Submitted by Email To: Senders Name

Submitted by email to: Senders Name [email protected] Senders address Pirton Hertfordshire Senders address Planning Control North Hertfordshire District Council PO Box 480 M33 0DE

Dear Ms Mary Caldwell,

Ref: 15/01618/1, Outline application to include access details (with all other matters: appearance, landscaping, layout and scale reserved) for residential development of up to 90 dwellings with associated infrastructure, public open space and planting. Land Adjacent To Elm Tree Farm, Hambridge Way, Pirton.

I understand that some items are ‘unreserved’ (Access) and others are reserved (everything apart from access). I also understand that North Hertfordshire District Council (NHDC) will be influenced by the Highway Authority, Hertfordshire County Council (HCC)’s view on the access. I have therefore included some of my objections made separately to them.

Key Reasons to Refuse this Application:

Location: This site is outside the current village boundary and is protected by Local Saved (and current) Policies: 'Policy 6 - Rural Areas beyond the Green Belt', 'Policy 7 - Selected Villages beyond the Green Belt' and Policy 29 - Rural Housing Needs. These policies have not been superseded and the application does not meet any of the requirements necessary in order for the policies not to be enforced. The application should therefore be rejected.

Previous applications: Applications for much smaller developments here have been refused and then rejected on appeal. Clearly 90 houses must have an even more significant and detrimental impact to the character and appearance of Pirton.

As evidence for this I draw your attention to the Council’s own and the Appeal Inspector’s decisions relating to other applications on this land (11/00413/1 and 12/00694/1). It should also be noted that both relate to much smaller proposed developments of 8 houses. The application for 90 houses should be recognised as having proportionately increased detrimental impact.

Detrimental to the Character and the Environment: Character is an important issue within the planning process, Localism and sustainability and has been a prime reason for refusing development on this site and others in the past.

The proposed development is contrary to its rural setting and its designation as part of the village conservation area.

Hambridge Way: The proposal would have a detrimental impact to this bridleway and public footpath. Hambridge Way is part of the Icknield Way Trail which is of regional, and national, significance, as it links other regional routes, namely the Peddars Way National Trail and the Ridgeway National Trail, which in turn link to the Wessex Ridgeway. The proposed development would form a harsh edge to Pirton and be very visible from significant parts of the Hambridge Way and the wider countryside. Any proposed edge softening would still leave the development visible for at least five years and beyond, probably taking up to fifteen years for screening to be effective and even then not likely to overcome the urbanising effect of the development.

Size: The application proposes 90 houses over three years. The site would increase the built area of Pirton by 13%, an increase of 17.3% (current housing) and 20% (population) - all within 3 years. These numbers are of such a scale that it would overwhelm the village of Pirton, rather than support the community.

Shape: Unusually for North Hertfordshire, Pirton is a nucleated, triangulated village, with no major through routes. This helps form the unusual character of Pirton. The proposed development has an adverse impact because it would extend the development area well beyond the village triangle - effectively producing a new satellite built area contrary to the existing character.

Density: The current average village density is 13 dph (dwellings per hectare) and in the immediate vicinity it is even lower. Generally the density reduces from the centre as the built area reaches the edges. The proposed density of 30 dph is totally unsuitable, both in terms of general density and in terms of its specific location.

Visual Character Impact: The site is on one of the only three approaches to the village. The proposed development would be highly visible and detrimental to the rural vista for those entering the village from the Holwell direction and it would dominate the views from the public footpath and bridleway, known as Hambridge Way. Although the proposed screen may help, it cannot sufficiently alleviate the detrimental impact on the visual character of Pirton.

The impact of a development here was clearly recognised by the planning appeal inspector when refusing the two appeals on the earlier applications.

Impact on the Community’s Wellbeing: The community’s sense of wellbeing comes from the close-knit nature of the community formed over many years and by the integration of existing and new residents into the community and its activities. This is not something that can be forced quickly. One of the core principles of the National Planning Policy Framework is that development should support and enhance the community, so I believe that community well-being is at least as important as other key elements of sustainability.

The proposed development represents a massive increase of 17.3% to the number of dwellings and 20% to the population in just three years. The community’s wellbeing cannot be maintained if it is overwhelmed by the size and rate of development. The proposal fails this test of sustainability.

Environmental Impact: I note that the submission is weak on the environment and contains no environmental impact assessment. Any decision must be reserved against such an assessment.

The proposed development is contrary to the NHDC Landscape Character Assessment of the Pirton Lowlands which states that for “Smaller urban extensions (<5ha): This type of development would not be suitable for the Character Area, due to its rural character. The landscape capacity for small urban extensions is considered to be low.”

The development would increase the number of cars and the lack of convenient public transport (both detailed elsewhere) would combine to significantly increase traffic movements within Pirton and the locality. The environmental impact will be detrimental and should be considered here against the principle of sustainable development.

Facilities and Utilities : The following key facilities either do not have the capacity to cope with the increase in population that would be generated or cannot be expanded to do so: Shop/Post Office – too small and no possibility to expand; School/Pre-school too few available spaces; Village Hall runs at capacity for major events and public meetings.

There are known deficiencies in the sewerage system which are demonstrated by the periodic foul water flooding near the pumping station in Burge End Lane.

Housing Mix and Design: The village need is for affordable, affordable rented homes and houses for downsizing. Indeed this is acknowledged by the applicant, however the proposed mix of housing does not meet this need.

The application clearly suggests that some of the housing will exceed two-storeys. This would be contrary to the rural character of Pirton and the Village Design Statement and is totally unacceptable.

Localism (and the Localism Act (2011): “The Government thinks that the local community should have a greater say in shaping the way their local area develops”. In considering this application, and all others, the planning authority should be able to demonstrate that they seek to comply with this aspiration.

The ministerial forward of the National Planning Policy Framework (NPPF) says “Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives” and that “this should be a collective enterprise”. The NPPF Core Planning Principle 17 states that planning should: “be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area.”

The application fails to meet any of the community’s views on what is sustainable for Pirton as evidenced by the consultation for Pirton’s Neighbourhood Plan. This achieved the returns from 70% (over 16s) and 80% (households). The community’s view of what is sustainable includes:  Less than 50 houses to 2013 - 63%  The rate of development should be an even across each of the 5-year bands 2011-2031 - 58%  Developments of less than 26 – 70  Only 11% specifically supported development of the PT2 (part of this proposed site), although a further 17% supported development split between this site and PT1.

For Localism to have any value it must be seen to take into account the wishes of the community. The view of the community, so clearly evidenced in Pirton, must be allowed to influence development.

The National Planning Policy Framework: The NPPF states that there should be presumption in favour of sustainable development (Ref: NPPF paragraph 14), unless “any adverse impacts of doing so would significantly and demonstrably outweigh the benefits of doing so when assessed against the policies in this framework as a whole”.

In its core principles the National Planning Policy Framework (NPPF) seeks to use development to enhance the community. Specifically paragraph 55 of the NPPF states “housing should be located where it will enhance or maintain the vitality of rural communities. For example, where there are groups of smaller settlements, development in one village may support services in a village nearby.”

The arguments set out above, and elsewhere, demonstrate that the proposed development would not enhance or maintain the vitality of the community; in fact it would overwhelm it. The proposed development does not provide, and will not enhance, any services capable of providing support to other villages. For these reasons the proposed development does not meet the requirement for sustainability and specifically in regard to paragraph 55 of the NPPF.

The NPPF Core Planning Principle 17 states “that development must take into account the different roles and character of different areas” and must recognise “the intrinsic character and beauty of the countryside and supporting thriving rural communities within it”. This application fails to do so.

For all the reasons given above there would clearly be a significant detrimental impact to Pirton and few, if any benefits. The criteria for acceptance therefore, has not been met and the application should be refused.

Site Access, Traffic and Safety: There was a Highway Engineer’s report commissioned by Pirton residents, which I am aware has been submitted by others. I consider the contents to be relevant, albeit that the detrimental impact and the conclusions should be extrapolated for 90 houses and I ask that you take this into account.

Pirton is a small village in a rural setting and the use of a roundabout is inappropriate in planning terms and contrary to its distinctive rural character. Sustainable development means that development should not have a detrimental impact on character. The roundabout is necessarily of a design which allows larger vehicles to mount it and indeed effectively be on the opposite carriageway, in order to traverse this junction (reference the Swept Path Analysis). The lack of sight lines means that this is unsafe because two larger vehicles or a larger vehicle and a car travelling in opposite directions could come into conflict.

Traffic: I dispute the findings of the applicant’s traffic survey which suggests that the flow along Holwell Road is 88 (am) and 89 (pm) vehicles with no heavy vehicles and that the increase would only be 60 vehicles, because:  My own experience, although only subjective, is that this figure is far too low.  It has failed to identify the 12 bus movements through Holwell Road.  The Highway Engineer employed by villagers in 2012 counted 73 vehicles on this road between 8 and 8.30am, including 3 buses and a recycling lorry.”  It fails to identify ‘transit’ sized vehicles separately, which due to the narrowness of the road have more significant impact than cars.

Additional Cars: The proposal would generate at least 2 cars per house, i.e. 180 cars, an increase of over 20% to Pirton, plus additional delivery, visitor and service vehicle movements. As public transport is inadequate for employment and most social and domestic purposes and the local school has insufficient capacity, this will inevitably increase traffic movements, particularly at peak times. Clearly a large percentage of the 180 cars generated would pass through Holwell Road at peak times.

Traffic Issues & Safety: The following are safety issues and would be made worse by the increase in traffic.

There are sight-line problems at Holwell Turn and the junction of High Street/Royal Oak Lane/Hambridge Way/Walnut Tree Road. There are also speeding cars and those with drivers failing to observe the give-way requirements at the junctions of Hitchin Road/Walnut Tree Road, Priors Hill/Danefield and Priors Hill/Great Green and near collisions are already too common.

The applicant does not recognise road speed as an issue, however that is not the perception of the community and in recent consultations a 20mph speed limit has been placed high on our list of aspirations.

There is an accident blackspot at the junction of the Hitchin Road with the B655 and Carters Lane. There are dangerous bends on the B655, between Carters Lane and Hitchin, especially the first one, some 400 to 500m from Carters Lane. There is a blind crest to the hill at the edge of Hitchin. These all prevent any view of queuing traffic and the speed limit only drops to 30mph immediately after the crest of the hill, so any conflict with queuing traffic would be serious.

Any increase in traffic though Holwell - one of only two convenient routes out of Pirton to a main road – would have a significant detrimental impact on Holwell. The road from Pirton to Holwell is very narrow in places and has blind bends.

Safe Routes: There are site specific issues in Holwell Road. No layout for the site and its access can resolve the lack of a safe pedestrian or cycle route along Holwell Road. This is due to the narrowness of the road and no footpath which is further exacerbated by the lack of off-street parking which forces the occupants of the terraced cottages to park on Holwell Road. The applicant is suggesting that some off-road parking will be provided, but it cannot be certain that the occupants of the cottages will use them, if provided. In fact this could make the situation worse as without a footpath or the protection offered by parked cars, residents would step straight out of their front doors into traffic.

The lack of footways in and around Pirton particularly in Holwell Road, Royal Oak Lane and Walnut Tree Road, it may be argued that this currently presents an acceptable level of risk, however I believe that with a further increase in traffic this would become a significant safety issue.

Transport and Car Use:

Part of sustainability is the need to reduce the requirement to use personal transport. There is a lack of good, frequent public transport and poor broadband and mobile telephone services restrict people’s ability to work from home. All of this combines to force workers to use personal transport at peak times.

The bus service is also inadequate for social and domestic purposes and the lack of facilities such shops, doctors and dentists etc. combine to increase other traffic movements. For this reason this proposed development cannot achieve this measure of sustainable development.

Spurious Arguments:

The applicant goes to great length to expound the massive financial benefits to North Hertfordshire District Council, when this is not a planning matter and any argument for financial sustainability needs to be made on a much more local basis and to benefit Pirton to qualify as sustainability under the Localism Act.

For all of the above objections raised, I respectfully ask that the application be refused.

Yours Sincerely