Local Plan 2011-2031 Proposed Submission Draft

I object to North Herts District Council's Local Plan 2011 - 2031 on two main counts: first the violation of the Green Belt; second, the specific proposal to build on Green Belt land North of Letchworth (LG1).
NHDC proposes to build large housing estates East of Luton, East of Hitchin, North of Letchworth, North of Stevenage and North of Baldock. It is against Government policy to build on Green belt land unless "very special circumstances" pertain (see attachment 1). Nowhere in the Local Plan are any "very special circumstance" identified. The Green Belt was expressly put into place to curb urban sprawl. The siting of these proposed developments, mostly adjoining already existing estates is typical of the urban sprawl long discredited by town planners for its poor environmental impact and weakening of community and sense of identity. Several hitherto distinct village communities such as Cockernhoe, Gravely and Bygrave will be either absorbed or annexed. The Green belt promotes physical and mental health by providing recreational space. It is vital for biodiversity, especially when 60% of British wild species are in decline. Up to the present, NHDC has a good record of management of the Green belt. In its Biodiversity Action Plan of 2005 it pledged to protect it (see attachment 2). This measure, having had no formal modifications since, is deemed to be still in force. Therefore I question the legality of NHDC's proposed flagrant disregard of it.
My second main objection is specifically to the Green belt site North of Letchworth (LG1). Apart from my objection above to building on the Green belt in general, there are three further objections specific to this site: first, the uniqueness of this site for its archaeology, geology and biodiversity; second, its particular unsuitability owing to the unique heritage of Letchworth Garden City; third the role of the Letchworth Garden City Heritage Foundation in selling the site for development to NHDC.
The site LG1 is ancient cultivated land dating back to medieval times and probably far beyond. Its ditches, banks and hedges are artifacts of early agricultural systems of archeological significance. There are a number of pollarded oak trees estimated to be over four centuries old. These features carry their own biodiversity which has evolved over the same time-span. The richness of biodiversity is also the result of soil diversity, generated by the particular mix of sand, gravel, chalk and boulder clay laid 500,000 years ago in the last glaciations and known to geologists as 'The Letchworth Gravels'. NHDC has played its part too, cutting down the use of agri-chemicals and encouraging wide field margins. 114 bird species have been recorded, 28 of which are endangered, together with Great Crested Newt, Brown Hare, Common Toad, Polecat and 3 rare butterfly species (see attachment 3). There is a House Sparrow roost of over 300 birds, the biggest in the county which is now under consideration for a designation of protected status. There is in increasing currency an idea that land lost to the Green Belt can be balanced by new Green belt designation elsewhere. Quite apart from the fact that there is no spare land in North Herts for such new designation, an eco-system such as that of LG1 cannot be moved as its centuries of evolution has been specific to that site. Therefore I object to the proposed development of site LG1 because it will necessitate the destruction of biodiversity and study opportunity for archaeology and geology.

I object to site LG1 because of the threat it poses to the unique heritage of Letchworth. This heritage is that of the world's first garden city, embodying influential principles of town planning and social welfare. Proximity to the open countryside was one of them, to which end the founding father, Ebenezer Howard, proposed to limit the population to 32,000 (thereby limiting the footprint of the town)(see attachment 4). He further stated nowhere on the urban boundary should be more than 15 minutes walk from the town centre. Such principles have already been infringed but this is no reason to abandon the spirit of them; there is still a heritage to be preserved if tourists and visiting students of town-planning from all over the world are not to be disappointed. Another principle was the town should be self-sustaining, in the sense that the population would work locally, so housing and industry were carefully balanced. Rather than use the opportunity to restore this balance, the Local Plan proposes to upset it further. With the increase in population generated by LG1, plus the change of use from industrial to residential of many of the smaller sites in the town under the Plan, the percentage of residents employed locally will sharply decrease. Letchworth will become predominantly a dormitory town with all the weakening of community that entails. The increase in commuter numbers will cause insuperable problems for road infrastructure as Letchworth's narrow roads were designed for low car use. In a self-sustaining town everybody could walk to work or school. The crucial routes from LG1 into the town centre and station are already bottlenecks: narrow roads lined with grass verges and specimen trees, some rare, which cannot be removed for road widening without completely destroying the distinctive garden city ambience. There is no scope for enlarging the railway station carpark.
I object to site LG1 because of the circumstances of its proposed sale by the owners. The owners, Letchworth Garden City Heritage Foundation, proposes to abdicate its responsibilities to protect and preserve the site. The Foundation was set up by Parliament in 1993 to continue the town's development by the principles espoused by Ebenezer Howard. The Green Belt was integral to the project, deemed essential to the concept of combining the best of both town and country living. As such it was the world's first Green Belt. The sad irony is this proposed sale represents a betrayal of principle by those whom Parliament has charged to be its protector. The sale of the land could be (and should be) open to legal challenge.
Attachments:
1. Extract from Hansard 15.7.16
2.Foreword to NHDC Biodiversity Action Plan 2005
3. Endangered species on LG1
4. Extract from Ebenezer Howard's Garden Cities of To-morrow (Faber and Faber, London, 1902)

I object to North Herts District Council's Local Plan 2011 - 2031 on two main counts: first the violation of the Green Belt; second, the specific proposal to build on Green Belt land North of Letchworth (LG1).
NHDC proposes to build large housing estates East of Luton, East of Hitchin, North of Letchworth, North of Stevenage and North of Baldock. It is against Government policy to build on Green belt land unless "very special circumstances" pertain (see attachment 1). Nowhere in the Local Plan are any "very special circumstance" identified. The Green Belt was expressly put into place to curb urban sprawl. The siting of these proposed developments, mostly adjoining already existing estates is typical of the urban sprawl long discredited by town planners for its poor environmental impact and weakening of community and sense of identity. Several hitherto distinct village communities such as Cockernhoe, Gravely and Bygrave will be either absorbed or annexed. The Green belt promotes physical and mental health by providing recreational space. It is vital for biodiversity, especially when 60% of British wild species are in decline. Up to the present, NHDC has a good record of management of the Green belt. In its Biodiversity Action Plan of 2005 it pledged to protect it (see attachment 2). This measure, having had no formal modifications since, is deemed to be still in force. Therefore I question the legality of NHDC's proposed flagrant disregard of it.
My second main objection is specifically to the Green belt site North of Letchworth (LG1). Apart from my objection above to building on the Green belt in general, there are three further objections specific to this site: first, the uniqueness of this site for its archaeology, geology and biodiversity; second, its particular unsuitability owing to the unique heritage of Letchworth Garden City; third the role of the Letchworth Garden City Heritage Foundation in selling the site for development to NHDC.
The site LG1 is ancient cultivated land dating back to medieval times and probably far beyond. Its ditches, banks and hedges are artifacts of early agricultural systems of archeological significance. There are a number of pollarded oak trees estimated to be over four centuries old. These features carry their own biodiversity which has evolved over the same time-span. The richness of biodiversity is also the result of soil diversity, generated by the particular mix of sand, gravel, chalk and boulder clay laid 500,000 years ago in the last glaciations and known to geologists as 'The Letchworth Gravels'. NHDC has played its part too, cutting down the use of agri-chemicals and encouraging wide field margins. 114 bird species have been recorded, 28 of which are endangered, together with Great Crested Newt, Brown Hare, Common Toad, Polecat and 3 rare butterfly species (see attachment 3). There is a House Sparrow roost of over 300 birds, the biggest in the county which is now under consideration for a designation of protected status. There is in increasing currency an idea that land lost to the Green Belt can be balanced by new Green belt designation elsewhere. Quite apart from the fact that there is no spare land in North Herts for such new designation, an eco-system such as that of LG1 cannot be moved as its centuries of evolution has been specific to that site. Therefore I object to the proposed development of site LG1 because it will necessitate the destruction of biodiversity and study opportunity for archaeology and geology.

I object to site LG1 because of the threat it poses to the unique heritage of Letchworth. This heritage is that of the world's first garden city, embodying influential principles of town planning and social welfare. Proximity to the open countryside was one of them, to which end the founding father, Ebenezer Howard, proposed to limit the population to 32,000 (thereby limiting the footprint of the town)(see attachment 4). He further stated nowhere on the urban boundary should be more than 15 minutes walk from the town centre. Such principles have already been infringed but this is no reason to abandon the spirit of them; there is still a heritage to be preserved if tourists and visiting students of town-planning from all over the world are not to be disappointed. Another principle was the town should be self-sustaining, in the sense that the population would work locally, so housing and industry were carefully balanced. Rather than use the opportunity to restore this balance, the Local Plan proposes to upset it further. With the increase in population generated by LG1, plus the change of use from industrial to residential of many of the smaller sites in the town under the Plan, the percentage of residents employed locally will sharply decrease. Letchworth will become predominantly a dormitory town with all the weakening of community that entails. The increase in commuter numbers will cause insuperable problems for road infrastructure as Letchworth's narrow roads were designed for low car use. In a self-sustaining town everybody could walk to work or school. The crucial routes from LG1 into the town centre and station are already bottlenecks: narrow roads lined with grass verges and specimen trees, some rare, which cannot be removed for road widening without completely destroying the distinctive garden city ambience. There is no scope for enlarging the railway station carpark.
I object to site LG1 because of the circumstances of its proposed sale by the owners. The owners, Letchworth Garden City Heritage Foundation, proposes to abdicate its responsibilities to protect and preserve the site. The Foundation was set up by Parliament in 1993 to continue the town's development by the principles espoused by Ebenezer Howard. The Green Belt was integral to the project, deemed essential to the concept of combining the best of both town and country living. As such it was the world's first Green Belt. The sad irony is this proposed sale represents a betrayal of principle by those whom Parliament has charged to be its protector. The sale of the land could be (and should be) open to legal challenge.
Attachments:
1. Extract from Hansard 15.7.16
2.Foreword to NHDC Biodiversity Action Plan 2005
3. Endangered species on LG1
4. Extract from Ebenezer Howard's Garden Cities of To-morrow (Faber and Faber, London, 1902)