Local Plan 2011-2031 Proposed Submission Draft

Chapt 13 Site Allocation SP2 Whitwell.

(Note that although the Parish of St Pauls Walden had 537 houses in the 2011 census, the village of Whitwell (with site SP2 outside its boundary) only has around 370 houses.)

Para 13.324 - Whitwell designation as a Category A village - Objection on grounds of Soundness (not justified and not compliant with National policy) - see representation Chapt 4 Settlements site SP2. In summary The NPPF requires settlements to be sustainable but because of its rural location, lack of nearby amenities and absence of practically useful public transport, necessitating increased car use on an inadequate road infrastructure, a proposed development of 40 houses or more will not be sustainable. Increase traffic generation will be further exacerbated by the proposed inclusion of sites EL1,2,&3 which will generate even more traffic feeding into the Lilley Bottom Road which runs through the village. There is no evidence that this cumulative effect of the PSDP's proposed sites has been assessed and taken into account.

Inclusion of SP2 as a site for development - Objection on legal grounds - see representation Chapt 4 Policy SP8 - No demonstrated need for inclusion of site SP2 in view of downward OAN revision; allocation of site not based on Council's own LP background evidence and up to date research and data on flood risk assessment. Therefore not sound as not justified.

Impact on Countryside
Whitwell lies in the Mimram valley and SP2 is a sloping field on the side of this beautiful unspoiled valley. It is unsuitable for development because of significant impact on the countryside and rural nature of the village. The North Herts and Stevenage Landscape Character Assessment (an independent background paper for the LP) of the Mimram Valley states that visual sensitivities are moderate to high and that 'Cross valley views from the higher vantage points are an important feature of the character area. Panoramic views are common from the higher valley slopes, views along the valley are an important feature in the character area.' The assessment states that for sites over 5 hectares in size, large urban developments would not be appropriate, and goes on to say that for sites under 5 hectares 'This type of development would not be entirely appropriate within this character area due to its rural and undeveloped character. Visual impacts could be high, due to the cross valley views currently experienced. Some small scale expansion at the periphery of Whitwell, carefully designed and in keeping with the existing character of the village, could possibly be accommodated. The landscape capacity for small urban extensions is considered to be low.' SP2 is more than 5 hectares in area. The PSDP text states that the indicated house numbers for sites should not be assumed to be maximums (the potential capacity of the site could be more than 100 houses).

The Chiltern Conservation Board has submitted a proposal to the Government for the Chiltern Area of Outstanding Natural Beauty (AONB) to be extended down the Mimram Valley to include Whitwell. This is a clear indication of the quality of the landscape around Whitwell from a national perspective. Any development which damages that would be contrary to the Chiltern Conservation Board Proposal and could compromise it.

The allocation of this site for development is unsound (not justified) as it is not based on the Council's own evidence and runs counter to the NPPF which seeks to protect the intrinsic beauty of the countryside.

Flooding
SP2 lies within a flood zone 1 and has significant surface flooding issues. The sloping site's lower ground (with least visual impact) is prone to flooding (most recent episode winter of 2014-2015). The inclusion of the site in the PSDP ignores up to date evidence from the SFRA . There is evidence that this flood risk cannot be solved by sustainable and appropriate drainage measures. Therefore its inclusion in the plan is contrary to NPPF guidelines which states that such sites should not be used for development unless a sequential test for sites not prone to flooding have been carried out. There is no documentation that this has been done and there are many other sites elsewhere in the district where flooding is not an issue. JBA flood consultancy state that there is evidence that in previous flood events raised groundwater levels in the underlying chalk aquifer are a key element causing flooding events in chalk land areas in Hertfordshire and neighbouring counties. They advise that this would be a significant risk at the SP2 site. This view is supported by circumstantial evidence has been presented by the flood risk consultants who carried out the section 19 report for the 2014-2015 flooding event (see attached).

If raised groundwater levels are present they would render the standard flood risk mitigation scheme based on infiltration ineffective. Schemes based on piped drainage off the site are not economic or practical for SP2 and have not been suggested by developers. The problem can not be surmounted by building on the higher parts of the site without significantly increasing the adverse visual impact of any development and this option was rejected by the local planning officers in a recent planning application.

The Lead Local Flood Risk Authority at first dismissed the role played by groundwater but have now acknowledged that it may have a part to play and have called for more investigation. The problem is that it is not possible to either prove or disprove that raised groundwater levels are a key issue in the flooding events until the conditions which lead to another flooding event arise. Only then will test borings demonstrate the true picture. Test borings done at other times will be meaningless. The precautionary principle should apply.

As has been argued above in relation to housing need, development on this site is not required and therefore SP2 should be removed from the list of sites for development in accordance with NPPF guidance.

Sewerage and Groundwater Contamination:-
The main sewer running through the village has no peak-time capacity for more houses. The proposal for 41 houses requires a holding tank and pumps to hold sewage until the night and then to pump it into the sewer. This proposal is not sustainable and risks leakage into the chalk aquifer which forms a source protection zone 1 for abstractions at Nine Wells Watercress Farm. This is an unacceptable risk when there is no proven need for the site to be developed.

Green Belt
In previous versions of the LP SP2 was designated as green belt with good community support. This was deemed necessary to mitigate the proposed high levels of expansion proposed to the East of Luton and W of Stevenage. There is still a need for this land to be designated green belt for the above reasons.
Community Involvement
The NPPF states that 'Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities'. There was good support for SP2 and other land around the village boundary to be designated as green belt however there is strong opposition to it being developed for building.

Chapt 4 SP2 Settelement
I object on the grounds that the assessment of sustainable locations for housing in rural areas is not sound as not based on an adequate assessment of environmental impact as required by the NPPF and not consistent with NHDC's own transport policy criteria (T1) 'developments to be in locations which enable sustainable journeys to be made to key services and facilities.'

Climate Change is the biggest long term threat that we face. It is vital that the NPPF's requirement for sustainable development which reduces our environmental impact (especially CO2 emissions and air pollution) is followed. Siting more than very small numbers of new houses in villages with little or no public transport and at distances from essential amenities such as employment, supermarkets, secondary schools etc which require the use of cars is not sustainable.

Paragraph 13.324 Site SP2 in Whitwell designated for over 40 houses (site capacity over 100 houses) is more than 5 miles from the nearest supermarket and other essential amenities such as employment and secondary schools. Public transport is impractical (2 hr bus service).

The road infrastructure supplying the village consists of narrow country lanes often with single track passing places. These roads are already overcongested at peak times.

The inclusion of Whitwell as a category A village and of SP2 as a potential development site is not sound as it is not justified (not the most appropriate way of fulfilling housing needs) and is not consistent with National Policy for sustainability or the core planning principals of the NPPF para 17 which states that patterns of growth should be actively managed to make the fullest possible use of public transport, walking and cycling and focus on locations which are or can be made sustainable.