Local Plan 2011-2031 Proposed Submission Draft

I am writing to register my comments and objections to the Local Plan in relation to the proposed residential sites in Ickleford, sites IC1, IC2, IC3 and LS1.

IC1 (Duncots Close)

Whilst this site is within the Green Belt and is therefore in contravention of National Planning Policy Framework, in principle I would support small housing development here. The incursion into Green Belt is relatively minor and would bring the building line in line with the houses on adjacent Laurel Way. There is also a natural boundary with trees etc shielding the landscape impact of this proposed development from Duncots field.

However, I understand there are concerns over sewer capacity and flooding and any development would need to be sensitively done and be sympathetic to the conservation area. If these concerns can be properly allayed then I am broadly supportive of this site.

IC2 (Burford Grange)

I wish to strongly object to the allocation of site IC2 for the proposed residential allocation of 40 + houses.

I consider the allocation of this site to be Not Sound for a number of reasons.

This site sits within the Green Belt and as such would be in contravention of National Planning Policy and conflicts with NHDC Strategic Objectives on the Green Belt.

The strip of Green Belt within which IC2 sits provides a critical role separating Hitchin from Ickleford and is also environmentally sensitive being in close proximity to Oughtonhead Nature Reserve and providing protection into beautiful open countryside beyond.

I would like to take issue and highlight inaccuracies and errors in the appraisal of this site, which make the allocation Not Sound.

Firstly, within the Green Belt Review July 2016, this site is identified as sitting within the Green Belt subparcel Oughtonhead 12A (page 33 of report), which concludes on page 49 that it plays an important role in preventing expansion of Hitchin northwards. It also plays a significant role in safeguarding the countryside. Overall the report concludes it makes a Significant Contribution.

However, the assessment of 12A makes an error when it says it plays no role in preventing merger of neighbouring towns.

This is clearly wrong as this narrow stretch of green belt where IC2 sits plays a key role separating Hitchin from Ickleford. My conclusion is confirmed by the assessment of green belt sub sector 13c on page 50 (which contains the Ickleford Manor site diagonally opposite IC2 on the other side of the A600), which is noted as playing a key role separating Hitchin from Ickleford. The Green Belt review is therefore inconsistent and clearly the findings in relation to 12A and specifically the land that IC2 occupies is in error. The allocation is therefore Not Sound.

How can the council come to a different conclusion on two adjacent pieces of greenbelt land playing the same role separating Hitchin from Ickleford, the only difference being the sites are on different sides of the A600.

I would also highlight that when you then turn to the site specific consideration of IC2 within the Greenbelt review (ref. 40 on page 112) IC2 is then only classed as making a Moderate contribution to Geen Belt. This is inconsistent with the report finding of the site being within Subparcel 12A, which the report concludes makes a Significant Contribution and I personally think this micro location within Subparcel 12A is particularly important in separating Hitchin and Ickleford.


I would encourage the council and the Inspector to review this proposed site allocation closely and reject it. The Green Belt around Hitchin is at its narrowest in this area and the proposed development represents an unacceptable and substantial erosion of the Green Belt. The situation is exacerbated by the site's close proximity to the Oughtonhead Nature Reserve, where its immediate surrounds should be preserved in my opinion. There is a lovely walk along the River Oughton from the Bedford Road into Oughtonhead Common and the proposed development of IC2 would significantly detract from this. To say there is no landscape impact of this development is in my opinion incorrect.

I also want to highlight inaccuracies in the council's Environmental Sustainability Appraisal dated September 2016.

In the site matrix (Appendix 6, page 76), the site is correctly noted under 'Land Use' as greenfield and grade 3 agricultural land but then under 'Environmental Protection' it is incorrectly noted as an existing brownfield site. The vast majority of the site is open field and grazing land. Living nearby and walking along the river into Oughton Head, I regularly see birds of prey hunting over that site in the field and I am sure the field part of the site provides an important ecological resource. This aspect of the site sustainability review is therefore Not Sound.

I also take issue with the comments within 'Protect and enhance landscapes' where the report states "the landscape is common and the impact of development moderate'. As already mentioned, this development would significantly impact on the outlook and landscape from the River Oughton pathway, which currently benefits from open countryside views here. If suddenly the horizon outlook is 40 houses this would significantly detract from the landscape. The report notes that this is a Landscape Conservation Area and it should therefore be protected. Again I think the comments and proposed allocation are therefore Not Sound.

The report also says that the site has access to open space. Yes the site adjoins green fields but these are in private ownership and used for agricultural purposes. There is therefore actually no access to open space. Again the comment is Not Sound.

I fundamentally believe this is a very important strip of Green Belt that needs to be preserved. If it was allocated, I am very concerned this would set a precedent for further incursion into the Green Belt in this area. I hope you will reject this allocation.

As a final comment, if an allocation in this vicinity is deemed necessary or justified, which I sincerely hope will not be the case, I would request that consideration is given to only the currently built portion of the site being available for residential, leaving the current field and grazing land open green space. I have marked up a plan and aerial photo showing my suggested amendment as a fall back.

The Ickleford development boundary should be similarly amended to exclude the green field part of the site.

However, I would reiterate my position that IC2 should be rejected outright.

Site IC3 - Bedford Road

In principle, I do not object to some housing allocation on part of this land but not all of it. A portion of it seems to be large derelict greenhouses and to a degree could be viewed as brownfield land sitting within the Green Belt that could be put to a better use.

However, I am concerned about the scale of the proposed allocation of 150 houses and the lack of detailed consultation on this site which has been added late in the process. My concern is increased as the plan envisages the relocation of the primary school, which is a fundamental part of the character of the village. What would happen to the existing school site, redevelopment for more housing?? Again I am not totally averse to this possibility but greater consultation and detail is required and then if housing could be accommodated on the existing school site could the allocations on un-built, Green Belt land be scaled back or removed entirely.

I therefore object to this site on grounds of being 'Not Legally Compliant' due to lack of prior detailed consultation. However, the principle of some residential on part of this site is something I would be willing to support subject to more detail on the nature and scale and interrelationship with the primary school.

My personal suggestion would be to allocate land to the south of the Icknield Way path (with a landscape buffer) for residential and for the Green Belt, agricultural land to the north of the Icknield Way path to remain protected Green Belt.

I have attached a plan with my suggested amendments.


SITE LS1 - Lower Stondon

In principle, I support a residential allocation here. Whilst in a rural area, it is beyond and outside the Green Belt and is in relative scale with the village of Lower Stondon and adjoins an existing new housing development. An allocation here would not lead to an erosion of the fragile Green Belt gap between Ickleford and Hitchin and is therefore preferable in my view.


OTHER CONCERNS:

Traffic generation: The scale of the three proposed sites on the Bedford Road (IC2, IC3 and LS1 in Lower Stondon) in my opinion will lead to an unacceptable cumulative traffic effect on the A600 Bedford Road, which is already very busy and congested at peak times.

I understand that the traffic modelling which the council has used is flawed and therefore this places further doubt over the Soundness of the allocations in this area.

I would also comment that in addition to additional cars pulling out onto Bedford Road, a pedestrian crossing would be required from IC2 to the bus stop on the other side of the Bedford Road, which would cause further traffic tail backs so close to the roundabout. Another reason why IC2 should be rejected as not suitable for this scale of development.

I would also highlight the proposals at RAF Henlow further up the Bedford Road outside of the NHDC Local Plan area, which is set to close by 2020 and become up to 780 homes. This development will further add to the traffic pressure on the Bedford Road with a significant proportion of people travelling into Hitchin.

I understand that NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan, which would include developments such as RAF Henlow. As a result, due to lack of coordination with neighbouring authorities the allocation for sites IC1, IC2, IC3 and LS1 are potentially not sound and I think this is particularly the case for those developments along the Bedford Road. The cumulative traffic impact of all these allocations needs to be properly considered and the analysis is currently flawed.


OTHER SUGGESTIONS:

The plan also does not take account of potential other housing sites in Ickleford. The vacant Green Man pub could accommodate a small housing development, the already developed commercial area at Ickleford Manor could also accommodate a residential development and I also understand that certain areas of Bowman's Mill are to be taken out of operation and could possibly provide potential in the future.

In my opinion, a better solution to housing needs could be achieved in Ickleford utilising brownfield sites, some of which sit within the Green Belt, that would reduce the need to build over valuable virgin Green Belt, that once it is gone we can never get back.

I am writing to register my comments and objections to the Local Plan in relation to the proposed residential sites in Ickleford, sites IC1, IC2, IC3 and LS1.

IC1 (Duncots Close)

Whilst this site is within the Green Belt and is therefore in contravention of National Planning Policy Framework, in principle I would support small housing development here. The incursion into Green Belt is relatively minor and would bring the building line in line with the houses on adjacent Laurel Way. There is also a natural boundary with trees etc shielding the landscape impact of this proposed development from Duncots field.

However, I understand there are concerns over sewer capacity and flooding and any development would need to be sensitively done and be sympathetic to the conservation area. If these concerns can be properly allayed then I am broadly supportive of this site.

IC2 (Burford Grange)

I wish to strongly object to the allocation of site IC2 for the proposed residential allocation of 40 + houses.

I consider the allocation of this site to be Not Sound for a number of reasons.

This site sits within the Green Belt and as such would be in contravention of National Planning Policy and conflicts with NHDC Strategic Objectives on the Green Belt.

The strip of Green Belt within which IC2 sits provides a critical role separating Hitchin from Ickleford and is also environmentally sensitive being in close proximity to Oughtonhead Nature Reserve and providing protection into beautiful open countryside beyond.

I would like to take issue and highlight inaccuracies and errors in the appraisal of this site, which make the allocation Not Sound.

Firstly, within the Green Belt Review July 2016, this site is identified as sitting within the Green Belt subparcel Oughtonhead 12A (page 33 of report), which concludes on page 49 that it plays an important role in preventing expansion of Hitchin northwards. It also plays a significant role in safeguarding the countryside. Overall the report concludes it makes a Significant Contribution.

However, the assessment of 12A makes an error when it says it plays no role in preventing merger of neighbouring towns.

This is clearly wrong as this narrow stretch of green belt where IC2 sits plays a key role separating Hitchin from Ickleford. My conclusion is confirmed by the assessment of green belt sub sector 13c on page 50 (which contains the Ickleford Manor site diagonally opposite IC2 on the other side of the A600), which is noted as playing a key role separating Hitchin from Ickleford. The Green Belt review is therefore inconsistent and clearly the findings in relation to 12A and specifically the land that IC2 occupies is in error. The allocation is therefore Not Sound.

How can the council come to a different conclusion on two adjacent pieces of greenbelt land playing the same role separating Hitchin from Ickleford, the only difference being the sites are on different sides of the A600.

I would also highlight that when you then turn to the site specific consideration of IC2 within the Greenbelt review (ref. 40 on page 112) IC2 is then only classed as making a Moderate contribution to Geen Belt. This is inconsistent with the report finding of the site being within Subparcel 12A, which the report concludes makes a Significant Contribution and I personally think this micro location within Subparcel 12A is particularly important in separating Hitchin and Ickleford.


I would encourage the council and the Inspector to review this proposed site allocation closely and reject it. The Green Belt around Hitchin is at its narrowest in this area and the proposed development represents an unacceptable and substantial erosion of the Green Belt. The situation is exacerbated by the site's close proximity to the Oughtonhead Nature Reserve, where its immediate surrounds should be preserved in my opinion. There is a lovely walk along the River Oughton from the Bedford Road into Oughtonhead Common and the proposed development of IC2 would significantly detract from this. To say there is no landscape impact of this development is in my opinion incorrect.

I also want to highlight inaccuracies in the council's Environmental Sustainability Appraisal dated September 2016.

In the site matrix (Appendix 6, page 76), the site is correctly noted under 'Land Use' as greenfield and grade 3 agricultural land but then under 'Environmental Protection' it is incorrectly noted as an existing brownfield site. The vast majority of the site is open field and grazing land. Living nearby and walking along the river into Oughton Head, I regularly see birds of prey hunting over that site in the field and I am sure the field part of the site provides an important ecological resource. This aspect of the site sustainability review is therefore Not Sound.

I also take issue with the comments within 'Protect and enhance landscapes' where the report states "the landscape is common and the impact of development moderate'. As already mentioned, this development would significantly impact on the outlook and landscape from the River Oughton pathway, which currently benefits from open countryside views here. If suddenly the horizon outlook is 40 houses this would significantly detract from the landscape. The report notes that this is a Landscape Conservation Area and it should therefore be protected. Again I think the comments and proposed allocation are therefore Not Sound.

The report also says that the site has access to open space. Yes the site adjoins green fields but these are in private ownership and used for agricultural purposes. There is therefore actually no access to open space. Again the comment is Not Sound.

I fundamentally believe this is a very important strip of Green Belt that needs to be preserved. If it was allocated, I am very concerned this would set a precedent for further incursion into the Green Belt in this area. I hope you will reject this allocation.

As a final comment, if an allocation in this vicinity is deemed necessary or justified, which I sincerely hope will not be the case, I would request that consideration is given to only the currently built portion of the site being available for residential, leaving the current field and grazing land open green space. I have marked up a plan and aerial photo showing my suggested amendment as a fall back.

The Ickleford development boundary should be similarly amended to exclude the green field part of the site.

However, I would reiterate my position that IC2 should be rejected outright.

Site IC3 - Bedford Road

In principle, I do not object to some housing allocation on part of this land but not all of it. A portion of it seems to be large derelict greenhouses and to a degree could be viewed as brownfield land sitting within the Green Belt that could be put to a better use.

However, I am concerned about the scale of the proposed allocation of 150 houses and the lack of detailed consultation on this site which has been added late in the process. My concern is increased as the plan envisages the relocation of the primary school, which is a fundamental part of the character of the village. What would happen to the existing school site, redevelopment for more housing?? Again I am not totally averse to this possibility but greater consultation and detail is required and then if housing could be accommodated on the existing school site could the allocations on un-built, Green Belt land be scaled back or removed entirely.

I therefore object to this site on grounds of being 'Not Legally Compliant' due to lack of prior detailed consultation. However, the principle of some residential on part of this site is something I would be willing to support subject to more detail on the nature and scale and interrelationship with the primary school.

My personal suggestion would be to allocate land to the south of the Icknield Way path (with a landscape buffer) for residential and for the Green Belt, agricultural land to the north of the Icknield Way path to remain protected Green Belt.

I have attached a plan with my suggested amendments.


SITE LS1 - Lower Stondon

In principle, I support a residential allocation here. Whilst in a rural area, it is beyond and outside the Green Belt and is in relative scale with the village of Lower Stondon and adjoins an existing new housing development. An allocation here would not lead to an erosion of the fragile Green Belt gap between Ickleford and Hitchin and is therefore preferable in my view.


OTHER CONCERNS:

Traffic generation: The scale of the three proposed sites on the Bedford Road (IC2, IC3 and LS1 in Lower Stondon) in my opinion will lead to an unacceptable cumulative traffic effect on the A600 Bedford Road, which is already very busy and congested at peak times.

I understand that the traffic modelling which the council has used is flawed and therefore this places further doubt over the Soundness of the allocations in this area.

I would also comment that in addition to additional cars pulling out onto Bedford Road, a pedestrian crossing would be required from IC2 to the bus stop on the other side of the Bedford Road, which would cause further traffic tail backs so close to the roundabout. Another reason why IC2 should be rejected as not suitable for this scale of development.

I would also highlight the proposals at RAF Henlow further up the Bedford Road outside of the NHDC Local Plan area, which is set to close by 2020 and become up to 780 homes. This development will further add to the traffic pressure on the Bedford Road with a significant proportion of people travelling into Hitchin.

I understand that NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan, which would include developments such as RAF Henlow. As a result, due to lack of coordination with neighbouring authorities the allocation for sites IC1, IC2, IC3 and LS1 are potentially not sound and I think this is particularly the case for those developments along the Bedford Road. The cumulative traffic impact of all these allocations needs to be properly considered and the analysis is currently flawed.


OTHER SUGGESTIONS:

The plan also does not take account of potential other housing sites in Ickleford. The vacant Green Man pub could accommodate a small housing development, the already developed commercial area at Ickleford Manor could also accommodate a residential development and I also understand that certain areas of Bowman's Mill are to be taken out of operation and could possibly provide potential in the future.

In my opinion, a better solution to housing needs could be achieved in Ickleford utilising brownfield sites, some of which sit within the Green Belt, that would reduce the need to build over valuable virgin Green Belt, that once it is gone we can never get back.

I am writing to register my comments and objections to the Local Plan in relation to the proposed residential sites in Ickleford, sites IC1, IC2, IC3 and LS1.

IC1 (Duncots Close)

Whilst this site is within the Green Belt and is therefore in contravention of National Planning Policy Framework, in principle I would support small housing development here. The incursion into Green Belt is relatively minor and would bring the building line in line with the houses on adjacent Laurel Way. There is also a natural boundary with trees etc shielding the landscape impact of this proposed development from Duncots field.

However, I understand there are concerns over sewer capacity and flooding and any development would need to be sensitively done and be sympathetic to the conservation area. If these concerns can be properly allayed then I am broadly supportive of this site.

IC2 (Burford Grange)

I wish to strongly object to the allocation of site IC2 for the proposed residential allocation of 40 + houses.

I consider the allocation of this site to be Not Sound for a number of reasons.

This site sits within the Green Belt and as such would be in contravention of National Planning Policy and conflicts with NHDC Strategic Objectives on the Green Belt.

The strip of Green Belt within which IC2 sits provides a critical role separating Hitchin from Ickleford and is also environmentally sensitive being in close proximity to Oughtonhead Nature Reserve and providing protection into beautiful open countryside beyond.

I would like to take issue and highlight inaccuracies and errors in the appraisal of this site, which make the allocation Not Sound.

Firstly, within the Green Belt Review July 2016, this site is identified as sitting within the Green Belt subparcel Oughtonhead 12A (page 33 of report), which concludes on page 49 that it plays an important role in preventing expansion of Hitchin northwards. It also plays a significant role in safeguarding the countryside. Overall the report concludes it makes a Significant Contribution.

However, the assessment of 12A makes an error when it says it plays no role in preventing merger of neighbouring towns.

This is clearly wrong as this narrow stretch of green belt where IC2 sits plays a key role separating Hitchin from Ickleford. My conclusion is confirmed by the assessment of green belt sub sector 13c on page 50 (which contains the Ickleford Manor site diagonally opposite IC2 on the other side of the A600), which is noted as playing a key role separating Hitchin from Ickleford. The Green Belt review is therefore inconsistent and clearly the findings in relation to 12A and specifically the land that IC2 occupies is in error. The allocation is therefore Not Sound.

How can the council come to a different conclusion on two adjacent pieces of greenbelt land playing the same role separating Hitchin from Ickleford, the only difference being the sites are on different sides of the A600.

I would also highlight that when you then turn to the site specific consideration of IC2 within the Greenbelt review (ref. 40 on page 112) IC2 is then only classed as making a Moderate contribution to Geen Belt. This is inconsistent with the report finding of the site being within Subparcel 12A, which the report concludes makes a Significant Contribution and I personally think this micro location within Subparcel 12A is particularly important in separating Hitchin and Ickleford.


I would encourage the council and the Inspector to review this proposed site allocation closely and reject it. The Green Belt around Hitchin is at its narrowest in this area and the proposed development represents an unacceptable and substantial erosion of the Green Belt. The situation is exacerbated by the site's close proximity to the Oughtonhead Nature Reserve, where its immediate surrounds should be preserved in my opinion. There is a lovely walk along the River Oughton from the Bedford Road into Oughtonhead Common and the proposed development of IC2 would significantly detract from this. To say there is no landscape impact of this development is in my opinion incorrect.

I also want to highlight inaccuracies in the council's Environmental Sustainability Appraisal dated September 2016.

In the site matrix (Appendix 6, page 76), the site is correctly noted under 'Land Use' as greenfield and grade 3 agricultural land but then under 'Environmental Protection' it is incorrectly noted as an existing brownfield site. The vast majority of the site is open field and grazing land. Living nearby and walking along the river into Oughton Head, I regularly see birds of prey hunting over that site in the field and I am sure the field part of the site provides an important ecological resource. This aspect of the site sustainability review is therefore Not Sound.

I also take issue with the comments within 'Protect and enhance landscapes' where the report states "the landscape is common and the impact of development moderate'. As already mentioned, this development would significantly impact on the outlook and landscape from the River Oughton pathway, which currently benefits from open countryside views here. If suddenly the horizon outlook is 40 houses this would significantly detract from the landscape. The report notes that this is a Landscape Conservation Area and it should therefore be protected. Again I think the comments and proposed allocation are therefore Not Sound.

The report also says that the site has access to open space. Yes the site adjoins green fields but these are in private ownership and used for agricultural purposes. There is therefore actually no access to open space. Again the comment is Not Sound.

I fundamentally believe this is a very important strip of Green Belt that needs to be preserved. If it was allocated, I am very concerned this would set a precedent for further incursion into the Green Belt in this area. I hope you will reject this allocation.

As a final comment, if an allocation in this vicinity is deemed necessary or justified, which I sincerely hope will not be the case, I would request that consideration is given to only the currently built portion of the site being available for residential, leaving the current field and grazing land open green space. I have marked up a plan and aerial photo showing my suggested amendment as a fall back.

The Ickleford development boundary should be similarly amended to exclude the green field part of the site.

However, I would reiterate my position that IC2 should be rejected outright.

Site IC3 - Bedford Road

In principle, I do not object to some housing allocation on part of this land but not all of it. A portion of it seems to be large derelict greenhouses and to a degree could be viewed as brownfield land sitting within the Green Belt that could be put to a better use.

However, I am concerned about the scale of the proposed allocation of 150 houses and the lack of detailed consultation on this site which has been added late in the process. My concern is increased as the plan envisages the relocation of the primary school, which is a fundamental part of the character of the village. What would happen to the existing school site, redevelopment for more housing?? Again I am not totally averse to this possibility but greater consultation and detail is required and then if housing could be accommodated on the existing school site could the allocations on un-built, Green Belt land be scaled back or removed entirely.

I therefore object to this site on grounds of being 'Not Legally Compliant' due to lack of prior detailed consultation. However, the principle of some residential on part of this site is something I would be willing to support subject to more detail on the nature and scale and interrelationship with the primary school.

My personal suggestion would be to allocate land to the south of the Icknield Way path (with a landscape buffer) for residential and for the Green Belt, agricultural land to the north of the Icknield Way path to remain protected Green Belt.

I have attached a plan with my suggested amendments.


SITE LS1 - Lower Stondon

In principle, I support a residential allocation here. Whilst in a rural area, it is beyond and outside the Green Belt and is in relative scale with the village of Lower Stondon and adjoins an existing new housing development. An allocation here would not lead to an erosion of the fragile Green Belt gap between Ickleford and Hitchin and is therefore preferable in my view.


OTHER CONCERNS:

Traffic generation: The scale of the three proposed sites on the Bedford Road (IC2, IC3 and LS1 in Lower Stondon) in my opinion will lead to an unacceptable cumulative traffic effect on the A600 Bedford Road, which is already very busy and congested at peak times.

I understand that the traffic modelling which the council has used is flawed and therefore this places further doubt over the Soundness of the allocations in this area.

I would also comment that in addition to additional cars pulling out onto Bedford Road, a pedestrian crossing would be required from IC2 to the bus stop on the other side of the Bedford Road, which would cause further traffic tail backs so close to the roundabout. Another reason why IC2 should be rejected as not suitable for this scale of development.

I would also highlight the proposals at RAF Henlow further up the Bedford Road outside of the NHDC Local Plan area, which is set to close by 2020 and become up to 780 homes. This development will further add to the traffic pressure on the Bedford Road with a significant proportion of people travelling into Hitchin.

I understand that NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan, which would include developments such as RAF Henlow. As a result, due to lack of coordination with neighbouring authorities the allocation for sites IC1, IC2, IC3 and LS1 are potentially not sound and I think this is particularly the case for those developments along the Bedford Road. The cumulative traffic impact of all these allocations needs to be properly considered and the analysis is currently flawed.


OTHER SUGGESTIONS:

The plan also does not take account of potential other housing sites in Ickleford. The vacant Green Man pub could accommodate a small housing development, the already developed commercial area at Ickleford Manor could also accommodate a residential development and I also understand that certain areas of Bowman's Mill are to be taken out of operation and could possibly provide potential in the future.

In my opinion, a better solution to housing needs could be achieved in Ickleford utilising brownfield sites, some of which sit within the Green Belt, that would reduce the need to build over valuable virgin Green Belt, that once it is gone we can never get back.

I am writing to register my comments and objections to the Local Plan in relation to the proposed residential sites in Ickleford, sites IC1, IC2, IC3 and LS1.

IC1 (Duncots Close)

Whilst this site is within the Green Belt and is therefore in contravention of National Planning Policy Framework, in principle I would support small housing development here. The incursion into Green Belt is relatively minor and would bring the building line in line with the houses on adjacent Laurel Way. There is also a natural boundary with trees etc shielding the landscape impact of this proposed development from Duncots field.

However, I understand there are concerns over sewer capacity and flooding and any development would need to be sensitively done and be sympathetic to the conservation area. If these concerns can be properly allayed then I am broadly supportive of this site.

IC2 (Burford Grange)

I wish to strongly object to the allocation of site IC2 for the proposed residential allocation of 40 + houses.

I consider the allocation of this site to be Not Sound for a number of reasons.

This site sits within the Green Belt and as such would be in contravention of National Planning Policy and conflicts with NHDC Strategic Objectives on the Green Belt.

The strip of Green Belt within which IC2 sits provides a critical role separating Hitchin from Ickleford and is also environmentally sensitive being in close proximity to Oughtonhead Nature Reserve and providing protection into beautiful open countryside beyond.

I would like to take issue and highlight inaccuracies and errors in the appraisal of this site, which make the allocation Not Sound.

Firstly, within the Green Belt Review July 2016, this site is identified as sitting within the Green Belt subparcel Oughtonhead 12A (page 33 of report), which concludes on page 49 that it plays an important role in preventing expansion of Hitchin northwards. It also plays a significant role in safeguarding the countryside. Overall the report concludes it makes a Significant Contribution.

However, the assessment of 12A makes an error when it says it plays no role in preventing merger of neighbouring towns.

This is clearly wrong as this narrow stretch of green belt where IC2 sits plays a key role separating Hitchin from Ickleford. My conclusion is confirmed by the assessment of green belt sub sector 13c on page 50 (which contains the Ickleford Manor site diagonally opposite IC2 on the other side of the A600), which is noted as playing a key role separating Hitchin from Ickleford. The Green Belt review is therefore inconsistent and clearly the findings in relation to 12A and specifically the land that IC2 occupies is in error. The allocation is therefore Not Sound.

How can the council come to a different conclusion on two adjacent pieces of greenbelt land playing the same role separating Hitchin from Ickleford, the only difference being the sites are on different sides of the A600.

I would also highlight that when you then turn to the site specific consideration of IC2 within the Greenbelt review (ref. 40 on page 112) IC2 is then only classed as making a Moderate contribution to Geen Belt. This is inconsistent with the report finding of the site being within Subparcel 12A, which the report concludes makes a Significant Contribution and I personally think this micro location within Subparcel 12A is particularly important in separating Hitchin and Ickleford.


I would encourage the council and the Inspector to review this proposed site allocation closely and reject it. The Green Belt around Hitchin is at its narrowest in this area and the proposed development represents an unacceptable and substantial erosion of the Green Belt. The situation is exacerbated by the site's close proximity to the Oughtonhead Nature Reserve, where its immediate surrounds should be preserved in my opinion. There is a lovely walk along the River Oughton from the Bedford Road into Oughtonhead Common and the proposed development of IC2 would significantly detract from this. To say there is no landscape impact of this development is in my opinion incorrect.

I also want to highlight inaccuracies in the council's Environmental Sustainability Appraisal dated September 2016.

In the site matrix (Appendix 6, page 76), the site is correctly noted under 'Land Use' as greenfield and grade 3 agricultural land but then under 'Environmental Protection' it is incorrectly noted as an existing brownfield site. The vast majority of the site is open field and grazing land. Living nearby and walking along the river into Oughton Head, I regularly see birds of prey hunting over that site in the field and I am sure the field part of the site provides an important ecological resource. This aspect of the site sustainability review is therefore Not Sound.

I also take issue with the comments within 'Protect and enhance landscapes' where the report states "the landscape is common and the impact of development moderate'. As already mentioned, this development would significantly impact on the outlook and landscape from the River Oughton pathway, which currently benefits from open countryside views here. If suddenly the horizon outlook is 40 houses this would significantly detract from the landscape. The report notes that this is a Landscape Conservation Area and it should therefore be protected. Again I think the comments and proposed allocation are therefore Not Sound.

The report also says that the site has access to open space. Yes the site adjoins green fields but these are in private ownership and used for agricultural purposes. There is therefore actually no access to open space. Again the comment is Not Sound.

I fundamentally believe this is a very important strip of Green Belt that needs to be preserved. If it was allocated, I am very concerned this would set a precedent for further incursion into the Green Belt in this area. I hope you will reject this allocation.

As a final comment, if an allocation in this vicinity is deemed necessary or justified, which I sincerely hope will not be the case, I would request that consideration is given to only the currently built portion of the site being available for residential, leaving the current field and grazing land open green space. I have marked up a plan and aerial photo showing my suggested amendment as a fall back.

The Ickleford development boundary should be similarly amended to exclude the green field part of the site.

However, I would reiterate my position that IC2 should be rejected outright.

Site IC3 - Bedford Road

In principle, I do not object to some housing allocation on part of this land but not all of it. A portion of it seems to be large derelict greenhouses and to a degree could be viewed as brownfield land sitting within the Green Belt that could be put to a better use.

However, I am concerned about the scale of the proposed allocation of 150 houses and the lack of detailed consultation on this site which has been added late in the process. My concern is increased as the plan envisages the relocation of the primary school, which is a fundamental part of the character of the village. What would happen to the existing school site, redevelopment for more housing?? Again I am not totally averse to this possibility but greater consultation and detail is required and then if housing could be accommodated on the existing school site could the allocations on un-built, Green Belt land be scaled back or removed entirely.

I therefore object to this site on grounds of being 'Not Legally Compliant' due to lack of prior detailed consultation. However, the principle of some residential on part of this site is something I would be willing to support subject to more detail on the nature and scale and interrelationship with the primary school.

My personal suggestion would be to allocate land to the south of the Icknield Way path (with a landscape buffer) for residential and for the Green Belt, agricultural land to the north of the Icknield Way path to remain protected Green Belt.

I have attached a plan with my suggested amendments.


SITE LS1 - Lower Stondon

In principle, I support a residential allocation here. Whilst in a rural area, it is beyond and outside the Green Belt and is in relative scale with the village of Lower Stondon and adjoins an existing new housing development. An allocation here would not lead to an erosion of the fragile Green Belt gap between Ickleford and Hitchin and is therefore preferable in my view.


OTHER CONCERNS:

Traffic generation: The scale of the three proposed sites on the Bedford Road (IC2, IC3 and LS1 in Lower Stondon) in my opinion will lead to an unacceptable cumulative traffic effect on the A600 Bedford Road, which is already very busy and congested at peak times.

I understand that the traffic modelling which the council has used is flawed and therefore this places further doubt over the Soundness of the allocations in this area.

I would also comment that in addition to additional cars pulling out onto Bedford Road, a pedestrian crossing would be required from IC2 to the bus stop on the other side of the Bedford Road, which would cause further traffic tail backs so close to the roundabout. Another reason why IC2 should be rejected as not suitable for this scale of development.

I would also highlight the proposals at RAF Henlow further up the Bedford Road outside of the NHDC Local Plan area, which is set to close by 2020 and become up to 780 homes. This development will further add to the traffic pressure on the Bedford Road with a significant proportion of people travelling into Hitchin.

I understand that NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan, which would include developments such as RAF Henlow. As a result, due to lack of coordination with neighbouring authorities the allocation for sites IC1, IC2, IC3 and LS1 are potentially not sound and I think this is particularly the case for those developments along the Bedford Road. The cumulative traffic impact of all these allocations needs to be properly considered and the analysis is currently flawed.


OTHER SUGGESTIONS:

The plan also does not take account of potential other housing sites in Ickleford. The vacant Green Man pub could accommodate a small housing development, the already developed commercial area at Ickleford Manor could also accommodate a residential development and I also understand that certain areas of Bowman's Mill are to be taken out of operation and could possibly provide potential in the future.

In my opinion, a better solution to housing needs could be achieved in Ickleford utilising brownfield sites, some of which sit within the Green Belt, that would reduce the need to build over valuable virgin Green Belt, that once it is gone we can never get back.

I am writing to register my comments and objections to the Local Plan in relation to the proposed residential sites in Ickleford, sites IC1, IC2, IC3 and LS1.

IC1 (Duncots Close)

Whilst this site is within the Green Belt and is therefore in contravention of National Planning Policy Framework, in principle I would support small housing development here. The incursion into Green Belt is relatively minor and would bring the building line in line with the houses on adjacent Laurel Way. There is also a natural boundary with trees etc shielding the landscape impact of this proposed development from Duncots field.

However, I understand there are concerns over sewer capacity and flooding and any development would need to be sensitively done and be sympathetic to the conservation area. If these concerns can be properly allayed then I am broadly supportive of this site.

IC2 (Burford Grange)

I wish to strongly object to the allocation of site IC2 for the proposed residential allocation of 40 + houses.

I consider the allocation of this site to be Not Sound for a number of reasons.

This site sits within the Green Belt and as such would be in contravention of National Planning Policy and conflicts with NHDC Strategic Objectives on the Green Belt.

The strip of Green Belt within which IC2 sits provides a critical role separating Hitchin from Ickleford and is also environmentally sensitive being in close proximity to Oughtonhead Nature Reserve and providing protection into beautiful open countryside beyond.

I would like to take issue and highlight inaccuracies and errors in the appraisal of this site, which make the allocation Not Sound.

Firstly, within the Green Belt Review July 2016, this site is identified as sitting within the Green Belt subparcel Oughtonhead 12A (page 33 of report), which concludes on page 49 that it plays an important role in preventing expansion of Hitchin northwards. It also plays a significant role in safeguarding the countryside. Overall the report concludes it makes a Significant Contribution.

However, the assessment of 12A makes an error when it says it plays no role in preventing merger of neighbouring towns.

This is clearly wrong as this narrow stretch of green belt where IC2 sits plays a key role separating Hitchin from Ickleford. My conclusion is confirmed by the assessment of green belt sub sector 13c on page 50 (which contains the Ickleford Manor site diagonally opposite IC2 on the other side of the A600), which is noted as playing a key role separating Hitchin from Ickleford. The Green Belt review is therefore inconsistent and clearly the findings in relation to 12A and specifically the land that IC2 occupies is in error. The allocation is therefore Not Sound.

How can the council come to a different conclusion on two adjacent pieces of greenbelt land playing the same role separating Hitchin from Ickleford, the only difference being the sites are on different sides of the A600.

I would also highlight that when you then turn to the site specific consideration of IC2 within the Greenbelt review (ref. 40 on page 112) IC2 is then only classed as making a Moderate contribution to Geen Belt. This is inconsistent with the report finding of the site being within Subparcel 12A, which the report concludes makes a Significant Contribution and I personally think this micro location within Subparcel 12A is particularly important in separating Hitchin and Ickleford.


I would encourage the council and the Inspector to review this proposed site allocation closely and reject it. The Green Belt around Hitchin is at its narrowest in this area and the proposed development represents an unacceptable and substantial erosion of the Green Belt. The situation is exacerbated by the site's close proximity to the Oughtonhead Nature Reserve, where its immediate surrounds should be preserved in my opinion. There is a lovely walk along the River Oughton from the Bedford Road into Oughtonhead Common and the proposed development of IC2 would significantly detract from this. To say there is no landscape impact of this development is in my opinion incorrect.

I also want to highlight inaccuracies in the council's Environmental Sustainability Appraisal dated September 2016.

In the site matrix (Appendix 6, page 76), the site is correctly noted under 'Land Use' as greenfield and grade 3 agricultural land but then under 'Environmental Protection' it is incorrectly noted as an existing brownfield site. The vast majority of the site is open field and grazing land. Living nearby and walking along the river into Oughton Head, I regularly see birds of prey hunting over that site in the field and I am sure the field part of the site provides an important ecological resource. This aspect of the site sustainability review is therefore Not Sound.

I also take issue with the comments within 'Protect and enhance landscapes' where the report states "the landscape is common and the impact of development moderate'. As already mentioned, this development would significantly impact on the outlook and landscape from the River Oughton pathway, which currently benefits from open countryside views here. If suddenly the horizon outlook is 40 houses this would significantly detract from the landscape. The report notes that this is a Landscape Conservation Area and it should therefore be protected. Again I think the comments and proposed allocation are therefore Not Sound.

The report also says that the site has access to open space. Yes the site adjoins green fields but these are in private ownership and used for agricultural purposes. There is therefore actually no access to open space. Again the comment is Not Sound.

I fundamentally believe this is a very important strip of Green Belt that needs to be preserved. If it was allocated, I am very concerned this would set a precedent for further incursion into the Green Belt in this area. I hope you will reject this allocation.

As a final comment, if an allocation in this vicinity is deemed necessary or justified, which I sincerely hope will not be the case, I would request that consideration is given to only the currently built portion of the site being available for residential, leaving the current field and grazing land open green space. I have marked up a plan and aerial photo showing my suggested amendment as a fall back.

The Ickleford development boundary should be similarly amended to exclude the green field part of the site.

However, I would reiterate my position that IC2 should be rejected outright.

Site IC3 - Bedford Road

In principle, I do not object to some housing allocation on part of this land but not all of it. A portion of it seems to be large derelict greenhouses and to a degree could be viewed as brownfield land sitting within the Green Belt that could be put to a better use.

However, I am concerned about the scale of the proposed allocation of 150 houses and the lack of detailed consultation on this site which has been added late in the process. My concern is increased as the plan envisages the relocation of the primary school, which is a fundamental part of the character of the village. What would happen to the existing school site, redevelopment for more housing?? Again I am not totally averse to this possibility but greater consultation and detail is required and then if housing could be accommodated on the existing school site could the allocations on un-built, Green Belt land be scaled back or removed entirely.

I therefore object to this site on grounds of being 'Not Legally Compliant' due to lack of prior detailed consultation. However, the principle of some residential on part of this site is something I would be willing to support subject to more detail on the nature and scale and interrelationship with the primary school.

My personal suggestion would be to allocate land to the south of the Icknield Way path (with a landscape buffer) for residential and for the Green Belt, agricultural land to the north of the Icknield Way path to remain protected Green Belt.

I have attached a plan with my suggested amendments.


SITE LS1 - Lower Stondon

In principle, I support a residential allocation here. Whilst in a rural area, it is beyond and outside the Green Belt and is in relative scale with the village of Lower Stondon and adjoins an existing new housing development. An allocation here would not lead to an erosion of the fragile Green Belt gap between Ickleford and Hitchin and is therefore preferable in my view.


OTHER CONCERNS:

Traffic generation: The scale of the three proposed sites on the Bedford Road (IC2, IC3 and LS1 in Lower Stondon) in my opinion will lead to an unacceptable cumulative traffic effect on the A600 Bedford Road, which is already very busy and congested at peak times.

I understand that the traffic modelling which the council has used is flawed and therefore this places further doubt over the Soundness of the allocations in this area.

I would also comment that in addition to additional cars pulling out onto Bedford Road, a pedestrian crossing would be required from IC2 to the bus stop on the other side of the Bedford Road, which would cause further traffic tail backs so close to the roundabout. Another reason why IC2 should be rejected as not suitable for this scale of development.

I would also highlight the proposals at RAF Henlow further up the Bedford Road outside of the NHDC Local Plan area, which is set to close by 2020 and become up to 780 homes. This development will further add to the traffic pressure on the Bedford Road with a significant proportion of people travelling into Hitchin.

I understand that NHDC have not accounted for any impact associated with the Central Bedfordshire Local Plan, which would include developments such as RAF Henlow. As a result, due to lack of coordination with neighbouring authorities the allocation for sites IC1, IC2, IC3 and LS1 are potentially not sound and I think this is particularly the case for those developments along the Bedford Road. The cumulative traffic impact of all these allocations needs to be properly considered and the analysis is currently flawed.


OTHER SUGGESTIONS:

The plan also does not take account of potential other housing sites in Ickleford. The vacant Green Man pub could accommodate a small housing development, the already developed commercial area at Ickleford Manor could also accommodate a residential development and I also understand that certain areas of Bowman's Mill are to be taken out of operation and could possibly provide potential in the future.

In my opinion, a better solution to housing needs could be achieved in Ickleford utilising brownfield sites, some of which sit within the Green Belt, that would reduce the need to build over valuable virgin Green Belt, that once it is gone we can never get back.