Local Plan 2011-2031 Proposed Submission Draft

I am writing to you in connection with the District Council's consultation on its Local Plan, and particularly in relation to the proposed expansion of Codicote. I strongly object to the proposal to allow the construction of over 300 houses in the Green Belt surrounding Codicote. I shall explain my reasoning beginning with reference to the National Planning Policy Framework (NPPF). I shall also demonstrate that the proposal is inconsistent with North Hertfordshire District Council (NHDC's) own policies.

Driving a coach & horses through the principles outlined in the NPPF
The proposals for building houses in the areas CD1 - 5 run contrary to the principles enshrined in the NPPF, as follows:

Par. 79
'The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.'

Par. 87
'As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.'

Comment: Building in the Green Belt is only allowable under very special circumstances, and NHDC has simply not demonstrated this is the case. Here I would like to refer to CPRE's submission of 23rd November 2016, and there is little purpose in my repeating what CPRE has said. However, it is worth emphasising that case law has demonstrated that general housing need does not constitute an exceptional circumstance, as were it to do so then in effect the Green Belt would be afforded no protection. This argument is made very clearly by CPRE and I would like to endorse everything they say concerning the fact that NHDC has failed to demonstrate the case for exceptional circumstances justifying the release of the Green Belt for development around Codicote.

Par. 109
'The planning system should contribute to and enhance the natural and local environment by:

* protecting and enhancing valued landscapes,...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..'

Comment: This proposal can only harm biodiversity, resulting in the local extinctions of farmland dependent species.

Par. 113
'Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife... or landscape areas will be judged... commensurate with their status.. [giving] appropriate weight to their importance and the contribution that they make to wider ecological networks.'

Comment: Where has the Council established a policy that states that new developments are acceptable in the context of eliminating populations of fauna that rely on farmland?

Incompatibilities with NHDC's District Local Plan with Alterations (1996)
The proposal to expand Codicote by nearly 25 per cent is not supported by the Council's Local Plan:

Policy 3
Settlements within the Green Belt
Comment: This policy states that development may only be considered for strict agricultural need, the service needs of the settlement within which the development is proposed, a single dwelling not resulting in outward expansion, or an identified rural housing need which meets the criteria of Policy 29. Policy 29 refers to a 'specific and proven local need,' which would not be available on the 'general housing market,' visually sympathetic to the existing character of, in this case Codicote, not detracting from the 'character' or local 'landscape,' all of which would be 'secured in a legal agreement.' In short, neither Policy 3 nor Policy 29 permits development of the nature envisaged for Codicote in NHDC's Local Plan.

Policy 5
Excluded Villages
Comment: This policy states that the Council may permit development in Codicote 'only if the development is compatible with the maintenance and enhancement of village character [my emphasis] and the maintenance of Green Belt boundaries... Clearly increasing a settlement by some 25 per cent cannot by any definition 'maintain and enhance' village character - what this development does is begin the inexorable transformation of our village into a small town. How can the following inevitable consequences of this expansion maintain or enhance Codicote as a village, but to the contrary it will degrade village life in a number of respects:

* there is insufficient capacity in the local primary school for more pupils and as it is secondary school pupils have to travel on overcrowded buses to neighbouring towns like Welwyn Garden City on congested roads;
* Codicote does not have a GP's surgery and the local surgery at Bridge Cottage is already at overcapacity;
* Codicote's High Street is already overfull with limited parking, with cars often obstructing the pavement - this situation can only worsen with more housing;
* Affinity Water will not (rightly in my view) allow any more abstraction from the Mimram. How, therefore, is the demand for more water going to be met? There are already constraints on the infrastructure for waste water;
* There are currently frequent short power cuts in Codicote - how can this improve with more demand for electricity unless power cables are to be strengthened.

Expanding Codicote by 25 per cent is unsustainable
The NPPF makes clear the Government's support for sustainable development but the NPPF also incorporates the Brundtland understanding of what sustainability entails, namely that it must have economic, social and environmental protection at its heart. The proposal in the Local Plan fails on all three criteria. That is, there will be few economic benefits to the village with this development (in terms of long term employment - as almost all the new householders will work elsewhere), when there is already pressure on schools, health facilities and other infrastructure the development can only create tensions rather than improved community cohesiveness, and finally environmentally it can only be very harmful. The new houses - assuming they will not be zero carbon homes - will produce green house gases and 315 new houses will result in approximately 550 additional cars, all of them queuing at rush hour along the rural roads surrounding Codicote as the new residents drive to work elsewhere. So together, home energy consumption and transport, will contribute to Climate Change. And what these developments will be replacing is rural land which currently serves as a habitat for wildlife.

Conclusion
In summary, the NPPF explicitly states that the Green Belt can only be developed in very exceptional circumstances, and as CPRE has pointed out NHDC has not demonstrated any such exceptional circumstances, and general housing need categorically does not constitute an exceptional circumstance. In this regard I would like to quote from the letter of the Chief Planner to all Planning Authorities in 2015. Here he says:
The National Planning Policy Framework makes clear that most development in the Green Belt is inappropriate and should be approved only in very special circumstances. Consistent with this... unmet need are unlikely to clearly outweigh harm to the Green Belt... so as to establish very special circumstances. (Letter from Steve Quartmain CBE of 31 August 2015)
Moreover, when the Council considers its own Local Plan, it is clear that the development proposed for Codicote does not 'maintain or enhance' but rather is of a place changing scale and should not be permitted. It is also wholly unsustainable, from the perspective of socially dividing the community rather than bringing people together, increasing the congestion on lanes not designed for 'rush hour' traffic, increasing green house gas emissions, threatening already overstretched water supplies, and replacing wildlife habitats at a time when the State of Nature report published recently tells us how much of our rural wildlife is declining. In every respect, therefore, the proposal to expand Codicote should not be permitted.
Thank you for considering the evidence I presented in this letter.

I am writing to you in connection with the District Council's consultation on its Local Plan, and particularly in relation to the proposed expansion of Codicote. I strongly object to the proposal to allow the construction of over 300 houses in the Green Belt surrounding Codicote. I shall explain my reasoning beginning with reference to the National Planning Policy Framework (NPPF). I shall also demonstrate that the proposal is inconsistent with North Hertfordshire District Council (NHDC's) own policies.

Driving a coach & horses through the principles outlined in the NPPF
The proposals for building houses in the areas CD1 - 5 run contrary to the principles enshrined in the NPPF, as follows:

Par. 79
'The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.'

Par. 87
'As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.'

Comment: Building in the Green Belt is only allowable under very special circumstances, and NHDC has simply not demonstrated this is the case. Here I would like to refer to CPRE's submission of 23rd November 2016, and there is little purpose in my repeating what CPRE has said. However, it is worth emphasising that case law has demonstrated that general housing need does not constitute an exceptional circumstance, as were it to do so then in effect the Green Belt would be afforded no protection. This argument is made very clearly by CPRE and I would like to endorse everything they say concerning the fact that NHDC has failed to demonstrate the case for exceptional circumstances justifying the release of the Green Belt for development around Codicote.

Par. 109
'The planning system should contribute to and enhance the natural and local environment by:

* protecting and enhancing valued landscapes,...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..'

Comment: This proposal can only harm biodiversity, resulting in the local extinctions of farmland dependent species.

Par. 113
'Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife... or landscape areas will be judged... commensurate with their status.. [giving] appropriate weight to their importance and the contribution that they make to wider ecological networks.'

Comment: Where has the Council established a policy that states that new developments are acceptable in the context of eliminating populations of fauna that rely on farmland?

Incompatibilities with NHDC's District Local Plan with Alterations (1996)
The proposal to expand Codicote by nearly 25 per cent is not supported by the Council's Local Plan:

Policy 3
Settlements within the Green Belt
Comment: This policy states that development may only be considered for strict agricultural need, the service needs of the settlement within which the development is proposed, a single dwelling not resulting in outward expansion, or an identified rural housing need which meets the criteria of Policy 29. Policy 29 refers to a 'specific and proven local need,' which would not be available on the 'general housing market,' visually sympathetic to the existing character of, in this case Codicote, not detracting from the 'character' or local 'landscape,' all of which would be 'secured in a legal agreement.' In short, neither Policy 3 nor Policy 29 permits development of the nature envisaged for Codicote in NHDC's Local Plan.

Policy 5
Excluded Villages
Comment: This policy states that the Council may permit development in Codicote 'only if the development is compatible with the maintenance and enhancement of village character [my emphasis] and the maintenance of Green Belt boundaries... Clearly increasing a settlement by some 25 per cent cannot by any definition 'maintain and enhance' village character - what this development does is begin the inexorable transformation of our village into a small town. How can the following inevitable consequences of this expansion maintain or enhance Codicote as a village, but to the contrary it will degrade village life in a number of respects:

* there is insufficient capacity in the local primary school for more pupils and as it is secondary school pupils have to travel on overcrowded buses to neighbouring towns like Welwyn Garden City on congested roads;
* Codicote does not have a GP's surgery and the local surgery at Bridge Cottage is already at overcapacity;
* Codicote's High Street is already overfull with limited parking, with cars often obstructing the pavement - this situation can only worsen with more housing;
* Affinity Water will not (rightly in my view) allow any more abstraction from the Mimram. How, therefore, is the demand for more water going to be met? There are already constraints on the infrastructure for waste water;
* There are currently frequent short power cuts in Codicote - how can this improve with more demand for electricity unless power cables are to be strengthened.

Expanding Codicote by 25 per cent is unsustainable
The NPPF makes clear the Government's support for sustainable development but the NPPF also incorporates the Brundtland understanding of what sustainability entails, namely that it must have economic, social and environmental protection at its heart. The proposal in the Local Plan fails on all three criteria. That is, there will be few economic benefits to the village with this development (in terms of long term employment - as almost all the new householders will work elsewhere), when there is already pressure on schools, health facilities and other infrastructure the development can only create tensions rather than improved community cohesiveness, and finally environmentally it can only be very harmful. The new houses - assuming they will not be zero carbon homes - will produce green house gases and 315 new houses will result in approximately 550 additional cars, all of them queuing at rush hour along the rural roads surrounding Codicote as the new residents drive to work elsewhere. So together, home energy consumption and transport, will contribute to Climate Change. And what these developments will be replacing is rural land which currently serves as a habitat for wildlife.

Conclusion
In summary, the NPPF explicitly states that the Green Belt can only be developed in very exceptional circumstances, and as CPRE has pointed out NHDC has not demonstrated any such exceptional circumstances, and general housing need categorically does not constitute an exceptional circumstance. In this regard I would like to quote from the letter of the Chief Planner to all Planning Authorities in 2015. Here he says:
The National Planning Policy Framework makes clear that most development in the Green Belt is inappropriate and should be approved only in very special circumstances. Consistent with this... unmet need are unlikely to clearly outweigh harm to the Green Belt... so as to establish very special circumstances. (Letter from Steve Quartmain CBE of 31 August 2015)
Moreover, when the Council considers its own Local Plan, it is clear that the development proposed for Codicote does not 'maintain or enhance' but rather is of a place changing scale and should not be permitted. It is also wholly unsustainable, from the perspective of socially dividing the community rather than bringing people together, increasing the congestion on lanes not designed for 'rush hour' traffic, increasing green house gas emissions, threatening already overstretched water supplies, and replacing wildlife habitats at a time when the State of Nature report published recently tells us how much of our rural wildlife is declining. In every respect, therefore, the proposal to expand Codicote should not be permitted.
Thank you for considering the evidence I presented in this letter.

I am writing to you in connection with the District Council's consultation on its Local Plan, and particularly in relation to the proposed expansion of Codicote. I strongly object to the proposal to allow the construction of over 300 houses in the Green Belt surrounding Codicote. I shall explain my reasoning beginning with reference to the National Planning Policy Framework (NPPF). I shall also demonstrate that the proposal is inconsistent with North Hertfordshire District Council (NHDC's) own policies.

Driving a coach & horses through the principles outlined in the NPPF
The proposals for building houses in the areas CD1 - 5 run contrary to the principles enshrined in the NPPF, as follows:

Par. 79
'The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.'

Par. 87
'As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.'

Comment: Building in the Green Belt is only allowable under very special circumstances, and NHDC has simply not demonstrated this is the case. Here I would like to refer to CPRE's submission of 23rd November 2016, and there is little purpose in my repeating what CPRE has said. However, it is worth emphasising that case law has demonstrated that general housing need does not constitute an exceptional circumstance, as were it to do so then in effect the Green Belt would be afforded no protection. This argument is made very clearly by CPRE and I would like to endorse everything they say concerning the fact that NHDC has failed to demonstrate the case for exceptional circumstances justifying the release of the Green Belt for development around Codicote.

Par. 109
'The planning system should contribute to and enhance the natural and local environment by:

* protecting and enhancing valued landscapes,...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..'

Comment: This proposal can only harm biodiversity, resulting in the local extinctions of farmland dependent species.

Par. 113
'Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife... or landscape areas will be judged... commensurate with their status.. [giving] appropriate weight to their importance and the contribution that they make to wider ecological networks.'

Comment: Where has the Council established a policy that states that new developments are acceptable in the context of eliminating populations of fauna that rely on farmland?

Incompatibilities with NHDC's District Local Plan with Alterations (1996)
The proposal to expand Codicote by nearly 25 per cent is not supported by the Council's Local Plan:

Policy 3
Settlements within the Green Belt
Comment: This policy states that development may only be considered for strict agricultural need, the service needs of the settlement within which the development is proposed, a single dwelling not resulting in outward expansion, or an identified rural housing need which meets the criteria of Policy 29. Policy 29 refers to a 'specific and proven local need,' which would not be available on the 'general housing market,' visually sympathetic to the existing character of, in this case Codicote, not detracting from the 'character' or local 'landscape,' all of which would be 'secured in a legal agreement.' In short, neither Policy 3 nor Policy 29 permits development of the nature envisaged for Codicote in NHDC's Local Plan.

Policy 5
Excluded Villages
Comment: This policy states that the Council may permit development in Codicote 'only if the development is compatible with the maintenance and enhancement of village character [my emphasis] and the maintenance of Green Belt boundaries... Clearly increasing a settlement by some 25 per cent cannot by any definition 'maintain and enhance' village character - what this development does is begin the inexorable transformation of our village into a small town. How can the following inevitable consequences of this expansion maintain or enhance Codicote as a village, but to the contrary it will degrade village life in a number of respects:

* there is insufficient capacity in the local primary school for more pupils and as it is secondary school pupils have to travel on overcrowded buses to neighbouring towns like Welwyn Garden City on congested roads;
* Codicote does not have a GP's surgery and the local surgery at Bridge Cottage is already at overcapacity;
* Codicote's High Street is already overfull with limited parking, with cars often obstructing the pavement - this situation can only worsen with more housing;
* Affinity Water will not (rightly in my view) allow any more abstraction from the Mimram. How, therefore, is the demand for more water going to be met? There are already constraints on the infrastructure for waste water;
* There are currently frequent short power cuts in Codicote - how can this improve with more demand for electricity unless power cables are to be strengthened.

Expanding Codicote by 25 per cent is unsustainable
The NPPF makes clear the Government's support for sustainable development but the NPPF also incorporates the Brundtland understanding of what sustainability entails, namely that it must have economic, social and environmental protection at its heart. The proposal in the Local Plan fails on all three criteria. That is, there will be few economic benefits to the village with this development (in terms of long term employment - as almost all the new householders will work elsewhere), when there is already pressure on schools, health facilities and other infrastructure the development can only create tensions rather than improved community cohesiveness, and finally environmentally it can only be very harmful. The new houses - assuming they will not be zero carbon homes - will produce green house gases and 315 new houses will result in approximately 550 additional cars, all of them queuing at rush hour along the rural roads surrounding Codicote as the new residents drive to work elsewhere. So together, home energy consumption and transport, will contribute to Climate Change. And what these developments will be replacing is rural land which currently serves as a habitat for wildlife.

Conclusion
In summary, the NPPF explicitly states that the Green Belt can only be developed in very exceptional circumstances, and as CPRE has pointed out NHDC has not demonstrated any such exceptional circumstances, and general housing need categorically does not constitute an exceptional circumstance. In this regard I would like to quote from the letter of the Chief Planner to all Planning Authorities in 2015. Here he says:
The National Planning Policy Framework makes clear that most development in the Green Belt is inappropriate and should be approved only in very special circumstances. Consistent with this... unmet need are unlikely to clearly outweigh harm to the Green Belt... so as to establish very special circumstances. (Letter from Steve Quartmain CBE of 31 August 2015)
Moreover, when the Council considers its own Local Plan, it is clear that the development proposed for Codicote does not 'maintain or enhance' but rather is of a place changing scale and should not be permitted. It is also wholly unsustainable, from the perspective of socially dividing the community rather than bringing people together, increasing the congestion on lanes not designed for 'rush hour' traffic, increasing green house gas emissions, threatening already overstretched water supplies, and replacing wildlife habitats at a time when the State of Nature report published recently tells us how much of our rural wildlife is declining. In every respect, therefore, the proposal to expand Codicote should not be permitted.
Thank you for considering the evidence I presented in this letter.

I am writing to you in connection with the District Council's consultation on its Local Plan, and particularly in relation to the proposed expansion of Codicote. I strongly object to the proposal to allow the construction of over 300 houses in the Green Belt surrounding Codicote. I shall explain my reasoning beginning with reference to the National Planning Policy Framework (NPPF). I shall also demonstrate that the proposal is inconsistent with North Hertfordshire District Council (NHDC's) own policies.

Driving a coach & horses through the principles outlined in the NPPF
The proposals for building houses in the areas CD1 - 5 run contrary to the principles enshrined in the NPPF, as follows:

Par. 79
'The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.'

Par. 87
'As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.'

Comment: Building in the Green Belt is only allowable under very special circumstances, and NHDC has simply not demonstrated this is the case. Here I would like to refer to CPRE's submission of 23rd November 2016, and there is little purpose in my repeating what CPRE has said. However, it is worth emphasising that case law has demonstrated that general housing need does not constitute an exceptional circumstance, as were it to do so then in effect the Green Belt would be afforded no protection. This argument is made very clearly by CPRE and I would like to endorse everything they say concerning the fact that NHDC has failed to demonstrate the case for exceptional circumstances justifying the release of the Green Belt for development around Codicote.

Par. 109
'The planning system should contribute to and enhance the natural and local environment by:

* protecting and enhancing valued landscapes,...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..'

Comment: This proposal can only harm biodiversity, resulting in the local extinctions of farmland dependent species.

Par. 113
'Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife... or landscape areas will be judged... commensurate with their status.. [giving] appropriate weight to their importance and the contribution that they make to wider ecological networks.'

Comment: Where has the Council established a policy that states that new developments are acceptable in the context of eliminating populations of fauna that rely on farmland?

Incompatibilities with NHDC's District Local Plan with Alterations (1996)
The proposal to expand Codicote by nearly 25 per cent is not supported by the Council's Local Plan:

Policy 3
Settlements within the Green Belt
Comment: This policy states that development may only be considered for strict agricultural need, the service needs of the settlement within which the development is proposed, a single dwelling not resulting in outward expansion, or an identified rural housing need which meets the criteria of Policy 29. Policy 29 refers to a 'specific and proven local need,' which would not be available on the 'general housing market,' visually sympathetic to the existing character of, in this case Codicote, not detracting from the 'character' or local 'landscape,' all of which would be 'secured in a legal agreement.' In short, neither Policy 3 nor Policy 29 permits development of the nature envisaged for Codicote in NHDC's Local Plan.

Policy 5
Excluded Villages
Comment: This policy states that the Council may permit development in Codicote 'only if the development is compatible with the maintenance and enhancement of village character [my emphasis] and the maintenance of Green Belt boundaries... Clearly increasing a settlement by some 25 per cent cannot by any definition 'maintain and enhance' village character - what this development does is begin the inexorable transformation of our village into a small town. How can the following inevitable consequences of this expansion maintain or enhance Codicote as a village, but to the contrary it will degrade village life in a number of respects:

* there is insufficient capacity in the local primary school for more pupils and as it is secondary school pupils have to travel on overcrowded buses to neighbouring towns like Welwyn Garden City on congested roads;
* Codicote does not have a GP's surgery and the local surgery at Bridge Cottage is already at overcapacity;
* Codicote's High Street is already overfull with limited parking, with cars often obstructing the pavement - this situation can only worsen with more housing;
* Affinity Water will not (rightly in my view) allow any more abstraction from the Mimram. How, therefore, is the demand for more water going to be met? There are already constraints on the infrastructure for waste water;
* There are currently frequent short power cuts in Codicote - how can this improve with more demand for electricity unless power cables are to be strengthened.

Expanding Codicote by 25 per cent is unsustainable
The NPPF makes clear the Government's support for sustainable development but the NPPF also incorporates the Brundtland understanding of what sustainability entails, namely that it must have economic, social and environmental protection at its heart. The proposal in the Local Plan fails on all three criteria. That is, there will be few economic benefits to the village with this development (in terms of long term employment - as almost all the new householders will work elsewhere), when there is already pressure on schools, health facilities and other infrastructure the development can only create tensions rather than improved community cohesiveness, and finally environmentally it can only be very harmful. The new houses - assuming they will not be zero carbon homes - will produce green house gases and 315 new houses will result in approximately 550 additional cars, all of them queuing at rush hour along the rural roads surrounding Codicote as the new residents drive to work elsewhere. So together, home energy consumption and transport, will contribute to Climate Change. And what these developments will be replacing is rural land which currently serves as a habitat for wildlife.

Conclusion
In summary, the NPPF explicitly states that the Green Belt can only be developed in very exceptional circumstances, and as CPRE has pointed out NHDC has not demonstrated any such exceptional circumstances, and general housing need categorically does not constitute an exceptional circumstance. In this regard I would like to quote from the letter of the Chief Planner to all Planning Authorities in 2015. Here he says:
The National Planning Policy Framework makes clear that most development in the Green Belt is inappropriate and should be approved only in very special circumstances. Consistent with this... unmet need are unlikely to clearly outweigh harm to the Green Belt... so as to establish very special circumstances. (Letter from Steve Quartmain CBE of 31 August 2015)
Moreover, when the Council considers its own Local Plan, it is clear that the development proposed for Codicote does not 'maintain or enhance' but rather is of a place changing scale and should not be permitted. It is also wholly unsustainable, from the perspective of socially dividing the community rather than bringing people together, increasing the congestion on lanes not designed for 'rush hour' traffic, increasing green house gas emissions, threatening already overstretched water supplies, and replacing wildlife habitats at a time when the State of Nature report published recently tells us how much of our rural wildlife is declining. In every respect, therefore, the proposal to expand Codicote should not be permitted.
Thank you for considering the evidence I presented in this letter.

I am writing to you in connection with the District Council's consultation on its Local Plan, and particularly in relation to the proposed expansion of Codicote. I strongly object to the proposal to allow the construction of over 300 houses in the Green Belt surrounding Codicote. I shall explain my reasoning beginning with reference to the National Planning Policy Framework (NPPF). I shall also demonstrate that the proposal is inconsistent with North Hertfordshire District Council (NHDC's) own policies.

Driving a coach & horses through the principles outlined in the NPPF
The proposals for building houses in the areas CD1 - 5 run contrary to the principles enshrined in the NPPF, as follows:

Par. 79
'The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.'

Par. 87
'As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.'

Comment: Building in the Green Belt is only allowable under very special circumstances, and NHDC has simply not demonstrated this is the case. Here I would like to refer to CPRE's submission of 23rd November 2016, and there is little purpose in my repeating what CPRE has said. However, it is worth emphasising that case law has demonstrated that general housing need does not constitute an exceptional circumstance, as were it to do so then in effect the Green Belt would be afforded no protection. This argument is made very clearly by CPRE and I would like to endorse everything they say concerning the fact that NHDC has failed to demonstrate the case for exceptional circumstances justifying the release of the Green Belt for development around Codicote.

Par. 109
'The planning system should contribute to and enhance the natural and local environment by:

* protecting and enhancing valued landscapes,...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..'

Comment: This proposal can only harm biodiversity, resulting in the local extinctions of farmland dependent species.

Par. 113
'Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife... or landscape areas will be judged... commensurate with their status.. [giving] appropriate weight to their importance and the contribution that they make to wider ecological networks.'

Comment: Where has the Council established a policy that states that new developments are acceptable in the context of eliminating populations of fauna that rely on farmland?

Incompatibilities with NHDC's District Local Plan with Alterations (1996)
The proposal to expand Codicote by nearly 25 per cent is not supported by the Council's Local Plan:

Policy 3
Settlements within the Green Belt
Comment: This policy states that development may only be considered for strict agricultural need, the service needs of the settlement within which the development is proposed, a single dwelling not resulting in outward expansion, or an identified rural housing need which meets the criteria of Policy 29. Policy 29 refers to a 'specific and proven local need,' which would not be available on the 'general housing market,' visually sympathetic to the existing character of, in this case Codicote, not detracting from the 'character' or local 'landscape,' all of which would be 'secured in a legal agreement.' In short, neither Policy 3 nor Policy 29 permits development of the nature envisaged for Codicote in NHDC's Local Plan.

Policy 5
Excluded Villages
Comment: This policy states that the Council may permit development in Codicote 'only if the development is compatible with the maintenance and enhancement of village character [my emphasis] and the maintenance of Green Belt boundaries... Clearly increasing a settlement by some 25 per cent cannot by any definition 'maintain and enhance' village character - what this development does is begin the inexorable transformation of our village into a small town. How can the following inevitable consequences of this expansion maintain or enhance Codicote as a village, but to the contrary it will degrade village life in a number of respects:

* there is insufficient capacity in the local primary school for more pupils and as it is secondary school pupils have to travel on overcrowded buses to neighbouring towns like Welwyn Garden City on congested roads;
* Codicote does not have a GP's surgery and the local surgery at Bridge Cottage is already at overcapacity;
* Codicote's High Street is already overfull with limited parking, with cars often obstructing the pavement - this situation can only worsen with more housing;
* Affinity Water will not (rightly in my view) allow any more abstraction from the Mimram. How, therefore, is the demand for more water going to be met? There are already constraints on the infrastructure for waste water;
* There are currently frequent short power cuts in Codicote - how can this improve with more demand for electricity unless power cables are to be strengthened.

Expanding Codicote by 25 per cent is unsustainable
The NPPF makes clear the Government's support for sustainable development but the NPPF also incorporates the Brundtland understanding of what sustainability entails, namely that it must have economic, social and environmental protection at its heart. The proposal in the Local Plan fails on all three criteria. That is, there will be few economic benefits to the village with this development (in terms of long term employment - as almost all the new householders will work elsewhere), when there is already pressure on schools, health facilities and other infrastructure the development can only create tensions rather than improved community cohesiveness, and finally environmentally it can only be very harmful. The new houses - assuming they will not be zero carbon homes - will produce green house gases and 315 new houses will result in approximately 550 additional cars, all of them queuing at rush hour along the rural roads surrounding Codicote as the new residents drive to work elsewhere. So together, home energy consumption and transport, will contribute to Climate Change. And what these developments will be replacing is rural land which currently serves as a habitat for wildlife.

Conclusion
In summary, the NPPF explicitly states that the Green Belt can only be developed in very exceptional circumstances, and as CPRE has pointed out NHDC has not demonstrated any such exceptional circumstances, and general housing need categorically does not constitute an exceptional circumstance. In this regard I would like to quote from the letter of the Chief Planner to all Planning Authorities in 2015. Here he says:
The National Planning Policy Framework makes clear that most development in the Green Belt is inappropriate and should be approved only in very special circumstances. Consistent with this... unmet need are unlikely to clearly outweigh harm to the Green Belt... so as to establish very special circumstances. (Letter from Steve Quartmain CBE of 31 August 2015)
Moreover, when the Council considers its own Local Plan, it is clear that the development proposed for Codicote does not 'maintain or enhance' but rather is of a place changing scale and should not be permitted. It is also wholly unsustainable, from the perspective of socially dividing the community rather than bringing people together, increasing the congestion on lanes not designed for 'rush hour' traffic, increasing green house gas emissions, threatening already overstretched water supplies, and replacing wildlife habitats at a time when the State of Nature report published recently tells us how much of our rural wildlife is declining. In every respect, therefore, the proposal to expand Codicote should not be permitted.
Thank you for considering the evidence I presented in this letter.