Local Plan 2011-2031 Proposed Submission Draft

I wish to have on record that I support the response to the local plan from Weston Parish Council in its entirety. Attached to this email, and copied below the footer

NHDC Local Plan - Weston Parish Response November 2016

Weston Parish Council (WPC) generally supports the NHDC plan for more much needed housing, especially affordable, and recognises that because North Herts is largely within the Metropolitan Green Belt a limited release for this land for essential development is unavoidable.

In relation to the Tests of Soundness:
Positively Prepared
The first draft of the NHDC Local Plan proposed 7700 houses. WPC remains unconvinced that the current housing numbers are accurate because no clear justification for the increase has been made. These doubts concerning the robustness of the housing figures proposed is reinforced by the recent announcement that fewer homes are now required, albeit this lower figure has not been incorporated into the Local Plan. WPC contends that much of the development being proposed is not essential and therefore should not justify release of Green Belt land. WPC recommends that NHDC should determine the minimum need for essential housing and that this becomes the basis for the release of Green Belt. The remaining housing should be concentrated in brown field sites and areas beyond the Green Belt. WPC supports the view a new Garden City should be the favoured approach for future housing needs.

Effectiveness of the Plan
WPC believes this to be at severe risk because of the inadequacy of the North Herts trunk road network. This inadequacy already causes severe congestion in the local towns of Baldock, Letchworth and Hitchin, and on the rural roads congested by traffic avoiding the trunk routes (rat-running). This is particularly severe at peak times in the morning and afternoon. This is endorsed by the A1 East of England interim report (June 2016). There is, as yet, no visible plan or timescale to resolve the issues raised in this report.

WPC also considers that this Local Plan is flawed in that there is no provision for an effective East/West route through the area of proposed development. The A505 to the East of Baldock and to the West of Hitchin is dual carriageway but these two parts need to be linked. The problem of congestion caused by the lack of this link will be worsened by the Local Plans' large increase in population and the already agreed expansion of Luton Airport.

WPC considers these two trunk routes should be improved before any widespread development takes place.

Justified and Consistent with National Policy
WPC contend that the proposal to release land with the potential for 3100 house to the West of Stevenage, but then reserving it for future use, is not commensurate with the principle of Green Belt protection, i.e. only to be released for essential development purposes.

However, if, as required by the NPPF, there must be cooperation between adjacent Districts, then development of the West of Stevenage site should be a priority now as it will support financially the development by Stevenage Borough Council of their land west of the A1(M). WPC therefore contend that this site should be developed now instead of GA1, GA2 and NS1 and this increased capacity counted towards the 2011-31 housing need.

WPC considers the advantages of the West of Stevenage site to be its close proximity to the town centre, the rail and bus stations, retail parks, and to Junctions 7 and 8 of the A1(M). It would also be close to a newly constructed east-west A505 link to Luton and Royston (for Cambridge), as proposed in the NHDC Infrastructure Plan. The A1 East of England Interim Report, June 2016, states that the A1(M) between Junctions 6 and 8 needs urgent improvement work. Work to service the West of Stevenage Development could be incorporated into these improvements.

WPC opposes GA1 (Roundwood) and GA2 (SP18) for the following reasons:
* Both sites are within the Green Belt and are remote from the town centre, bus and rail stations, retail parks and motorway access points.
* Access for both sites is planned through a residential area that was built without making adequate provision for new development of this magnitude.
* GA2 (SP18) in particular would create a weak indefensible Green Belt boundary that could be open to challenge in the future (see para 4.215).
* The NHDC Infrastructure Plant identifies the need for a new secondary school in this area but the Local Plan does not include this in either proposed sites (GA1 or GA2). It is clear. therefore, that the NHDC will be seeking to release further land from the Green Belt outwith the releases contained in the Local Plan proposal. WPC have been unable to get details of this and have made a Freedom of Information request to Herts CC to clarify their secondary school plans for this area.
* WPC disputes the validity of the traffic assessment for GA1 (Roundwood) and WPC commissioned a survey from a specialist traffic consultant. The main findings of this report are:

a. That the traffic assessment prepared for the GA1 development is deeply flawed in that the assessment did not take account of the change in traffic flows from and to existing properties in Great Ashby as a result of the changes to access roads being provided for GA1. In particular this would greatly increase traffic affecting the nearby villages of Weston and Gravely.

b. That the traffic assessment made no attempt to determine traffic flows by considering the destination of journeys and thereby the likely route to be taken to that destination.

c. That it is reasonable to assume the findings of the consultant's report could be applied equally to the GA2 development as it is nearby and access to it is proposed to be along the same route as GA1 (Mendip Way).

The consultant's report is appended to this submission.

WPC instigated a Housing Needs Survey that indicated a need for 14 affordable homes. WPC supported the proposal for 25 homes on land that was originally designated for housing when the adjoining estate was constructed. However, WPC opposes the addition of 15 additional houses on the grounds that it is an unnecessary incursion into the Green Belt, and that it will not increase the number of affordable housing for the village based on the NHDC's stated target of 33% being affordable (SP8).

Summary

WPC supports the need for a limited and targeted release of Green Belt land for housing but only for that considered absolutely essential to support the current social and economic needs of North Hertfordshire.

WPC are strongly of the view that the proposed developments to the north-east of Stevenage (GA1 and GA2) are poorly positioned in terms of access and provision of infrastructure. If it is considered that new building bordering Stevenage within the Green Belt is vital to the success of North Hertfordshire, a properly designed development to the West of Stevenage containing all essential infrastructure should be built as part of the NHDC Local Plan 2011-31.

I wish to have on record that I support the response to the local plan from Weston Parish Council in its entirety. Attached to this email, and copied below the footer

NHDC Local Plan - Weston Parish Response November 2016

Weston Parish Council (WPC) generally supports the NHDC plan for more much needed housing, especially affordable, and recognises that because North Herts is largely within the Metropolitan Green Belt a limited release for this land for essential development is unavoidable.

In relation to the Tests of Soundness:
Positively Prepared
The first draft of the NHDC Local Plan proposed 7700 houses. WPC remains unconvinced that the current housing numbers are accurate because no clear justification for the increase has been made. These doubts concerning the robustness of the housing figures proposed is reinforced by the recent announcement that fewer homes are now required, albeit this lower figure has not been incorporated into the Local Plan. WPC contends that much of the development being proposed is not essential and therefore should not justify release of Green Belt land. WPC recommends that NHDC should determine the minimum need for essential housing and that this becomes the basis for the release of Green Belt. The remaining housing should be concentrated in brown field sites and areas beyond the Green Belt. WPC supports the view a new Garden City should be the favoured approach for future housing needs.

Effectiveness of the Plan
WPC believes this to be at severe risk because of the inadequacy of the North Herts trunk road network. This inadequacy already causes severe congestion in the local towns of Baldock, Letchworth and Hitchin, and on the rural roads congested by traffic avoiding the trunk routes (rat-running). This is particularly severe at peak times in the morning and afternoon. This is endorsed by the A1 East of England interim report (June 2016). There is, as yet, no visible plan or timescale to resolve the issues raised in this report.

WPC also considers that this Local Plan is flawed in that there is no provision for an effective East/West route through the area of proposed development. The A505 to the East of Baldock and to the West of Hitchin is dual carriageway but these two parts need to be linked. The problem of congestion caused by the lack of this link will be worsened by the Local Plans' large increase in population and the already agreed expansion of Luton Airport.

WPC considers these two trunk routes should be improved before any widespread development takes place.

Justified and Consistent with National Policy
WPC contend that the proposal to release land with the potential for 3100 house to the West of Stevenage, but then reserving it for future use, is not commensurate with the principle of Green Belt protection, i.e. only to be released for essential development purposes.

However, if, as required by the NPPF, there must be cooperation between adjacent Districts, then development of the West of Stevenage site should be a priority now as it will support financially the development by Stevenage Borough Council of their land west of the A1(M). WPC therefore contend that this site should be developed now instead of GA1, GA2 and NS1 and this increased capacity counted towards the 2011-31 housing need.

WPC considers the advantages of the West of Stevenage site to be its close proximity to the town centre, the rail and bus stations, retail parks, and to Junctions 7 and 8 of the A1(M). It would also be close to a newly constructed east-west A505 link to Luton and Royston (for Cambridge), as proposed in the NHDC Infrastructure Plan. The A1 East of England Interim Report, June 2016, states that the A1(M) between Junctions 6 and 8 needs urgent improvement work. Work to service the West of Stevenage Development could be incorporated into these improvements.

WPC opposes GA1 (Roundwood) and GA2 (SP18) for the following reasons:
* Both sites are within the Green Belt and are remote from the town centre, bus and rail stations, retail parks and motorway access points.
* Access for both sites is planned through a residential area that was built without making adequate provision for new development of this magnitude.
* GA2 (SP18) in particular would create a weak indefensible Green Belt boundary that could be open to challenge in the future (see para 4.215).
* The NHDC Infrastructure Plant identifies the need for a new secondary school in this area but the Local Plan does not include this in either proposed sites (GA1 or GA2). It is clear. therefore, that the NHDC will be seeking to release further land from the Green Belt outwith the releases contained in the Local Plan proposal. WPC have been unable to get details of this and have made a Freedom of Information request to Herts CC to clarify their secondary school plans for this area.
* WPC disputes the validity of the traffic assessment for GA1 (Roundwood) and WPC commissioned a survey from a specialist traffic consultant. The main findings of this report are:

a. That the traffic assessment prepared for the GA1 development is deeply flawed in that the assessment did not take account of the change in traffic flows from and to existing properties in Great Ashby as a result of the changes to access roads being provided for GA1. In particular this would greatly increase traffic affecting the nearby villages of Weston and Gravely.

b. That the traffic assessment made no attempt to determine traffic flows by considering the destination of journeys and thereby the likely route to be taken to that destination.

c. That it is reasonable to assume the findings of the consultant's report could be applied equally to the GA2 development as it is nearby and access to it is proposed to be along the same route as GA1 (Mendip Way).

The consultant's report is appended to this submission.

WPC instigated a Housing Needs Survey that indicated a need for 14 affordable homes. WPC supported the proposal for 25 homes on land that was originally designated for housing when the adjoining estate was constructed. However, WPC opposes the addition of 15 additional houses on the grounds that it is an unnecessary incursion into the Green Belt, and that it will not increase the number of affordable housing for the village based on the NHDC's stated target of 33% being affordable (SP8).

Summary

WPC supports the need for a limited and targeted release of Green Belt land for housing but only for that considered absolutely essential to support the current social and economic needs of North Hertfordshire.

WPC are strongly of the view that the proposed developments to the north-east of Stevenage (GA1 and GA2) are poorly positioned in terms of access and provision of infrastructure. If it is considered that new building bordering Stevenage within the Green Belt is vital to the success of North Hertfordshire, a properly designed development to the West of Stevenage containing all essential infrastructure should be built as part of the NHDC Local Plan 2011-31.