Local Plan 2011-2031 Proposed Submission Draft

I object to the inclusion in the draft local plan of housing site IC2 (Burford Grange, Ickleford) and part of housing site IC3 (Bedford Road, Ickleford). In both cases my objection is based on the argument that the site's inclusion is not based on proportionate evidence and is therefore not justified as described by paragraph 182 of the National Planning Policy Framework.

Site IC2

This site was first identified as a possible site for housing in 2013 when the council published its Housing Options paper. It was then called 'site 40' and it was categorised as a 'priority 3' site. In order to be included as a 'priority' site it was only necessary for sites to be physically capable of being developed by a willing owner and to be capable of making a profit (Housing Options para. 3.2). In other words, no planning judgement was involved. Planning judgement was only used to divide the 'priority' sites into categories: category 1 (those 'most likely to be acceptable'), category 2 (those that were 'moderately acceptable'), and category 3 (those 'least likely to be developed'). Priority 3 sites were therefore ones that were considered unsuitable in planning terms in varying degrees. Even sites that were totally unacceptable from a planning point of view were given a 'priority 3' ranking. I objected at the time, arguing that such a terminology was misleading because it implied that all sites with a 'priority' were regarded as being preferable to others - those over which they had a priority - when in fact all sites that had been put forward by owners were included provided that they were physically and financially capable of being developed.

The explanation for giving the site only a 'priority 3' classification was given in the SHLAA, the most recent of which had been published in December 2012. It was stated that developing this green belt site would 'erode the narrow gap between Ickleford and Hitchin'. (Maintaining the separation of settlements is, of course, a key green belt function.) That conclusion was not surprising. Ickleford is a separate village from its neighbouring town but that separation is fragile.

The distance between the nearest properties in Hitchin and those in Ickleford is only about 250m. The intervening land, of which Site IC2 forms a major part, accommodates just a very few houses in largish grounds. Having that break produces for both residents and all those travelling on Bedford Road - the main road between the two settlements - a sense of leaving one settlement before entering the other. That sense would be destroyed if this site were to be developed as a new housing estate. Ickleford would be perceived to be simply a part of Hitchin.

Only one other road links Ickleford to Hitchin - Old Hale Way (which becomes 'Arlesey Road' in Ickleford). On that road, too, there is a gap between the two settlements. The gap is similar to that on the Bedford Road, comprising a roughly 250m stretch of mainly undeveloped land. That gap is also important in maintaining the identity of the village as a separate settlement, and I note that there is no proposal to allocate housing there.

Of those two gaps which separate the village from Hitchin, the one in which the objection site lies is by far the more important. Bedford Road is an 'A' road (the A600) and is the main route between Hitchin (and Stevenage further south) and Bedford. It carries a huge amount of traffic, whereas Old Hale Way is just a residential street. For most people, therefore, the perception of Ickleford as comprising a distinct settlement and not being merely a part of Hitchin is critically dependent on maintaining Site IC2 as open land.

I assume that the reason why the council has changed its mind since the Housing Options paper was issued, and now proposes allocating Site IC2 for housing despite its earlier view that its development 'would erode the narrow gap between Ickleford and Hitchin' is that its allocation is necessitated by the demand for housing land. I am not arguing that the mere fact that Site IC2 lies in the green belt is sufficient to rule it out. It may be the case generally that the demand for housing in North Herts is such as to constitute exceptional circumstances justifying the redrawing of green belt boundaries. However, when the Housing Options paper was published Ickleford was envisaged to provide a total of just 9 dwellings, all of which were to be located on what is now Site IC1 (land to the rear of Duncots Close). The 48 dwellings then estimated to be possible on Site IC2 were obviously not required - or at least not sufficiently required as to justify the harm that would be done by eroding the green belt gap between the village and Hitchin.

It may be the case that since 2013 the perceived demand for housing has increased. However, I find it hard to believe that that increase has been sufficient to justify the enormous increase in housing provision demanded of Ickleford. The Proposed Submission local plan envisages no fewer than 319 houses being added to the village. In addition, since the Housing Options paper was issued, planning permission has been granted for 8 houses right in the centre of the village on the site of the former Green Man pub, and a planning application (which I have written to support) has been submitted for a development of 19 houses, again right in the centre of the village on the Ickleford Manor site. These sites (the latter if approved) cannot be dismissed as 'windfall' sites, irrelevant to the local plan process. They go towards meeting housing need. They are both 'previously developed' sites. Their contribution allows less acceptable sites, such as Site IC2, being dropped from the plan.

The additional housing sites in Ickleford - IC3 and LS1 - were added to the draft plan only at the most recent stage, when the Proposed Submission version was issued. They have therefore not been the subject of public consultation until now. Together, they would provide a total of 270 homes. In my opinion (and I comment in more detail below on Site IC3) their development, although regrettable and harmful to the countryside, would not be as harmful to the green belt as would the development of Site IC2 because they are not located in the gap between Ickleford and Hitchin. When the council was alerted to these sites it should have reconsidered whether it was still right to maintain Site IC2 as an allocated site. Had it done so, I believe that it would have concluded that Site IC2 should now be dropped.


Site IC3

This site straddles a public footpath which runs from the Bedford Road eastwards to the village playing field. The footpath's eastern half forms the northern boundary of the village's built up area. In my opinion the development of that part of the site which lies on the unbuilt southern side of the footpath would be acceptable, but to allow the built up part of the village to cross over to the northern side of the footpath would not. Development of the part of the site that lies south of the footpath could almost be regarded as infilling.

Allowing housing development to the north of the footpath would have two damaging effects. First, it would ruin a very pleasant walk. Instead of a walk with fields on at least one side, with the path forming a natural and obvious boundary to the village on the other, the walk would be reduced to a route through a new housing estate. Second, it would see an unacceptable degree of encroachment onto open countryside. While there is some development north of the path on the Bedford Road, it is not visible from the path itself and the view northwards from the path is one of open countryside. That would be totally ruined the whole of Site IC3 were developed.


Traffic

Bedford Road is very busy already. In the morning peak, and especially during school term time, there is always a long a queue of cars into Hitchin. Often the queue stretches all the way from the mini roundabout at the top of Turnpike Lane right to the town centre. I know that route intimately as I live on it, and for many years until I retired I used it daily to get to Hitchin train station to commute into London. Now, if I have an appointment at 9 am in Hitchin I have to leave the house before 8.30, and even then I often choose to go via the village centre, which is itself busy at that time.

In my opinion Bedford Road is not capable of accommodating any significant increase in traffic, either from Site IC2 or Site IC3. Development on Site LS1 would exacerbate the problem.


Appearance at the Public Examination

I do wish to appear at the public examination. However, if there are others who will be appearing who make the same points, not least Ickleford Parish Council, I would be happy to allow this written objection to suffice.

I object to the inclusion in the draft local plan of housing site IC2 (Burford Grange, Ickleford) and part of housing site IC3 (Bedford Road, Ickleford). In both cases my objection is based on the argument that the site's inclusion is not based on proportionate evidence and is therefore not justified as described by paragraph 182 of the National Planning Policy Framework.

Site IC2

This site was first identified as a possible site for housing in 2013 when the council published its Housing Options paper. It was then called 'site 40' and it was categorised as a 'priority 3' site. In order to be included as a 'priority' site it was only necessary for sites to be physically capable of being developed by a willing owner and to be capable of making a profit (Housing Options para. 3.2). In other words, no planning judgement was involved. Planning judgement was only used to divide the 'priority' sites into categories: category 1 (those 'most likely to be acceptable'), category 2 (those that were 'moderately acceptable'), and category 3 (those 'least likely to be developed'). Priority 3 sites were therefore ones that were considered unsuitable in planning terms in varying degrees. Even sites that were totally unacceptable from a planning point of view were given a 'priority 3' ranking. I objected at the time, arguing that such a terminology was misleading because it implied that all sites with a 'priority' were regarded as being preferable to others - those over which they had a priority - when in fact all sites that had been put forward by owners were included provided that they were physically and financially capable of being developed.

The explanation for giving the site only a 'priority 3' classification was given in the SHLAA, the most recent of which had been published in December 2012. It was stated that developing this green belt site would 'erode the narrow gap between Ickleford and Hitchin'. (Maintaining the separation of settlements is, of course, a key green belt function.) That conclusion was not surprising. Ickleford is a separate village from its neighbouring town but that separation is fragile.

The distance between the nearest properties in Hitchin and those in Ickleford is only about 250m. The intervening land, of which Site IC2 forms a major part, accommodates just a very few houses in largish grounds. Having that break produces for both residents and all those travelling on Bedford Road - the main road between the two settlements - a sense of leaving one settlement before entering the other. That sense would be destroyed if this site were to be developed as a new housing estate. Ickleford would be perceived to be simply a part of Hitchin.

Only one other road links Ickleford to Hitchin - Old Hale Way (which becomes 'Arlesey Road' in Ickleford). On that road, too, there is a gap between the two settlements. The gap is similar to that on the Bedford Road, comprising a roughly 250m stretch of mainly undeveloped land. That gap is also important in maintaining the identity of the village as a separate settlement, and I note that there is no proposal to allocate housing there.

Of those two gaps which separate the village from Hitchin, the one in which the objection site lies is by far the more important. Bedford Road is an 'A' road (the A600) and is the main route between Hitchin (and Stevenage further south) and Bedford. It carries a huge amount of traffic, whereas Old Hale Way is just a residential street. For most people, therefore, the perception of Ickleford as comprising a distinct settlement and not being merely a part of Hitchin is critically dependent on maintaining Site IC2 as open land.

I assume that the reason why the council has changed its mind since the Housing Options paper was issued, and now proposes allocating Site IC2 for housing despite its earlier view that its development 'would erode the narrow gap between Ickleford and Hitchin' is that its allocation is necessitated by the demand for housing land. I am not arguing that the mere fact that Site IC2 lies in the green belt is sufficient to rule it out. It may be the case generally that the demand for housing in North Herts is such as to constitute exceptional circumstances justifying the redrawing of green belt boundaries. However, when the Housing Options paper was published Ickleford was envisaged to provide a total of just 9 dwellings, all of which were to be located on what is now Site IC1 (land to the rear of Duncots Close). The 48 dwellings then estimated to be possible on Site IC2 were obviously not required - or at least not sufficiently required as to justify the harm that would be done by eroding the green belt gap between the village and Hitchin.

It may be the case that since 2013 the perceived demand for housing has increased. However, I find it hard to believe that that increase has been sufficient to justify the enormous increase in housing provision demanded of Ickleford. The Proposed Submission local plan envisages no fewer than 319 houses being added to the village. In addition, since the Housing Options paper was issued, planning permission has been granted for 8 houses right in the centre of the village on the site of the former Green Man pub, and a planning application (which I have written to support) has been submitted for a development of 19 houses, again right in the centre of the village on the Ickleford Manor site. These sites (the latter if approved) cannot be dismissed as 'windfall' sites, irrelevant to the local plan process. They go towards meeting housing need. They are both 'previously developed' sites. Their contribution allows less acceptable sites, such as Site IC2, being dropped from the plan.

The additional housing sites in Ickleford - IC3 and LS1 - were added to the draft plan only at the most recent stage, when the Proposed Submission version was issued. They have therefore not been the subject of public consultation until now. Together, they would provide a total of 270 homes. In my opinion (and I comment in more detail below on Site IC3) their development, although regrettable and harmful to the countryside, would not be as harmful to the green belt as would the development of Site IC2 because they are not located in the gap between Ickleford and Hitchin. When the council was alerted to these sites it should have reconsidered whether it was still right to maintain Site IC2 as an allocated site. Had it done so, I believe that it would have concluded that Site IC2 should now be dropped.


Site IC3

This site straddles a public footpath which runs from the Bedford Road eastwards to the village playing field. The footpath's eastern half forms the northern boundary of the village's built up area. In my opinion the development of that part of the site which lies on the unbuilt southern side of the footpath would be acceptable, but to allow the built up part of the village to cross over to the northern side of the footpath would not. Development of the part of the site that lies south of the footpath could almost be regarded as infilling.

Allowing housing development to the north of the footpath would have two damaging effects. First, it would ruin a very pleasant walk. Instead of a walk with fields on at least one side, with the path forming a natural and obvious boundary to the village on the other, the walk would be reduced to a route through a new housing estate. Second, it would see an unacceptable degree of encroachment onto open countryside. While there is some development north of the path on the Bedford Road, it is not visible from the path itself and the view northwards from the path is one of open countryside. That would be totally ruined the whole of Site IC3 were developed.


Traffic

Bedford Road is very busy already. In the morning peak, and especially during school term time, there is always a long a queue of cars into Hitchin. Often the queue stretches all the way from the mini roundabout at the top of Turnpike Lane right to the town centre. I know that route intimately as I live on it, and for many years until I retired I used it daily to get to Hitchin train station to commute into London. Now, if I have an appointment at 9 am in Hitchin I have to leave the house before 8.30, and even then I often choose to go via the village centre, which is itself busy at that time.

In my opinion Bedford Road is not capable of accommodating any significant increase in traffic, either from Site IC2 or Site IC3. Development on Site LS1 would exacerbate the problem.


Appearance at the Public Examination

I do wish to appear at the public examination. However, if there are others who will be appearing who make the same points, not least Ickleford Parish Council, I would be happy to allow this written objection to suffice.