Local Plan 2011-2031 Proposed Submission Draft

I am writing to object to the NHDC draft local plan on the grounds that the inclusion of SP2 in the plan neither complies with legal requirements or is a sound and sustainable plan for the future of North Hertfordshire
The area designated SP2 was not in the previous plan and was allocated as potential green belt outside the Village boundary. Recently planning permission for this area was refused as a high risk of flood and high impact to the visual beauty of the area. A strong village reaction to the planning permission co-ordinated through the Parish council helped defeat this planning application. The Parish council wrote a number of letter expressing the Villages objection to this area whilst accepting that some smaller developments at more suitable locations in the Village would be entertained. Despite the fact that the governmental targets for housing have been reduced the local plan contains SP2 within a re-defined Village boundary at a very late stage without proper recourse to the content and consultation set out in the town and country planning regulations of 2012. In addition it is contrary to the decisions made by its own planning committee to reject planning for this area.
The sustainability appraisal carried out for the SP2 by the NHDC in "The Sustainability Appraisal (update 2016, (attached)) presents evidence in the form of appraisal matrices for these preferred sites (Appendix 6) and non-preferred sites (Appendix 7). Each site is rated positive, negative or neutral against 14 objectives. On this evidence, the "preferred site" SP2 ranks equal lowest (most negative) of all the sites. Thus it is clear that the decision to allocate the site is contrary to the evidence presented to support the plan.
With regards to soundness, the plan has not been positively prepared. It has been prepared on the categorisation of the Village as category A village. This assessment is flawed. The Village is serviced by narrow roads and has a very poor public transport structure only travelling between Hitchin and St Albans every 2 hours with no service after 8pm or on Sundays. The Village has one primary school which is at capacity, one small post office come general store, one small café (summer only) and one Public House. It does not need further development to survive in fact it is creaking at the seams from a 15% housing increase over the last 10 years. A housing development of this nature cannot be accommodated by the present facilities such as sewage and will add dramatically to the traffic on the high street already used as a rat run to the A1 through Codicote. It is clearly an unsustainable site for development . The access is directly opposite the school raising safety concerns as noted by the school governors and headmistress in their objections to the planning permission in August. The nearest secondary school is 5 miles away and so pupils will require additional buses and there are not sufficient shopping or entertainment facilities to keep people in the village. Rather than sustaining a rural village the impact will be the creation of another suburb. It is the rural aspect and beauty of the area that brings the many walkers and cyclists to Village.
The plan to include SP2 is not the most appropriate strategy. The Parish council survey demonstrated that the majority of the Village believed that smaller developments in appropriate areas was the correct strategy. This has been ignored in the NHDC plan. The plan is not effective in meeting its housing targets. Adding this number of houses will only stretch and destroy the Village when in fact the housing targets have been reduced (through the recent OAN) and the plan now carries a 7% contingency when it is only required to carry 3%. The site is a known area where flood water goes through and such an area should only be considered in exceptional circumstances and when a strategic flood risk assessment has been carried out. Given the 7% contingency/surplus in the plan this is not an exceptional circumstance and a SFRA has not been carried out.

For the reasons above I believe the plan is neither legal or sound due to the inclusion of SP2 in the plan. To improve the plan the SP2 site should be removed and Whitwell village re-categorised from A