2 A Picture of North Hertfordshire

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5294

Received: 30/11/2016

Respondent: Hertfordshire County Council - Public Health

Representation:

Objection 2 A Picture of North Hertfordshire:
- would be sensible to reference the Hertfordshire Health and Wellbeing Strategy 2016-2020. This document is available at
www.hertfordshire.gov.uk/hwb and recognises that the things affecting our health and wellbeing vary over the course of our lifetime. Therefore, the strategy has been developed using four significant stages of the life course (starting well, developing well, living & working well, ageing well).
- Planning has a fundamental role to play in creating the environments that support these.

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6042

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Representation:

Para 2.8 - text demonstrates that the plan fails to seek to limit population and household growth in the district to a level consistent with national planning policy , and in particular para 14 and footnote 9 of the NPPF.
Para 2.35 - This para should include the key caveat in para 47 of the NPPF, which requires constraints such as Green Belt and AONB to be taken into account in determining the scale of housing provision in the district and HMA.
Para 2.39 - The final sentence fails to state that the needs of the HMA can only be met in full if the constraints imposed by paragraphs 14 and 47 of the NPPF are ignored, resulting in significant harm to the Green Belt.
Para 2.41 and 2.42 Figures for Lutons housing capacity are out of date and this has an important bearing on the scale for new housing that North Hertfordshire should contribute to Luton's needs. Figures updated through EIP process. Specific intention in para 2.42 to meet all of the Plans proposed contribution to Luton's housing needs within the small strip of GB land immediately abutting Luton is unjustified, particularly when weighed against the harm that would be caused to the GB and the high quality landscape of the whole of this area, and the likely impact on the communities in the area and rural infrastructure.
Para 2.44 - The plan does not justify he statement that Stevenage is unable to provide adequate employment land within its own administrative area to meet the scale of need that is acceptable in the context of NPPF para 14. The evidence on capacity within Stevenage has yet to be tested through the SBC Local Plan examination which is due to commence in January. NHDC plan should not pre-judge the inspectors conclusions on this issue.
Para 2.66 - The second bullet point fails to include the important caveat in NPPF para 14 and footnote 9, which set out the context for meeting development needs and the principal constraints limiting this aspiration.

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6210

Received: 28/11/2016

Respondent: Bedfordshire & River Ivel IDB

Representation:

Object to Ch.2 : Significant flooding events have occurred downstream due to run off in NHDC contrary to para 2.29, SuDS infrastructure should be included in para 2.78

Full text:

The Bedfordshire and River Ivel Internal Drainage Board makes the following comments to your proposed Local Plan 2011 -2031 consultation.

The Plan does not adequately address Flood Risk and should be amended to strengthen the requirements of addressing flood risk and development, particularly in the north of the District in Letchworth and Baldock.

Below are some examples of paragraphs which should be redrafted to ensure development does not have a detrimental effect on flooding:

2.29 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

2.78 The paragraph must include infrastructure that is required to accommodate growth as SuDS which are strategic, integrated and maintained. This is critical given the scale of development in Letchworth (900+ houses) and Baldock (2800 + houses).

3.6 The spatial vision of high quality sustainable design and managing flood risk needs to refer to the provision of strategic and integrated SuDS, which include effective and funded SuDS maintenance.

4.73 Policy SP7. This infrastructure should include SuDS and flood risk management, such that a public authority can ensure drainage infrastructure operates as designed in the future.

4.131 Policy SP11. It is inadequate to state that this Plan 'seeks'.... when other policy state 'will'. The Policy should state the Plan will deliver the provision of strategic and integrated SuDS that will be maintained.

4.136 For clarity, WFD seeks to meet good ecological "potential" for heavily modified and artificial water bodies, as well as good ecological "status" for natural water bodies.

4.137 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

SP14. Downstream of Baldock is Stotfold which has experienced flooding from the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

SP15. Downstream of Letchworth is Stotfold which has experienced significant flooding from the Pix Brook and the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

NE7. There is a requirement to reduce the existing flood risk in Stotfold immediately downstream of the urban runoff areas of Letchworth and Baldock, as in SP14 and SP15, this Policy should be strengthened to include mitigation being designed and implemented on development sites to attenuate flows c) and d). It is fundamental that flood risk is minimised and that functional and effective infrastructure is provided that is maintainable in addition to items e).

NE8. This Policy should include strategic, integrated and maintainable SuDS for all sources of flood risk, and not just surface water, particularly given that flood risk exists from the Ivel and Pix Brook. The area is heavily modified with public storm sewers, modified watercourses and large flood attenuation reservoirs (Pix Brook), so any solution for development needs to be appropriate to the scale of development, rather than simply mimic the natural drainage pattern.

NE8 and 11.59. For developments draining in the Ivel and Pix Brook catchment, the Council and developers should also consult the IDB, as well as the Lead Local Flood Authority and the EA.

NE9. For any development in the Bedfordshire and River Ivel IDB district, a developer will be required to comply with the Board's Byelaws including maintaining a minimum 7 m wide undeveloped buffer zone for ordinary watercourses and applying the land drainage consenting regime.

I trust you find the Board's comments clear and informative.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6291

Received: 30/11/2016

Respondent: Hertfordshire County Council

Representation:

Object to para 2.55: Additional detail on minerals planning required

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6298

Received: 30/11/2016

Respondent: Hertfordshire County Council

Representation:

Object to Ch.2: Full range of heritage assets should be identified as per NPPF definition of historic environment

Full text:

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