Local Plan 2011-2031 Proposed Submission Draft

As stated by Rt Hon G Clark MP, Minister for Planning; 'planning should be a collective enterprise'. 'It has tended to exclude people and communities rather than include them' yet, I feel with regards to GA2 proposed plan for 900 homes by NHDC - this seems to still be the case. NHDC have yet again not considered the residents of either North Stevenage or the residents of Great Ashby. I became aware of GA2 because I stumbled across a notification that had been put up at the further point from the beginning of any of the footpaths of the planned area during the first consultation whilst walking my dog. I have followed the process closely and regularly checked for the second consultation. I would like to point out that I have found no evidence this time round of any notices within the actual area, notification within Ashby itself, nor have any leaflets or information been made available to any residents via NHDC. NHDC has a page on their website asking for residents to have their say - but how is this possible, when they are not even notified local residents in the first instance? NPPF 17 states that planning should empower local people to shape their surroundings and I believe NHDC has failed to do this by simply ignoring people's responses during the first consultation. I believe with SP2 there is lack of support for the local plan: contrary to NPPF 150, NHDC's plan does not 'reflect the vision and aspirations of the local community' or NPPF 69 that 'local planning authorities should create a shared vision with communities of the residential environment and facilities they wish to see.'

The Rt Hon G Clark MP also states that planning should be a creative exercise in finding ways to enhance and improve the places in which we live our lives. I would actually question whether NHDC even care about the residents of North Hertfordshire and how their proposed plans are going to have an effect on residents who have lived here for much of their lives. I feel they haven't looked at other viable options, the figures for housing needs that NHDC have provided do not seem in line with projection figures for population for the area and these have been questioned in recent documentation by CPRE. It would also seem that they haven't even taken notice of the thousands of comments/objections they received during the first consultation, and this would most definitely seem the case with regards to GA2 which has actually increased in size encroaching on the many paths and woodlands that local residents use daily/weekly.

I feel that there are a number of other avenues that NHDC have failed to look into and a number of issues have been highlighted;
The housing target produced by NHDC is questionable leading to an unsound strategy, it would seem the proposed development West of Stevenage has not been taken into account with regards to housing needs being met within the area, and I can see no evidence (with regards to removing land from the Green Belt area) of NHDC considering a site by site basis with regards to meeting exceptional circumstances.
Policy SP5, paragraph 'a' I believe to be unsound and not consistent with the NPPF and unjustified.
Wording is based on a fundamental misinterpretation, outlined in paragraph 4.53 of the Plan and the Council's Green Belt Review 2016, of national Planning policy as set out in NPPF paragraphs 83 to 86. Paragraph 83 specifically requires exceptional circumstances to be shown to justify removal of land from the Green Belt by the redrawing of any individual Green Belt boundary. None of the three categories of site listed in SP5, paragraph 'a' satisfy this national policy requirement. This applies to the proposed strategic allocations and development around towns and villages in the Green Belt. Paragraph 4.53 of the Plan fails to meet the requirement as set out in NPPF paragraph 83 to set out exceptional circumstances for changing established Green Belt boundaries in the District. The text currently simply states that 'it is considered that the relevant circumstances do exist within North Hertfordshire to review boundaries and enable development to meet locally identified needs', but such circumstances are not identified either in the plan, and the only 'evidence' referred to is the Council's Green Belt Review 2016 (which does not address the issue of exceptional circumstances).

As noted through court cases with regards to Green Belt and development - if the council's approach were adopted then 'exceptional circumstances' will always be found if a housing need exists in general terms that cannot be met from non Green Belt land, but that would negate the basic protection given to Green Belt land in paragraph 14 of the NPPF and I believe this needs to be taken into account. I would also like to bring to your attention what the Minister of Planning stated in a letter to Members of Parliament on 7 June 2016
"the Government has put in place the strongest protections for the Green Belt. The Framework (the NPPF) makes it clear that inappropriate development may be allowed only where very special circumstances exist, and that Green Belt boundaries should be adjusted only in exceptional circumstances , through the Local Plan process and with the support of local people. We have been repeatedly clear that demand for housing alone will not change Green Belt boundaries."
I would like to make very clear that neither I, nor any of my family and a great many fellow residents do NOT support many of the proposed
plans including GA2 and I do believe that is a clear point in local authorities building on green belt - it has to be an exceptional circumstance
and have the support of the local community, which I believe GA2 does not have. Therefore I find the policy SP18 unsound, not consistent with
the NPPF and not justified and I would like to participate in further processes regarding this.


CPRE advised that there were enough brownfield sites within the UK to build 1.1 -1.4 million homes. I have asked NHDC if they have a register of brownfield sites within North Hertfordshire and I was advised no register or list existed. I am horrified to see that approximately 84% of the proposed development areas are on Green Belt and yet only a very small percentage is on identified brownfield sites. Surely in line with the NPPF (17 & 111); focus should be made on brownfield sites in the first instance and that it is a local authorities role to address this and identify possible sites. It would seem to me that as far as NHDC and developers are concerned - green belt development seems much more lucrative which is maybe why they haven't prioritised by locating and identifying further brown fields sites or old employment areas. With regards to ECT1/2 - given the scale of housing need identified by NHDC and the limited capacity of urban locations that the Council has been able to identify to meet that need, the plan should allow and encourage the use or redevelopment of suitably located employment sites for housing where this does not adversely affect the current owners and occupiers of such sites in line with the NPPF.

It has also been suggested that NHDC should identify a 5 year land supply and then work with other authorities to look at the possibility of a new garden settlement. This has been suggested by local MPs and District Councillors and is backed by a great many residents. This would have many benefits:
- a new infrastructure consisting of roads and access to nearby A roads/motorways, health services; doctors, dentists, primary and secondary schools, possibly a hospital or college
- this would create thousands of jobs within the country for local people
- this would not put extra pressure on currently failing towns such as Stevenage where many business and organisations have moved away or closed down, resulting in redundancies and many office buildings and part of Pin Green industrial estate being turned into housing
- this would not put extra pressure on health services and education already at full capacity and under strain
- this would not encroach on class A villages, losing their character
- it would not increase congestion on already congested roads, such as Great Ashby's Mendip Way which stands at gridlock during the rush hour
- it could be located away from ancient woodland or woodland that is home to a huge diversity of mammals and birds, such as that in the proposed GA2 planned development
- it would not remove more green belt which was put in place to stop urban sprawl, provide a habitat for wildlife and offer benefits, such as health benefits to urban and rural residents/communities - something that NHDC certainly have not taken into account with many of their proposed planning areas and in particular GA2 and that East of Luton, an area of outstanding beauty and one used by hundreds of local residents from within Luton (I do believe the Chilterns Conservation Board looking in to applying for AONB for this area).

With regards to housing needs and figures; I would also like to point out that the figure offered up by NHDC actually includes 63% of people migrating into the area - therefore it is false in that it is not entirely the needs of 'local people' and this should be investigated and reduced accordingly. I therefore find the figures for the local housing needs unjustified and should be reduced if talking about 'local need'. I do feel unfortunately that the government's Housing Bonus Scheme has had some influence with the level of development proposed instead of actually being needed!!!

I do believe that other proposed plans by Stevenage Borough Council should also be taken into consideration. The proposed plan for West of Stevenage would see a number of homes built and surely this should be considered as part of NHDC housing needs? This would surely remove the need for proposed planning areas; GA2, GA1 etc which would increase congestion considerably in the North of Stevenage. With the West - there is a possibility of access to Gunnel's Wood Road and the A1m where as this is not the case with regards to GA1/GA2. I do believe that Hertfordshire Highways already had concerns with regards to access for GA1, Mendip Way is often at gridlock. Should verges be removed as was suggested - this would cause considerable risks to residents as many homes are very close to the actual roads, with possibilities of children being knocked down, wheelchair users having to use the actual road on bin day and not to mention the issues of emergency vehicles having access. The proposal of GA2 would put even more pressure on to the Mendip Way area and this would surely be highly dangerous for residents.

I am aware that a number of local groups have commissioned a company PTB Transport Consultants Ltd to carry out a full transport report and this has highlighted a number of flaws in the report than NHDC had completed by another company. This has to be taken into account for the welfare of the residents and others journeying through Great Ashby and I would like this to be considered by NHDC and the Planning Inspector.

Stevenage is a failing town with many businesses and organisations closing down and moving away forcing redundancies and a decrease in jobs. After the closure of the QEII this has also seen lengthening waiting times for appointments and longer waiting times in A&E. It is difficult to get doctor's appointments and dentist appointments and secondary schools I believe are at full capacity. We simply cannot keep adding more and more homes on to the edge of Stevenage without the infrastructure to back it which is why we desperately need authorities to look at a new garden settlement.

GA2 is a beautiful area and is used by thousands of people every year. We regularly walk the many footpaths and see joggers, other dog walkers, people horse riding and family groups out for a stroll. The abundance of wildlife in this area is next to none. We have badgers, deer, foxes, bats, owls and birds of prey. Homes are important but not the only important thing. The countryside that NHDC want to develop as GA2 is of huge importance to thousands of local residents for relaxation and health benefits. We accepted Great Ashby but now we must make a stand against this. Please do not allow this to go through. How far do you want local people to travel to benefit from the open countryside? What do you propose to do with the local wildlife such as the badgers as this would have a huge impact on them and the biodiversity in the area which is also mentioned in the NPPF in the section re Nature and Conservation.

Houses are needed, but please identify old employment sites and brownfield sites first. Please look into building upwards and not outwards - there are a number of 4/6/8 storey apartment buildings in Ashby and Stevenage that are well designed and highly desirable. Please look at a 5 year plan for local needs and look towards a new garden settlement that will not have so many adverse affects on us who have lived here for many years and in some cases, their whole lives. There are other sites that do not include woodland, wildlife and do not have such social benefits as areas such as GA2 and that, East of Luton, north of the Grange in Letchworth. Sites such as Clothall Common in Baldock, the West of Stevenage and small areas within current town/village boundaries.

I do find many of the policies within the local plan, unsound, unjustified and not in line with the NPPF. I would like to participate in further examinations and processes particularly to do with GA2.

Thank you for your consideration and time in this matter.