Local Plan 2011-2031 Proposed Submission Draft

I wish to make an objection to building on plot behind Radburn Way Letchworth in the NHDC Local Plan 2011 - 2031, Proposed submission, dated October 2016.

This is the site of an existing, old, culturally significant and well established orchard where the oldest trees were likely to have been planted when Letchworth Garden City was first established in 1908 or soon afterwards.

Traditional orchards are Priority habitat and they deserve protection. This orchard is part of the cultural legacy of the early Garden City movement.

In two major respects the loss of an existing old well established and culturally significant orchard does not meet the aims of Government Strategy on Biodiversity 2020 in that there should be no net loss of habitat. Also the ecological aim of the NPPF of net gains in habitat outlined below is not met.

11. Conserving and enhancing the natural environment
109. The planning system should contribute to and enhance the natural and local environment by:
● protecting and enhancing valued landscapes, geological conservation interests and soils;
● recognising the wider benefits of ecosystem services;
● 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;
118. When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles:
● if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;


In the NHDC Local Plan Proposed Submission, Section 3.7 Strategic objectives, ENV5, and Section 4 Natural and Historic environment, sections 4.145, 4.148, and 4.165 (the consideration of applying TPOs) afford protection to a site such as this.

I am concerned on p183 LG6 states
'Retention of an area of priority orchard habitat within any scheme with appropriate compensatory provision for any habitat lost as a result of development.'

There are no details as to what area would be retained nor any details as to what compensation is considered nor where a new orchard would be sited. The retained area could be two trees!! Nothing can replace old existing trees. It will be difficult to avoid damage to existing habitat if building work were to take place in adjacent areas.

Particularly I also want to comment on Draft Sustainability Appraisal of North Hertfordshire Proposed Submission Local Plan by CAG consultants from September 2016.

Appendix 6 p 96
'Objective 2a Greenfield site within an urban area -former orchard / smallholding overgrown - no amenity value. Development would remove an urban eyesore.'

I am surprised this traditional orchard site is still referred to as an urban eyesore when it has been acknowledged as an orchard in the Local Plan Proposed Submission. It has amenity value on an ecological and visual basis and as a resource such as improved pollination for surrounding areas. It is neglected but that it because it has been compulsorily purchased and not been looked after by its owners.

'Open spaces and footpaths in walking distance. Site has no public access, i.e. no loss of open space for informal recreation.' The space is open ie not developed but because it is fenced there is no public access. This does not mean there is no loss of open space if it were to be built on.

3a' The overgrown nature of the site would indicate a number of wildlife habitats on site - survey should be conducted.' Because specialist nature of orchards, expert help should be sought particularly on identification of apple, pear, plum and cherry cultivars existing on this site.
Potential to preserve those as part of the new site layout. The very fact that this is suggested here must mean that the space has habitat value.

3c 'There is no historical designation on the site.' This is unfortunate as the oldest trees are of an age that it is likely they were planted when Letchworth was created around 1908 or soon afterwards.

5a 'On the other hand development would remove an urban eyesore.' So there is greater benefit destroying an orchard to put in houses with minimal gardens as is the current trend. Only manicured plots permitted.

5c 'The site is a major development and appears to be in a residential area.' I am interested that the allotments adjacent to this site are being retained for growing fruit and vegetables engendering a sense of wellbeing. However the orchard which could be utilised for the benefit of the local community by making it into a community resource is not being considered. Retaining only a few trees would not understand how an orchard works as an ecosystem.

Appendix 9 p 65/6 for site LG6. Nothing has been included under Mitigation for the loss of a large traditional orchard Priority Habitat. Currently the extent of the orchard is unknown as the site has not been surveyed but large surviving trees can be observed from all corners of the site. This is unacceptable. Proper expert surveys should be carried out.

Appendix 11 p 22 states that policy CGB5 Offers protection to urban open land on the urban fringes, much of which is valuable green space. If that is the case then clearly this site falls under this remit.

I would strongly urge that this whole site remain as a traditional orchard. If this is not possible then the majority of the orchard should remain. If this is not possible then adequate provision should be made for a large orchard five times the current site be planted in compensation. However this goes against the spirit of habitat preservation.