Local Plan 2011-2031 Proposed Submission Draft

DUTY TO CO-OPERATE
I understand that North Hertfordshire District Council (NHDC) did not comply with its duty to co-operate with Stondon Parish Council (SPC), as set out under s20(5)(c) of the Planning and Compulsory Purchase Act 2004 (as amended) (PCPA), regarding the allocation of LS1 in the NHLP 2011-2031.
At their October Parish Council meeting, SPC discussed that they could find no evidence of being approached in any way by NHDC with regard to this proposal and only discovered the proposal for LS1: Land at Bedford Road, through their own research. My comments relate specifically to site LS1: Land at Bedford Road, as detailed on Page 190 - 191 of the draft Local Plan. As NHDC have failed to discharge their duties under the duty to co-operate with SPC and the PCPA establishes that failure to comply with the duty to co-operate cannot be remedied after the Plan has been submitted, in my opinion this makes the draft Local Plan unsound.
Extrapolating this, in my opinion, if a similar approach has been taken regarding not cooperating with other local authorities this would, this would question the entire draft Local Plan's soundness.
LS1: Land at Bedford Road
The draft Local Plan states site LS1 has been allocated for 120 dwellings adjacent to Lower Stondon, a large village in the rural area of Central Bedfordshire. The draft Local Plan does not reference that the entire Northern Boundary of the site is actually joining with the Parish of Henlow.
Best and Most VersatileLand
The sites is shown as Grade 1 quality in the Natural England Agricultural Land Classification. Grades 1 to 3a are defined as the best and most versatile (BMV) land by policy guidance (as per Annex 2 of the National Planning Policy Framework (NPPF)).
Paragraph 112 of the NPPF states 'local authorities should seek to use areas of poorer quality land in preference to that of a higher quality' and paragraph 143 states that 'in preparing Local Plans, local planning authorities should...safeguard the long term potential of best and most versatile agricultural land'. I understand that there are sites of a lower agricultural grade available within the District and those sites should be developed, if required to meet the OAN, in preference to such valuable agricultural land.
Historic Setting
* Development of the site, LS1, will result in substantial harm to the Grade II* Listed building 'Old Ramerick Manor'.
* NHDC have not undertaken a heritage assessment of the Grade II* building and its setting and the impact that a 120 dwelling housing development would have upon its character and particular importance.


Defendable Boundary and Flooding
* Development of this site will breach the current defendable Eastern boundary of the Parish of Stondon and will breach the current defendable southern boundary of the development of Henlow Camp.
* Running west to east along the Northern Boundary of LS1 together with its associated trees, hedging and green space is a tributary of the River Ivel/Hiz/Purwell. This provides a defensible southern boundary to the existing built environment and screens views of the urban area from open countryside when approaching from the south.
* Due to the ordinary watercourse, there is significant flooding across the northern area of the site, including Flood Zone 3b - Functional Floodplain (Appendix G - Land at Ramerick, NHDC SFRA update 2016). Residential development should not be located in an area of FZ3b and as such there will be a significant area disconnecting the allocated site from the rest of Henlow Camp, making the site more isolated and unsustainable from the existing settlement.
* In addition, there is significant surface water flooding associated with the same northern extent of the site (Appendix G (surface water) - Lower Stondon, NHDC SFRA update 2016). To ensure it does not cause a flood risk to anyone further downstream, the site will have to achieve greenfield runoff rates, it is not clear if this would be possible on this site. Regardless, significant surface water flooding on site increases the isolation of the whole site from Lower Stondon and Henlow Camp and results in the unsustainability of the site as a residential development.
Infrastructure
* The site does not support sustainable development. There is very little employment locally, so development at this site will result in an increase in more unsustainable transportation in the form of car-commuting, even if it is only to get to the nearest railway station; buses are limited in frequency. While the plan does mention a traffic impact towards the South (Hitchin) it ignores impact to the North (Arlesey Rail Station is closer than Hitchin, quicker to access and has cheaper parking), which would result in more traffic through Lower Stondon/Henlow Camp Village. I understand the roundabout between the B659 and A507 which is used to access the station is reported by recent developer led traffic studies to be already "at capacity in peak periods".
* The local of the site will result for increased use of facilities and resources in the Stondon (and Henlow) Parish areas. Many of these are already at capacity, for example the local doctors surgery where a non-emergency appointment can require wait of more than a week.
* There is no amenity provision on site, for example a local shop. It is worth noting that the Household survey results reported by the NLP in the North Hertfordshire Retail Study Update 2016, remarks the nearest shopping centre is in Hitchin, implying that residents will travel some 4 miles to purchase convenience goods.
* There is not comment of the impact of the development on doctors surgeries and school places that would be required. NHDC would receive any CIL or S106 monies, it would not be Central Bedfordshire Council, Stondon Parish Council & Henlow Parish Council which would be required to support the development. Paragraph 13.245 of the draft Local Plan itself acknowledges that 'development of this site will tie in to the urban area of Lower Stondon and parents may express a preference for their children to go to school within the village'; i understand these schools are already full.
* The site proposes no defensible southern boundary which leads me to conclude that development of LS1 will encourage further development southwards into open countryside, which NHDC will continue to rely upon CBC, SPC & HPC to support through amenity provision.
* It appears the site appears has been selected as it does impact on North Hertfordshire. This would not create a sense of community for the site which will be a satellite 'state' of NHDC on a far away border. The site will also be remote from Stondon and Henlow Camp as they can only be accessed via the busy A600, increasing travel by car.