Proposed Main Modifications

Our client supports proposed Main Modification 010 which amends Policy SP2 to alter the categorisation of Little Wymondley from a Category A village to an 'identified village for growth'.

We agree that this change better explains the spatial strategy as it distinguishes those settlements on which the Plan is reliant for the provision of the majority of the development needed to ensure the delivery of the overall spatial strategy.

We note that a figure of 306 dwellings is ascribed to Little Wymondley.

The equivalent figure set out in ED37 2A - Draft Revision to Policy SP2 is given as 316. We question which is the correct figure, albeit, that for the following reasons we do not consider this discrepancy critical to our support in principle to MM010.

Notwithstanding consideration of the correct 'baseline' figure for Little Wymondley, the figures quoted need to be understood in the context of the requirement set out in the policy to provide at least 15,950 new homes and therefore we also support the footnote to the Policy which makes clear that the figures quoted are not a target and do not necessarily represent the maximum number of new homes that will be built. For absolute clarity however we would ask that 'in any given location' is added to the end of the footnote.

We support the proposed additional paragraph as it sets out a series of simple justifications for the understanding of the reader, explaining the broad rationale underlying the identification of the villages considered suitable to accommodate a higher level of planned growth. We believe that this justification is sufficient in detail within this part of the Plan, which should in any case be read in the round to understand why the allocation of sites in those specific locations are considered appropriate: conversely it is not necessary to provide a detailed exposition as to why individual settlements are included or excluded from consideration - where again the Plan should be read in its entirety. The additional wording is considered therefore sufficient to support the effectiveness of the Plan in providing context to the spatial strategy.

In that context we support MM012 insofar as it identifies Little Wymondley as a suitable location based on its proximity to, and sustainable transport connections with, neighbouring towns.

We support the amendment to part f insofar as it allows for the consideration of robust evidence on viability to be taken into account in the consideration of the contributions otherwise to be required towards the delivery of infrastructure and/or mitigation measures.

We consider that this is an important amendment to the published policy as it allows each proposal to be considered on its merits and is more likely to enable development to proceed - this is especially important where the overall spatial strategy is dependent on a relatively small number of allocated sites and a failure or delay in delivery could have an overall adverse impact on the planned growth of the District. The amendment to the Policy will provide the basis for a rational consideration of all relevant viability factors and therefore supports the effectiveness of the Plan when read as a whole.

Consequent on our support for the Modification of Policy SP7 part f set out in MM032, we also support the Modification of paragraph 4.83 to support the effectiveness of the changes set out in MM032.

We support the Modification of Policy SP8 as proposed for consistency with the Modification of Policy SP2 in relation to the description of the spatial strategy.

We support the Modification to Policy NE8 as the alteration allows discretion to the Council to determine whether the most appropriate drainage solution has been proposed having regard to the context of the site and proposed development as a whole. We consider that this therefore supports the effectiveness of the Plan as an instrument for determining the suitability of development.

Consequent on our support for the Modifications to Policy SP2 and supporting text (MM010 and MM012) we support the Modification of paragraph 13.348 for the purposes of consistency and effectiveness within the Plan.

Having regard to our comment on the inconsistency between MM010 with reference to a figure of 306 dwellings in Little Wymondley in relation to a figure of 316 dwellings referred to in ED37 2A, we note that the Modification to paragraph 13.352 implies that the figure should be 317.

We invite consistency between MM010 and MM366 without comment on which should be the correct figure.

We note and broadly support the Modifications to Policy WY1 having regard to the discussions undertaken at the Examination. Specifically, we note the Inspector's requested actions as set out in ED96 and the Council's proposed responses in ED148B.

Bullet 3
Specifically, we consider that the Modification to the wording of bullet 3 makes sufficiently clear that the solutions necessary to avoid exacerbating flood risk and to address an appropriate surface water drainage regime are not bound by a requirement also to redress the propensity for flooding within the existing built up area of Little Wymondley - which lies upstream of the potential discharge points of the allocated site - but that such solutions should not compound existing issues.

We do not object to the reference to consulting the Lead Local Flood Authority notwithstanding that this shall be a matter of course as part of any planning application, but note that no reference is made to any consultation with the Environment Agency who are responsible from flooding arising from "main rivers" and are also likely to be a consultee on any development proposal.

However, notwithstanding the actions recorded as necessary in ED96, we do question why the policy should be modified to require consultation with Stevenage Borough Council which has no jurisdiction over flood risk matters even within the boundary of its own authority and whose administrative area lies entirely upstream of Little Wymondley and the Ash Brook into which it is anticipated that surface water flows will be directed. We note in this context that the Stevenage Borough Council's own website directs all matters concerning flooding and flood risk to the County Council (as LLFA) and to the Environment Agency and that the website makes clear that the Borough Council itself is only responsible for "the drainage of the roads and pedestrian areas within the town centre and for flooding on areas of land in the Council's ownership" (http://www.stevenage.gov.uk/about-the-council/156034/41316/). Moreover, the Flood Alleviation Feasibility Study August 2015 commissioned by Hertfordshire County Council did not include any reference to, or obvious input by, Stevenage Borough Council - notwithstanding that it considers the Ash Brook catchment within the Borough Council's area.

We therefore suggest that reference to Stevenage Borough Council, who demonstrably have no jurisdiction or expertise in the matter of flooding, be removed from the Policy as clearly any consultation will not be able to be effectively addressed by that Authority. We would not object to reference to consultation with the Environment Agency being substituted albeit this will, as with the LLFA, be expected to be undertaken as a matter of course.

Bullet 5
We agree the addition of a new bullet 5 in order to make clear that any application will need to consider the traffic impacts on Stevenage Road as it passes through the village, which considers non-motorised access opportunities, and which addresses the issue of potential severance between the north and south of the village. In this respect we consider that any perception of severance may depend on the solution to primary education provision noted in bullet 1 but we do not object to the identification of the issue as necessary to be considered in any application.

Bullet 11
Whilst we do not see in ED96 reference to the need to undertake a Contaminated Land Preliminary Risk Assessment for the site, having regard to the discussion at the EiP and to our client's knowledge of the site, we do not object to the additional bullet point where it supports the effectiveness of the Plan.

Whilst we do not disagree with the principle of adding to the wording proposed in respect of paragraph 13.355, as it reflects the potential impact of development arising from Site WY1, we are concerned that as published it could be interpreted to require investigation, mitigation packages and wider consideration of network issues concerning A1(M) J8 to be concluded prior to the development of Site WY1.

Whilst we note and support the reference in new bullet 5 to the actions specifically necessary in relation to Site WY1 we believe that the effectiveness of the Plan would be enhanced by distinguishing more clearly between the works necessary to deliver Site WY1 and those which may be needed to improve the operation of the wider network having regard to factors other than the development of the allocated site within the Parish.

We therefore suggest that the Modification be revised to make that distinction clear to the reader, achieved by additional wording as follows:

Our transport modelling identifies the junction between Hitchin Road and Arch Road in Great Wymondley as a location where a mitigation scheme will be required to support new development. Some minor roads leading to and from the villages within Wymondley parish may require other traffic management measures in addition to those which may be required as part of site allocation Policy WY1. These measures will also need to be investigated and will be reflected in future iterations of the Infrastructure Development Plan. Mitigation could include environmental improvements to the village centre. The mitigation of these issues will be part of the wider package of measures identified through the wider consideration of network issues concerning A1(M) J8 and alternate routeings to this.