposed development of Highover Farm site. The main thrust of my concern is access, `Stotfold Road and Cambridge Road would be the obvious routes in and out. These are both already busy roads first thing in the morning and also in the evening it is almost impossible to get out of the Rosehill estate, also there is flooding at the bottom of Stotfold road which has never been addressed since I move into the area. Hence this is not an appropriate area for this development due to the traffic issues that it raises.
This land is Green Belt land. Once this land is gone, its gone for good. I do not believe that is land should be developed, as long as there are alternative sites available.
I also would like to be kept informed as to the proposed development in future.

Hitchin is already much higher than the national average in terms of number of people living in every square mile (Hitchin 10,400, national average 1,065).
This means that services such as the train station will struggle to cope with a large influx of extra people using it. Trains are already extremely busy at peak times with no seats available.
Car parking in town will also be more of an issue, it can be hard to find parking spaces at the weekend.
Water running from the field at Highover Farm into the gardens of houses on Grovelands Avenue is a regular occurrence. The buidling of roads and paths will make this even worse.

See attachment

See attachment

The main access is to be Stotfold Road which is a series of very steep hills which must make a suitable access point difficult to identify and dangerous to traffic flow. The traffic coming down the Stotfold Road to access Hitchin/Stevenage/Luton in the morning to join the busy A505 during rush hour already leads to extensive tailbacks. The effect of this makes householders on the Rosehill Estate bordering both roads virtual prisoners during these periods. We queue to get out of our estate for work, or GP appointments etc.Hitchin is accessed by A505 and is busy all day. These roads are very slow moving and at times little more than a car park. The Estate is a rat run to cut off the junction and emerge further down the A505. The drivers using the shortcut often drive at speeds incompatible with the built up area. These issues will be exacerbated by this new estate unless and until NHDC/HCC do something to alleviate tailbacks on A505. Add in the development on Walsworth Cross Road at the site of the old N Herts College with hundreds more potential vehicles swelling the A505 and I struggle to find an appropriate single descriptive word. Polluted mayhem in a snail paced traffic jam on inadequate roads - would be a starter.

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

Garden City principles as first implemented at Letchworth GC include a surrounding belt of countryside to prevent urban sprawl and coalescence. This principle is re-inforced in Section 9 of the NPPF. Development at site HT1 will diminish the extent of the green belt around Letchworth (as noted in the Policy SP17) .The green belt is not only part of the setting of the heritage asset that is our first garden city but also part of that heritage asset. Development here will cause harm to the significance of Letchworth and its garden city status.

This development narrows the already slim green belt between Hitchin and Letchworth Garden City. The roadway into Hitchin from Letchworth (Cambridge Road) is already a major traffic jam at peak times with the traffic sometimes backing up as far as the Letchworth Broadway.

According to the Green Belt Assessment ref 39, Highover Farm, makes a significant contribution to the green belt.
Green belt is green belt. I made a conscious decision to live where I do due to the nature of the land and its designation as green belt and by definition protected from development. When I acquired the property the land registry search confirmed the designation of land to the west of the property as adjacent to green belt and countryside. By proposing to develop on the green belt the goal posts are being moved.
Having concluded that Section 22 is greenbelt to then sub divide it seems a nonsense.
Open space and green belt once lost, is lost forever. The diversity of nature and wildlife, eg the existence of bats, newts, frogs and birdlife are thanks to the proximity of the farm. Trees on the farm run alongside the rear of my property and ensure I am not overlooked.
Replacing open fields with concrete will impact on drainage and run offs. Suburban sprawl will replace balanced vistas.
The distance of the proposed development from the town and train station will mean that most people will take their cars, thereby increasing congestion. The proposed access to the development will add more traffic to existing residential roads which are already difficult to navigate due to parked cars and where children play.
Current infrastructure is inadequate, specifically access to Hitchin station and town from the Letchworth side of Hitchin. Parking for the station is also already an issue, with residential roads being used and main roads restricted in width due to roadside parking (eg St Michael's Road, Hitchin). Every single route into and out of Hitchin suffers from severe congestion and therefore any additional housing will only exacerbate the situation.
The A1M is already saturated at peak times and train services are at capacity. Upgrading the A1M to a "smart" motorway may ease current levels of congestion but may not accommodate yet more traffic due to increased population associated with the proposed housing developments.

We object to the soundness of the NHDC proposed development of site HT1, on the following grounds:

1. Incursion into the Greenbelt

Whilst the need for more housing in North Hertfordshire is understood, the allocation at site HT1 (700 dwellings), combined with the relative distance from the centre of Hitchin is (>0.8 miles at nearest point) places unnecessary stress on the limited Greenbelt in this area. As previously highlighted in the original Local Plan consultation period (attached), the Green Belt land at site HT1 acts as a limited buffer between the towns of Letchworth and Hitchin. As the Local Plan states:

'...each town retains a distinct identity of its own. The needs for development arising from the three towns are comparatively high, but the gaps separating the towns are small and of great importance if the town's urban areas and identities are to be kept distinct.'

Development of site HT1 would bring the extent of Hitchin's outermost housing areas to within 400m of Letchworth's periphery. If the full 700-home allocation is permitted, the remaining Green Belt would be little more than a token gesture, providing not one of the key aims of Green Belt land as outlined by the CPRE:

* to prevent urban sprawl;

* to stop neighbouring towns and cities from joining-up;

* to protect the countryside;

* 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.

2. Air quality

The development of site HT1 would have a significant impact on air quality as a result of the increased traffic expected to access the site; the principle areas of concern area being Cambridge road, which is at, or near capacity and subject to significant periods of stationary traffic. From details provided in the Air Quality Emissions Planning Guidance it can be surmised that with areas of the A505 already designated Air Quality Management Areas (AQMAs) this is likely to be a significant argument against such a development.

3. Provision of Local Amenities

In order to support a housing development of such magnitude it is necessary to ensure that the existing infrastructure of local amenities is sufficient to cope with the extra demand, or if not provide suitable development plans that address the shortfall. Whilst the planning caveat for an additional primary school is welcome, we believe that the Local Plan provides little evidence that the proposed development can be supported solely by an additional 500m2 of retail space proposed (roughly one medium-sized convenience store). Furthermore, there is little to no evidence of any other planned amenity development within the local area that would help integrate the site at HT1 into the town.

With respect to the proposed site's impact on local amenities, we still believe the proposed development is unsound with respect to the following Local Plan policy:

Local Amenities (General):

Manual for Streets (Department for Transport, 2007) states that "Walkable neighbourhoods are typically characterised by having a range of facilities within 10 minutes (up to about 800m [0.5 miles]) walking distance of residential areas which residents may access comfortably on foot". Therefore, convenient walking, as set out in the policy, will be taken to be up to 800m.

In order for local amenities to be convenient, they must be within walking distance - which with reference to the above should be within 800m (0.5 miles). Outside of the proposed minimal 500m2 allocation for HT1, the Local Plan states (Section 12.9.2) that the following (local) community centres would be provided:

* The area around Café Valeriya (Grove road/Woolgrove road crossroads) 0.4 miles, or 8 minutes from nearest HT1 access point

* The area around Polcaro's Fish and Chip shop (Woolgrove road/Cambridge road crossroads) 0.5 miles, or 11 minutes from nearest HT1 access point

* The area around Cambridge Road Stores (Cambridge Road). Just over 0.5 miles or 11 minutes from nearest HT1 access point.

Of these three, only one is within the maximum walking distance of the periphery of the HT1 site, the other two are at the maximum distance, with the majority of the development site outside of this maximum distance (to provide context, the periphery of site HT1 is 1.3km or 0.8 miles from the town centre). There is no supporting evidence to suggest that the development of these areas is being pursued in the Preferred options document.

In the Transport infrastructure plan, both sites HM5.5 (Grove road/Woolgrove road crossroads) and Site HM5.1 (Woolgrove road/Cambridge road crossroads) are indicated as being at near-capacity and are thus proposed for improvement schemes to encourage traffic flow, neither having any local parking.

Given the above, it is extremely unlikely that residents (other than those at the periphery of site HT1) are going to walk to local amenities outside the nominal small allocation provided for site HT1. If the majority drive, the likelihood is that most would travel to either Hitchin or Letchworth town centres in preference, given the ease of access and greater choice. Since the proposed development caters for approximately 700 homes, or circa 1500 people, one can expect in excess of 900 cars (assuming 1.3 cars per household) to be associated with the development. This is approximately 100% of the allocated town centre car parking spaces provided by NHDC (neglecting Nightingale road, Hitchin swim centre and the shopping centre private car parks).

Unless sustainable transport alternatives are provided, or significantly more local amenities (i.e within the development) are included on site HT1, the stress upon Hitchin town centre generated by increased car travel would be severe.

In the context above, the term 'local amenities' is used loosely to cover those premises which provide necessary services for day-to-day life; this includes the private and public sector (shops, doctors, dentists, schools, nurseries etc.). NHDC should be well aware that local amenity provision in the area is already poor:

* There are just two local shops (MPM stores on Woolgrove road and Lifestyle express on Cadwell lane) within the proposed 800m walking distance.

* The local pub (the Sailor) has recently closed pending private development, with the nearest alternative - the Anchor 0.6 miles away; this ignores the Gardeners' Arms which is positioned along a dangerous section of highway - inaccessible by foot, especially given the pedestrian-unfriendly nature of the Stotfold road entrance.

* The nearest doctors, dentists, opticians and other basic amenities are all classically defined as being within the town centre and well outside walking distance.

* Walsworth community centre is already under threat of closure. Should this happen, one of the key focal points necessary for any large community would be lost.

The Local Plan preferred options document fails to provide any mitigation to the added pressures the development of site HT1 would provide, with all referenced community centre sites lacking specific detail, as well as being at the extreme or outside what is defined as 'walkable'.

4. Impact on Transport Infrastructure

With respect to the proposed site's impact on local transport infrastructure, we believe the proposed development is unsound with respect to the following Local Plan policies:

Transport Policy T1: Sustainable Transport

To help deliver accessibility improvements and the promotion of sustainable transport, development proposals should:

1. be in locations which enable sustainable journeys to be made to key services and facilities;

2. comply with the provisions of the Local Transport Plan and other supporting documents as considered necessary;

3. ensure that a range of alternative transport options are available to occupants or users. This may involve new or improved pedestrian, cycle and passenger transport links and routes;

4. in the construction of strategic sites, allow for the early implementation of sustainable travel infrastructure in order to influence the behaviour of occupiers or users and in order that sustainable travel patterns become embedded at an early stage; and

5. protect existing rights of way, cycling and equestrian routes and, should diversion be unavoidable, provide replacement routes to the satisfaction of the Council.

As already stated in Section 2, there is little provision in terms of local amenities (with respect to the 800m maximum walking distance), it is also highly likely (despite NHDC's best intentions) that the majority of residents would either be commuters (it has been estimated that 49% of all North Hertfordshire residents who are in employment commute out of the district for work), or would seek employment in areas outside of walking distance.

Travel by Car

As previously detailed, it can be expected that in excess of 900 cars would be added to the road infrastructure as a result of the development of site HT1. It is already noted from the Local Plan that the infrastructure at the key junctions associated with this development (those on the A505) are already at or near capacity. Although it is unrealistic to expect this total volume of cars to be journeying simultaneously, it is probable that a majority would travel during peak times, given the distance of the site from the town. Furthermore the majority of these journeys would involve travel along the A505, as this is the principle access road to the development, linking to the site to the A1.

Proposed mitigations have previously been shown to be insufficient and it can therefore be concluded that the proposed improvements to traffic infrastructure are likely to have little or no benefit over the 2011-2031 time frame.

Train

From the Local Plan (Section 22.23):

Whilst the station is easily accessible from the town centre by walking and cycling, the lack of an eastern and southern access to the station is problematic for journeys from the periphery of the town. The station car park is privately owned, providing 338 long stay spaces which are in high demand during the week.

Other than implying that train service operators must act to create extra services from Hitchin to cater for the growing population, there is no mention of how commuters from the HT1 site are to access the station. As covered above, the roads in the area are already gridlocked. There is little mention of planned cycle infrastructure between site HT1 and the station and it is worth noting that the railway bridge over Cambridge road and the accompanying junction to Nightingale road pose significant dangers to cyclists. Site HT1 is also outside the 800m walking distance target from the station. Should pedestrian access be encouraged, there are further issues posed by the constriction of the pathway under the railway bridge, as well as the frequent use of Walsworth common as a 'cut-through', a route which is unlit at night.

Bus

The Local Plan states that research has showed that only 3% of people living in Hitchin commute to work using the bus. The plan goes no further in suggesting how the use of buses might be encouraged to relieve pressure on other forms of transport (principally cars). From this it can be inferred that no effort would made by NHDC to promote bus services to site HT1.

Cycling

As covered above, there is little or no provision of cycling infrastructure in Hitchin. The transport infrastructure plan places strong emphasis on easing traffic congestion at sites HM5.1 and HM5.2, including filter lanes on the former to keep traffic at speed. This emphasis would have a negative effect on potential commuters' adoption of cycling as a means to access either the centre of town or the railway station. Again the Cambridge road bridge also poses a significant danger area which has not been addressed in the Local Plan.

It can be concluded from the above, that the proposed development of site HT1 is unfeasible with respect to creating a synergistic sustainable transport system that acts to unify this site with the other keys areas of Hitchin (the station and the town centre). Such a development would, as a result, sit in isolation; its residents forced to use private cars as a means to access work and local amenities.

5. Employment

One of the main premises underlying the support of development of site HT1 is the intended promotion of site HE1 as a local employment centre. As previously detailed during the consultation period, there are major flaws in this assumption, including:

* The scope for increasing employment is slim.

* The majority of households occupying site HT1 are likely to be commuters either travelling to London or outside of North Hertfordshire for work.

* There is a significant mismatch between the predominantly light industry occupying this site and the mainly professional workforce expected to occupy site HT1.

The Local Plan lacks credible evidence that employers can be attracted to site HE1 and as such the premise that it can act as a major employment centre for site HT1 is unfounded.

It is unsafe to add so many homes in this particular area. It is already very congested traffic wise and emergency services struggle multiple times a day to navigate the heavy traffic system between Hitchin and Letchworth. Adding in excess of 600 vehicles each day to this will prove increasingly dangerous. The risk of people using side roads as rat rubs puts everyone at risk. The local schools, doctors and dentists are over subscribed and the Lister hospital can barely deal with the through flow as it is. To increase the number of people accessing the local amenities such as health and education without the ability to increase capacity is sheer madness. There has already been numerous traffic calming attempts locally to no avail. It only takes small road works or a spell of bad weather to block access to or through from Hitchin to Letchworth. Parking is already difficult- people double park which reduces emergency vehicle access

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

Policy SP17: Site HT1
We previously highlighted that a Preliminary Risk Assessment (PRA) would be required but this has not been included.

The scale of the development would overwhelm surrounding residential area. In particular access via Highover Way - a difficult read to navigate at the top- which will becoming a rat run for motorists avoiding Cambridge road. Not good considering the proximity of highover school
Surrounding infrastructure will not support such a large scale development.
Land is green belt
Essentially the size of a large village being attached medium size town.

The proposal conflicts with the National Green Belt policy.
There is a lack of justification for the excessive housing target that does not take proper account of Green Belt constraints. Green belt should only be built on exceptional circumstances and these are not exceptional.

Contrary to the NPPF paragraph 150 NHDC's Plan does not reflect the vision and aspirations of the local community

The roads around the proposed development are regularly gridlocked during the rush hour and the addition of another 700 homes would only worsen the situation. Virtually all traffic entering or leaving Hitchin or accessing the industrial area on that side of town has to pass through Walsworth crossroads. It could not cope with another massive increase in traffic.

Another 700 homes would put a massive strain on our already overstretched doctors' and dentists' practices. There would not be sufficient secondary school places to cope with the extra number of pupils.

See attached

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


Share this debate
18 July 2016
Volume 613
* Philip Davies (Shipley) (Con)
Share this contribution
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)

Share this contribution
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


Share this contribution
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

Share this contribution
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

Share this contribution
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 to say that I find the potential development at Highover Farm totally incomprehensible!
The thought processes of those responsible, ill-conceived and totally lacking in foresight
The current infrastructure cannot even cope with the quantity of traffic generated at present time peak periods.
The additional volume of traffic created by the proposed 60 flat development at Walsworth together with the Highover Farm development could potentially generate an additional 1400 vehicles on an already congested highway. If we also factor in the additional vehicles created by school and shop traffic, the prospect is alarming!
It does not take great intellectual capacity to envisage the gridlock at Walsworth crossroads - with tailback traffic from Letchworth, Stotfold Road, Woolgrove Road and Willian Road backing up to Millard Way .
Many areas of Hitchin (Stevenage Road , Paynes Park , Parkway and Upper Tilehouse Street ) already suffer from very high levels of air pollution generated by petrol and diesel fumes . At present, during peak periods on Cambridge Road, fumes from vehicles, both stationary and passing, can easily be detected. The additional vehicles generated by the proposed development would generate intolerable, possibly hazardous levels of air pollution, leading to serious health issues and concerns.
There is also concern that the existing cul de sacs of Collison Close and Roundwood Close would be tied into the proposed development at Highover Farm creating the huge potential of rat running through the Rosehill estate . Millard Way in particular has a large volume of school traffic parking up to deliver and collect children from Highover School . A rat-run of this nature could seriously compromise child safety.
The government has continually stressed that houses must only be built on Greenbelt land as an absolute last resort. However, with the introduction of the new homes bonus scheme , the revenue generated by this incentive has obviously been irresistible to North Herts District Council who it now seems are willing to allow development on any such Greenbelt and at any cost to local residents and environment.
I would draw your attention to a government report dated 2011 entitled :
Foresight .The Future of Food and Farming which stresses that we and other countries will need to grow more crops to feed ourselves therefore Greenbelt is crucial for this requirement.
It therefore follows that development on Greenbelt sites should be resisted at all costs .

Please find below my objections to site HT1 Hitchin, as part of the Local Plan consultation.

* Lack of local facilities such as schools, doctors surgeries, dentists, hospitals - the local area for schools is already over subscribed at all age levels, and with more families moving to in the area, urgent additional provision is required. Furthermore, there has been no specific detail on what local facilities will be provided for. It should be mandatory that any development has conditions proposed on it that adequate facilities be provided.
* Road Transportation - the local area is already gridlocked, particularly at peak times. It can be hard to exit Grovelands Avenue to Stotfold Road (heading towards Cambridge Road) due to congestion. With potentially 700 new homes, many with multiple cars, this situation will get much worse without new roads or improvements to existing roads. Junctions in the local area need to be improved before any development occurs to prevent the town grinding to a halt and affecting the town's economic development. High pollution levels from stationary vehicles will affect my family's health and those around me due to my proximity to Stotfold Road. A new link road bypassing Hitchin may be the answer?
* Roundwood Close/Grovelands Avenue - no vehicle access should be provided from HT1 to these roads as there will be a severe adverse impact on the neighbourhood. There are other more suitable options.

I wish to challenge the soundness of the Submission Local Plan on grounds of inconsistency with NPPF para 35 on sustainable transport.

I will outline concerns relating to only one development - that proposed for Site HT1, Highover Farm, Hitchin - which will mean that it will have a particularly adverse impact on traffic in Hitchin. Strategic Policy 17 and its explanatory paragraphs make no explicit mention of pedestrian and cycling routes or public transport. Development management policies as they are currently written are insufficiently robust to ensure that the impact of this, and possibly other developments, will be mitigated.

Location relative to key destinations
This development is on high ground. For pedestrians or cyclists, depending on the route chosen, the journey from Hitchin town centre is about 1.5 miles, and involves a climb of some 100 feet. It is just under a mile from Hitchin station. A similar climb to the development is involved. Most significantly, pedestrians and cyclists have no alternative to passing under the rail bridge on the A505 just to the north west of the station. For pedestrians, this involves the negotiation of what can only be described as a chicane, where it is barely possible for two people to pass. For cyclists, the roadway under the bridge is narrow and often very busy - only the very confident or foolhardy would choose to use it at such times.

The impact of the development on the local transport network
As SLP para 4.204 states, the intention is that an access road will be created onto the Stotfold Road. The intention is that the development should not 'turn its back' on Hitchin. If that aspiration is fulfilled, the majority of residents will travel into or through Hitchin on a regular basis. Given the above obstructions to active modes of transport if no extra provision is made to incentivise and facilitate them, future residents are likely to regard a car as essential, and use it on a daily basis. The result will be that pressure on the already congested pinch-point of the Cambridge Road/Stotfold Road roundabout will be increased. For those driving on the A505 from the north east, into Hitchin or beyond to Stevenage or Luton, there will be increased congestion at the Woolgrove Road/Cambridge Road traffic lights, in the vicinity of the station or at the Woolgrove Road/Grove Road/Cadwell Lane/Wilbury Way junction.

Conclusion
In order for the development to be sustainable, policies to prioritise the development of safe and secure walking and cycling routes within, and providing connectivity to, the development are essential. Significantly improved public transport links are also critical. The effectiveness of such policies needs to be assessed against appropriate indicators and targets on a regular basis.

I would therefore like to endorse the Hitchin Town Action Group's (HTAG) submission, section 10A, which addresses the policy omissions and suggests alterations to address these issues. It goes on to suggest an indicator and target by which progress could be measured.

In addition, I strongly support the suggestion made in HTAG submission paras 1.6(ii), that the congested area around the station, including the Cambridge Road under-bridge and potential access to the station from the east, be visited by the Inspector.

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

See attachment

See attached

See attachment

See attachment

See attachment

See attached

See attachment