Local Plan 2011-2031 Proposed Submission Draft

1) (Chapter 13 SP2; NPPF para. 150) The decision by NHDC Planners to re-draw the boundary of the village has been made at very short notice. It immediately followed the rejection of (West Whitwell) SP2 by the Planning Committee in August, giving the village minimal time to react. If the Planners thought that changing the boundary was a desirable end in itself, why did they not propose it at an early stage? Changing the boundary of a community is a decision of major impact and consequence, not something to be done with the stroke of a pen. This lack of value given to the community's existence and views was something I encountered early on. My objection (along with others') was designated "Not Applicable". I do not understand why the Council used this misleading and dissuasive term, which most obviously means "Not Valid". It was only after enquiry that I discovered that I could re-submit my objection and it would be published in full. Again I do not understand why, if I could simply re-submit my objection, the Council could not itself have published all those previously unpublished contributions or at least informed us that we could do so. When mine was re-published, it prompted a flurry of interest on Facebook for the possible historical interest of the location. What I take from these two examples is that the Planning Dept. is less interested in the responses of individuals or the public at large than in exerting the fullest pressure to fulfil its intentions. This runs counter to a "positively prepared" and "objectively assessed" strategy.

2) It is inappropriate to designate Whitwell as a Category A village. It is accessed by small country lanes, its poor public transport service has recently been further reduced, it has no supermarket or any other relevant infrastructure. It should be re-classified as a Category B village more suited to infill. (Chapter 4, Policy SP2).

3) The number of houses which NHDC is required to deliver has been reduced from 14,400 to 13,800 but the Council has increased its contingency buffer from 3% to 7%. This suggests that the Council is taking unnecessary advantage of the opportunity provided by the Local Plan at the cost of disadvantaging the existing village. This does not meet the criteria of "justified" and "positively prepared."

4) In the last draft of the local plan, SP2 was allocated for green belt land. This was appropriate in the light of the proposed urban expansions of Luton and Stevenage. The designation has now been overturned. This indicates how little the Planning Department estimates the amenity value of the Whitwell environment. This action does not meet the criterion of "justified."

5) The site has been assessed by the Environment Agency as having a high-medium risk of surface water flooding. Para. 100 of NPPF asserts that development should be directed away from sites at high risk of flooding. This contradicts "positively prepared", "justified", and "consistent with national policy" criteria.

6) NHDC has omitted from its documentation that Thames Water state that the existing sewage system cannot cope with any additional requirements. The proposed development would depend upon a septic tank and pump. Given the proximity of the historic water-cress beds, the potential for disaster is unthinkable. This contradicts national policy in terms of sustainability.

7) No mention throughout has been given to the possible historical value of the site, which is known clearly to older residents as "Meeting House" on the basis that it was used by John Bunyan for his open air meetings. The amphitheatre shape of the site gives credence to this assertion and oral tradition usually has a reliable basis. Bunyan is known to have frequented Bendish for smaller gatherings; a larger site would have been necessary for an assembly of followers from surrounding villages. The former church of St. Mary in Bendish Lane was preceded by a chapel of the Countess of Huntingdon's Connexion, both of which are likely to mark the site of previous religious gatherings. In addition to the quality of the visual landscape, it is important to give credit also to the historical landscape. Although this factor was mentioned in my original submission, for six months it lay unpublished as a result of the Planning Department's haphazard supervision of its website, dedicated as it is to the recording of the concerns of its constituents; for this inadequacy it accepts no responsibility.

For all these reasons, I believe that the proposed Local Plan for Whitwell/St. Paul's Walden fails to meet the desired criteria in regard to positive strategy, justification, effectiveness and consistency with national policy.