ICKLEFORD PARISH COUNCIL

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1 ICKLEFORD PARISH COUNCIL w w w.i ckl ef or dpc.c om 1 Freewaters Close, Ickleford, Hertfordshire, SG5 3TQ mail@icklefordpc.com Telephone: NHDC Proposed Submission Local Plan IPC draft perspective Points of agreement Need for additional housing IPC understands the need for additional housing, and is willing to accept a share of this which is commensurate with maintaining its village status and minimises the impact on the environment. Need for the Proposed Submission Local Plan IPC understands the need for NHDC to produce its own Local Plan; not to do so would leave the District Council open to aggressive planning applications over which it would have limited control. In this context, IPC understands the reasons for Cllr Spencer-Smith s support of the Local Plan as a whole, but with reservations about specific aspects. Points of Disagreement/ Concerns 1. Development on Green Belt Most of the proposed developments for Ickleford are on Green Belt land and this poses concerns not just to the Parish Council but to other groups. Recently, a planning application was received by NHDC for a proposed development of 18 dwellings at Land adjacent to Arnold s Farm, (15/02832/1), off Chambers Lane. This is Green Belt land and was subject to strong opposition from the Campaign to Protect Rural England (CPRE), which noted, and I quote: the proposal is contrary to the Green Belt provisions of the National Planning Policy Framework and Local Plan, Policies 2 (Green Belt), 3 (Settlements within the Green Belt), 5 (Excluded Villages) and 16 (Areas of Archaeological Significance). The proposal is for inappropriate development in the Green Belt under NPPF paragraph 89 and as such very special circumstances have to be demonstrated which outweigh the harm to the openness and other harm to the Green Belt. The Design and Access Statement puts Page 1 of 6

2 forward no case for Very Special Circumstances. There is reference to the provision of a new footpath along Chambers Lane and a contribution to local housing need. Neither of these constitutes exceptional circumstances. End of quote. While that planning application was withdrawn, the objections noted by CPRE to building on Green Belt are pertinent to the Proposed Submission Local Plan because three of the four sites in Ickleford are on Green Belt land. NHDC themselves have been mindful of the importance of the Green Belt. In July 2016, they refused planning permission (16/01159/1HH) for a part two storey and part single storey rear extension in Ickleford because, and I quote,...the proposed development would adversely affect the openness of the Green Belt... Therefore, Ickleford Parish Council find it perverse that NHDC are now proposing a major incursion into the Green Belt around Ickleford at sites IC1, IC2 and IC3. Additionally, the National Planning Policy Framework (NPPF) (March 2012) (Section 89) is clear that a local planning authority should regard the construction of new buildings as inappropriate in Green Belt. While this also goes on to say limited infilling is an exception, we do not believe that what is proposed for Ickleford is either limited or infilling. IPC feels that the North Hertfordshire Green Belt Review (July 2016) misrepresents the value of the Ickleford Green Belt in preventing the merging of neighbouring towns; this is given a low ranking of 1. However, the Ickleford Green Belt plays an important role in preventing the merger of Hitchin and Letchworth, and also that of Hitchin and Henlow/ Stondon. The NPPF is clear that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open, with essential characteristics of Green Belt being openness and permanence. It also states that Once established, Green Belt boundaries should only be altered in exceptional circumstances (NPPF 79 and 83 respectively) Furthermore, Ickleford is listed as an Excluded village in policy 5 of the North Hertfordshire District Local Plan [No.2 with Alterations]. Within this policy, it is noted that that the Council will normally permit development for housing only if the development is compatible with the maintenance and enhancement of village character, and the maintenance of Green Belt boundaries. The Parish Council firmly believes that inclusion of the proposed sites at IC1, IC2 and IC3 would be contrary to this policy. Page 2 of 6

3 The North Hertfordshire Green Belt Review is also inconsistent in the ranking given to the Preserve setting and special character of historic towns category. Ickleford is rated as having no direct visual link with the historic core of Hitchin, whereas Willian has a strong visual relationship ; IPC cannot see the difference between the rating given to these two villages with similar geographical and visual relationships to Hitchin s historic core. 2. Sewers, drains and flooding The statement in on page 37 of the Draft Communities section of the Plan is less than transparent in its handling of drainage and sewerage. No doubt Anglian Water has confirmed that the sewerage treatment plant can accommodate the increased housing in Ickleford. This is not, however, the issue. Discussions Ickleford Parish Council has had with Anglian Water raised a number of concerns: The use of dry weather data as criteria for capacities of treatment equipment and pipes. The combined rain water and sewerage pipe through the village was fit for purpose in Victorian times when the village was a fraction of its current size. It is clearly as evidenced by the increased frequency of incidents of back-flow of sewerage into Laurel Way and Duncots Close unable to cope with current capacity. The proposed growth of 150 homes (IC3) and 9 homes in Duncots Close (IC1) would join the existing, overburdened sewerage pipes in the village. The additional proposed application (16/02012/1) at Ickleford Manor for 19 dwellings and approved construction of 8 houses on the site of the former Green Man pub (15/03233/1), which are separate to the Plan will also feed into this pipe. The Anglian Water statement in the proposed District plan only refers to Sewerage Treatment Equipment and does not include pipe capacity. Residents in parts of the Ickleford adjacent to the proposed developments already experience issues with surface water flooding during heavy rainfall which is likely to be the new norm as the climate warms. This does not appear to have been given the prominence it deserves in the Plan. Page 3 of 6

4 It is worth noting that Planning Guidelines are clear on this subject: Development proposals will be expected to: be designed and constructed to reduce the overall level of flood risk within the parish We do not believe that these expectations are evident in the Plan. Until such time as Anglian Water is able to address the sewerage and drainage capacity issues within the centre of the village, Ickleford Parish Council is likely to oppose any new development which adds to the already overburdened system. 3. The extent of additional housing in Ickleford 319 new dwellings within the parish boundaries are included in the Proposed Submission Local Plan. This is in addition to 8 houses approved at the Green Man site and 19 proposed at Ickleford Manor; a total of 346 new dwellings. With approximately 850 dwellings currently within Ickleford this represents a 40% increase (a 38% increase on just the Local Plan numbers). About 16,550 new homes are proposed for the District as a whole. The current population in NHDC is 131,000, with that of Ickleford being 1,833 representing 1.40% of the District s population. A per capita increase in dwellings in Ickleford would be 232, rather than the 346 proposed, indicating a disproportionate burden falling on Ickleford. We feel that the Proposed Submission Local Plan is incorrect in listing the development LS1 under Lower Stondon. This development is within Ickleford Parish Boundary, and should be included in the Ickleford section as IC4. 4. Change in nature of the village Such a massive increase in the number of dwellings/ residents will fundamentally alter the nature of the village. The larger villages and towns in NHDC are better able to absorb the increase in housing without altering the basic character. The historical roots of Ickleford are as a farming community. The loss of farming/ grazing land at IC2, IC3 and LS1 would also alter the character of the village. The current primary school is a focal point within the village, being part of the triangle church, school and village hall which is the heart of Ickleford. Additionally, Ickleford Primary School is a C of E VC school and as such has strong links with St Katharine s Church. Relocation of the primary school to the proposed new location at IC3 will rupture the Page 4 of 6

5 social and historic bonds in the centre of the village with significant impact on the fabric of Ickleford. Ickleford Parish Council believes that the strong history and heritage of our village has been disregarded in the formulation of the Plan. 5. Erosion of the boundary between Ickleford and Hitchin Related to the above, the proposed development at IC2 represents a significant incursion to the natural boundary between Ickleford and Hitchin. This runs the risk of making Ickleford a suburb of Hitchin, thus further changing the nature of the village. Indeed, the North Hertfordshire Green Belt Review agrees that the Ickleford Green Belt plays a significant contribution in preventing sprawl northward from Hitchin, but the Plan, perversely, then ignores this in its proposal for IC2. 6. Impact on infrastructure While the Plan mentions a new, two-form entry primary school to accommodate the increased population, current Local Authority admissions policy cannot guarantee places at that school for all children within the new, enlarged Ickleford. This will be detrimental to the children s social development and, via the school run to other schools, additionally strain the village s road infrastructure. Moreover, we do not feel sufficient attention has been paid to secondary school transfers. There are serious, on-going issues for children from Ickleford not being able to attain their first preference, particularly if their choice is Hitchin Boys School or Hitchin Girls School. These issues will inevitably be exacerbated by the increased housing and population associated with the Plan. As the two secondary schools mentioned set their own admissions criteria NHDC can obviously make no guarantee that this problem will be addressed. In addition, there is much less specific reference to other aspects of infrastructure. The roads in and around Hitchin are already near grid-locked for several hours each weekday. Additionally, access from the Burford Grange and Bedford Road sites onto the A600 will need careful planning and management. The recently announced closure of RAF Henlow, with the suggested addition of around 750 new dwellings is also relevant here. A significant proportion of the flow of traffic from this new development will be south bound on the A600, with clear impact on traffic through Ickleford in to Hitchin. Page 5 of 6

6 Section of the Local Plan states that.. transport modelling work does not identify any specific mitigation works that are required on the Ickleford road network. Ickleford Parish Council suggests that this modelling is inaccurate. Traffic surveys conducted by Hertfordshire Highways about 8 years ago showed nearly 60,000 vehicle movements through the centre of the village (Arlesey Road/ Turnpike Lane) each week; this number will have increased in the intervening time. The strain that this puts on to the main road network through Ickleford is evident to residents and any casual observer. The proposed increase in housing in the Plan and not just that associated with Ickleford with the consequent increases in population and car ownership, will require mitigation on our road network. The pavements in Ickleford are very narrow in parts, making pedestrian access in the village challenging. Increased footfall and increased road traffic inevitable consequences of the proposals in the Plan will increase the danger to pedestrians in Ickleford. Section of the Plan makes reference to the need for safe access on to the A600 from IC3, but makes no mention of the proposed new crematorium which will have its access/ egress at a similar location. Local GP surgeries and hospitals are already under strain. It is clear that the impact on quality of life for residents of the Plan is profound. 7. Relocation of school The Parish Council is concerned about the future of the current school premises, if a new school is built at IC3. We fear the likeliest scenario is yet further additional housing on the site of the current school, magnifying the already adverse consequences cited above. Conclusion It will be obvious from the above that Ickleford Parish Council has many, significant and justified concerns about the Proposed Submission Local Plan and its impact on our village. Our formal response to NHDC will be formulated at our October and November Parish Council meetings, but I would be surprised if we accepted the Plan in its current form and without cast-iron guarantees that the issues we raise will be addressed. 6 October 2016 Page 6 of 6