Local Plan 2011-2031 Proposed Submission Draft

I do not agree with the categorisation of Whitwell as a category A village where development is permitted within the village boundary when part of this plan is extending the village boundary to make it bigger to enable development of greater than 10% of the current housing numbers. Whitwell could facilitate some infill growth. Extending the village boundary to enable growth in a particularly landscape and flood sensitive area is not sustainable growth for the village, nor is it necessary to meet the small scale growth that the village can support within existing boundaries.

There is no reference for the need for the ST to be applied to surface water flood risk or to groundwater flood risk as defined in the NPPF.

Needs to include reference to a long term management and maintenance plan to ensure SuDS are managed appropriately.

No reference to protecting groundwater quality in the chalk aquifer, or abstraction points, or chalk river headwaters.

This site has not been adequately assessed. The risk of flooding is highlighted in the Herts county council section 19 report from the actual flood event in 2014. This site was added late to the SFRA and not properly consulted on and no evidence of the sequential test seems to be available. Even if the site was to be developed, it may not be possible to develop 41 properties outside the overland flow route. Thames Water have raised serious concerns about the wastewater infrastructure for this site. Upgrades would be required, this was not flagged in the sustainability appraisal for the site. The site is in a source protection zone 1 so particularly vulnerable to uses that could pollute groundwater, including on site storage of sewage and inappropriate SuDS reliant on infiltration without tertiary treatment. The EA have highlighted that groundwater levels beneath the site are likely to be high in winter so infiltration is unlikely to work. Therefore SuDS and any flood mitigation measures proposed that are based on infiltration won't be functional in winter, when groundwater is high, which will lead to an increased risk of flooding to off site properties. Surface water can't be disposed off to sewer or river as they are not available at this site. The site is likely to be impacted by groundwater flooding when the water table is particularly high as it is of the same geology as the dry valley at Kimpton that has a disruptive history of flooding. The site is characteristic of the Chilterns landscape, visible from historic parks and gardens, ancient rights of way and promoted cycle routes and walks promoted as Chilterns explorer routes.
Although well connected to landscape and rights of way, SP2 is not well connected to the village of Whitwell and this development would not be integrated into the village.
Development would not be compliant with proposed policies SP9 on design as not well located or related to local context; SP11 - no sustainable transport options; D1 sustainable design, development proposals based on pumped systems will not lead to long term reduction in energy consumption and it will be difficult to incorporate effective SuDS that don't impact water quality or actually function; NE7 - no evidence the sequential test has been carried out and difficult to justify the exception test in a location where there is no demonstrable need or sustainability. In addition flow routes should be protected from all development, making this site difficult to access. The site provides feeding ground for iconic species including red kites, toads and swifts which are abundant in the area. This is a particularly constrained site.