Local Plan 2011-2031 Proposed Submission Draft

I am writing to object to the inclusion of site SP2 in the local plan Whitwell and would like to make the following comments.

Public Engagement- Chapter 4, Policy SP8
SP2 has been added to the draft local plan at the final round of consultation, very late in the process. This means that the community has had insufficient and unacceptable time to respond. The NPPF states that true community consultation must be undertaken. It states 'early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential'. By adding SP2 at this final stage this requirement has not been met.
In introducing this site, the draft local plan disregards:-
a) the findings of the NHDC planning committee who rejected an application and found the site inappropriate for development in August 2016;
b) has not engaged early with the community;
c) disregarded the previous comments from our community and St Pauls Walden Parish Council supporting green belt protection to this land.
Articles 18-20 of The Town and Country Planning (Local Planning) (England) Regulations 2012 outline the requirement for a Statement of Community Involvement This demonstrates that the plan is not consistent with National Policy.
To make the plan sound, SP2 should be allocated as new green belt.
Object to Chapter 4, Policy SP2
The plan is not sound as the evidence used to identify sustainable villages is flawed. Hence the result being that isolated village, with no facilities such as a senior school and shops, and very little public transport, are seen as unsuitable for significant development.
NHDC has labelled Whitwell a 'category A' village deeming that it requires an increase in housing numbers in order to thrive. This is simply not correct and unsound, also contradicting the Parish Council's own assessment of local needs. Whitwell is totally accessed by narrow country lanes, has no supermarket or secondary schools within 5 miles, very few employment opportunities, only 1 public house, and minimal public transport. This cannot be regarded as a sustainable location for significant volumes of new housing. In the previous Local Plan Whitwell was designated as a village beyond the Green belt, which is a more appropriate designation.
The NPPF core planning principles at paragraph 17 clearly state that patterns of growth should be actively managed to make the fullest possible use of public transport, walking and cycling and focus significant development in locations which are, or can be made sustainable. Whitwell's unique rural location, set in unspoilt Chiltern valley landscape surrounded by larger conurbations, attracts high volumes of ramblers and cyclists who appreciate its beauty and amenity values. It lies within the proposed extension to the Chiltern AONB. The draft local plan has failed to grasp the essence of Whitwell's identity and function. Whitwell's role should not be to provide housing towards district targets, but to continue to provide highly valued amenity for North Herts, Luton, Stevenage and other neighbouring urban districts.
To make the Local Plan justified, effective and legally compliant Whitwell should be reclassified as Category B village and SP2 removed as an allocated site.
Object to Chapter 13, Site Allocation SP2
The plan is unsound as it identifies SP2 as suitable for development. There are a number of physical features and constraints that render the site SP2 as completely unsuitable.
a. Flood risk
SP2 site is assessed, by the Environment Agency, as having a high - medium risk of surface water flooding. The higher ground topography funnels rainfall into the natural valley landscape area marked as SP2 increasing flood risk for properties lying in its direct fall including Cresswick and Mimram View. Indeed the SFRA clearly shows water flowing across the site in a 1 in 30 year flood event. Paragraph 100 of NPPF asserts that development should be directed away from sites at high risk of flooding
The NPPF also outlines the need for a Strategic Flood Risk Assessment (SFRA) to be completed to determine flood risk in relation to allocating sites for housing. The SFRA commissioned by NHDC in 2008 predates the inclusion of SP2. On updating the SFRA, NHDC acknowledge the serious surface water issues present at the site. This is against NPPF guidance which states development should be directed away from flood risk altogether, towards sites with a lower flood risk.
New sites should not be sited in areas at high flood risk.
b. Sewerage and Ground Water
Thames Water has determined that there is insufficient capacity remaining in the sewage system for new homes on SP2. This fact has been omitted by NHDC in their documentation. SP2 lies on the principle chalk aquifer, a source of water for the River Mimram. SP2 is therefore a highly sensitive location for groundwater. In fact Whitwell is in a source protection zone 1. Whitwell's famous water cress beds are located just 100 meters from SP2. If the ground water source were to become contaminated, the potential for pollutants to very quickly damage water quality at the cress beds is disastrously high.
Pump based solutions, most often introduced by developers under these circumstances, are unsustainable. Continued maintenance measures that these systems require, to avoid common problems such as septic tank overflow, cannot be guaranteed.
c. Visual Impact
SP2 is a widely valued, attractive Greenfield agricultural site. It is visible from the Chiltern Way and other popular footpaths and bridleways. It forms a prominent part of our unique valley character landscape.
The North Hertfordshire and Stevenage Landscape Character Assessment, an independent report instructed by NHDC to review the landscape character area of Whitwell Valley, identifies SP2's location visual sensitivities as being moderate - high. "Cross valley views from the higher vantage points are an important feature of the character area. Panoramic views are common from the higher valley slopes, views along the valley are an important feature in the character area."
It also states that:
"large urban extensions and new settlements (>5ha) would not be appropriate within this Character Area, due to its relatively remote, rural and undeveloped character. It would be of an inappropriate scale and would introduce elements that would urbanise the landscape, altering the character and removing the existing key characteristics. Visual impacts would also be high due to the cross valley views currently experienced."
SP2 is a site of nearly 6ha. The allocation of the site is contrary to the independent report findings for reason of visual impact.
In summary we consider that amendment of SP2 from housing development to new Green Belt is necessary to make the plan sound.
Object to Chapter 13, site allocation SP2
The proposed development is not in a sustainable location and will depend heavily on private transport for most travel. The NHDC Planning Committee on August 25 determined that required sustainable drainage (SUDS) would have unacceptable impact on the visual impact of the site and the planning application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable
For the reasons above I consider that SP2 should be removed from the Local Plan 2011-2031

I am writing to object to the inclusion of site SP2 in the local plan Whitwell and would like to make the following comments.

Public Engagement- Chapter 4, Policy SP8
SP2 has been added to the draft local plan at the final round of consultation, very late in the process. This means that the community has had insufficient and unacceptable time to respond. The NPPF states that true community consultation must be undertaken. It states 'early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential'. By adding SP2 at this final stage this requirement has not been met.
In introducing this site, the draft local plan disregards:-
a) the findings of the NHDC planning committee who rejected an application and found the site inappropriate for development in August 2016;
b) has not engaged early with the community;
c) disregarded the previous comments from our community and St Pauls Walden Parish Council supporting green belt protection to this land.
Articles 18-20 of The Town and Country Planning (Local Planning) (England) Regulations 2012 outline the requirement for a Statement of Community Involvement This demonstrates that the plan is not consistent with National Policy.
To make the plan sound, SP2 should be allocated as new green belt.
Object to Chapter 4, Policy SP2
The plan is not sound as the evidence used to identify sustainable villages is flawed. Hence the result being that isolated village, with no facilities such as a senior school and shops, and very little public transport, are seen as unsuitable for significant development.
NHDC has labelled Whitwell a 'category A' village deeming that it requires an increase in housing numbers in order to thrive. This is simply not correct and unsound, also contradicting the Parish Council's own assessment of local needs. Whitwell is totally accessed by narrow country lanes, has no supermarket or secondary schools within 5 miles, very few employment opportunities, only 1 public house, and minimal public transport. This cannot be regarded as a sustainable location for significant volumes of new housing. In the previous Local Plan Whitwell was designated as a village beyond the Green belt, which is a more appropriate designation.
The NPPF core planning principles at paragraph 17 clearly state that patterns of growth should be actively managed to make the fullest possible use of public transport, walking and cycling and focus significant development in locations which are, or can be made sustainable. Whitwell's unique rural location, set in unspoilt Chiltern valley landscape surrounded by larger conurbations, attracts high volumes of ramblers and cyclists who appreciate its beauty and amenity values. It lies within the proposed extension to the Chiltern AONB. The draft local plan has failed to grasp the essence of Whitwell's identity and function. Whitwell's role should not be to provide housing towards district targets, but to continue to provide highly valued amenity for North Herts, Luton, Stevenage and other neighbouring urban districts.
To make the Local Plan justified, effective and legally compliant Whitwell should be reclassified as Category B village and SP2 removed as an allocated site.
Object to Chapter 13, Site Allocation SP2
The plan is unsound as it identifies SP2 as suitable for development. There are a number of physical features and constraints that render the site SP2 as completely unsuitable.
a. Flood risk
SP2 site is assessed, by the Environment Agency, as having a high - medium risk of surface water flooding. The higher ground topography funnels rainfall into the natural valley landscape area marked as SP2 increasing flood risk for properties lying in its direct fall including Cresswick and Mimram View. Indeed the SFRA clearly shows water flowing across the site in a 1 in 30 year flood event. Paragraph 100 of NPPF asserts that development should be directed away from sites at high risk of flooding
The NPPF also outlines the need for a Strategic Flood Risk Assessment (SFRA) to be completed to determine flood risk in relation to allocating sites for housing. The SFRA commissioned by NHDC in 2008 predates the inclusion of SP2. On updating the SFRA, NHDC acknowledge the serious surface water issues present at the site. This is against NPPF guidance which states development should be directed away from flood risk altogether, towards sites with a lower flood risk.
New sites should not be sited in areas at high flood risk.
b. Sewerage and Ground Water
Thames Water has determined that there is insufficient capacity remaining in the sewage system for new homes on SP2. This fact has been omitted by NHDC in their documentation. SP2 lies on the principle chalk aquifer, a source of water for the River Mimram. SP2 is therefore a highly sensitive location for groundwater. In fact Whitwell is in a source protection zone 1. Whitwell's famous water cress beds are located just 100 meters from SP2. If the ground water source were to become contaminated, the potential for pollutants to very quickly damage water quality at the cress beds is disastrously high.
Pump based solutions, most often introduced by developers under these circumstances, are unsustainable. Continued maintenance measures that these systems require, to avoid common problems such as septic tank overflow, cannot be guaranteed.
c. Visual Impact
SP2 is a widely valued, attractive Greenfield agricultural site. It is visible from the Chiltern Way and other popular footpaths and bridleways. It forms a prominent part of our unique valley character landscape.
The North Hertfordshire and Stevenage Landscape Character Assessment, an independent report instructed by NHDC to review the landscape character area of Whitwell Valley, identifies SP2's location visual sensitivities as being moderate - high. "Cross valley views from the higher vantage points are an important feature of the character area. Panoramic views are common from the higher valley slopes, views along the valley are an important feature in the character area."
It also states that:
"large urban extensions and new settlements (>5ha) would not be appropriate within this Character Area, due to its relatively remote, rural and undeveloped character. It would be of an inappropriate scale and would introduce elements that would urbanise the landscape, altering the character and removing the existing key characteristics. Visual impacts would also be high due to the cross valley views currently experienced."
SP2 is a site of nearly 6ha. The allocation of the site is contrary to the independent report findings for reason of visual impact.
In summary we consider that amendment of SP2 from housing development to new Green Belt is necessary to make the plan sound.
Object to Chapter 13, site allocation SP2
The proposed development is not in a sustainable location and will depend heavily on private transport for most travel. The NHDC Planning Committee on August 25 determined that required sustainable drainage (SUDS) would have unacceptable impact on the visual impact of the site and the planning application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable
For the reasons above I consider that SP2 should be removed from the Local Plan 2011-2031