Ashwell Neighbourhood Plan Regulation 16 Submission

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. The comments within this representation reflect the interests of the following services that are provided by HCC (Excluding HCC Property), along with other relevant areas within the Environment & Infrastructure Department:
• Children’s Services (School Place Planning)
• Historic Environment
• Highways and Transport
This representation follows the format of the consultation document itself, whilst largely keeping each HCC service separate for clarity. It should be noted that comments have only been made on the parts of the document and the sites contained within that are of interest to HCC. Comments relating to a specific HCC service and department have been stated.
Please note that HCC made its representations to the previous iteration of the neighbourhood plan in August 2020. This response builds upon comments made at the previous stage with new updated and specific comments relating to this regulation 16 iteration of the plan in the below. HCC would also like to reiterate and encourage the inclusion of the comments made at the regulation 14 stage which largely have not been included within this version of the neighbourhood plan. The omission of many of the comments made by HCC is concerning and HCC would like to remind the Parish Council of the need for the neighbourhood plan to be in conformity with the draft North Herts Local Plan and the need for the neighbourhood plan to be found sound. Some teams have no further comments to make on this new iteration of the ANP but would reiterate comments submitted in the regulation 14 representation which can be found attached to this email for your convenience.

4. Vision and Objectives
Highways Authority
The following point was stated in the HCC representation to the previous regulation 14 consultation and requires specific reiteration. The Highways Authority wish to seek an additional objective that supports and encourages the use of sustainable transport (e.g. walking, cycling and passenger transport) where possible. This is to ensure that the ANP is in line with HCC’s Local Transport Plan 4 (LTP4) Policy 1: Transport User Hierarchy which supports the creation of built environments that encourage greater and safer use of sustainable transport modes. In order to achieve this, HCC will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs

7. Natural Environment
Historic Environment
Policy ASH8 uses the phrase historic assets. This terminology is not defined by the NPPF, nor by the plan’s own glossary. The policy largely repeats the NPPF. The discussion on non-designated heritage assets implies this only refers to historic structures and this, as well as the Plan itself, fails to mention the primary record for non-designated heritages assets in the county, the Herts Historic Environment Record. As a result the opportunity has been lost to consider what is important and unique to the Parish in terms of below ground archaeology, historic landscapes and the potential for as yet undiscovered archaeological remains; and in the section/policy ASH9 Significant Views, the spatial relationship between them.
Nevertheless, HCC welcomes the aspiration for future built development to reflect the historic and local character of existing buildings in Policy ASH3, and in Policy ASH 15 part C, sympathetic reuse of historic buildings.

11. Healthcare and education
Children’s Services
Background
The County Council is the Local Authority with the statutory responsibility for the provision of education services. It has a duty to ensure that there are sufficient school places to meet the needs of the population.
The County Council forecasts future demand for school places using education planning areas. The villages of Ashwell, Sandon and Weston make up the Baldock Villages Primary Planning Area (PPA) with each village having its own village primary school. Ashwell Primary School is the only school in Ashwell village and serves its local community.
The latest pupil forecast (published summer 2020/21) indicates there is sufficient capacity to meet demand within the Baldock villages PPA.
Ashwell Primary School has a Published Admission Number (PAN) of 30, offering 30 Reception places each year.
When looking specifically at the village of Ashwell, latest analysis of pre-school aged children obtained from GP registrations indicates a close match between the number of 0-4 year olds residing within Ashwell and the number of places currently available at the school. Ashwell Primary School is therefore the right size currently to meet the needs of the local community it serves.
The North Hertfordshire District Council (NHDC) Local Plan 2011-2031 Regulation 19 Proposed Submission Plan (October 2016) identified only one housing site for Ashwell; land west of Claybush Road (ref AS1) for 33 homes. Site AS1 is considered an allocated housing site for this village for education planning purposes and it is considered that there is sufficient capacity at Ashwell Primary School to accommodate the children arising from the AS1 development.
New homes in Ashwell
Primary
It is noted that within the Ashwell Neighbourhood Plan, whilst no new housing sites are identified, reference is made to the potential for new smaller dwellings, including a mix of affordable homes as well as retirement housing. Whilst HCC is not objecting to the proposal, HCC raises a concern with regards to the impact any additional new housing over and above that proposed on site AS1 would have on primary pupil demand in the local area. Ashwell Primary School is currently full and has no expansion potential beyond its current size of 1 Form of Entry (1FE).
The pupil yield arising from any further new homes proposed in Ashwell is likely to increase pupil demand beyond the capacity of the school. This would result in some children in the village being unable to gain a place at the school and having to travel to schools outside the village.
In summary, Ashwell Primary School at 1FE has no further expansion potential to mitigate the impact of any further windfall development and S106 contributions cannot be sought as there are no mitigation options available at the school.
Para 11.14
Ashwell Primary is not a feeder school to Knights Templar School in Baldock.
Ashwell is within the Priority Area for Knights Templar School, so pupils who live in the village applying for a place would be more likely to be offered a place than those living outside of Knights Templar Priority Area.
For information the Priority Area for Knights Templar School consists of Baldock, and the Parishes of Ashwell, Bygrave, Caldecote, Clothall, Edworth, Hinxworth, Newnham, Radwell, Rushden, Sandon, Wallington and Weston.

12. Transport and movement
Highways
It is concerning that the HCC Local Transport Plan (LTP4) is not mentioned anywhere within the neighbourhood plan. Policies would benefit from strengthening to align with the ambitions of HCCs LTP4 and the user hierarchy to ensure any new development allows and encourages the use of sustainable transport.
General Highways comments
As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire and to minimise impact on the environment. The Neighbourhood Plan should align with the County Councils Transport strategy documents. The County Council’s adopted Local Transport Plan 4 (LTP4) 2018 – 2031 sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 provides a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

The Highway Authority is a statutory consultee to planning applications submitted to North Hertfordshire District Council. These are assessed and considered in the context of the current legislation. Both National and local policies are considered in relation to sustainable transport. Developers need to ensure that their development sites support their share of the required infrastructure and service improvements, and are accessible by all transport modes. Any new design/any associated off-site highway infrastructure will have to undergo appropriate scrutiny that promotes highway safety.
Specific Highways comments
Para 12.4, HCC disagrees with the statement that the Baldock bypass has had little discernible impact on the traffic driving through the village.
Para 12.4 states “Inadequate road maintenance undertaken by the County Council”. HCC understands the context in which this statement is portrayed, however, this sentence is not appropriate within the neighbourhood plan. HCC would also consider this statement to be incorrect.
Policy ASH 4 and paragraph 12.21 are of concern. This section represents a rather archaic and rigid approach to car parking standards for new developments, which now should be assessed in this respect much more holistically, respecting a number of local environmental factors (i.e. car parking standards are now very much the starting point, not necessarily the end point). Whilst the premise behind the statement “There will be a presumption against the loss of any publicly accessible off-street car parking in the neighbourhood area” is understood, it again is too rigid and does not represent the countywide direction of travel. HCCs LTP4 is clear in that the County Council seeks a significant move away from private car based trips (especially for shorter journeys), with part of the solution for this being less ‘space’ provision for private motorcars and more ‘space’ provision for sustainable transport methods.
Not once does the Neighbourhood Plan reference HCCs LTP4 or the key highways/transport sections of the NPPF (e.g. paragraphs 108-110), and overall it does not relate well to national planning policy in a highways context, or local policy in the form of HCCs LTP4 and supporting plans. The user hierarchy (i.e. considering pedestrians and cyclists first, with the needs of the private motorcar considered last) should be at the heart of this Plan and whilst the greater challenges this brings in more rural areas such as Ashwell is acknowledged, the draft Plan could be bolder in its aspirations to shift modal split towards more sustainable means.
Policies ASH20 -22 – These policies contain no reference to the HCC Local Transport Plan 4 (LTP). Only ASH22 D contains a comment on cycling however cycle parking would be needed at existing locations also, such as the village centre, school, pre-school, leisure sites etc. for cycling to be a viable alternative to shorter local trips. This would assist with reducing car trips and potentially the parking problem mentioned.

13 – Infrastructure and Improvements
Para 13.2 – A section 106 agreement is a public (not private) agreement between the developer and the Local Planning Authority (of which HCC is often a party to the agreement) relevant to the development in question. A Section 278 agreement is with the Highway Authority, not the Local Planning Authority.
Please also note the three tests set out in Regulation 122 of the 2010 Community Infrastructure Levy regulations which need to be observed when securing a S106. These are:
a. necessary to make the development acceptable in planning terms
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.
Financial Contributions secured via a S106 agreement should only be spent on the terms of the legal agreement and not to implement the local community’s ‘wish list’ as is implied in 13.4.

Other Remarks
HCC would encourage a proper review of, and amends based on, the regulation 14 consultation representation made by HCC in August 2020. Comments made at the regulation 14 stage are valid and have largely not been reiterated in this representation, this is due to the whole regulation 14 representation needing reiteration. Therefore, the HCC representation to the second round regulation 14 consultation is attached for proper consideration.