Local Plan 2011-2031 Proposed Submission Draft

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Object

Local Plan 2011-2031 Proposed Submission Draft

Policy SP18: Site GA2 - Land off Mendip Way, Great Ashby

Representation ID: 3607

Received: 29/11/2016

Respondent: Mr and Dr R Noble

Number of people: 2

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP18 - GA2:
- Unsustainable development
- Access constraints
- Sensitive natural habitats and biodiversity (SSSI's)
- Air quality, pollution and climate change
- Highway infrastructure and congestion
- Heritage and historic character of the area
- Disrupted water courses and increased flood risk
- Scale of development
- Loss of Green Belt and village boundaries
- Local resources
- Cyclist and pedestrian facilities
- Local infrastructure/service requirements
- Duty to cooperate
- Schooling provision and health services
- Employment and leisure provision
- Removal of greenbelt
- Public transport
- Biodiversity offsetting

Full text:

The current planning proposal of North Herts for 330 homes in GA1, 600 in GA2 and 900 homes in NS1 are irresponsibly placed and not supported at all by local communities. North Herts council have failed in their remit to provide sustainable future build plans. They have also contradicted their own aims (see below). Current plans will:
1. Undermine and disrupt all local access routes
2. Destroy sensitive natural habitats and biodiversity
3. Increase carbon emissions in the area by developing significantly more dwellings away from local train stations, relying on carbon-heavy bus and car traffic. Increases in air pollution east of the A1(M) corridor.
4. Negatively impact the heritage and historic character of the area
5. Disrupt important water courses, negatively impacting water supplies (quality and quantity) and increasing risk of localised flooding
6. Put pressure on the organisation of local councils -close proximity of this "town"-size dwelling site will demand increased and unsustainable interactions across the boundaries of two different council authorities (Stevenage and North Herts)
7. Remove greenbelt and confuse boundaries
8. Fracture local communities and their resources

1. Unsustainable roads/traffic access to the site
Disruptive influence on current local access routes
NS1 site: The Graveley/North Road junction has been underestimated. Altering the junction alone will not improve flow of traffic or access in this region. If traffic is diverted from a significant new development North of Great Ashby towards the B197/North Road, greater traffic will be forced onto an already busy road.
The south section of the B197, North Road is normally a quiet 30mph high street and provides access for local village residents as well as access to the Lister hospital. At quiet times, road users often drive well over the speed limit through the village of Graveley. At peak times, the roads and all junctions become very congested. At peak traffic times (8am-9.30am and 4.30pm-6.30pm), the B197 North Road comes under severe traffic pressure with queues stretching from both junctions 8 and 9 of the A1(M). Only the Hitchin Rd/Lannock Hill access from Weston village or the Little Wymondley Lanes offer relief from these queues.
If road access is increased from the east towards this road - it will become impassable at peak periods. It will also increase pressure on the already-busy A1(M) junction 8 roundabout. If the current North Herts housing plan becomes an extension of Great Ashby, the road towards Graveley is likely to become a rat-run. Conversely, if the road system becomes segregated, access to local amenities will be undermined.

GA1 site: The current plan proposed to the council by Croudace Homes for GA1 cites Mendip Way as a new access point. This small, residential road is permanently double-parked and notorious to local residents for lack of parking and bad access. How can it safely become a major access route!?!?! There is also planned disruption of the secondary route to the large (i.e. >1,000 inhabitants) Weston village and surrounding area, impacting local rural, intellectual, technical and industrial businesses.

2. Destroy sensitive habitats
There are several Sites of Special Scientific Interest within GA1. These include sensitive woodland areas. The Proposal refers to a "protection" of these areas but does not mention any wildlife corridors.

A well-known ecological fact is that 'small island' or isolated habitats are more vulnerable to local extinctions. Development including building of up to 600 homes in this area could not support the current biodiversity in this area and would, without doubt, lead to considerable loss of natural habitats and endangered species.

The current pylon corridor in Great Ashby is named as something to be preserved - what function does this serve, other than reducing the potential danger of pylons and overhead cables from local dwellings? There are no other apparent functions for this corridor as it does NOT fulfil key habitat requirements to sustain local biodiversity. It is clear of vegetation (except grass) for health and safety purposes.
The conservation of the sensitive biodiversity of this site is the greatest fault in building here. There is MUCH to lose in the GA1 site by developing it for housing. GA1 would be most usefully directed towards development of renewable energy.

Willow/Miscanthus plantations in GA1, particularly surrounding the spring zones, would act to cleanse and protect local water systems and drive forward an innovative and sustainable renewables economy for Hertfordshire.

3. Impacts on air pollution and climate change
The North Herts proposal aims to: "ENV3, Mitigate the effects of climate change by encouraging the use of sustainable construction techniques, the appropriate use of renewable energy technologies and reducing the risk of flooding."

By extending the area of Great Ashby, the distance of central Stevenage from the surrounding settlements will increase. This will result in increased car and bus exhaust emissions. Plans should include greater access for cyclists and pedestrians. There is no evidence for any plans to innovate and increase renewables development in this plan.

4. Negatively impact the historic character of the area
Currently, the Croudace planning proposals within the GA1 area outline a plan to further disturb the running of existing, functioning road systems. There has been a lack of reference to historical sites for GA1, GA2 and NS1 - ancient boundaries and the importance of roads to county heritage, as well as efficient access routes. Further, ancient boundaries and routes into villages will be altered similarly. (This contradicts North Herts proposal in ENV2 to: "Protect and enhance the historic character of North Hertfordshire's towns, villages, hamlets and landscape by promoting good design that creates a distinctive sense of place.")

Additionally, a letter by Stephen McPartland defended the NS1 area and refers to E.M. Forster's literature and heritage (also referred to in 4.200 of the proposal). I believe North Herts County Council have over-reached the area that should be allowed to be built on to the deficit of sensitive and heritage countryside. These will be lost forever if this plan is undertaken.

The GA1, GA2 and NS1 plans appear to have lost the sense of cultural heritage for this area, which is in contradiction to the North herts aim to "2.69 promote sustainable growth.....whilst remaining mindful of our cultural and physical heritage". In order to preserve GA1, GA2 and NS1 areas, they should adapt neighbouring villages to increase their communities and allow them to thrive.

5. Disruption of water supply
2.29 in the draft proposal indicates that "North Hertfordshire is identified as an area of water stress".

Ordnance Survey maps indicate a large number of natural springs in the area directly North of Great Ashby (GA1). Building over these would be hugely irresponsible considering point 2.29. It is highly likely to impact downstream water sources/supplies through disruption of the supply or pollution. Additionally this could add to local flooding in the area. Areas further into the valley/lowland parts of the county are likely to provide more predictable sites regarding water supply.

6. Cross-council interaction, access to services and balanced housing provision
The draft proposal states that Great Ashby is to be considered a town, therefore, North Herts District Council is increasing the scale of a settlement that is:

1. Split between two council jurisdictions and resources, and with
2. Existing pressures on resources (e.g. oversubscribed schools).
3. There is also limited access to local services e.g. significant supermarkets, public transport and major employment.

The recent High Court battle to build on North Herts land, west of the A1(M) corridor by Stevenage County Council is evidence that there are already tensions between Stevenage and North Herts District Council. This has already cost the taxpayer thousands of pounds in legal costs. Further development North of Stevenage threatens the same issue.
Further, future developments would all lie along the border to large developments with Stevenage which is likely to cause a conflict and confusion for local residents and risk a loss of identity....do they live in Stevenage or the North Hertfordshire area?

Schooling provision:
Education is currently at an excellent/good level in the North Herts area, in particular Baldock has very good primary/junior schools and secondary school. Current developments North of Baldock and North of Great Ashby would significantly impact these services.
A huge number of North Herts residents in Great Ashby currently send their children to Stevenage secondary schools, therefore the provision and cohesion of future education strategies should be addressed BEFORE further developments are allowed. It is not clear where the children of GA1, GA2 and NS1 areas would go to school from primary to secondary education - would they belong to Stevenage or North Herts administrative areas and education authorities?
Similarly, Stevenage health provision covers much of Great Ashby residents, while many North Herts village residents in the area would use Baldock/Letchworth services. Have the NHS user provisions been properly considered prior to development on this land? Is there a significant risk of this new development undermining current social, health and education services in the area?
Balanced housing provision:
"2.21 At the start of the plan period in 2011, there were approximately 55,000 homes in North Hertfordshire. Almost one-quarter of homes in North Hertfordshire were detached houses. This proportion was slightly higher than both the Hertfordshire county and national figures. Conversely, the proportion of flats (including converted houses) was slightly lower19."
- Stevenage council has recently encouraged development of several large blocks of flats, close to the train station and shopping/administrative centres.
- In contrast, the North Hertfordshire plan focusses on development of further rural/suburban sites.
- North Hertfordshire should demonstrate greater ability to improve the vitality of town centres - employment and leisure provision.
- North Herts should be focussing on greater development of flat/apartment buildings and terraced housing provision within town centres in line with their "target to build 20% of new homes on previously developed land" (point 4.95). This would provide much-needed access for more affordable housing, facilitating first-time buyers and boost the housing economy.
- GA1, GA2 and NS1 are currently rural areas with limited access and are not obvious sites for flats and smaller dwellings due to their remoteness. Such rural planning sites should be focussed across all villages to increase the size of current rural settlements and reduce their isolation from the greater community.
- Future planning sites should be focussed across multiple rural sites e.g. WE1. Expansion of new larger scale sites should be slower, more detailed and have greater access from major trunk roads and public transport links.

7. Removal of greenbelt
The current Green Belt forms a practical function in conserving many sites of special scientific interest and important biodiversity. It also forms a small corridor surrounding all three settlements for leisure. Additionally it provides space for diffusion and access of local traffic to important resources e.g. retail, hospitals and schools. There are businesses thriving in the local area (e.g. local pubs, industrial estates and farms) as a result of the current access to rural settlements.

Over-crowding of these adjacent areas in a non-strategic way will undermine the function of Weston and Graveley as larger satellite settlements around Stevenage for smaller villages and hamlets.

8. Fracture local communities and their resources

Pro-developers, Anti-local plan

North Herts strategic objectives 3.7 include:
ENV1 Direct development towards the most sustainable locations which seek to maintain the existing settlement pattern.

The current GA1, GA2 and NS1 plans appeal primarily to developers - they offer a blank canvas to large, unprotected and hidden areas, away from the public eye.
In a public North Herts planning document available in 2014 - the GA1 site was named as priority three after the sites that would "in-fill" the Stevenage zones adjacent to Saint Nicholas, Lister hospital and Graveley. Would the current plan nullify that statement?
North Herts District Council should be able to demonstrate a complete lack of conflicts of interest or susceptibility to be influenced by other major parties. In particular, North Herts District Council should be able to demonstrate they are not allowing large developers free-access to council plans and consultations outside of public debate. There is a clear trend of rapid, competitive development in the Great Ashby area. The Croudace purchase and development within the proposed GA2 site is direct evidence of the danger of land acquisition set-aside for housing developments - outside of the current permitted plans.
The Great Ashby site was in the original plans as a "successful and thriving community". The reality is that this area is notorious for poor building standards, ill-conceived road access, availability of parking and lack of cohesive community structure. Great Ashby is currently isolated from the rest of Stevenage and the rest of North Hertfordshire by small, limited roads. It is also tightly bound by the parishes of Stevenage, Graveley and Weston.

GA1 and GA2 show a lack of consideration to urban vs. rural function. It will funnel more urban traffic to a rural area. It will undermine the mainly rural economy and increase risk of pollution to the area.
Rural communities dominate in this region and are under-represented in this plan. Rural poverty has been identified as a major issue nationwide. The North Herts District Council could have acted to fight against this by increasing local community housing projects for each village and increased public support for existing communities across the region.
The Weston plan WE1 is an example of one such plan that is not sustainable alongside the huge developments planned North of Great Ashby. Sufficient consideration has clearly not been given to: education provision, policing protections, social care, council services, access to shopping centres, traffic management and public transport services impacted by potential new developments in the area.
In the words of their own proposal, North Herts District Council have acknowledged:
"2.83 Any new development will need to be located in places which have good access to jobs, shops, services and public transport and also provide opportunities to travel by foot or on a bike. Provision of measures for water conservation, improved biodiversity, increasing energy efficiency of new development, and renewable energy can help to ensure that development is more sustainable."

Personally, we have lived in Stevenage, Baldock and now Weston. We believe the combined plans of GA1, GA2 and NS1 will act to isolate Weston village and similar villages from the surrounding areas. We also think that, while adding new accommodation to Baldock could enhance it as a bustling area, more consideration should be given to the risk of traffic increases in the area. Additionally, infrastructure would currently be crushed under the suggested weight of development. We think these plans should be seriously reconsidered with more attention given to realistic access problems and environmental factors e.g. sensitive habitats, water conservation and development of renewables energy sources. The existing GA1, GA2 and NS1 proposals seem to simply achieve a very efficient annexing of another fractured, modern-build community, while wiping out further sensitive ecosystems that will never be recovered.


Additional plea:
4.185 "biodiversity offsetting" - is this an evidence-based method? How does the council plan to significantly conserve current species levels by using areas elsewhere? I don't believe this is an evidence-based or realistically practicable approach. Nature corridors are significantly more important for preservation of existing populations and should be included in every new development.
Please consider the allowance of nature corridors in all new developments. Retaining a continuous stretch of land with significant food sources/habitats to sustain protected/endangered species would enhance the conservation of any threatened ecosystems.
Please employ independent qualified ecologists AND conservationists in the development of this plan.

Object

Local Plan 2011-2031 Proposed Submission Draft

Policy SP16: Site NS1 - North of Stevenage

Representation ID: 3608

Received: 29/11/2016

Respondent: Mr and Dr R Noble

Number of people: 2

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP16 - NS1:
- Unsustainable development
- Access constraints
- Sensitive natural habitats and biodiversity (SSSI's)
- Air quality, pollution and climate change
- Highway infrastructure and congestion
- Heritage and historic character of the area
- Disrupted water courses and increased flood risk
- Scale of development
- Loss of Green Belt and village boundaries
- Local resources
- Cyclist and pedestrian facilities
- Local infrastructure/service requirements
- Duty to cooperate
- Schooling provision and health services
- Employment and leisure provision
- Removal of greenbelt
- Public transport
- Biodiversity offsetting

Full text:

The current planning proposal of North Herts for 330 homes in GA1, 600 in GA2 and 900 homes in NS1 are irresponsibly placed and not supported at all by local communities. North Herts council have failed in their remit to provide sustainable future build plans. They have also contradicted their own aims (see below). Current plans will:
1. Undermine and disrupt all local access routes
2. Destroy sensitive natural habitats and biodiversity
3. Increase carbon emissions in the area by developing significantly more dwellings away from local train stations, relying on carbon-heavy bus and car traffic. Increases in air pollution east of the A1(M) corridor.
4. Negatively impact the heritage and historic character of the area
5. Disrupt important water courses, negatively impacting water supplies (quality and quantity) and increasing risk of localised flooding
6. Put pressure on the organisation of local councils -close proximity of this "town"-size dwelling site will demand increased and unsustainable interactions across the boundaries of two different council authorities (Stevenage and North Herts)
7. Remove greenbelt and confuse boundaries
8. Fracture local communities and their resources

1. Unsustainable roads/traffic access to the site
Disruptive influence on current local access routes
NS1 site: The Graveley/North Road junction has been underestimated. Altering the junction alone will not improve flow of traffic or access in this region. If traffic is diverted from a significant new development North of Great Ashby towards the B197/North Road, greater traffic will be forced onto an already busy road.
The south section of the B197, North Road is normally a quiet 30mph high street and provides access for local village residents as well as access to the Lister hospital. At quiet times, road users often drive well over the speed limit through the village of Graveley. At peak times, the roads and all junctions become very congested. At peak traffic times (8am-9.30am and 4.30pm-6.30pm), the B197 North Road comes under severe traffic pressure with queues stretching from both junctions 8 and 9 of the A1(M). Only the Hitchin Rd/Lannock Hill access from Weston village or the Little Wymondley Lanes offer relief from these queues.
If road access is increased from the east towards this road - it will become impassable at peak periods. It will also increase pressure on the already-busy A1(M) junction 8 roundabout. If the current North Herts housing plan becomes an extension of Great Ashby, the road towards Graveley is likely to become a rat-run. Conversely, if the road system becomes segregated, access to local amenities will be undermined.

GA1 site: The current plan proposed to the council by Croudace Homes for GA1 cites Mendip Way as a new access point. This small, residential road is permanently double-parked and notorious to local residents for lack of parking and bad access. How can it safely become a major access route!?!?! There is also planned disruption of the secondary route to the large (i.e. >1,000 inhabitants) Weston village and surrounding area, impacting local rural, intellectual, technical and industrial businesses.

2. Destroy sensitive habitats
There are several Sites of Special Scientific Interest within GA1. These include sensitive woodland areas. The Proposal refers to a "protection" of these areas but does not mention any wildlife corridors.

A well-known ecological fact is that 'small island' or isolated habitats are more vulnerable to local extinctions. Development including building of up to 600 homes in this area could not support the current biodiversity in this area and would, without doubt, lead to considerable loss of natural habitats and endangered species.

The current pylon corridor in Great Ashby is named as something to be preserved - what function does this serve, other than reducing the potential danger of pylons and overhead cables from local dwellings? There are no other apparent functions for this corridor as it does NOT fulfil key habitat requirements to sustain local biodiversity. It is clear of vegetation (except grass) for health and safety purposes.
The conservation of the sensitive biodiversity of this site is the greatest fault in building here. There is MUCH to lose in the GA1 site by developing it for housing. GA1 would be most usefully directed towards development of renewable energy.

Willow/Miscanthus plantations in GA1, particularly surrounding the spring zones, would act to cleanse and protect local water systems and drive forward an innovative and sustainable renewables economy for Hertfordshire.

3. Impacts on air pollution and climate change
The North Herts proposal aims to: "ENV3, Mitigate the effects of climate change by encouraging the use of sustainable construction techniques, the appropriate use of renewable energy technologies and reducing the risk of flooding."

By extending the area of Great Ashby, the distance of central Stevenage from the surrounding settlements will increase. This will result in increased car and bus exhaust emissions. Plans should include greater access for cyclists and pedestrians. There is no evidence for any plans to innovate and increase renewables development in this plan.

4. Negatively impact the historic character of the area
Currently, the Croudace planning proposals within the GA1 area outline a plan to further disturb the running of existing, functioning road systems. There has been a lack of reference to historical sites for GA1, GA2 and NS1 - ancient boundaries and the importance of roads to county heritage, as well as efficient access routes. Further, ancient boundaries and routes into villages will be altered similarly. (This contradicts North Herts proposal in ENV2 to: "Protect and enhance the historic character of North Hertfordshire's towns, villages, hamlets and landscape by promoting good design that creates a distinctive sense of place.")

Additionally, a letter by Stephen McPartland defended the NS1 area and refers to E.M. Forster's literature and heritage (also referred to in 4.200 of the proposal). I believe North Herts County Council have over-reached the area that should be allowed to be built on to the deficit of sensitive and heritage countryside. These will be lost forever if this plan is undertaken.

The GA1, GA2 and NS1 plans appear to have lost the sense of cultural heritage for this area, which is in contradiction to the North herts aim to "2.69 promote sustainable growth.....whilst remaining mindful of our cultural and physical heritage". In order to preserve GA1, GA2 and NS1 areas, they should adapt neighbouring villages to increase their communities and allow them to thrive.

5. Disruption of water supply
2.29 in the draft proposal indicates that "North Hertfordshire is identified as an area of water stress".

Ordnance Survey maps indicate a large number of natural springs in the area directly North of Great Ashby (GA1). Building over these would be hugely irresponsible considering point 2.29. It is highly likely to impact downstream water sources/supplies through disruption of the supply or pollution. Additionally this could add to local flooding in the area. Areas further into the valley/lowland parts of the county are likely to provide more predictable sites regarding water supply.

6. Cross-council interaction, access to services and balanced housing provision
The draft proposal states that Great Ashby is to be considered a town, therefore, North Herts District Council is increasing the scale of a settlement that is:

1. Split between two council jurisdictions and resources, and with
2. Existing pressures on resources (e.g. oversubscribed schools).
3. There is also limited access to local services e.g. significant supermarkets, public transport and major employment.

The recent High Court battle to build on North Herts land, west of the A1(M) corridor by Stevenage County Council is evidence that there are already tensions between Stevenage and North Herts District Council. This has already cost the taxpayer thousands of pounds in legal costs. Further development North of Stevenage threatens the same issue.
Further, future developments would all lie along the border to large developments with Stevenage which is likely to cause a conflict and confusion for local residents and risk a loss of identity....do they live in Stevenage or the North Hertfordshire area?

Schooling provision:
Education is currently at an excellent/good level in the North Herts area, in particular Baldock has very good primary/junior schools and secondary school. Current developments North of Baldock and North of Great Ashby would significantly impact these services.
A huge number of North Herts residents in Great Ashby currently send their children to Stevenage secondary schools, therefore the provision and cohesion of future education strategies should be addressed BEFORE further developments are allowed. It is not clear where the children of GA1, GA2 and NS1 areas would go to school from primary to secondary education - would they belong to Stevenage or North Herts administrative areas and education authorities?
Similarly, Stevenage health provision covers much of Great Ashby residents, while many North Herts village residents in the area would use Baldock/Letchworth services. Have the NHS user provisions been properly considered prior to development on this land? Is there a significant risk of this new development undermining current social, health and education services in the area?
Balanced housing provision:
"2.21 At the start of the plan period in 2011, there were approximately 55,000 homes in North Hertfordshire. Almost one-quarter of homes in North Hertfordshire were detached houses. This proportion was slightly higher than both the Hertfordshire county and national figures. Conversely, the proportion of flats (including converted houses) was slightly lower19."
- Stevenage council has recently encouraged development of several large blocks of flats, close to the train station and shopping/administrative centres.
- In contrast, the North Hertfordshire plan focusses on development of further rural/suburban sites.
- North Hertfordshire should demonstrate greater ability to improve the vitality of town centres - employment and leisure provision.
- North Herts should be focussing on greater development of flat/apartment buildings and terraced housing provision within town centres in line with their "target to build 20% of new homes on previously developed land" (point 4.95). This would provide much-needed access for more affordable housing, facilitating first-time buyers and boost the housing economy.
- GA1, GA2 and NS1 are currently rural areas with limited access and are not obvious sites for flats and smaller dwellings due to their remoteness. Such rural planning sites should be focussed across all villages to increase the size of current rural settlements and reduce their isolation from the greater community.
- Future planning sites should be focussed across multiple rural sites e.g. WE1. Expansion of new larger scale sites should be slower, more detailed and have greater access from major trunk roads and public transport links.

7. Removal of greenbelt
The current Green Belt forms a practical function in conserving many sites of special scientific interest and important biodiversity. It also forms a small corridor surrounding all three settlements for leisure. Additionally it provides space for diffusion and access of local traffic to important resources e.g. retail, hospitals and schools. There are businesses thriving in the local area (e.g. local pubs, industrial estates and farms) as a result of the current access to rural settlements.

Over-crowding of these adjacent areas in a non-strategic way will undermine the function of Weston and Graveley as larger satellite settlements around Stevenage for smaller villages and hamlets.

8. Fracture local communities and their resources

Pro-developers, Anti-local plan

North Herts strategic objectives 3.7 include:
ENV1 Direct development towards the most sustainable locations which seek to maintain the existing settlement pattern.

The current GA1, GA2 and NS1 plans appeal primarily to developers - they offer a blank canvas to large, unprotected and hidden areas, away from the public eye.
In a public North Herts planning document available in 2014 - the GA1 site was named as priority three after the sites that would "in-fill" the Stevenage zones adjacent to Saint Nicholas, Lister hospital and Graveley. Would the current plan nullify that statement?
North Herts District Council should be able to demonstrate a complete lack of conflicts of interest or susceptibility to be influenced by other major parties. In particular, North Herts District Council should be able to demonstrate they are not allowing large developers free-access to council plans and consultations outside of public debate. There is a clear trend of rapid, competitive development in the Great Ashby area. The Croudace purchase and development within the proposed GA2 site is direct evidence of the danger of land acquisition set-aside for housing developments - outside of the current permitted plans.
The Great Ashby site was in the original plans as a "successful and thriving community". The reality is that this area is notorious for poor building standards, ill-conceived road access, availability of parking and lack of cohesive community structure. Great Ashby is currently isolated from the rest of Stevenage and the rest of North Hertfordshire by small, limited roads. It is also tightly bound by the parishes of Stevenage, Graveley and Weston.

GA1 and GA2 show a lack of consideration to urban vs. rural function. It will funnel more urban traffic to a rural area. It will undermine the mainly rural economy and increase risk of pollution to the area.
Rural communities dominate in this region and are under-represented in this plan. Rural poverty has been identified as a major issue nationwide. The North Herts District Council could have acted to fight against this by increasing local community housing projects for each village and increased public support for existing communities across the region.
The Weston plan WE1 is an example of one such plan that is not sustainable alongside the huge developments planned North of Great Ashby. Sufficient consideration has clearly not been given to: education provision, policing protections, social care, council services, access to shopping centres, traffic management and public transport services impacted by potential new developments in the area.
In the words of their own proposal, North Herts District Council have acknowledged:
"2.83 Any new development will need to be located in places which have good access to jobs, shops, services and public transport and also provide opportunities to travel by foot or on a bike. Provision of measures for water conservation, improved biodiversity, increasing energy efficiency of new development, and renewable energy can help to ensure that development is more sustainable."

Personally, we have lived in Stevenage, Baldock and now Weston. We believe the combined plans of GA1, GA2 and NS1 will act to isolate Weston village and similar villages from the surrounding areas. We also think that, while adding new accommodation to Baldock could enhance it as a bustling area, more consideration should be given to the risk of traffic increases in the area. Additionally, infrastructure would currently be crushed under the suggested weight of development. We think these plans should be seriously reconsidered with more attention given to realistic access problems and environmental factors e.g. sensitive habitats, water conservation and development of renewables energy sources. The existing GA1, GA2 and NS1 proposals seem to simply achieve a very efficient annexing of another fractured, modern-build community, while wiping out further sensitive ecosystems that will never be recovered.


Additional plea:
4.185 "biodiversity offsetting" - is this an evidence-based method? How does the council plan to significantly conserve current species levels by using areas elsewhere? I don't believe this is an evidence-based or realistically practicable approach. Nature corridors are significantly more important for preservation of existing populations and should be included in every new development.
Please consider the allowance of nature corridors in all new developments. Retaining a continuous stretch of land with significant food sources/habitats to sustain protected/endangered species would enhance the conservation of any threatened ecosystems.
Please employ independent qualified ecologists AND conservationists in the development of this plan.

Object

Local Plan 2011-2031 Proposed Submission Draft

GA1 Land at Roundwood (Graveley parish)

Representation ID: 3609

Received: 29/11/2016

Respondent: Mr and Dr R Noble

Number of people: 2

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to GA1:
- Unsustainable development
- Access constraints
- Sensitive natural habitats and biodiversity (SSSI's)
- Air quality, pollution and climate change
- Highway infrastructure and congestion
- Heritage and historic character of the area
- Disrupted water courses and increased flood risk
- Scale of development
- Loss of Green Belt and village boundaries
- Local resources
- Cyclist and pedestrian facilities
- Local infrastructure/service requirements
- Duty to cooperate
- Schooling provision and health services
- Employment and leisure provision
- Removal of greenbelt
- Public transport
- Biodiversity offsetting

Full text:

The current planning proposal of North Herts for 330 homes in GA1, 600 in GA2 and 900 homes in NS1 are irresponsibly placed and not supported at all by local communities. North Herts council have failed in their remit to provide sustainable future build plans. They have also contradicted their own aims (see below). Current plans will:
1. Undermine and disrupt all local access routes
2. Destroy sensitive natural habitats and biodiversity
3. Increase carbon emissions in the area by developing significantly more dwellings away from local train stations, relying on carbon-heavy bus and car traffic. Increases in air pollution east of the A1(M) corridor.
4. Negatively impact the heritage and historic character of the area
5. Disrupt important water courses, negatively impacting water supplies (quality and quantity) and increasing risk of localised flooding
6. Put pressure on the organisation of local councils -close proximity of this "town"-size dwelling site will demand increased and unsustainable interactions across the boundaries of two different council authorities (Stevenage and North Herts)
7. Remove greenbelt and confuse boundaries
8. Fracture local communities and their resources

1. Unsustainable roads/traffic access to the site
Disruptive influence on current local access routes
NS1 site: The Graveley/North Road junction has been underestimated. Altering the junction alone will not improve flow of traffic or access in this region. If traffic is diverted from a significant new development North of Great Ashby towards the B197/North Road, greater traffic will be forced onto an already busy road.
The south section of the B197, North Road is normally a quiet 30mph high street and provides access for local village residents as well as access to the Lister hospital. At quiet times, road users often drive well over the speed limit through the village of Graveley. At peak times, the roads and all junctions become very congested. At peak traffic times (8am-9.30am and 4.30pm-6.30pm), the B197 North Road comes under severe traffic pressure with queues stretching from both junctions 8 and 9 of the A1(M). Only the Hitchin Rd/Lannock Hill access from Weston village or the Little Wymondley Lanes offer relief from these queues.
If road access is increased from the east towards this road - it will become impassable at peak periods. It will also increase pressure on the already-busy A1(M) junction 8 roundabout. If the current North Herts housing plan becomes an extension of Great Ashby, the road towards Graveley is likely to become a rat-run. Conversely, if the road system becomes segregated, access to local amenities will be undermined.

GA1 site: The current plan proposed to the council by Croudace Homes for GA1 cites Mendip Way as a new access point. This small, residential road is permanently double-parked and notorious to local residents for lack of parking and bad access. How can it safely become a major access route!?!?! There is also planned disruption of the secondary route to the large (i.e. >1,000 inhabitants) Weston village and surrounding area, impacting local rural, intellectual, technical and industrial businesses.

2. Destroy sensitive habitats
There are several Sites of Special Scientific Interest within GA1. These include sensitive woodland areas. The Proposal refers to a "protection" of these areas but does not mention any wildlife corridors.

A well-known ecological fact is that 'small island' or isolated habitats are more vulnerable to local extinctions. Development including building of up to 600 homes in this area could not support the current biodiversity in this area and would, without doubt, lead to considerable loss of natural habitats and endangered species.

The current pylon corridor in Great Ashby is named as something to be preserved - what function does this serve, other than reducing the potential danger of pylons and overhead cables from local dwellings? There are no other apparent functions for this corridor as it does NOT fulfil key habitat requirements to sustain local biodiversity. It is clear of vegetation (except grass) for health and safety purposes.
The conservation of the sensitive biodiversity of this site is the greatest fault in building here. There is MUCH to lose in the GA1 site by developing it for housing. GA1 would be most usefully directed towards development of renewable energy.

Willow/Miscanthus plantations in GA1, particularly surrounding the spring zones, would act to cleanse and protect local water systems and drive forward an innovative and sustainable renewables economy for Hertfordshire.

3. Impacts on air pollution and climate change
The North Herts proposal aims to: "ENV3, Mitigate the effects of climate change by encouraging the use of sustainable construction techniques, the appropriate use of renewable energy technologies and reducing the risk of flooding."

By extending the area of Great Ashby, the distance of central Stevenage from the surrounding settlements will increase. This will result in increased car and bus exhaust emissions. Plans should include greater access for cyclists and pedestrians. There is no evidence for any plans to innovate and increase renewables development in this plan.

4. Negatively impact the historic character of the area
Currently, the Croudace planning proposals within the GA1 area outline a plan to further disturb the running of existing, functioning road systems. There has been a lack of reference to historical sites for GA1, GA2 and NS1 - ancient boundaries and the importance of roads to county heritage, as well as efficient access routes. Further, ancient boundaries and routes into villages will be altered similarly. (This contradicts North Herts proposal in ENV2 to: "Protect and enhance the historic character of North Hertfordshire's towns, villages, hamlets and landscape by promoting good design that creates a distinctive sense of place.")

Additionally, a letter by Stephen McPartland defended the NS1 area and refers to E.M. Forster's literature and heritage (also referred to in 4.200 of the proposal). I believe North Herts County Council have over-reached the area that should be allowed to be built on to the deficit of sensitive and heritage countryside. These will be lost forever if this plan is undertaken.

The GA1, GA2 and NS1 plans appear to have lost the sense of cultural heritage for this area, which is in contradiction to the North herts aim to "2.69 promote sustainable growth.....whilst remaining mindful of our cultural and physical heritage". In order to preserve GA1, GA2 and NS1 areas, they should adapt neighbouring villages to increase their communities and allow them to thrive.

5. Disruption of water supply
2.29 in the draft proposal indicates that "North Hertfordshire is identified as an area of water stress".

Ordnance Survey maps indicate a large number of natural springs in the area directly North of Great Ashby (GA1). Building over these would be hugely irresponsible considering point 2.29. It is highly likely to impact downstream water sources/supplies through disruption of the supply or pollution. Additionally this could add to local flooding in the area. Areas further into the valley/lowland parts of the county are likely to provide more predictable sites regarding water supply.

6. Cross-council interaction, access to services and balanced housing provision
The draft proposal states that Great Ashby is to be considered a town, therefore, North Herts District Council is increasing the scale of a settlement that is:

1. Split between two council jurisdictions and resources, and with
2. Existing pressures on resources (e.g. oversubscribed schools).
3. There is also limited access to local services e.g. significant supermarkets, public transport and major employment.

The recent High Court battle to build on North Herts land, west of the A1(M) corridor by Stevenage County Council is evidence that there are already tensions between Stevenage and North Herts District Council. This has already cost the taxpayer thousands of pounds in legal costs. Further development North of Stevenage threatens the same issue.
Further, future developments would all lie along the border to large developments with Stevenage which is likely to cause a conflict and confusion for local residents and risk a loss of identity....do they live in Stevenage or the North Hertfordshire area?

Schooling provision:
Education is currently at an excellent/good level in the North Herts area, in particular Baldock has very good primary/junior schools and secondary school. Current developments North of Baldock and North of Great Ashby would significantly impact these services.
A huge number of North Herts residents in Great Ashby currently send their children to Stevenage secondary schools, therefore the provision and cohesion of future education strategies should be addressed BEFORE further developments are allowed. It is not clear where the children of GA1, GA2 and NS1 areas would go to school from primary to secondary education - would they belong to Stevenage or North Herts administrative areas and education authorities?
Similarly, Stevenage health provision covers much of Great Ashby residents, while many North Herts village residents in the area would use Baldock/Letchworth services. Have the NHS user provisions been properly considered prior to development on this land? Is there a significant risk of this new development undermining current social, health and education services in the area?
Balanced housing provision:
"2.21 At the start of the plan period in 2011, there were approximately 55,000 homes in North Hertfordshire. Almost one-quarter of homes in North Hertfordshire were detached houses. This proportion was slightly higher than both the Hertfordshire county and national figures. Conversely, the proportion of flats (including converted houses) was slightly lower19."
- Stevenage council has recently encouraged development of several large blocks of flats, close to the train station and shopping/administrative centres.
- In contrast, the North Hertfordshire plan focusses on development of further rural/suburban sites.
- North Hertfordshire should demonstrate greater ability to improve the vitality of town centres - employment and leisure provision.
- North Herts should be focussing on greater development of flat/apartment buildings and terraced housing provision within town centres in line with their "target to build 20% of new homes on previously developed land" (point 4.95). This would provide much-needed access for more affordable housing, facilitating first-time buyers and boost the housing economy.
- GA1, GA2 and NS1 are currently rural areas with limited access and are not obvious sites for flats and smaller dwellings due to their remoteness. Such rural planning sites should be focussed across all villages to increase the size of current rural settlements and reduce their isolation from the greater community.
- Future planning sites should be focussed across multiple rural sites e.g. WE1. Expansion of new larger scale sites should be slower, more detailed and have greater access from major trunk roads and public transport links.

7. Removal of greenbelt
The current Green Belt forms a practical function in conserving many sites of special scientific interest and important biodiversity. It also forms a small corridor surrounding all three settlements for leisure. Additionally it provides space for diffusion and access of local traffic to important resources e.g. retail, hospitals and schools. There are businesses thriving in the local area (e.g. local pubs, industrial estates and farms) as a result of the current access to rural settlements.

Over-crowding of these adjacent areas in a non-strategic way will undermine the function of Weston and Graveley as larger satellite settlements around Stevenage for smaller villages and hamlets.

8. Fracture local communities and their resources

Pro-developers, Anti-local plan

North Herts strategic objectives 3.7 include:
ENV1 Direct development towards the most sustainable locations which seek to maintain the existing settlement pattern.

The current GA1, GA2 and NS1 plans appeal primarily to developers - they offer a blank canvas to large, unprotected and hidden areas, away from the public eye.
In a public North Herts planning document available in 2014 - the GA1 site was named as priority three after the sites that would "in-fill" the Stevenage zones adjacent to Saint Nicholas, Lister hospital and Graveley. Would the current plan nullify that statement?
North Herts District Council should be able to demonstrate a complete lack of conflicts of interest or susceptibility to be influenced by other major parties. In particular, North Herts District Council should be able to demonstrate they are not allowing large developers free-access to council plans and consultations outside of public debate. There is a clear trend of rapid, competitive development in the Great Ashby area. The Croudace purchase and development within the proposed GA2 site is direct evidence of the danger of land acquisition set-aside for housing developments - outside of the current permitted plans.
The Great Ashby site was in the original plans as a "successful and thriving community". The reality is that this area is notorious for poor building standards, ill-conceived road access, availability of parking and lack of cohesive community structure. Great Ashby is currently isolated from the rest of Stevenage and the rest of North Hertfordshire by small, limited roads. It is also tightly bound by the parishes of Stevenage, Graveley and Weston.

GA1 and GA2 show a lack of consideration to urban vs. rural function. It will funnel more urban traffic to a rural area. It will undermine the mainly rural economy and increase risk of pollution to the area.
Rural communities dominate in this region and are under-represented in this plan. Rural poverty has been identified as a major issue nationwide. The North Herts District Council could have acted to fight against this by increasing local community housing projects for each village and increased public support for existing communities across the region.
The Weston plan WE1 is an example of one such plan that is not sustainable alongside the huge developments planned North of Great Ashby. Sufficient consideration has clearly not been given to: education provision, policing protections, social care, council services, access to shopping centres, traffic management and public transport services impacted by potential new developments in the area.
In the words of their own proposal, North Herts District Council have acknowledged:
"2.83 Any new development will need to be located in places which have good access to jobs, shops, services and public transport and also provide opportunities to travel by foot or on a bike. Provision of measures for water conservation, improved biodiversity, increasing energy efficiency of new development, and renewable energy can help to ensure that development is more sustainable."

Personally, we have lived in Stevenage, Baldock and now Weston. We believe the combined plans of GA1, GA2 and NS1 will act to isolate Weston village and similar villages from the surrounding areas. We also think that, while adding new accommodation to Baldock could enhance it as a bustling area, more consideration should be given to the risk of traffic increases in the area. Additionally, infrastructure would currently be crushed under the suggested weight of development. We think these plans should be seriously reconsidered with more attention given to realistic access problems and environmental factors e.g. sensitive habitats, water conservation and development of renewables energy sources. The existing GA1, GA2 and NS1 proposals seem to simply achieve a very efficient annexing of another fractured, modern-build community, while wiping out further sensitive ecosystems that will never be recovered.


Additional plea:
4.185 "biodiversity offsetting" - is this an evidence-based method? How does the council plan to significantly conserve current species levels by using areas elsewhere? I don't believe this is an evidence-based or realistically practicable approach. Nature corridors are significantly more important for preservation of existing populations and should be included in every new development.
Please consider the allowance of nature corridors in all new developments. Retaining a continuous stretch of land with significant food sources/habitats to sustain protected/endangered species would enhance the conservation of any threatened ecosystems.
Please employ independent qualified ecologists AND conservationists in the development of this plan.

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