Local Plan 2011-2031 Proposed Submission Draft

I would like to comment on two particular areas of land/habitat/ecosystem that are familiar to me and being put forward as potential sites for future development in your Draft Local Plan for 2011-2031.

I would like to suggest that you reconsider any development of the mature orchard at Radburn Way (Site LG6, I believe.) and the interconnected, diverse habitats along the Western boundary of Hitchin (HT 3, 4, 5 & 6.).

The various habitats along the Western boundary of Hitchin are without doubt important and diverse ecosystems for local flora and fauna. These areas, encompassing the remnants of an old orchard and pasture (HT6, adjacent to Crow Furlong), open grassland/meadow (HT5, along Lucas Lane), open amenity playfields with mature established hedgerows (HT4, further along Lucas Lane) and mixed, open scrubland (HT3, along Oughtonhead Lane) together create diverse but ecologically valuable and endangered habitats - refuges for all manner of local wildlife - whilst also collectively creating a unique mosaic and network of habitats as an invaluable and irreplaceable corridor and buffer between what is arguably ecologically unfavourable and sterile agricultural land and the mixed and variable quality of habitat which is the urban and developed landscape.

When considered in conjunction with the recent loss of the ancient and thriving open green space that was the Gaping Lane Pleasure Gardens and allotments (Lost to ongoing development and expansion of Samuel Lucas School.) any further development here could effectively double the impact and shock to create the tipping point and aftershock that drives any remaining wildlife further out of the area with a rapid and successive loss of established and healthy green infrastructures and habitats.

I can find no mention or detail of any real commitment or truly balanced, genuine mitigation or offsetting for such losses to local ecology in your plans and this disturbs me in times that it is almost universally recognised that we need to counteract the national decline of biodiversity. For all these aforementioned reasons I strongly object any such inappropriate development in this area. Your own ecological and habitat surveys can only have drawn the same conclusions, without even considering the National Planning Policy Frameworks (NPPF) such developments ignore (Including the development of the Gaping Lane allotments), which state "Development proposals which affect sites or features of local biodiversity will not be permitted where there is an adverse impact on the ecological, geological or biodiversity interests of the site unless it can be demonstrated that adverse effects could be satisfactorily minimised through mitigation measures" and that authorities need to plan for the "creation, protection, enhancement and management of networks of biodiversity and green infrastructure" ensuring "that features of biodiversity value are not lost as a result of a development proposal and that where possible opportunities to incorporate biodiversity in and around development will be sought". There are many other references to the importance of such habitats in the NPPF which also states that the "planning system should contribute to and enhance the natural and local environment by minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures". A breach of such legislation would effectively and wilfully undermine the Government's strategies for Biodiversity 2020 wherein we could help foster and pioneer a more inclusive and progressive ethos instead for the long-term benefit of the wider environment.

Likewise, the negative effect on the health and wellbeing of local residents with the loss of such green space should not be overlooked wherein such developments would completely change the context and environment of the historic community whilst leaving the neighbourhood to jerk abruptly into barren agricultural land without a buffer and with few remaining historic and character features. Such developments would effectively and drastically scar the greenbelt and surviving habitats permanently.

The orchard at Radburn Way, Letchworth (LG6), from what information I have gathered, quite possibly predates the development of the Garden City itself (Listed as smallholdings on maps of the period) and fits in with the self-reliant and betterment ideals and aspirations of the Garden City movement's concepts and ethos. In this respect, the cultural legacy needs consideration and likewise appropriate historic designation with regards to any and all developmental proposals. Various specialists who have visited and studied the orchard believe some of the established and mature trees may exist as surviving plantings from that period, putting the older trees at possibly around 100 years old. We have identified some apple and pear varieties but there are still many more unknown which could be rare and/or lost local and regional varieties. Needless to say, for such reasons the site is undeniably of significant historical and cultural value and with much potential, with appropriate management, to be a truly valuable local asset for the surrounding neighbourhood and residents as well as the living and surviving ecology and future heritage of Letchworth as the world's first Garden City. While the orchard itself is unfortunately but wilfully neglected by the current owners, it does not fit and is not fairly described in the subjective report (Sustainability Appraisal and Strategic Environmental Assessment), which completely overlooks its ecological value and priority designation as well as its potential as a community amenity asset. The assertion that the orchard is an "eyesore" is purely subjective and cannot be regarded in a neutral, objective study of any sort and likewise ignores its genuine potential to be a focal point of local pride and community development etc. Amenity value is equally unrecognised with the inherent and wider benefits of ecosystem services to the surrounding residents, environment and wildlife blatantly ignored despite the potential benefits, in spite of its perceived unappealing appearance.

Orchards are now furthermore recognised properly for their unique importance as biodiverse and endangered ecological habitats and finally regarded as priority habitats by DEFRA in need of conservation under the UK Biodiversity Action Plan and similarly in the Natural Environment and Rural Communities Act (I believe the statistic to be something around 90% of our traditional orchards lost in the last 50 years.). As well as the NPPF policy criteria quoted before (Regarding HT3-6) which are also relevant here, deliberate and wanton neglect and destruction of such open spaces and natural corridors within urban areas goes against policy which requires planning to "minimise impacts on biodiversity and geodiversity... planning policies should promote the preservation, restoration and recreation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets...", and likewise "maintain patterns of open space or landscape features in the town by normally refusing development proposals which would have a significantly detrimental effect on the character, form, extent and structure of the pattern of open spaces". For other relevant legislation and guidance relating to such areas, please consult the Conserving and Enhancing the Natural Environment section of the National Planning Policy Framework for Achieving Sustainable Development which can be found easily by following the link below:

http://planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/11-conserving-and-enhancing-the-natural-environment/

Even if legitimate compensation and/or mitigation were considered in any of these instances, these cannot be realistically regarded as immediate remediation for the loss of established and matured ecosystems and habitats, especially those deemed endangered, scarce and/or national priorities, such as traditional orchards. How do you plan to properly compensate for the loss of an established thriving greenfield orchard Priority Habitat? Though retention of some specimens is touched upon in some of the assessments and compensation mentioned as a possibility, there is no guarantee or confirmation that this would necessarily be sufficient and/or conducted appropriately. The fact that this is discussed, however, and that the adjacent allotments are being protected beside Radburn, for instance, proves such sites are recognised for their diverse values and worth retaining despite construction work, in many instances, having a detrimental and long-term effect on soil structure and surviving components to the effect that the long-term success is jeopardised and ill-considered.

For all the aforementioned reasons, I ask you to please reconsider your stance on sites HT 3, 4, 5 & 6 and LG 6 and to recognize their true value as vital components in the complex and often neglected fabric of ecology and community life which is overlooked flippantly and blindly in these derogatory and inadequate appraisals and assessments. Policy NE2 on Green Infrastructure alone offers protection for these sites under the diverse criteria and there are many others such instances reflected in the Consultation Papers for the Preferred Options, such as those discussed in Policy CGB1 regarding Green Belts and sections 9 and 10 etc. Given the range and value of such sites, I would also heed you consider full and proper assessment with specialist surveys giving appropriate and due weight and respect to the results and findings. In the case of Priority Habitats, for instance, I would say this is warranted and appropriate to say the least, regardless of the perception surrounding access issues (Radburn orchard being divided and fenced). The strategic objectives of the Proposed Submission alone (See Sections 3, 4 and ENV5) should offer protection to such sites given their true nature with TPO's a reasonable consideration etc.

I would like to comment on two particular areas of land/habitat/ecosystem that are familiar to me and being put forward as potential sites for future development in your Draft Local Plan for 2011-2031.

I would like to suggest that you reconsider any development of the mature orchard at Radburn Way (Site LG6, I believe.) and the interconnected, diverse habitats along the Western boundary of Hitchin (HT 3, 4, 5 & 6.).

The various habitats along the Western boundary of Hitchin are without doubt important and diverse ecosystems for local flora and fauna. These areas, encompassing the remnants of an old orchard and pasture (HT6, adjacent to Crow Furlong), open grassland/meadow (HT5, along Lucas Lane), open amenity playfields with mature established hedgerows (HT4, further along Lucas Lane) and mixed, open scrubland (HT3, along Oughtonhead Lane) together create diverse but ecologically valuable and endangered habitats - refuges for all manner of local wildlife - whilst also collectively creating a unique mosaic and network of habitats as an invaluable and irreplaceable corridor and buffer between what is arguably ecologically unfavourable and sterile agricultural land and the mixed and variable quality of habitat which is the urban and developed landscape.

When considered in conjunction with the recent loss of the ancient and thriving open green space that was the Gaping Lane Pleasure Gardens and allotments (Lost to ongoing development and expansion of Samuel Lucas School.) any further development here could effectively double the impact and shock to create the tipping point and aftershock that drives any remaining wildlife further out of the area with a rapid and successive loss of established and healthy green infrastructures and habitats.

I can find no mention or detail of any real commitment or truly balanced, genuine mitigation or offsetting for such losses to local ecology in your plans and this disturbs me in times that it is almost universally recognised that we need to counteract the national decline of biodiversity. For all these aforementioned reasons I strongly object any such inappropriate development in this area. Your own ecological and habitat surveys can only have drawn the same conclusions, without even considering the National Planning Policy Frameworks (NPPF) such developments ignore (Including the development of the Gaping Lane allotments), which state "Development proposals which affect sites or features of local biodiversity will not be permitted where there is an adverse impact on the ecological, geological or biodiversity interests of the site unless it can be demonstrated that adverse effects could be satisfactorily minimised through mitigation measures" and that authorities need to plan for the "creation, protection, enhancement and management of networks of biodiversity and green infrastructure" ensuring "that features of biodiversity value are not lost as a result of a development proposal and that where possible opportunities to incorporate biodiversity in and around development will be sought". There are many other references to the importance of such habitats in the NPPF which also states that the "planning system should contribute to and enhance the natural and local environment by minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures". A breach of such legislation would effectively and wilfully undermine the Government's strategies for Biodiversity 2020 wherein we could help foster and pioneer a more inclusive and progressive ethos instead for the long-term benefit of the wider environment.

Likewise, the negative effect on the health and wellbeing of local residents with the loss of such green space should not be overlooked wherein such developments would completely change the context and environment of the historic community whilst leaving the neighbourhood to jerk abruptly into barren agricultural land without a buffer and with few remaining historic and character features. Such developments would effectively and drastically scar the greenbelt and surviving habitats permanently.

The orchard at Radburn Way, Letchworth (LG6), from what information I have gathered, quite possibly predates the development of the Garden City itself (Listed as smallholdings on maps of the period) and fits in with the self-reliant and betterment ideals and aspirations of the Garden City movement's concepts and ethos. In this respect, the cultural legacy needs consideration and likewise appropriate historic designation with regards to any and all developmental proposals. Various specialists who have visited and studied the orchard believe some of the established and mature trees may exist as surviving plantings from that period, putting the older trees at possibly around 100 years old. We have identified some apple and pear varieties but there are still many more unknown which could be rare and/or lost local and regional varieties. Needless to say, for such reasons the site is undeniably of significant historical and cultural value and with much potential, with appropriate management, to be a truly valuable local asset for the surrounding neighbourhood and residents as well as the living and surviving ecology and future heritage of Letchworth as the world's first Garden City. While the orchard itself is unfortunately but wilfully neglected by the current owners, it does not fit and is not fairly described in the subjective report (Sustainability Appraisal and Strategic Environmental Assessment), which completely overlooks its ecological value and priority designation as well as its potential as a community amenity asset. The assertion that the orchard is an "eyesore" is purely subjective and cannot be regarded in a neutral, objective study of any sort and likewise ignores its genuine potential to be a focal point of local pride and community development etc. Amenity value is equally unrecognised with the inherent and wider benefits of ecosystem services to the surrounding residents, environment and wildlife blatantly ignored despite the potential benefits, in spite of its perceived unappealing appearance.

Orchards are now furthermore recognised properly for their unique importance as biodiverse and endangered ecological habitats and finally regarded as priority habitats by DEFRA in need of conservation under the UK Biodiversity Action Plan and similarly in the Natural Environment and Rural Communities Act (I believe the statistic to be something around 90% of our traditional orchards lost in the last 50 years.). As well as the NPPF policy criteria quoted before (Regarding HT3-6) which are also relevant here, deliberate and wanton neglect and destruction of such open spaces and natural corridors within urban areas goes against policy which requires planning to "minimise impacts on biodiversity and geodiversity... planning policies should promote the preservation, restoration and recreation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets...", and likewise "maintain patterns of open space or landscape features in the town by normally refusing development proposals which would have a significantly detrimental effect on the character, form, extent and structure of the pattern of open spaces". For other relevant legislation and guidance relating to such areas, please consult the Conserving and Enhancing the Natural Environment section of the National Planning Policy Framework for Achieving Sustainable Development which can be found easily by following the link below:

http://planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/11-conserving-and-enhancing-the-natural-environment/

Even if legitimate compensation and/or mitigation were considered in any of these instances, these cannot be realistically regarded as immediate remediation for the loss of established and matured ecosystems and habitats, especially those deemed endangered, scarce and/or national priorities, such as traditional orchards. How do you plan to properly compensate for the loss of an established thriving greenfield orchard Priority Habitat? Though retention of some specimens is touched upon in some of the assessments and compensation mentioned as a possibility, there is no guarantee or confirmation that this would necessarily be sufficient and/or conducted appropriately. The fact that this is discussed, however, and that the adjacent allotments are being protected beside Radburn, for instance, proves such sites are recognised for their diverse values and worth retaining despite construction work, in many instances, having a detrimental and long-term effect on soil structure and surviving components to the effect that the long-term success is jeopardised and ill-considered.

For all the aforementioned reasons, I ask you to please reconsider your stance on sites HT 3, 4, 5 & 6 and LG 6 and to recognize their true value as vital components in the complex and often neglected fabric of ecology and community life which is overlooked flippantly and blindly in these derogatory and inadequate appraisals and assessments. Policy NE2 on Green Infrastructure alone offers protection for these sites under the diverse criteria and there are many others such instances reflected in the Consultation Papers for the Preferred Options, such as those discussed in Policy CGB1 regarding Green Belts and sections 9 and 10 etc. Given the range and value of such sites, I would also heed you consider full and proper assessment with specialist surveys giving appropriate and due weight and respect to the results and findings. In the case of Priority Habitats, for instance, I would say this is warranted and appropriate to say the least, regardless of the perception surrounding access issues (Radburn orchard being divided and fenced). The strategic objectives of the Proposed Submission alone (See Sections 3, 4 and ENV5) should offer protection to such sites given their true nature with TPO's a reasonable consideration etc.

I would like to comment on two particular areas of land/habitat/ecosystem that are familiar to me and being put forward as potential sites for future development in your Draft Local Plan for 2011-2031.

I would like to suggest that you reconsider any development of the mature orchard at Radburn Way (Site LG6, I believe.) and the interconnected, diverse habitats along the Western boundary of Hitchin (HT 3, 4, 5 & 6.).

The various habitats along the Western boundary of Hitchin are without doubt important and diverse ecosystems for local flora and fauna. These areas, encompassing the remnants of an old orchard and pasture (HT6, adjacent to Crow Furlong), open grassland/meadow (HT5, along Lucas Lane), open amenity playfields with mature established hedgerows (HT4, further along Lucas Lane) and mixed, open scrubland (HT3, along Oughtonhead Lane) together create diverse but ecologically valuable and endangered habitats - refuges for all manner of local wildlife - whilst also collectively creating a unique mosaic and network of habitats as an invaluable and irreplaceable corridor and buffer between what is arguably ecologically unfavourable and sterile agricultural land and the mixed and variable quality of habitat which is the urban and developed landscape.

When considered in conjunction with the recent loss of the ancient and thriving open green space that was the Gaping Lane Pleasure Gardens and allotments (Lost to ongoing development and expansion of Samuel Lucas School.) any further development here could effectively double the impact and shock to create the tipping point and aftershock that drives any remaining wildlife further out of the area with a rapid and successive loss of established and healthy green infrastructures and habitats.

I can find no mention or detail of any real commitment or truly balanced, genuine mitigation or offsetting for such losses to local ecology in your plans and this disturbs me in times that it is almost universally recognised that we need to counteract the national decline of biodiversity. For all these aforementioned reasons I strongly object any such inappropriate development in this area. Your own ecological and habitat surveys can only have drawn the same conclusions, without even considering the National Planning Policy Frameworks (NPPF) such developments ignore (Including the development of the Gaping Lane allotments), which state "Development proposals which affect sites or features of local biodiversity will not be permitted where there is an adverse impact on the ecological, geological or biodiversity interests of the site unless it can be demonstrated that adverse effects could be satisfactorily minimised through mitigation measures" and that authorities need to plan for the "creation, protection, enhancement and management of networks of biodiversity and green infrastructure" ensuring "that features of biodiversity value are not lost as a result of a development proposal and that where possible opportunities to incorporate biodiversity in and around development will be sought". There are many other references to the importance of such habitats in the NPPF which also states that the "planning system should contribute to and enhance the natural and local environment by minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures". A breach of such legislation would effectively and wilfully undermine the Government's strategies for Biodiversity 2020 wherein we could help foster and pioneer a more inclusive and progressive ethos instead for the long-term benefit of the wider environment.

Likewise, the negative effect on the health and wellbeing of local residents with the loss of such green space should not be overlooked wherein such developments would completely change the context and environment of the historic community whilst leaving the neighbourhood to jerk abruptly into barren agricultural land without a buffer and with few remaining historic and character features. Such developments would effectively and drastically scar the greenbelt and surviving habitats permanently.

The orchard at Radburn Way, Letchworth (LG6), from what information I have gathered, quite possibly predates the development of the Garden City itself (Listed as smallholdings on maps of the period) and fits in with the self-reliant and betterment ideals and aspirations of the Garden City movement's concepts and ethos. In this respect, the cultural legacy needs consideration and likewise appropriate historic designation with regards to any and all developmental proposals. Various specialists who have visited and studied the orchard believe some of the established and mature trees may exist as surviving plantings from that period, putting the older trees at possibly around 100 years old. We have identified some apple and pear varieties but there are still many more unknown which could be rare and/or lost local and regional varieties. Needless to say, for such reasons the site is undeniably of significant historical and cultural value and with much potential, with appropriate management, to be a truly valuable local asset for the surrounding neighbourhood and residents as well as the living and surviving ecology and future heritage of Letchworth as the world's first Garden City. While the orchard itself is unfortunately but wilfully neglected by the current owners, it does not fit and is not fairly described in the subjective report (Sustainability Appraisal and Strategic Environmental Assessment), which completely overlooks its ecological value and priority designation as well as its potential as a community amenity asset. The assertion that the orchard is an "eyesore" is purely subjective and cannot be regarded in a neutral, objective study of any sort and likewise ignores its genuine potential to be a focal point of local pride and community development etc. Amenity value is equally unrecognised with the inherent and wider benefits of ecosystem services to the surrounding residents, environment and wildlife blatantly ignored despite the potential benefits, in spite of its perceived unappealing appearance.

Orchards are now furthermore recognised properly for their unique importance as biodiverse and endangered ecological habitats and finally regarded as priority habitats by DEFRA in need of conservation under the UK Biodiversity Action Plan and similarly in the Natural Environment and Rural Communities Act (I believe the statistic to be something around 90% of our traditional orchards lost in the last 50 years.). As well as the NPPF policy criteria quoted before (Regarding HT3-6) which are also relevant here, deliberate and wanton neglect and destruction of such open spaces and natural corridors within urban areas goes against policy which requires planning to "minimise impacts on biodiversity and geodiversity... planning policies should promote the preservation, restoration and recreation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets...", and likewise "maintain patterns of open space or landscape features in the town by normally refusing development proposals which would have a significantly detrimental effect on the character, form, extent and structure of the pattern of open spaces". For other relevant legislation and guidance relating to such areas, please consult the Conserving and Enhancing the Natural Environment section of the National Planning Policy Framework for Achieving Sustainable Development which can be found easily by following the link below:

http://planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/11-conserving-and-enhancing-the-natural-environment/

Even if legitimate compensation and/or mitigation were considered in any of these instances, these cannot be realistically regarded as immediate remediation for the loss of established and matured ecosystems and habitats, especially those deemed endangered, scarce and/or national priorities, such as traditional orchards. How do you plan to properly compensate for the loss of an established thriving greenfield orchard Priority Habitat? Though retention of some specimens is touched upon in some of the assessments and compensation mentioned as a possibility, there is no guarantee or confirmation that this would necessarily be sufficient and/or conducted appropriately. The fact that this is discussed, however, and that the adjacent allotments are being protected beside Radburn, for instance, proves such sites are recognised for their diverse values and worth retaining despite construction work, in many instances, having a detrimental and long-term effect on soil structure and surviving components to the effect that the long-term success is jeopardised and ill-considered.

For all the aforementioned reasons, I ask you to please reconsider your stance on sites HT 3, 4, 5 & 6 and LG 6 and to recognize their true value as vital components in the complex and often neglected fabric of ecology and community life which is overlooked flippantly and blindly in these derogatory and inadequate appraisals and assessments. Policy NE2 on Green Infrastructure alone offers protection for these sites under the diverse criteria and there are many others such instances reflected in the Consultation Papers for the Preferred Options, such as those discussed in Policy CGB1 regarding Green Belts and sections 9 and 10 etc. Given the range and value of such sites, I would also heed you consider full and proper assessment with specialist surveys giving appropriate and due weight and respect to the results and findings. In the case of Priority Habitats, for instance, I would say this is warranted and appropriate to say the least, regardless of the perception surrounding access issues (Radburn orchard being divided and fenced). The strategic objectives of the Proposed Submission alone (See Sections 3, 4 and ENV5) should offer protection to such sites given their true nature with TPO's a reasonable consideration etc.

I would like to comment on two particular areas of land/habitat/ecosystem that are familiar to me and being put forward as potential sites for future development in your Draft Local Plan for 2011-2031.

I would like to suggest that you reconsider any development of the mature orchard at Radburn Way (Site LG6, I believe.) and the interconnected, diverse habitats along the Western boundary of Hitchin (HT 3, 4, 5 & 6.).

The various habitats along the Western boundary of Hitchin are without doubt important and diverse ecosystems for local flora and fauna. These areas, encompassing the remnants of an old orchard and pasture (HT6, adjacent to Crow Furlong), open grassland/meadow (HT5, along Lucas Lane), open amenity playfields with mature established hedgerows (HT4, further along Lucas Lane) and mixed, open scrubland (HT3, along Oughtonhead Lane) together create diverse but ecologically valuable and endangered habitats - refuges for all manner of local wildlife - whilst also collectively creating a unique mosaic and network of habitats as an invaluable and irreplaceable corridor and buffer between what is arguably ecologically unfavourable and sterile agricultural land and the mixed and variable quality of habitat which is the urban and developed landscape.

When considered in conjunction with the recent loss of the ancient and thriving open green space that was the Gaping Lane Pleasure Gardens and allotments (Lost to ongoing development and expansion of Samuel Lucas School.) any further development here could effectively double the impact and shock to create the tipping point and aftershock that drives any remaining wildlife further out of the area with a rapid and successive loss of established and healthy green infrastructures and habitats.

I can find no mention or detail of any real commitment or truly balanced, genuine mitigation or offsetting for such losses to local ecology in your plans and this disturbs me in times that it is almost universally recognised that we need to counteract the national decline of biodiversity. For all these aforementioned reasons I strongly object any such inappropriate development in this area. Your own ecological and habitat surveys can only have drawn the same conclusions, without even considering the National Planning Policy Frameworks (NPPF) such developments ignore (Including the development of the Gaping Lane allotments), which state "Development proposals which affect sites or features of local biodiversity will not be permitted where there is an adverse impact on the ecological, geological or biodiversity interests of the site unless it can be demonstrated that adverse effects could be satisfactorily minimised through mitigation measures" and that authorities need to plan for the "creation, protection, enhancement and management of networks of biodiversity and green infrastructure" ensuring "that features of biodiversity value are not lost as a result of a development proposal and that where possible opportunities to incorporate biodiversity in and around development will be sought". There are many other references to the importance of such habitats in the NPPF which also states that the "planning system should contribute to and enhance the natural and local environment by minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures". A breach of such legislation would effectively and wilfully undermine the Government's strategies for Biodiversity 2020 wherein we could help foster and pioneer a more inclusive and progressive ethos instead for the long-term benefit of the wider environment.

Likewise, the negative effect on the health and wellbeing of local residents with the loss of such green space should not be overlooked wherein such developments would completely change the context and environment of the historic community whilst leaving the neighbourhood to jerk abruptly into barren agricultural land without a buffer and with few remaining historic and character features. Such developments would effectively and drastically scar the greenbelt and surviving habitats permanently.

The orchard at Radburn Way, Letchworth (LG6), from what information I have gathered, quite possibly predates the development of the Garden City itself (Listed as smallholdings on maps of the period) and fits in with the self-reliant and betterment ideals and aspirations of the Garden City movement's concepts and ethos. In this respect, the cultural legacy needs consideration and likewise appropriate historic designation with regards to any and all developmental proposals. Various specialists who have visited and studied the orchard believe some of the established and mature trees may exist as surviving plantings from that period, putting the older trees at possibly around 100 years old. We have identified some apple and pear varieties but there are still many more unknown which could be rare and/or lost local and regional varieties. Needless to say, for such reasons the site is undeniably of significant historical and cultural value and with much potential, with appropriate management, to be a truly valuable local asset for the surrounding neighbourhood and residents as well as the living and surviving ecology and future heritage of Letchworth as the world's first Garden City. While the orchard itself is unfortunately but wilfully neglected by the current owners, it does not fit and is not fairly described in the subjective report (Sustainability Appraisal and Strategic Environmental Assessment), which completely overlooks its ecological value and priority designation as well as its potential as a community amenity asset. The assertion that the orchard is an "eyesore" is purely subjective and cannot be regarded in a neutral, objective study of any sort and likewise ignores its genuine potential to be a focal point of local pride and community development etc. Amenity value is equally unrecognised with the inherent and wider benefits of ecosystem services to the surrounding residents, environment and wildlife blatantly ignored despite the potential benefits, in spite of its perceived unappealing appearance.

Orchards are now furthermore recognised properly for their unique importance as biodiverse and endangered ecological habitats and finally regarded as priority habitats by DEFRA in need of conservation under the UK Biodiversity Action Plan and similarly in the Natural Environment and Rural Communities Act (I believe the statistic to be something around 90% of our traditional orchards lost in the last 50 years.). As well as the NPPF policy criteria quoted before (Regarding HT3-6) which are also relevant here, deliberate and wanton neglect and destruction of such open spaces and natural corridors within urban areas goes against policy which requires planning to "minimise impacts on biodiversity and geodiversity... planning policies should promote the preservation, restoration and recreation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets...", and likewise "maintain patterns of open space or landscape features in the town by normally refusing development proposals which would have a significantly detrimental effect on the character, form, extent and structure of the pattern of open spaces". For other relevant legislation and guidance relating to such areas, please consult the Conserving and Enhancing the Natural Environment section of the National Planning Policy Framework for Achieving Sustainable Development which can be found easily by following the link below:

http://planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/11-conserving-and-enhancing-the-natural-environment/

Even if legitimate compensation and/or mitigation were considered in any of these instances, these cannot be realistically regarded as immediate remediation for the loss of established and matured ecosystems and habitats, especially those deemed endangered, scarce and/or national priorities, such as traditional orchards. How do you plan to properly compensate for the loss of an established thriving greenfield orchard Priority Habitat? Though retention of some specimens is touched upon in some of the assessments and compensation mentioned as a possibility, there is no guarantee or confirmation that this would necessarily be sufficient and/or conducted appropriately. The fact that this is discussed, however, and that the adjacent allotments are being protected beside Radburn, for instance, proves such sites are recognised for their diverse values and worth retaining despite construction work, in many instances, having a detrimental and long-term effect on soil structure and surviving components to the effect that the long-term success is jeopardised and ill-considered.

For all the aforementioned reasons, I ask you to please reconsider your stance on sites HT 3, 4, 5 & 6 and LG 6 and to recognize their true value as vital components in the complex and often neglected fabric of ecology and community life which is overlooked flippantly and blindly in these derogatory and inadequate appraisals and assessments. Policy NE2 on Green Infrastructure alone offers protection for these sites under the diverse criteria and there are many others such instances reflected in the Consultation Papers for the Preferred Options, such as those discussed in Policy CGB1 regarding Green Belts and sections 9 and 10 etc. Given the range and value of such sites, I would also heed you consider full and proper assessment with specialist surveys giving appropriate and due weight and respect to the results and findings. In the case of Priority Habitats, for instance, I would say this is warranted and appropriate to say the least, regardless of the perception surrounding access issues (Radburn orchard being divided and fenced). The strategic objectives of the Proposed Submission alone (See Sections 3, 4 and ENV5) should offer protection to such sites given their true nature with TPO's a reasonable consideration etc.