Local Plan 2011-2031 Proposed Submission Draft

I am writing to express my objection to the proposed development Site PR1 (off Templar Lane) in Preston, Herts. It is my professional opinion that the arguments put forward in support of this site are flawed and inaccurate, discrediting the new rationales put forward by NHDC. I outline these significant concerns below, and would also point out that all the previous reasons for not progressing this development remain unresolved , such as lack of infrastructure, poor travel links, and no local services. Ignoring these problems doesn't mean they have gone away.

Specifically, I would like to draw attention to the flawed and factually-incorrect document entitled "The Wain Wood Site of Scientific Interest Impact", a desk-based study prepared by BSG Ecology in Derbyshire (June 2016), apparently to rebut issues raised by Natural England. These consultants use out-dated) publically-available data of extrapolated averages and estimates to make their conclusions and, as such, these do not truly reflect local reality. The assessment, methodology, assumptions and conclusions are not robust - I say these as a Professor of Agricultural Research with over 25 years' experience in both reading and preparing scientific analyses . The BSG Ecology document does not properly address the concerns raised by Natural England who commented on the Local Plan (letter dated 13 February 2013) as to 'the potential impacts that the development of the PR1 site for residential purposes will have on Wain Wood SSSI'. Contrary to the assertion of the BSG Ecology report, the allocation of housing proposed at PR1 is certain to impact upon Wain Wood SSSI. I point out below some of the primary problems with this report.
* The credibility of the document produced by BSG Ecology can immediately be called into question by the erroneous and irrelevant reference to Royston (Section 1.1) which is 18+ miles away from the PR1 site. Another error (Section 4.1) suggests that the PR1 site (SG4 7TU) lies within the Impact Risk Zone for the Therfield Heath SSSI (SG8 9NU), 16.9 miles away (Google Maps). Presumably, these same consultants with clearly no knowledge of North Hertfordshire (or ability to research, review or check their information), were also commissioned by NHDC to provide a desk study on Local Plan proposed sites in the Royston area. How many other mistakes, errors or miscalculations are present in this document for PR1? Below are some examples, but this may not be a complete list. It is very worrying that tax-payers money was spent on such a flawed report, and equally, one must ask why no-one at NHDC checked it for accuracy.
* It is a fact that Wain Wood SSSI already has a larger volume of human and dog traffic than is reported by BSG Ecology, who predicted visitor numbers using a 'Ramblers Association participation rate' taken from data compiled by Sports England in 2009. Walking for recreational purposes has significantly increased since 2009. Active People Surveys per local authority in England are conducted and published for Sports England every 6 months (gov.uk) and quote >50% higher rates (2014-15) than those used here. These latest figures have been ignored by the consultants who have not researched this adequately.
* A properly robust scientific survey should be undertaken on visitor and dog numbers. This should be conducted, over more than one season, to include weekdays, weekends and holidays, when children regularly use the wood for recreational purposes as can be evidenced by the numerous dens and tree swings within the wood.
* The attraction to Wain Wood SSSI by the occupants of PR1 will be high and frequent because there will then be a complete lack of green space within Preston village for recreational purposes if the PR1 site is developed for housing. Lack of green space alone will increase current footfall and activities within Wain Wood by existing villagers as well as additional occupants of the PR1 site. Furthermore, the majority of occupants are likely to be families (based upon the recently built and occupied affordable houses located adjacent to the site) and they will naturally be attracted to their nearest open space which is Wain Wood SSSI.
In general, the local road infrastructure within and around Preston is mainly narrow lanes rather than roads. This infrastructure would be unable to cope with the increased volume of traffic which the proposed housing development would generate. There continue to be issues with speeding without an additional 20+ cars. The road access to and from the site is mostly single carriage and is inadequate. Both Chequers Lane, leading to Templars Lane, and Butchers Lane struggle to cope with the amount of traffic using them at present and Butcher's Lane is single carriage with blind sharp bends. Widening would not only cause substantial upheaval at an enormous cost but such changes would also be destructive to the existing character of these ancient country lanes and would change the whole character of Preston Village.
All the access roads in and out of Preston have single carriage sections and are liable to flooding and snow fall leading to the village being cut off from the surrounding areas which is compounded by the absence of no Preston village shop, medical or dental practices. The roads include Preston Rd (Hitchin Rd), Charlton Road, Back Lane, St Albans Highway, School Lane, Little Almshoe Rd and Hitchwood Lane. The main access road (Preston/Hitchin road) has a steep incline close to the Preston where cars regularly get stuck in snow. Close to this inclination there is a 90 degree bend; a consistent site of cars skidding off the road into adjoining hedge and field. A few hundred yards further towards Gosmore, the road narrows to single carriage way, with another 90 degree bend at Dermal Laboratories. The narrow road continues with multiple sharp bends (site of recent fatality) to a blind cross roads where the road becomes single carriage way at the Bull Pub at Gosmore, where pedestrians become vulnerable to traffic. A few hundred yards beyond, there is regular flooding where the road has become impassable. Flooding also regularly occurs on Hitchwood Lane, close to the the B651, Almshoe Rd a few hundred yards before the B656 and Charlton Road approximately a quarter of a mile before Preston Village.
There is inadequate infrastructure in the village including no shops, no nearby medical practice, poor bus service (No 88. Luton to Hitchin between 8 am and 6 pm, 5 per weekday/4 on Saturdays and School Holidays; school children are regularly driven past and left behind because the buses are already full before they reach Preston) and inadequate sewage provision.
Since the building of 6 new dwellings adjacent to the PR1 field site, the manholes on Templars Lane are now prone to the back flooding of sewage. This is not only causing undesirable odours three times a day when sewage is pumped from the new dwellings, but also the flooding of raw sewage on to the open road is a potential public health hazard. Children have been observed playing in these puddles of raw sewage. This has continued despite quarterly rodding by professional sewer maintenance contractors.
The sewage problem has been investigated by a fully qualified experienced plumber. In the opinion of the plumber the addition of these 6 dwellings are overwhelming the current sewage capacity. The additional 21 houses will exacerbate this problem and would have the potential to cause back up of sewage to the top of Chequers lane and extending the hazard zone further.
If 35% of the new housing delivered on this site is affordable then the Council should seriously consider how sustainable this location will be for younger families who do not benefit from car ownership. A report published by University College London in July 2014 entitled 'Transport and Poverty - a review of the evidence' finds that ''lower incomes and unemployment benefits mean that the cost of owning and running a car are prohibitive for many young people (Commission for Rural Communities, 2012) and that the large distances and the higher cost of fuel in rural areas may exacerbate these barriers to travel.'' It is well evidenced that the level of car ownership of affordable housing tenants on low incomes is well below the national average and coupled with poor transport links begs the question just how sustainable is this location is for people in affordable housing to access shops, services and employment.
Furthermore, it was a struggle to fill the 6 affordable houses that were recently built adjacent to the PR1 site, with 2 being having to be converted to rented accommodation so they wouldn't remain empty. Thus, it appears that the demand for affordable housing does not exist in Preston.
The development of this site will lead to an increase in class sizes at Preston Primary School and a corresponding increase in pressure on the school's limited infrastructure. Currently 94 pupils attend the school, close to the full capacity of 100. The current year 3 /4 class size is already at full capacity. Capacity has also been a problem in the recent past where class sizes exceeded 30. Moreover, the school, which is open to children between the years of 4 - 11 has only 4 available classrooms. With Reception year children benefiting from their own classroom there are only three other classes available to service the educational needs of school years 1 to 6. This means the children are educated in mixed year groups where pupils of different school ages are educated in the same class room. Increased housing, particularly for young families will exacerbate this disadvantage to current and future pupils attending the school.
A 25% increase in dwellings in this small historic village will endanger the nature of the settlement. This increase is unsustainable and overwhelming for a village of this size. Given the high density of housing proposed for this site in comparison to the rest of the village dwellings, the unique character of Preston would be badly affected.
Much, if not all of Preston's housing demands could be met by in filling of other sites within the village development boundary. In addition there is an unsightly field adjoining Back lane, within the village envelope owned by a builder / developer. This field lies closer to the limited Preston facilities such as the school, Pub and village hall, and is further away from the SSSI than the field at PR1. Importantly, this field is not in recreational use and, in contrast to the PR1 field, is unlikely to be subjected to a potential future village green application from local residents. It is puzzling that this site is not considered as an option.