Local Plan 2011-2031 Proposed Submission Draft

The settlement hierarchy set out in Policy SP2 lists Ickleford as a Category A village, the second tier of the hierarchy behind the main towns. We support this conclusion as it reflects the size and function of the village. While development is understandably directed towards the main towns, the Local Plan nevertheless acknowledges that "it is important to allow growth of the villages in order to allow those communities to continue to function". We support the level of growth directed to Ickleford as part of the overall hierarchy.

We support the identification of Ickleford as a Category A village in the Settlement Hierarchy. We also support the recognition in the Local Plan that new housing is needed in Ickleford, not only to meet local needs but to contribute to the wider, district-level housing target. Furthermore, we support the identification of exceptional circumstances to justify Green Belt release around the village. The Council's evidence base identifies the scale of housing need, the lack of sufficient non-Green Belt sites to meet this need and the implications of not reviewing the Green Belt in terms of achieving sustainable development. It is clear that Green Belt sites are required in North Herts and it is also clear that, as a Category A village, Ickleford must make a contribution to housing need.

The scale of housing proposed in Ickleford over the twenty-year plan period (a total of 209 homes) appears reasonable, in comparison with other settlements and with past levels of growth. While the proposed site LS1 is technically within Ickleford Parish, it is in reality an extension of Lower Stondon and will look to Lower Stondon for its day-to-day infrastructure needs (schools, local shops etc). Additional transport movements would be created through Ickleford but the development will have little impact on the social infrastructure of Ickleford village.

Summary - We support the proposed allocation of site IC2 (Burford Grange). We broadly agree with the findings of the Council's assessment of the site in the SHLAA and the Green Belt review. While supporting the allocation, we object to the dwelling estimate for the site of 40 dwellings. This is based on retaining the Grange building which should not be retained in the interests of meeting housing needs and using land efficiently. A dwelling estimate of 50 dwellings would be more appropriate.

Introduction to the site
The report site extends to around 2.4 hectares. It is accessed from the A600 Bedford Road running north and south past the site. The site currently contains a large dwelling, together with various outbuildings and lorry storage. Part of the site is also used for commercial purposes. The site is adjacent to residential development within the village of Ickleford and is well contained by existing landscape features.

Ickleford is a village just north of the town of Hitchin in North Hertfordshire district. It has a population of around 1,800 people. The village has a primary school, 3 pubs, a hair salon and a general store. Ickleford is described in the draft Local Plan as a Category A Village, the 2nd tier of the Settlement Hierarchy. As such it is a sustainable location for future growth.


Pre-application advice
A pre-application submission to NHDC was made by DLA Town Planning on behalf of CALA Homes in July 2016. The submission consisted of a draft layout and accompanying Planning Report. This submission is attached as appendix B to these representations. The pre-application advice from Tom Rea, Area Planning Officer, is attached as appendix C to these representations. The original layout has been revised to meet highways standards in terms of the site access from Bedford Road. This layout is attached as appendix A to these representations. Further refinements of the layout are currently being made to take on board officer comments made through the pre-application process.

The pre-application advice was largely positive. No substantive technical issues or barriers were raised and the layout was considered "largely acceptable". In particular, the provision of the central green area was welcomed. Changes were recommended to the draft layout to provide for a less urban frontage on Bedford Road and a greater mix of dwelling types. These changes are being incorporated into a revised layout for further pre-application discussions with the Council.

The pre-application advice, based on a development of 51 units, indicated that this scale would be "broadly in line with a density guideline of 20 dwellings per hectare, which has been used to calculate dwelling capacity on new housing allocation sites." The officer raised no concerns about the loss of Burford Grange itself.

The layout submitted with the pre-application submission comments demonstrates that 51 dwellings can comfortably be accommodated on the site. Even taking into account officer comments about the Bedford Road frontage, the site is still capable of delivering 50+ dwellings. The dwelling estimate for this site should therefore be increased from 40 dwellings to 50 dwellings.


Strategic Housing Land Availability Assessment (SHLAA)
The Council's Strategic Housing Land Availability Assessment (2016 update) assessed the Burford Grange site as follows:

Agricultural Land Classification Grade 3
Air quality Management Area No
Area of Outstanding Natural Beauty No
Archaeological interest No
Common land/CROW No
Conservation Area No
Contaminated Land No
Flood - river No
Flood - surface No
Green Belt Yes
Habitats No
Listed Buildings No
Local Nature Reserve No
Public Rights of Way No
Registered Park and Garden No
Scheduled Ancient Monument No
Groundwater Source Protection Zone No
Site of Special Scientific Interest Impact zone > 100 dwellings
Wildlife Site Adjacent

The only items of interest here is the Green Belt designation of the site (which is the same as all the sites around Ickleford and Hitchin) and the adjacent Wildlife Site. The remaining 17 criteria confirmed no constraints. In confirming that the Burford Grange site was suitable, available and achievable, the SHLAA concluded as follows:

"Rectangular site consisting of existing Grange building and adjoining undeveloped land. Site well defined by surrounding planting and site capable of achieving satisfactory relationship with existing residential properties on Westmill Lane. Would require release from the Green Belt and amendment to village boundary. For the purposes of the SHLAA, it is assumed that the existing Grange building is retained and the dwelling estimate has been reduced to reflect this."

The dwelling estimate of 40 dwellings provided in the Local Plan for site IC2 is 40 dwellings. This is a reduction from 48 dwellings in the Preferred Options Local Plan from December 2014. The revised estimate is based on the assumption in the SHLAA that the existing Grange Building would be retained, although the text makes clear that this assumption is "for the purposes of the SHLAA". This conclusion was reached in the absence of a proposed layout. As set out above, a proposed layout is now attached to these representations showing how 51 dwellings could be accommodated on the site.

There is no reason to retain the Grange building as part of any development scheme. The building is not Listed, nor locally listed, nor within a Conservation Area. It was built in the 1960s/70s and is of no particular architectural or historic interest. At pre-application stage, the Council raised no concerns about the proposed loss of Burford Grange itself. In the interests of maximising the contribution towards the district's housing need and of using land efficiently, the dwelling estimate for this site should be increased to 50 dwellings.


Green Belt review
The Council has undertaken a review of the Green Belt in North Hertfordshire at both the strategic and local level. At the strategic level the value of the Green Belt around Ickleford is in preventing the northward expansion of Hitchin. In line with the NPPF, the Green Belt is not judged to perform a function in preventing the coalescence of Hitchin with Ickleford, nor of the outward expansion of Ickleford itself. At the local level for site IC2, the Council's review found:

"The site makes a moderate contribution to Green Belt. The site is outside settlement boundaries although adjoins existing development on one side. The site is close to Hitchin, however as Ickleford isn't a town, this isn't significant in Green Belt terms."

We support the Council's conclusion. While the site is within the Green Belt, it could be developed without causing harm to the fundamental principles of Green Belt designation.


Landscape Impact
A Landscape and Visual Impact Assessment (LVIA) was undertaken by ACD Environmental in July 2016 (see appendix D). This report provides an assessment of the potential landscape and visual effects of the proposed development on the receiving landscape. The report states:

"Given the substantial existing landscape framework and nature of local landform, the proposed site is very contained visually and physically. As a result, the potential for clear views from surrounding landscape will be limited and consequently the potential for visibility and effect on the locally defined network of local green spaces, including Oughtonhead Nature Reserve and the green belt land to the south and west, will also be limited."

Further:

"It can be determined that the introduction of new residential units at this point, with a similar offset from the river Oughton as existing residential development to the south of the river would not be uncharacteristic. Given the extent of mature boundary enclosure visual intrusion would be low and the character of the River Oughton would be retained."

The report concludes that "the introduction of residential development within the existing landscape framework would not be considered out of character when considered as part of the wider setting."

In terms of mitigation the report recommends that the scale of the development should be limited to 2.5 storey to retain the same skyline to views from the local landscape. It is also recommended that development should be kept back from the site boundaries, principally to the north, to allow for existing boundary vegetation to mature and new visual barrier elements to establish to minimise the potential impact of built form. These measures have been incorporated into the layout attached at appendix A and will help to minimise the landscape impact of the scheme.


Heritage
The Burford Grange site is some distance from the Conservation Area and has no specific heritage designations affecting it. As such, development of this site would have no impact on local heritage features. The site was not included in the Council's Heritage Assessment of Ickleford undertaken by Amec Foster Wheeler in June 2016.


Ecology
The site is adjacent to, and partly within, a County Wildlife Site (Westmill Lane, ref 11/038). Details of the ecological value of the site are set out in the attached report by Ethos Environmental Planning. The report sets out the ways in which development can mitigate any ecological impact.


Highways
A Transport Statement has been undertaken by Conisbee, see Appendix F. This confirms that the development proposals can be accommodated on the surrounding highway network. A revision to the layout has been made to meet the Local Highway Authority's requirements in terms of an acceptable access from the A600. The site is well located in respect of local services and facilities and offers residents a range of travel options. The scheme will involve extending the existing footway on the western side of the A600 and providing a pedestrian refuge to enable crossing of the A600.


Parish Council views
Ickleford Parish Council has raised a number of concerns to all four sites within the parish (including the site adjacent to Lower Stondon, LS1). However, a number of the points of objections made by the Parish Council are only directed at some of the sites and many do not relate to site IC2 at Burford Grange. For example, the concerns about sewerage and flooding are not expressed in relation to site IC2 and neither are the procedural concerns about lack of consultation (since site IC2 was included at the previous consultation stage, unlike sites IC3 and LS1). While the comments raised by the Council are not an untypical response to a draft Local Plan, it would appear that if some development has to be accommodated in Ickleford (as it surely must, given the district-wide housing need) then the Burford Grange site would seem to be the least-worst option in terms of the Parish Council's views.


Appendices
Appendix A - Indicative site layout
Appendix B - Pre-application submission
Appendix C - Pre-application response from NHDC
Appendix D - Landscape and Visual Impact Assessment, ACD Environmental, July 2016
Appendix E - Ecology, Ethos, November 2016
Appendix F - Transport Statement, Conisbee, November 2016