Policy SP18: Site GA2 - Land off Mendip Way, Great Ashby

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?

See attachment

I wish to have on record that I support the response to the local plan from Weston Parish Council in its entirety. Attached to this email, and copied below the footer

NHDC Local Plan - Weston Parish Response November 2016

Weston Parish Council (WPC) generally supports the NHDC plan for more much needed housing, especially affordable, and recognises that because North Herts is largely within the Metropolitan Green Belt a limited release for this land for essential development is unavoidable.

In relation to the Tests of Soundness:
Positively Prepared
The first draft of the NHDC Local Plan proposed 7700 houses. WPC remains unconvinced that the current housing numbers are accurate because no clear justification for the increase has been made. These doubts concerning the robustness of the housing figures proposed is reinforced by the recent announcement that fewer homes are now required, albeit this lower figure has not been incorporated into the Local Plan. WPC contends that much of the development being proposed is not essential and therefore should not justify release of Green Belt land. WPC recommends that NHDC should determine the minimum need for essential housing and that this becomes the basis for the release of Green Belt. The remaining housing should be concentrated in brown field sites and areas beyond the Green Belt. WPC supports the view a new Garden City should be the favoured approach for future housing needs.

Effectiveness of the Plan
WPC believes this to be at severe risk because of the inadequacy of the North Herts trunk road network. This inadequacy already causes severe congestion in the local towns of Baldock, Letchworth and Hitchin, and on the rural roads congested by traffic avoiding the trunk routes (rat-running). This is particularly severe at peak times in the morning and afternoon. This is endorsed by the A1 East of England interim report (June 2016). There is, as yet, no visible plan or timescale to resolve the issues raised in this report.

WPC also considers that this Local Plan is flawed in that there is no provision for an effective East/West route through the area of proposed development. The A505 to the East of Baldock and to the West of Hitchin is dual carriageway but these two parts need to be linked. The problem of congestion caused by the lack of this link will be worsened by the Local Plans' large increase in population and the already agreed expansion of Luton Airport.

WPC considers these two trunk routes should be improved before any widespread development takes place.

Justified and Consistent with National Policy
WPC contend that the proposal to release land with the potential for 3100 house to the West of Stevenage, but then reserving it for future use, is not commensurate with the principle of Green Belt protection, i.e. only to be released for essential development purposes.

However, if, as required by the NPPF, there must be cooperation between adjacent Districts, then development of the West of Stevenage site should be a priority now as it will support financially the development by Stevenage Borough Council of their land west of the A1(M). WPC therefore contend that this site should be developed now instead of GA1, GA2 and NS1 and this increased capacity counted towards the 2011-31 housing need.

WPC considers the advantages of the West of Stevenage site to be its close proximity to the town centre, the rail and bus stations, retail parks, and to Junctions 7 and 8 of the A1(M). It would also be close to a newly constructed east-west A505 link to Luton and Royston (for Cambridge), as proposed in the NHDC Infrastructure Plan. The A1 East of England Interim Report, June 2016, states that the A1(M) between Junctions 6 and 8 needs urgent improvement work. Work to service the West of Stevenage Development could be incorporated into these improvements.

WPC opposes GA1 (Roundwood) and GA2 (SP18) for the following reasons:
* Both sites are within the Green Belt and are remote from the town centre, bus and rail stations, retail parks and motorway access points.
* Access for both sites is planned through a residential area that was built without making adequate provision for new development of this magnitude.
* GA2 (SP18) in particular would create a weak indefensible Green Belt boundary that could be open to challenge in the future (see para 4.215).
* The NHDC Infrastructure Plant identifies the need for a new secondary school in this area but the Local Plan does not include this in either proposed sites (GA1 or GA2). It is clear. therefore, that the NHDC will be seeking to release further land from the Green Belt outwith the releases contained in the Local Plan proposal. WPC have been unable to get details of this and have made a Freedom of Information request to Herts CC to clarify their secondary school plans for this area.
* WPC disputes the validity of the traffic assessment for GA1 (Roundwood) and WPC commissioned a survey from a specialist traffic consultant. The main findings of this report are:

a. That the traffic assessment prepared for the GA1 development is deeply flawed in that the assessment did not take account of the change in traffic flows from and to existing properties in Great Ashby as a result of the changes to access roads being provided for GA1. In particular this would greatly increase traffic affecting the nearby villages of Weston and Gravely.

b. That the traffic assessment made no attempt to determine traffic flows by considering the destination of journeys and thereby the likely route to be taken to that destination.

c. That it is reasonable to assume the findings of the consultant's report could be applied equally to the GA2 development as it is nearby and access to it is proposed to be along the same route as GA1 (Mendip Way).

The consultant's report is appended to this submission.

WPC instigated a Housing Needs Survey that indicated a need for 14 affordable homes. WPC supported the proposal for 25 homes on land that was originally designated for housing when the adjoining estate was constructed. However, WPC opposes the addition of 15 additional houses on the grounds that it is an unnecessary incursion into the Green Belt, and that it will not increase the number of affordable housing for the village based on the NHDC's stated target of 33% being affordable (SP8).

Summary

WPC supports the need for a limited and targeted release of Green Belt land for housing but only for that considered absolutely essential to support the current social and economic needs of North Hertfordshire.

WPC are strongly of the view that the proposed developments to the north-east of Stevenage (GA1 and GA2) are poorly positioned in terms of access and provision of infrastructure. If it is considered that new building bordering Stevenage within the Green Belt is vital to the success of North Hertfordshire, a properly designed development to the West of Stevenage containing all essential infrastructure should be built as part of the NHDC Local Plan 2011-31.

I wish to have on record that I support the response to the local plan from Weston Parish Council in its entirety. Attached to this email, and copied below the footer

NHDC Local Plan - Weston Parish Response November 2016

Weston Parish Council (WPC) generally supports the NHDC plan for more much needed housing, especially affordable, and recognises that because North Herts is largely within the Metropolitan Green Belt a limited release for this land for essential development is unavoidable.

In relation to the Tests of Soundness:
Positively Prepared
The first draft of the NHDC Local Plan proposed 7700 houses. WPC remains unconvinced that the current housing numbers are accurate because no clear justification for the increase has been made. These doubts concerning the robustness of the housing figures proposed is reinforced by the recent announcement that fewer homes are now required, albeit this lower figure has not been incorporated into the Local Plan. WPC contends that much of the development being proposed is not essential and therefore should not justify release of Green Belt land. WPC recommends that NHDC should determine the minimum need for essential housing and that this becomes the basis for the release of Green Belt. The remaining housing should be concentrated in brown field sites and areas beyond the Green Belt. WPC supports the view a new Garden City should be the favoured approach for future housing needs.

Effectiveness of the Plan
WPC believes this to be at severe risk because of the inadequacy of the North Herts trunk road network. This inadequacy already causes severe congestion in the local towns of Baldock, Letchworth and Hitchin, and on the rural roads congested by traffic avoiding the trunk routes (rat-running). This is particularly severe at peak times in the morning and afternoon. This is endorsed by the A1 East of England interim report (June 2016). There is, as yet, no visible plan or timescale to resolve the issues raised in this report.

WPC also considers that this Local Plan is flawed in that there is no provision for an effective East/West route through the area of proposed development. The A505 to the East of Baldock and to the West of Hitchin is dual carriageway but these two parts need to be linked. The problem of congestion caused by the lack of this link will be worsened by the Local Plans' large increase in population and the already agreed expansion of Luton Airport.

WPC considers these two trunk routes should be improved before any widespread development takes place.

Justified and Consistent with National Policy
WPC contend that the proposal to release land with the potential for 3100 house to the West of Stevenage, but then reserving it for future use, is not commensurate with the principle of Green Belt protection, i.e. only to be released for essential development purposes.

However, if, as required by the NPPF, there must be cooperation between adjacent Districts, then development of the West of Stevenage site should be a priority now as it will support financially the development by Stevenage Borough Council of their land west of the A1(M). WPC therefore contend that this site should be developed now instead of GA1, GA2 and NS1 and this increased capacity counted towards the 2011-31 housing need.

WPC considers the advantages of the West of Stevenage site to be its close proximity to the town centre, the rail and bus stations, retail parks, and to Junctions 7 and 8 of the A1(M). It would also be close to a newly constructed east-west A505 link to Luton and Royston (for Cambridge), as proposed in the NHDC Infrastructure Plan. The A1 East of England Interim Report, June 2016, states that the A1(M) between Junctions 6 and 8 needs urgent improvement work. Work to service the West of Stevenage Development could be incorporated into these improvements.

WPC opposes GA1 (Roundwood) and GA2 (SP18) for the following reasons:
* Both sites are within the Green Belt and are remote from the town centre, bus and rail stations, retail parks and motorway access points.
* Access for both sites is planned through a residential area that was built without making adequate provision for new development of this magnitude.
* GA2 (SP18) in particular would create a weak indefensible Green Belt boundary that could be open to challenge in the future (see para 4.215).
* The NHDC Infrastructure Plant identifies the need for a new secondary school in this area but the Local Plan does not include this in either proposed sites (GA1 or GA2). It is clear. therefore, that the NHDC will be seeking to release further land from the Green Belt outwith the releases contained in the Local Plan proposal. WPC have been unable to get details of this and have made a Freedom of Information request to Herts CC to clarify their secondary school plans for this area.
* WPC disputes the validity of the traffic assessment for GA1 (Roundwood) and WPC commissioned a survey from a specialist traffic consultant. The main findings of this report are:

a. That the traffic assessment prepared for the GA1 development is deeply flawed in that the assessment did not take account of the change in traffic flows from and to existing properties in Great Ashby as a result of the changes to access roads being provided for GA1. In particular this would greatly increase traffic affecting the nearby villages of Weston and Gravely.

b. That the traffic assessment made no attempt to determine traffic flows by considering the destination of journeys and thereby the likely route to be taken to that destination.

c. That it is reasonable to assume the findings of the consultant's report could be applied equally to the GA2 development as it is nearby and access to it is proposed to be along the same route as GA1 (Mendip Way).

The consultant's report is appended to this submission.

WPC instigated a Housing Needs Survey that indicated a need for 14 affordable homes. WPC supported the proposal for 25 homes on land that was originally designated for housing when the adjoining estate was constructed. However, WPC opposes the addition of 15 additional houses on the grounds that it is an unnecessary incursion into the Green Belt, and that it will not increase the number of affordable housing for the village based on the NHDC's stated target of 33% being affordable (SP8).

Summary

WPC supports the need for a limited and targeted release of Green Belt land for housing but only for that considered absolutely essential to support the current social and economic needs of North Hertfordshire.

WPC are strongly of the view that the proposed developments to the north-east of Stevenage (GA1 and GA2) are poorly positioned in terms of access and provision of infrastructure. If it is considered that new building bordering Stevenage within the Green Belt is vital to the success of North Hertfordshire, a properly designed development to the West of Stevenage containing all essential infrastructure should be built as part of the NHDC Local Plan 2011-31.

I wish to register my strong opposition to this proposal. I believe the development would have profound detrimental and devastating effects for the local people, surrounding villages, wildlife, the environment and public services.

The proposed siting of the development is on green belt land used by many local people for recreation and dog-walking. The development will diminish the striking countryside views around the existing Great Ashby area. The impact on the local people and wildlife this development would create would be detrimental - with pollution from construction, noise pollution and increased traffic on existing residential streets.

I urge you to take note of the issues raised above and reject the proposed development for Great Ashby.

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

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

1. I JUDGE THIS PLAN TO BE UNSOUND

The plan is unsound for the following reasons:

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

NOT POSITIVELY PREPARED

Plan Policy SP8

Para 158 of the National Planning Policy Framework (NPPF)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

NOT JUSTIFIED

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

NOT EFFECTIVE

Plan Policy SP8

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

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

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

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

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

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

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

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

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

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

Plan Policy SP1

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

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

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

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

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

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

Policy SP5 - Countryside and Green Belt

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

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

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

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

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

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

6.03 Para 80 states that:

Green Belt serves five purposes:

Amongst these:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

7.04 One should consider:

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

It is not acuteness that matters it is exceptional acuteness.

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

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

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

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

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


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

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

Plan Policy SP10

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

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

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

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

Plan Policy SP13

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

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

10.00 Conclusion

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


ADDITIONAL COMMENTS

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

David

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

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








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

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

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

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

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


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



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

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

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

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

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

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