Local Plan 2011-2031 Proposed Submission Draft

We object to the soundness of the NHDC proposed development of site HT1, on the following grounds:

1. Incursion into the Greenbelt

Whilst the need for more housing in North Hertfordshire is understood, the allocation at site HT1 (700 dwellings), combined with the relative distance from the centre of Hitchin is (>0.8 miles at nearest point) places unnecessary stress on the limited Greenbelt in this area. As previously highlighted in the original Local Plan consultation period (attached), the Green Belt land at site HT1 acts as a limited buffer between the towns of Letchworth and Hitchin. As the Local Plan states:

'...each town retains a distinct identity of its own. The needs for development arising from the three towns are comparatively high, but the gaps separating the towns are small and of great importance if the town's urban areas and identities are to be kept distinct.'

Development of site HT1 would bring the extent of Hitchin's outermost housing areas to within 400m of Letchworth's periphery. If the full 700-home allocation is permitted, the remaining Green Belt would be little more than a token gesture, providing not one of the key aims of Green Belt land as outlined by the CPRE:

* to prevent urban sprawl;

* to stop neighbouring towns and cities from joining-up;

* to protect the countryside;

* to preserve the setting and special character of historic towns

* to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

2. Air quality

The development of site HT1 would have a significant impact on air quality as a result of the increased traffic expected to access the site; the principle areas of concern area being Cambridge road, which is at, or near capacity and subject to significant periods of stationary traffic. From details provided in the Air Quality Emissions Planning Guidance it can be surmised that with areas of the A505 already designated Air Quality Management Areas (AQMAs) this is likely to be a significant argument against such a development.

3. Provision of Local Amenities

In order to support a housing development of such magnitude it is necessary to ensure that the existing infrastructure of local amenities is sufficient to cope with the extra demand, or if not provide suitable development plans that address the shortfall. Whilst the planning caveat for an additional primary school is welcome, we believe that the Local Plan provides little evidence that the proposed development can be supported solely by an additional 500m2 of retail space proposed (roughly one medium-sized convenience store). Furthermore, there is little to no evidence of any other planned amenity development within the local area that would help integrate the site at HT1 into the town.

With respect to the proposed site's impact on local amenities, we still believe the proposed development is unsound with respect to the following Local Plan policy:

Local Amenities (General):

Manual for Streets (Department for Transport, 2007) states that "Walkable neighbourhoods are typically characterised by having a range of facilities within 10 minutes (up to about 800m [0.5 miles]) walking distance of residential areas which residents may access comfortably on foot". Therefore, convenient walking, as set out in the policy, will be taken to be up to 800m.

In order for local amenities to be convenient, they must be within walking distance - which with reference to the above should be within 800m (0.5 miles). Outside of the proposed minimal 500m2 allocation for HT1, the Local Plan states (Section 12.9.2) that the following (local) community centres would be provided:

* The area around Café Valeriya (Grove road/Woolgrove road crossroads) 0.4 miles, or 8 minutes from nearest HT1 access point

* The area around Polcaro's Fish and Chip shop (Woolgrove road/Cambridge road crossroads) 0.5 miles, or 11 minutes from nearest HT1 access point

* The area around Cambridge Road Stores (Cambridge Road). Just over 0.5 miles or 11 minutes from nearest HT1 access point.

Of these three, only one is within the maximum walking distance of the periphery of the HT1 site, the other two are at the maximum distance, with the majority of the development site outside of this maximum distance (to provide context, the periphery of site HT1 is 1.3km or 0.8 miles from the town centre). There is no supporting evidence to suggest that the development of these areas is being pursued in the Preferred options document.

In the Transport infrastructure plan, both sites HM5.5 (Grove road/Woolgrove road crossroads) and Site HM5.1 (Woolgrove road/Cambridge road crossroads) are indicated as being at near-capacity and are thus proposed for improvement schemes to encourage traffic flow, neither having any local parking.

Given the above, it is extremely unlikely that residents (other than those at the periphery of site HT1) are going to walk to local amenities outside the nominal small allocation provided for site HT1. If the majority drive, the likelihood is that most would travel to either Hitchin or Letchworth town centres in preference, given the ease of access and greater choice. Since the proposed development caters for approximately 700 homes, or circa 1500 people, one can expect in excess of 900 cars (assuming 1.3 cars per household) to be associated with the development. This is approximately 100% of the allocated town centre car parking spaces provided by NHDC (neglecting Nightingale road, Hitchin swim centre and the shopping centre private car parks).

Unless sustainable transport alternatives are provided, or significantly more local amenities (i.e within the development) are included on site HT1, the stress upon Hitchin town centre generated by increased car travel would be severe.

In the context above, the term 'local amenities' is used loosely to cover those premises which provide necessary services for day-to-day life; this includes the private and public sector (shops, doctors, dentists, schools, nurseries etc.). NHDC should be well aware that local amenity provision in the area is already poor:

* There are just two local shops (MPM stores on Woolgrove road and Lifestyle express on Cadwell lane) within the proposed 800m walking distance.

* The local pub (the Sailor) has recently closed pending private development, with the nearest alternative - the Anchor 0.6 miles away; this ignores the Gardeners' Arms which is positioned along a dangerous section of highway - inaccessible by foot, especially given the pedestrian-unfriendly nature of the Stotfold road entrance.

* The nearest doctors, dentists, opticians and other basic amenities are all classically defined as being within the town centre and well outside walking distance.

* Walsworth community centre is already under threat of closure. Should this happen, one of the key focal points necessary for any large community would be lost.

The Local Plan preferred options document fails to provide any mitigation to the added pressures the development of site HT1 would provide, with all referenced community centre sites lacking specific detail, as well as being at the extreme or outside what is defined as 'walkable'.

4. Impact on Transport Infrastructure

With respect to the proposed site's impact on local transport infrastructure, we believe the proposed development is unsound with respect to the following Local Plan policies:

Transport Policy T1: Sustainable Transport

To help deliver accessibility improvements and the promotion of sustainable transport, development proposals should:

1. be in locations which enable sustainable journeys to be made to key services and facilities;

2. comply with the provisions of the Local Transport Plan and other supporting documents as considered necessary;

3. ensure that a range of alternative transport options are available to occupants or users. This may involve new or improved pedestrian, cycle and passenger transport links and routes;

4. in the construction of strategic sites, allow for the early implementation of sustainable travel infrastructure in order to influence the behaviour of occupiers or users and in order that sustainable travel patterns become embedded at an early stage; and

5. protect existing rights of way, cycling and equestrian routes and, should diversion be unavoidable, provide replacement routes to the satisfaction of the Council.

As already stated in Section 2, there is little provision in terms of local amenities (with respect to the 800m maximum walking distance), it is also highly likely (despite NHDC's best intentions) that the majority of residents would either be commuters (it has been estimated that 49% of all North Hertfordshire residents who are in employment commute out of the district for work), or would seek employment in areas outside of walking distance.

Travel by Car

As previously detailed, it can be expected that in excess of 900 cars would be added to the road infrastructure as a result of the development of site HT1. It is already noted from the Local Plan that the infrastructure at the key junctions associated with this development (those on the A505) are already at or near capacity. Although it is unrealistic to expect this total volume of cars to be journeying simultaneously, it is probable that a majority would travel during peak times, given the distance of the site from the town. Furthermore the majority of these journeys would involve travel along the A505, as this is the principle access road to the development, linking to the site to the A1.

Proposed mitigations have previously been shown to be insufficient and it can therefore be concluded that the proposed improvements to traffic infrastructure are likely to have little or no benefit over the 2011-2031 time frame.

Train

From the Local Plan (Section 22.23):

Whilst the station is easily accessible from the town centre by walking and cycling, the lack of an eastern and southern access to the station is problematic for journeys from the periphery of the town. The station car park is privately owned, providing 338 long stay spaces which are in high demand during the week.

Other than implying that train service operators must act to create extra services from Hitchin to cater for the growing population, there is no mention of how commuters from the HT1 site are to access the station. As covered above, the roads in the area are already gridlocked. There is little mention of planned cycle infrastructure between site HT1 and the station and it is worth noting that the railway bridge over Cambridge road and the accompanying junction to Nightingale road pose significant dangers to cyclists. Site HT1 is also outside the 800m walking distance target from the station. Should pedestrian access be encouraged, there are further issues posed by the constriction of the pathway under the railway bridge, as well as the frequent use of Walsworth common as a 'cut-through', a route which is unlit at night.

Bus

The Local Plan states that research has showed that only 3% of people living in Hitchin commute to work using the bus. The plan goes no further in suggesting how the use of buses might be encouraged to relieve pressure on other forms of transport (principally cars). From this it can be inferred that no effort would made by NHDC to promote bus services to site HT1.

Cycling

As covered above, there is little or no provision of cycling infrastructure in Hitchin. The transport infrastructure plan places strong emphasis on easing traffic congestion at sites HM5.1 and HM5.2, including filter lanes on the former to keep traffic at speed. This emphasis would have a negative effect on potential commuters' adoption of cycling as a means to access either the centre of town or the railway station. Again the Cambridge road bridge also poses a significant danger area which has not been addressed in the Local Plan.

It can be concluded from the above, that the proposed development of site HT1 is unfeasible with respect to creating a synergistic sustainable transport system that acts to unify this site with the other keys areas of Hitchin (the station and the town centre). Such a development would, as a result, sit in isolation; its residents forced to use private cars as a means to access work and local amenities.

5. Employment

One of the main premises underlying the support of development of site HT1 is the intended promotion of site HE1 as a local employment centre. As previously detailed during the consultation period, there are major flaws in this assumption, including:

* The scope for increasing employment is slim.

* The majority of households occupying site HT1 are likely to be commuters either travelling to London or outside of North Hertfordshire for work.

* There is a significant mismatch between the predominantly light industry occupying this site and the mainly professional workforce expected to occupy site HT1.

The Local Plan lacks credible evidence that employers can be attracted to site HE1 and as such the premise that it can act as a major employment centre for site HT1 is unfounded.