Section One - Introduction and Context

Showing comments and forms 1 to 30 of 48

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 227

Received: 24/10/2016

Respondent: Mr Peter F Constable

Representation:

General concerns (no policies or locations specified): Loss of Green Belt, traffic in rural lanes, pressure on A505

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 465

Received: 29/11/2016

Respondent: Mr Alan Gordon

Representation:

Object to SA (Baldock): Assessment of alternates, contribution to local housing needs overplayed as homes will be occupied by outward migration from London, impact of releasing land close to station at Baldock not properly considered, assumption that infrastructure improvements can be leveraged from new development, no account of existing deficiencies, assumes development can be brought forward quickly, negative effects not always addressed in plan, different weight given to loss of Green Belt in assessment of new settlements vs existing towns

Full text:

4.62 the Sustainability Appraisal in fact lists many negative effects of releasing Green Belt. However, in comparing two options - development around existing towns or development of new Settlements - the Sustainability Appraisal makes three flawed assumptions which have had a drastic impact on the plan.
Firstly, it assumes that development of land north of Baldock will help to meet local housing need, however, it takes no account of the fact that the land is right next to the train station which has a direct fast (34 minutes) link to central London - the impact of this is that a large strip of this development (the area within 20 minutes walk of the station) will go toward London housing need and so will be strongly affected by house prices in the London Housing Market and will leave local housing need unmet and it may well act to drive up local house prices. The reason, I think, that this has been ignored is because it has been assumed that the Stevenage Housing Market will apply to this development - but that assumption is based on normal organic growth, where existing high value locations (for example close to fast connections to London) have previously been developed - however this is not the case for this site because this land was previously protected by the Green Belt allocation. The Sustainability Appraisal has failed to consider properly the impact of releasing so much previously Green Belt land so close to the train station. As mentioned elsewhere, this omission can be mitigated by separating the new development from Baldock so that very little of it is less than 20 minutes walk of the station, or by developing this strip only when the rest of the site has been developed.
Secondly, the Sustainability Review assumes that existing facilities of existing towns can be efficiently leveraged by building onto those town, but takes no account of the fact that (in Baldock at least) existing facilities and resources are severely overstretched. For example, schools are very over subscribed, the GP surgery is a capacity, open space and leisure facilities are far below national averages and target values (from tables within Sustainability Appraisal documents themsleves) - so extending existing towns is actually starting from a deficit of local facilities and resources. However, it is clear the development creates opportunities to address this deficit and it is vital that the plan takes positive action to do so. It must recognise the poor starting point and deliberately set out to improve the overall situation as a result of any large scale development (for example the large site north of Baldock, or the cluster of sites surround Clothall Common, to the east of Baldock).
Thirdly, it assumes that the District Council and County Council have the competency maturity to develop large sites quickly. Recent experiences, (for example, Great Ashby or the Church Gate development in Hitchin) point to this not being the case, and the largest sites should be scaled back and development distributed more evenly around the district.
I also feel strongly that establishing (starting) 2 new garden villages by the end of the plan, will help create new options and facilitate an effective and achievable increase in the amount of housing and employment in the district - it will also set up options for continued sustainable development in the following planning period (rather than creating another cliff edge, like-it-or-lump situation of manufactured urgency).

Sustainability Appraisal does not consider the release of so much Green Belt close to Baldock train station (with a fast link to London) as exceptional and instead assumes Stevenage HMA house prices will apply - it will in fact encourage migration from London and there needs to be a mitigation against this. It also assumes the district and county councils can deliver large developments quickly, against recent experience. Without these flawed assumptions the option of new settlements would have risen above the option of extending existing towns, or a least a blend of both approaches.

With regard to point 4.62 there are flaw in the Sustainability Appraisal.
The sustainability assessment is comprised of multiple documents concatenated together. I have only had time to skim this document. I do not have a planning background and I apologise if my comments misuse jargon or repeat things.
> Page 89 approx., points out that BA1, BA10, BA4, BA3 and BA2 all lie in open countryside on the northern and eastern edge of Baldock. 2(b) points to a requirement to provide access to green spaces and Maintain existing rights of way. It is highlighted that the distance to open countryside from existing housing will be increased.
Policies mentioned in these documents don't seem to match up with the latest version of this plan - perhaps they relate to earlier versions? It states policy D1 will ensure through-routes are incorporated in new development, but that must be a different policy. The location of these sites to the north and east of Baldock and of all the major sites of employment and entertainment is a major flaw with these sites that hasn't been considered properly.
> Page 90 approx., states that Baldock BA1, BA10, BA4, BA3 and BA2 all lie in areas of high or moderate sensitivity. 3(b) states there will be residual landscape impact.
In seeking to develop up to 'defensible' boundaries, it is important to respect the impact on the landscape.
> Page 96 approx., reduced access to open countryside, potential negative effects on human health - highlights Baldock, Royston and Great Ashby.
Steps must be incorporated into the plan to increase access to open countryside and not simply accept this as a negative consequence of development at these sites!
> Page 103 approx., Table 35: Residual significant sustainability effects of the Plan. States reduced access to the countryside. Sites this as being of high probability.
Again, vital to take steps against this, or indeed to reverse this.
> Page 104 approx., Reduction in quality of landscape and townscape character. For Baldock (and other sites) this is sited as of high probability, permanent and irreversible.
It is vital that the character of the landscape and townscape is respected as much as possible - I believe, separating the development to the north of Baldock, from Baldock will help to preserve the townscape character and will also preserve the character of the countryside around that location (rather than converting Baldock from a small town to a large town with the consequent impact).
> Targets for England: hectares per 1000 people, playing fields 1.2, all outdoor sports 1.6, equipped/designated play areas 0.25, other outdoor provision 0.3. Targets for East of England: children's playspace 0.7, outdoor sporting space 1.7, amenity space 0.8 (from Planning Obligations Strategy 2009). Actual for Baldock: outdoor sports facilities 0.41.
This is far below the target values, far below the average for the district and only Royston is lower on the table (which has been the recipient of a lot of recent development and is not a good precedent of the likely effect of development at Baldock). It is vital that development north and east of Baldock results in new open playing fields as well as new sporting facilities (for example tennis courts or new leisure facilities, perhaps tied to a new school). For the north of Baldock site it is possible to imagine that this will be ensured by the strategic plan covering that site, however, the cluster of developments surrounding Clothall Common on the east of Baldock is not covered by a strategic plan - it should be so as to ensure proper consideration of factors like additional facilities (among many other concerns of adding so much housing at one location - even though it is in 4 sites, they are very close to each other around a single part of Baldock).
> It seems from a skim of this Sustainability Assessment that it takes loss of Green Belt into account when considering the impact of a new settlement, but then does not take it into account (certainly gives it a lower consideration) when considering the impact of a large development attached to an existing town.
This is a serious flaw in the analysis - it needs to be acknowledged and remedied as best as possible.
> The Sustainability Assessment appears to assume that house prices will go down with a large development on the edge of an existing town.
However, releasing land for development so close to Baldock train station (with a 34 minute direct link to London) may drive house prices up. This is a significant flaw in the assessment.
> (item 1 and item 5(d) of option (a) continue development of 4 main towns including development of greenbelt). Option C, item 1 and item 5(d) of option (c)
Appear to suffer the same flawed assumption that building large numbers of housing must necessarily improve affordability, without taking into account the possibility of London commuters taking advantage of newly released land close to the train station and so actually driving house prices up and reducing affordability. It is vital mitigations are put in place - for example, leaving a strip of Green Belt near the train station, or ensuring this land can only be developed when the rest of the site (and other site around Baldock) are been developed. This assumption though is correct in the case of Item 1 and item 5(d) for a new settlement, as the only sites available for new settlements will not provide attractive settlement locations for people wishing to commute to London. This option will make housing more affordable across North Hertfordshire. There is no reason that some progress on this option could not be made over the period of the plan. The expectation that sites will be identified and development will commence during the period of the plan should be included in this plan. If progress is made on this option, other aspects of the plan can be reviewed accordingly. In fact, a long list of possible sites could be included in this plan to show good faith toward pursuing this option over the period of the plan. To kick the can down the road until the next plan is to accept unaffordable housing and non-sustainable development, with the hope that new settlements might be included in the next plan - this is why I feel it is vital that this aspect is included in this plan, so we can see progress against it over the period of this plan. Such sites cannot be counted against forecasts of housing to be delivered by this plan, as such sites might not be deliverable during the time-frame of the plan, however, it is vital that progress is made against this option, and it is also possible the development could (in fact should) commence, in part, on new settlements during the period of this plan and this must not be deliberately excluded by this plan.
> page 533 approx., 5(b) of section 2.2 Baldock site BA1, fails to take into account the proximity of the train station in relation to affordability of housing.
> page 535 approx., 2(b) of section 2.2 Baldock site BA3,
I agree that the site provides the potential for new sporting or recreational spaces and at this position in relation to Baldock and the few other areas, this would likely have a big impact on health and well being of residents in Clothall Common, this new site, and this side of Baldock.
> Page 530 approx., Site BA1 mitigation tables
the proximity to the train station with a direct fast link to the centre of London is an important feature of this site and mitigation should be put in place to ensure new housing doesn't simply contribute toward inward migration of people currently living in London and who will continue to work in London (a long and environmentally friendly journey). For example that the land nearest the train station be given a special status, be developed last of other such mitigation.
> Section 1 - HMA housing market areas,
fails to take any account of 'commuter belt' - areas that receive an uplift due to an easy commute into London and the higher salaries that can be obtained there. This is because it assumes organic growth, where locations close to good transport links into London tend to already be occupied and growth will be via in-fill (as has occurred in the centre of Baldock). However, the massive site to the north of Baldock (BA1, Blackhorse farm) is exceptional as it lies very close to the train station and has been left undeveloped due to it's prior greenbelt status which has been removed as part of the review which forms part of this plan. The plan makes no accommodation for the exceptional nature of this site, situated so close to a train station with a fast (34 minutes) link directly into central London (London Kings Cross). It assumes that the normal HMA will apply to these houses, whereas, the strip of this development within a 20 minute walk will not fall into the normal rules of the Stevenage HMA but will instead be influenced by a significant uplift due to inward migration of people currently living in London (who are influenced by a very different and much more expensive HMA in London) and who will continue to work in London, leading to a large uplift on these houses. This seems obvious, so it is extra ordinary that this has not been considered as part of the plan. It is vital that this is considered. Easy mitigations, such as leaving the area closest to the train station undeveloped, or developing this strip last will greatly affect how effective this plan is at meeting local housing need in a deliverable and sustainable manner.

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 681

Received: 17/11/2016

Respondent: National Grid

Agent: Amec Foster Wheeler E&I UK

Representation:

No comments to make in response

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 712

Received: 29/11/2016

Respondent: Dr John Webb

Representation:

Object to Section One:
- This relates to points in several chapters of the document, in which some items contain minor yet significant errors ('typos') or they lack clarity.
- These hamper accessibility and undermine a reader's confidence in their own understanding, especially where the meaning is unclear or reversed.

Full text:

This relates to points in several chapters of the document, in which some items contain minor yet significant errors ('typos') or they lack clarity.
These hamper accessibility and undermine a reader's confidence in their own understanding, especially where the meaning is unclear or reversed.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 844

Received: 29/11/2016

Respondent: Mr Alan Gordon

Representation:

Object to Plan (general): Little change from Preferred Options, the Planning Inspector should consider reviewing the comments from the Preferred Options version as they will remain mostly valid.

Full text:

The plan remains largely unchanged from the Preferred Options Plan. Despite record levels of participation, the sites, distribution and volumes of development remain unchanged (in fact they have slightly increased and are slightly more disproportionately spread). Policies have been strengthened, but they are still vague and aspirational, rather than concrete and unambiguous - unless they are strengthened, perhaps with examples, then they will be easily pushed aside by the planning and development process and rendered irrelevant. Since there is so little change from the Preferred Options Plan, this raises a question mark over the consultation exercise. If they are not available already, the Planning Inspector should consider asking to see the comments raised against the Preferred Options Plan - these remain relevant as the vast majority of comments were about the location, distribution and volume of development sites (which are almost entirely unchanged). It feels like the Preferred Options Plan, rather than being a genuine consultation, was an exercise in manufacturing urgency. It has succeeded. Like many in North Hertfordshire I have no desire for our district to be left without a development plan (either a 5 year land release plan or a full Local Plan) and I fear the dangers of speculative development in the absence of a Local Plan. For this reason I will not be re-raising objections to the plan as a whole or the disproportionate distribution and volume of development contained within it; I will be limiting my comments as much as possible to areas of North Hertfordshire I know best and to specific elements of the plan that most affect me. This does not mean that the distribution and volume of development described in this Local Plan are any more proportionate, sustainable or desirable than they were in the Preferred Options Plan, but that I think it is important that a valid plan is now put in place. For this reason I think the Planning Inspector should look at the comments raised on the Preferred Options Plan and should recommend any adjustments to the Local Plan that might ensure a more proportionate and sustainable (and less risky) plan is put in place, rather than rejecting it out-right.
In respect to the specific policies affecting the areas of North Hertfordshire that I know well and that affect me most closely, I see a marked improvement over the previous version in the Preffered Options Plan.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1351

Received: 18/10/2016

Respondent: Mr David Parker

Representation:

Object to consultation method: Website not fit for purpose

Full text:

I object to the above application for the following reasons.
It is said this development is to help Lutons unmet housing needs, this would only be true if the properties were only sold to persons on Lutons housing list, and the Hertfordshire county boundary would need to be redrawn to include this development into Luton council boundary. Lutons unmet needs could be met if the Bushwood site was developed, as was planned when the M1 motorway was built, when 2 very large tunnels were built to allow access to this site. Luton also has plenty of unused brownfield sites. So has no need of NHDC "help".
Some towns and villages in North Herts have no or limited developments planned, but NHDC have ensured they keep a complete Green belt around them, this follows government guidelines that communities should not coalesce.I wonder how many councillors and officials from North Herts live in these places, there are certainly none living in Luton as NHDC do not care if Luton residents loose part of their green belt, which is against government guidelines that communities should not coalesce.

The infrastructure of Luton cannot cope with any more traffic, they are gridlocked around Crawley Green and Eaton Green roads as it is. 2000 extra homes could quite easily mean 3000 extra vehicles on Lutons roads at peak times, as there is no feasible route for any of these vehicles to go into North Herts unless the council and government commit to spending £millions on new roads before planning consent is granted, roads which would need to be in place before any building work starts. NHDC has not taken into account the new special needs school being built on Crawley Green Road. This will need access, probably a roundabout. Further slowing traffic at peak times.

No account of the Luton Airport expansion has been taken into account, this will inevitably lead to further air pollution, already depending on wind direction and cloud cover, kerosene fumes drift over the area, with further aircraft movements this will increase. Are NHDC and the Government prepared for legal action over cancers, asthma and other illnesses that can result from their granting of building development in an area of known high pollution, when proper investigations have not been carried out.

I and plenty of other people have registered with NHDC over this matter, and we are all finding it impossible to register our complaints on this website, and are having to use other sites to complain., either your website is not fit for purpose, or is this deliberate. I will be sending a copy of this e-mail to the Secretary of State for him to ask questions about your website.
Please send acknowledgement of receipt.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2039

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Representation:

Para 1.6 - the final sentence lacks and important comma before the phrase "or specific policies in thiss framework indicate development should be restricted" as set out in the NPPF and omits the vitally important cross-reference to Footnote 9 in the NPPF, which sets out the principal constraints that justify limiting housing targets.

Para 1.7 - Bullet 2 in this paragraph omits the key caveat in paragraph 47 of the NPPF which the Council is required to take into account in determining the scale of housing provision in the district and HMA

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2079

Received: 25/11/2016

Respondent: House of Commons

Representation:

Object to Local Plan (general): Support submission of Cllr Jim McNally [1966], Preferred Options submission attached.

Full text:

Dear Sirs

I have seen the objection to the Local Plan which has been submitted by Councillor Jim McNally and I would like to support it. As you will know, I put in a reasoned objection at the previous Local Plan consultation and, although there have been improvements, I still think the points that Councillor McNally makes are well taken. My previous submission is attached.

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2175

Received: 30/11/2016

Respondent: Ms Lynne Bogie

Representation:

Object to Glossary: Definition of previously developed land

Full text:

The proposed Definition of "Brownfield Site/Previously Developed Land(PDL)" in the Glossary to the Submission Draft is defective and leads to absurd, arbitrary and undesirable results

The proposed definition is as follows:

"Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. This excludes: land that is or has been occupied by agricultural or forestry buildings;...."

This contrasts with the long-standing definition in national planning policy guidance, which is as follows:

"Land which is or was occupied by a permanent structure (excluding agricultural or forestry buildings), including the curtilage of the land attached to the permanent structure (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. This excludes: land that is or has been in use for agricultural or forestry purposes;...."

The definition proposed in the Submission Draft leads to absurd and undesirable results.

Imagine a fenced field with a grain store on it, with tarmac laid to and beyond the field gate to the highway. Under the existing definition, no part of the fenced field nor any of the associated fixed surface infrastructure would be a brownfield site (as one would expect). Under the definition proposed in the Submission Draft however, the whole of the field, except for the land on which the grain store actually stands, and all of the associated fixed surface infrastructure outside the curtilage would be a brownfield site. This is an absurd and wholly undesirable result, making the Plan as respects this definition both not legally compliant and unsound.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2885

Received: 30/11/2016

Respondent: Mr John Barry

Representation:

The Local Plan may be legally unsound because:
the Plan is open to legal challenge on the grounds that its approval by councillors was not impartial;
NHDC cannot be regarded as impartial as it stands to benefit from the New Homes Bonus and additional Council Tax receipts; and
NHDC may not have acted impartially as the Local Enterprise Partnership exists to encourage growth in their areas.

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Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3223

Received: 29/11/2016

Respondent: Uttlesford District Council

Representation:

Support

No objections on issues of legal compliance, Soundness or Duty To Cooperate to the North Herts Local Plan.

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Thank you for consulting Uttlesford District Council on the Submission Local Plan. Uttlesford District Council raise no objections on issues of legal compliance, Soundness or Duty To Cooperate to the North Herts Local Plan.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3370

Received: 29/11/2016

Respondent: Mr John Hare

Representation:

Object to plan (general): Difficulties accessing website to complete response forms is making the consultation process untenable and undemocratic

Full text:

Would you please append this email to my letter dated 24th November 2016 delivered by hand to Strategic Planning & Projects Group, NHDC, Gernon Road on the 28th November 2016 at 12.35.

* The Draft Emerging Allocation July 2016, Ashwell shows the boundary of Ashwell has been changed to exclude two of the three sites identified for development in Ashwell's Neighbourhood Plan. Bearing in mind that NHDC's Planners were aware of these sites prior to the cut-off date of March 2016 makes one think that NHDC has removed them wilfully in an attempt to influence the Neighbourhood Plan prior to the Inspector viewing the contents. It appears that there has been no reference or contact with Ashwell Parish Council.
* The CPRE has objected to the development of AS1 because of its impact on the landscape and Ancient Monument and their reasons should be taken into consideration as they are the Trustee for Rural England
* NHDC's website has and still is creating major problems to access and complete the form provided. Although there are alternatives the failure of this website is making the process untenable as having made several unsuccessful attempts they abort it, so their views are not represented making the democratic process unworkable. No doubt this problem will be reflected in the number of responses that will be forwarded to NHDC re AS1 Ashwell.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3720

Received: 22/11/2016

Respondent: Mrs Sarah Talks

Representation:

Object to consultation process: Documents and online form are designed to confuse and in fact deter comment

Full text:

Site AS1 does NOT meet the requirements for highway safety to protect pedestrians and other road users as defined in both NPPF and NHDC's own current and emerging planning policy for Highway Safety Policy T1) It is not possible to create a safe pedestrian access due to the sloping site and narrow roads.
There are other issues with protecting valued landscapes and the historic environment.
The process by which you are seeking responses is completely flawed. This form is almost impossible to engage with. The section under Soundness Test does not make sense and must have been drafted with the specific aim to make it impossible for most people to respond. There should be 'I don't know' buttons, not just Yes and No.
As for 'Appear at examination', I take it to mean that I could ask to come to the 'examination' but this again is not made clear. I suspect that the form has been designed to confuse people who quite legitimately would like to engage with the Local Plan, and to deter people from commenting.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3805

Received: 30/11/2016

Respondent: Beechwood Homes

Agent: JB Planning Associates

Representation:

Object to SA (Site HT2): Detailed observations on scoring and conclusions in relation to this site.

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3978

Received: 30/11/2016

Respondent: Croudace Homes

Agent: Savills

Representation:

Object to SA: Factual inaccuracies in assessment of Site AS1

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3982

Received: 28/11/2016

Respondent: Mr Toby Croft

Representation:

Object to Section One - Introduction and Context:
- Paragraph 2.57 is unsound as it is not consistent with the NPPF
- The overarching transport policy document for the area, Local Transport Plan 3, Does not take into consideration the new development sites, associated traffic generation, set out in the local plan. A Transport Assessment should be undertaken and its conclusions taken in to consideration within the Local Plan.

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4089

Received: 30/11/2016

Respondent: James Property Investments LLP

Agent: JB Planning Associates

Representation:

Object to SA (Site RY7): Detailed observations on scoring and conclusions in relation to this site.

Full text:

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Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4325

Received: 29/11/2016

Respondent: Three Rivers District Council

Representation:

Comment: Limited nature of duty to co-operate issues between Councils, no specific concerns, content with approach to housing provision, AMR should continue to monitor gypsy and traveller accommodation.

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4504

Received: 30/11/2016

Respondent: Transition Town Letchworth

Representation:

Object to Introduction and Context:
- Duty to Co-operate
- The focus of co-operation with public authorities and bodies overlooks non-public bodies of local significance, such as the Letchworth Garden City Heritage Foundation
- "the Housing Market Areas and Functional Economic Market Area in which North Hertfordshire sits" ignores the ecological continuities
- Add the rationale for extent of application of the Duty to Co-operate
- Inconsistency with consideration of neighbourhood groups
- Suggest Minor Modifications
- Add to Glossary; 'Waste Hierarchy', 'Vegetarian', 'Vegan' and 'Strategic Planning'
Object to Introduction and Context:

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5215

Received: 29/11/2016

Respondent: Wymondley Parish Council

Representation:

Object (general): Inadequate response to previous consultations, Sustainability Appraisal has not considered all reasonable alternatives such as new garden city

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5291

Received: 30/11/2016

Respondent: Letchworth Sustainability Forum

Representation:

Object to Introduction and Context:
- Add to Glossary 'Zero waste of materials (as an aspiration)' and ' Circular Economy of materials'
- Suggested minor modifications

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5471

Received: 30/11/2016

Respondent: Mr Peter Bracey

Representation:

Object to Introduction and Context:
- This plan has failed to enter dialogue with democratically elected Parish Councils and communities
- This has resulted in a plan that has been developer led rather than the needs of local communities
- Prior consultations
- Planning Minister's letter to Parliament June 2016

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5525

Received: 30/11/2016

Respondent: New Road (Ashbrook) Ltd and the Taylor Family

Agent: DLP (Planning) Limited

Representation:

Object to SA: No assessment of south-west Hitchin as reasonable alternative, no assessment of reasonable alternatives for housing or highway infrastructure, mis-assessment of potential impacts of development south-west of Hitchin.

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5526

Received: 30/11/2016

Respondent: Natural England - East of England Region

Representation:

Object to SA: Alternatives for meeting unmet needs of Luton not considered, Sustainability Appraisal has not adequately assessed the impacts of development on Therfield Heath SSSI or the Chilterns AONB.

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5560

Received: 30/11/2016

Respondent: People's Trust for Endangered Species

Representation:

Object to inaccuracies in the Sustainability Appraisal - Appendix 6 with regard to site LR6, Land off Radburn Way.

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5591

Received: 24/11/2016

Respondent: Mr and Mr Aldrich

Representation:

Difficulty navigating and registering objection on website

Full text:

I am having no luck in navigating and registering my objection to the above housing development proposals for Knebworth, on your website.

Please take this email as my objection to the proposals for all of the proposed sites around Knebworth.

My primary concerns would be the traffic issues and the strain on current village resources, ie Station, primary school. The village roads are just not built to cope with such a huge increase in volume of traffic. These developments would be detrimental to the livelyhood of the village as we know it, putting huge strain on current resources and roads in and around Knebworth.

Therefore, I strongly object to the development of Knebworth. The plans have been badly thoughtout, clearly with no knowledge of this village.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5597

Received: 30/11/2016

Respondent: Keep Hitchin Special

Representation:

Objection to whole Local Plan:
- lacks vision and realism
- no understanding of what makes Hitchin different to Letchworth
- consultation on the plan has been limited to issue of diffuse papers replied to by earnest, informed, well-intentioned but unrepresentative groups
- zero effort to involve people off the streets through 'Planning for Real' workshops modeling not paper, collection of life experiences from real people
- relies heavily on advice from NLP: academic model and desk based studies.

Full text:

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5598

Received: 30/11/2016

Respondent: Knebworth Primary and Nursery School

Representation:

Objection:
Positively prepared

KB4 not included in the Preferred Options -first time been able to comment

Full text:

3.ii Soundness

Positively prepared

The Preferred Options document was open to public consultation between Dec 2014 and Jan 2015. Site KB4 (the land to the East of Knebworth) was not included in that document. This is, therefore, the first time that local residents and the school have had the opportunity of seeing, and commenting on, the planned KB4 development

The North Herts Local Plan is for an increase of 598 new homes in Knebworth plus a further 65 homes which have already been granted planning permission. This is a 31% increase in the size of the village. For development of more than 500 houses (what NHDC call a 'Strategic Housing Site') they require a Strategic Policy. Whilst none of the individual proposed sites around the outskirts of Knebworth meet this threshold, collectively they do.

Additional development is proposed in the Local Plans of adjacent district councils of Stevenage and Welwyn Hatfield (at Woolmer Green). All of the proposed sites will impact on the infrastructure of the village. I have outlined, in section 4 below, some of the infrastructure requirements that directly affect the school which appear have been overlooked.
The failure to have an integrated Strategic Policy for Knebworth is clear evidence that the Plan has not been positively prepared.

Effective

1. Infrastructure

Schools

Additional primary school place provision is an obvious requirement should the proposed development proceed. This has been acknowledged in the Plan
Section 13.191 says, site KB2 will provide an additional primary school in the West of Knebworth. This was a reasonable approach in the preferred options document of 2014/15, when KB4 was not included in the development proposals, However, now that KB4 is in the final version of the Local Plan, this does not make sense.

It is my considered opinion that Primary schooling in Knebworth is not best delivered from 2 separate sites, so far apart. It is unlikely that from an effectiveness and efficiency aspect, 2 separate primary schools, requiring separate management and administration teams, could be justified.
Also, if you have 2 sites with the separation proposed, if you can imagine a parent with a child in each site, which is a likelihood, dropping children off at their respective schools at the same time. Difficult without a fast car!
This would do little encourage parents to walk with their children to school. This would not be sustainable and do little to ease the traffic and parking problems.

So the additional school should be as close as possible to the existing site.

In the current Local Plan, land adjacent to the existing school site, KB4, is now proposed for development. Surely, if the developments proceed, it would be better if the additional primary school were adjacent to the existing school. This would appear to be possible, but has not been considered.

In addition, there is no additional provision for school spaces for the 150 houses proposed for Woolmer Green. The current school site at Woolmer Green has no space for additional classrooms and is at capacity. The location of their proposed housing development is North of Woolmer Green and South of Knebworth, but within walking distance of the current school and would, I believe fall into our catchment area.

Roads and Footways

Traffic and parking are significant problems in the vicinity of the school, particularly when parents are dropping off and picking up children from school. This adds to the delays in the High Street and joining roads and creates hazardous situations for pedestrians crossing at the road junctions.
Swangleys Lane often becomes impassable for wider vehicles, due to parents parking their cars.
Swangleys Lane is not wide enough to cope with the traffic that would result from the new development
There are no footways on Old Lane, Swangleys Lane or St Martins Road for much of their length.
There are no safe drop off or pick up points adjacent to the school. Perhaps the local Plan could provide this facility ?

One of the main pedestrian routes, for parents and children on the west side of the railway to get to the school, is by the Station Road bridge footway. The footway is approximately 1 metre wide over the 52 metre length of the underbridge. This is insufficient for 2 people to pass without 1 person stepping in to the road.
The current situation for pedestrians is unsafe.

This is not an exhaustive list. In the event that development proceeds in accordance with the Local Plan, all of the the infrastructure needs should be addressed

Safeguarding and KB4

Safeguarding the children attending Knebworth school is our highest priority.
Governors, staff and parents have expressed concerns previously about new developments overlooking the school playing fields. This is currently a particularly sensitive issue. The school has no control of who lives in these developments and whether they have been assessed through the Disclosure and Debarring Service.
KB4 would appear to overlook the School Playing Fields. If the development of KB4 proceeds the school would want assurance that the design of the buildings will prevent or significantly reduce the incidence of oversight of the School Playing Fields.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5632

Received: 29/11/2016

Respondent: Mr Nick Richardson

Representation:

Object to SA (site IC2): Detailed comments on analysis, incorrect conclusions reached

Full text:

I am writing to register my comments and objections to the Local Plan in relation to the proposed residential sites in Ickleford, sites IC1, IC2, IC3 and LS1.

IC1 (Duncots Close)

Whilst this site is within the Green Belt and is therefore in contravention of National Planning Policy Framework, in principle I would support small housing development here. The incursion into Green Belt is relatively minor and would bring the building line in line with the houses on adjacent Laurel Way. There is also a natural boundary with trees etc shielding the landscape impact of this proposed development from Duncots field.

However, I understand there are concerns over sewer capacity and flooding and any development would need to be sensitively done and be sympathetic to the conservation area. If these concerns can be properly allayed then I am broadly supportive of this site.

IC2 (Burford Grange)

I wish to strongly object to the allocation of site IC2 for the proposed residential allocation of 40 + houses.

I consider the allocation of this site to be Not Sound for a number of reasons.

This site sits within the Green Belt and as such would be in contravention of National Planning Policy and conflicts with NHDC Strategic Objectives on the Green Belt.

The strip of Green Belt within which IC2 sits provides a critical role separating Hitchin from Ickleford and is also environmentally sensitive being in close proximity to Oughtonhead Nature Reserve and providing protection into beautiful open countryside beyond.

I would like to take issue and highlight inaccuracies and errors in the appraisal of this site, which make the allocation Not Sound.

Firstly, within the Green Belt Review July 2016, this site is identified as sitting within the Green Belt subparcel Oughtonhead 12A (page 33 of report), which concludes on page 49 that it plays an important role in preventing expansion of Hitchin northwards. It also plays a significant role in safeguarding the countryside. Overall the report concludes it makes a Significant Contribution.

However, the assessment of 12A makes an error when it says it plays no role in preventing merger of neighbouring towns.

This is clearly wrong as this narrow stretch of green belt where IC2 sits plays a key role separating Hitchin from Ickleford. My conclusion is confirmed by the assessment of green belt sub sector 13c on page 50 (which contains the Ickleford Manor site diagonally opposite IC2 on the other side of the A600), which is noted as playing a key role separating Hitchin from Ickleford. The Green Belt review is therefore inconsistent and clearly the findings in relation to 12A and specifically the land that IC2 occupies is in error. The allocation is therefore Not Sound.

How can the council come to a different conclusion on two adjacent pieces of greenbelt land playing the same role separating Hitchin from Ickleford, the only difference being the sites are on different sides of the A600.

I would also highlight that when you then turn to the site specific consideration of IC2 within the Greenbelt review (ref. 40 on page 112) IC2 is then only classed as making a Moderate contribution to Geen Belt. This is inconsistent with the report finding of the site being within Subparcel 12A, which the report concludes makes a Significant Contribution and I personally think this micro location within Subparcel 12A is particularly important in separating Hitchin and Ickleford.


I would encourage the council and the Inspector to review this proposed site allocation closely and reject it. The Green Belt around Hitchin is at its narrowest in this area and the proposed development represents an unacceptable and substantial erosion of the Green Belt. The situation is exacerbated by the site's close proximity to the Oughtonhead Nature Reserve, where its immediate surrounds should be preserved in my opinion. There is a lovely walk along the River Oughton from the Bedford Road into Oughtonhead Common and the proposed development of IC2 would significantly detract from this. To say there is no landscape impact of this development is in my opinion incorrect.

I also want to highlight inaccuracies in the council's Environmental Sustainability Appraisal dated September 2016.

In the site matrix (Appendix 6, page 76), the site is correctly noted under 'Land Use' as greenfield and grade 3 agricultural land but then under 'Environmental Protection' it is incorrectly noted as an existing brownfield site. The vast majority of the site is open field and grazing land. Living nearby and walking along the river into Oughton Head, I regularly see birds of prey hunting over that site in the field and I am sure the field part of the site provides an important ecological resource. This aspect of the site sustainability review is therefore Not Sound.

I also take issue with the comments within 'Protect and enhance landscapes' where the report states "the landscape is common and the impact of development moderate'. As already mentioned, this development would significantly impact on the outlook and landscape from the River Oughton pathway, which currently benefits from open countryside views here. If suddenly the horizon outlook is 40 houses this would significantly detract from the landscape. The report notes that this is a Landscape Conservation Area and it should therefore be protected. Again I think the comments and proposed allocation are therefore Not Sound.

The report also says that the site has access to open space. Yes the site adjoins green fields but these are in private ownership and used for agricultural purposes. There is therefore actually no access to open space. Again the comment is Not Sound.

I fundamentally believe this is a very important strip of Green Belt that needs to be preserved. If it was allocated, I am very concerned this would set a precedent for further incursion into the Green Belt in this area. I hope you will reject this allocation.

As a final comment, if an allocation in this vicinity is deemed necessary or justified, which I sincerely hope will not be the case, I would request that consideration is given to only the currently built portion of the site being available for residential, leaving the current field and grazing land open green space. I have marked up a plan and aerial photo showing my suggested amendment as a fall back.

The Ickleford development boundary should be similarly amended to exclude the green field part of the site.

However, I would reiterate my position that IC2 should be rejected outright.

Site IC3 - Bedford Road

In principle, I do not object to some housing allocation on part of this land but not all of it. A portion of it seems to be large derelict greenhouses and to a degree could be viewed as brownfield land sitting within the Green Belt that could be put to a better use.

However, I am concerned about the scale of the proposed allocation of 150 houses and the lack of detailed consultation on this site which has been added late in the process. My concern is increased as the plan envisages the relocation of the primary school, which is a fundamental part of the character of the village. What would happen to the existing school site, redevelopment for more housing?? Again I am not totally averse to this possibility but greater consultation and detail is required and then if housing could be accommodated on the existing school site could the allocations on un-built, Green Belt land be scaled back or removed entirely.

I therefore object to this site on grounds of being 'Not Legally Compliant' due to lack of prior detailed consultation. However, the principle of some residential on part of this site is something I would be willing to support subject to more detail on the nature and scale and interrelationship with the primary school.

My personal suggestion would be to allocate land to the south of the Icknield Way path (with a landscape buffer) for residential and for the Green Belt, agricultural land to the north of the Icknield Way path to remain protected Green Belt.

I have attached a plan with my suggested amendments.


SITE LS1 - Lower Stondon

In principle, I support a residential allocation here. Whilst in a rural area, it is beyond and outside the Green Belt and is in relative scale with the village of Lower Stondon and adjoins an existing new housing development. An allocation here would not lead to an erosion of the fragile Green Belt gap between Ickleford and Hitchin and is therefore preferable in my view.


OTHER CONCERNS:

Traffic generation: The scale of the three proposed sites on the Bedford Road (IC2, IC3 and LS1 in Lower Stondon) in my opinion will lead to an unacceptable cumulative traffic effect on the A600 Bedford Road, which is already very busy and congested at peak times.

I understand that the traffic modelling which the council has used is flawed and therefore this places further doubt over the Soundness of the allocations in this area.

I would also comment that in addition to additional cars pulling out onto Bedford Road, a pedestrian crossing would be required from IC2 to the bus stop on the other side of the Bedford Road, which would cause further traffic tail backs so close to the roundabout. Another reason why IC2 should be rejected as not suitable for this scale of development.

I would also highlight the proposals at RAF Henlow further up the Bedford Road outside of the NHDC Local Plan area, which is set to close by 2020 and become up to 780 homes. This development will further add to the traffic pressure on the Bedford Road with a significant proportion of people travelling into Hitchin.

I understand that NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan, which would include developments such as RAF Henlow. As a result, due to lack of coordination with neighbouring authorities the allocation for sites IC1, IC2, IC3 and LS1 are potentially not sound and I think this is particularly the case for those developments along the Bedford Road. The cumulative traffic impact of all these allocations needs to be properly considered and the analysis is currently flawed.


OTHER SUGGESTIONS:

The plan also does not take account of potential other housing sites in Ickleford. The vacant Green Man pub could accommodate a small housing development, the already developed commercial area at Ickleford Manor could also accommodate a residential development and I also understand that certain areas of Bowman's Mill are to be taken out of operation and could possibly provide potential in the future.

In my opinion, a better solution to housing needs could be achieved in Ickleford utilising brownfield sites, some of which sit within the Green Belt, that would reduce the need to build over valuable virgin Green Belt, that once it is gone we can never get back.

Attachments: